Do restaurants need a HACCP plan?

Short answer: most restaurants don't need a written HACCP plan for ordinary cooking, but many need one for at least one process on their menu. Whether you do depends on what you make and on which edition of the FDA Food Code your state or county has adopted.

Isn't the Food Code already a HACCP system?

The FDA Food Code is built on HACCP principles. Its cooking temperatures, cooling times and holding temperatures are critical limits for the hazards restaurants face every day. If you cook chicken to 165°F (§3-401.11(A)(3)), cool chili from 135°F to 70°F in 2 hours and to 41°F within 6 hours total (§3-501.14), and hold salads at 41°F or below (§3-501.16), you are already following a HACCP-style system: the Food Code wrote the plan for you.

That's why the Food Code doesn't require every restaurant to write its own plan.

When does a written HACCP plan become mandatory?

Section 8-201.13 lists when a HACCP plan must be submitted. In restaurant terms:

1. You need a variance under §3-502.11. That covers smoking food as a method of preservation (not just flavour), curing food, using additives like vinegar to make food non-TCS (acidified sushi rice), reduced oxygen packaging outside the conditions in §3-502.12, keeping molluscan shellfish in a display tank, custom processing animals, sprouting seeds or beans, and other methods your regulator decides need one.
2. You do reduced oxygen packaging, vacuum packaging, cook-chill, sous vide, under §3-502.12. A plan is required unless the food is labelled with the production time and date, held at 41°F or less, and taken out of the package within 48 hours of packaging (§3-502.12(F)).

Which processes catch restaurants out?

• Vacuum-sealing prepped proteins to extend shelf life.
• Sous vide where bags are cooked, chilled, and held for more than 48 hours.
• House-cured meats, gravlax, bacon, salumi.
• Smoking where the smoke is part of preservation rather than flavour.
• Sushi rice held at room temperature with vinegar, which needs a pH of 4.2 or below under the guidance in Food Code Annex 4 (and an approved plan or variance).
• Dry aging in a dedicated cabinet: the Food Code sets no specific limits, so many regulators treat it as needing a variance or at least a written plan.
• Live shellfish tanks.

Can local rules go further than the Food Code?

States adopt the Food Code with amendments, and some still use the 2013 or 2017 editions. Some health departments ask for HACCP plans for new restaurants with complex menus, after repeated violations, or for commissaries serving food trucks. A five-minute call to your inspector is the fastest way to find out.

If you do need one, what does it contain?

Section 8-201.14 lists the contents: a categorisation of the foods covered; a flow diagram for each, marked with critical control points; ingredients, recipes and equipment; a CCP summary with critical limits, monitoring, corrective actions, verification and records; and supporting documents like training. Most plans for a single process run to 6 to 15 pages.

How much does a restaurant HACCP plan cost?

Consultants quote anywhere from roughly $600 to $9,500 for restaurant HACCP plans, and some start at $3,250 per plan. Subscription software runs about $99 to $299 a month. If you know your recipes, a structured template gets you most of the way, and you can buy consultant time only for review or validation.

Next step: see what a full plan looks like, or start a free draft in the builder.

This post is general information based on the FDA Food Code 2022, not legal advice. Your regulatory authority decides what applies to you.