Bakery HACCP Plan: Fillings, Cooling, Allergens and Logs

A bakery HACCP plan looks different from a plan for a restaurant line. Ovens kill most vegetative bacteria, and much of what a bakery sells is dry enough that bacteria cannot grow. The risk sits in a narrower group of products: custards, pastry cream, whipped cream, cheesecake, cream cheese frostings, meat pies, quiche, and anything filled after baking. Those are where the plan does its work.

This guide covers how to sort your products, where the critical control points usually land, the allergen controls that matter most in baking, and the records that make the plan believable to an inspector. It is meant for US retail bakeries, cafés with a pastry program, and wholesale bakers who supply restaurants. Whatever you produce is a draft for your health department to review.

Do bakeries need a HACCP plan?

Under the FDA Food Code, which most states adopt in some form, a written HACCP plan is required in specific cases. Section 8-201.13 ties the requirement to special processes listed in 3-502.11 (such as curing, smoking for preservation, or acidifying foods to make them shelf stable) and to some packaging methods. If your bakery does none of those, your local code may not require a written HACCP plan at all. The FDA Food Code 2022 is the model; your state's adopted version is what applies.

Bakeries that sell wholesale across state lines may fall under the FDA preventive controls rule instead of retail rules. That is a separate system with its own plan. Our HACCP vs FSMA post explains the difference.

Even where a plan is not mandatory, many bakery owners write one because:

• Custards and creams are a known source of outbreaks when they cool slowly.
• Wholesale customers sometimes ask for a food safety plan.
• A health department may request one after a complaint or a failed inspection.
• It forces clear written procedures for new staff.

If you are not sure whether your operation needs one, read when a HACCP plan is required and ask your health department.

Sort your bakery products by risk

Start with a product list. Then sort each item by whether it is a TCS food once finished.

Usually not TCS

• Plain breads, rolls and baguettes.
• Dry cookies, biscotti and crackers.
• Most fruit pies made with high-sugar fillings.
• Cakes with buttercream made mostly of sugar and fat, depending on the recipe.

The Food Code defines TCS food using tables of pH and water activity, plus a product assessment option. Whether a frosting or fruit filling is TCS can depend on the recipe. If you are relying on a product being non-TCS to leave it out at room temperature, keep the basis for that decision with the plan. Some health departments ask for a lab test of pH and water activity.

Usually TCS

• Custards, pastry cream, crème brûlée, flan.
• Whipped cream and cream fillings.
• Cheesecake and cream cheese frostings.
• Quiche and savory pies with eggs, meat or vegetables.
• Meat or cheese filled pastries, empanadas and sausage rolls.
• Cooked rice or vegetable fillings.
• Cut melons or cut tomatoes used as toppings.

These items need temperature control or time control. They are where your critical control points go.

Flow diagram for a custard or cream-filled product

A typical flow for pastry cream used in éclairs:

Draw one for each product family rather than every product. "Cooked custards and creams" can cover crème pâtissière, lemon curd and crème anglaise if the steps are the same. Our HACCP flow diagram examples show other layouts.

Hazard analysis for bakery products

For each step, list biological, chemical and physical hazards, decide if each is significant, and say why.

| Step | Hazard | Significant? | Reason and control | |---|---|---|---| | Receive eggs and dairy | Salmonella, Listeria, temperature abuse | Yes | Receiving checks at 41°F or 45°F as the Food Code allows; pasteurized products where possible | | Cook custard | Survival of Salmonella from eggs | Yes | Cook to a set temperature (CCP 1) | | Cool custard | Growth of spore-formers and survivors | Yes | Two-stage cooling (CCP 2) | | Cold hold | Growth | Yes | 41°F or below (CCP 3) | | Filling | Contamination from hands and tools | Yes, prerequisite | Handwashing, clean piping bags | | All products | Undeclared allergens | Yes | Allergen program and label checks | | Mixing | Metal from mixer wear, glass | Low, prerequisite | Equipment maintenance |

FDA's HACCP principles and application guidelines describe this process in detail. For more filled-in examples, see hazard analysis examples.

Critical control points in a bakery

CCP 1: Cooking egg-based fillings

Eggs can carry Salmonella. Cooking is what reduces it. For custards made with raw shell eggs, write a cooking critical limit your health department accepts. Food Code section 3-401.11 sets cooking times and temperatures for raw animal foods, including raw eggs that are not prepared for immediate service. Many bakeries avoid the question by using pasteurized eggs, which are a common control for products that are lightly cooked or not cooked at all, like some mousses or meringues.

Monitor with a calibrated probe thermometer at the end of cooking. Record the temperature, time and initials for each batch.

CCP 2: Cooling custards and creams

Thick, dense fillings cool slowly. Slow cooling is a classic cause of illness in cooked foods. The Food Code (3-501.14) requires cooked TCS food to cool from 135°F to 70°F within 2 hours, and to 41°F or below within 6 hours total.

Ways bakeries hit those numbers:

• Spread cream into shallow pans, about 2 inches deep or less.
• Use an ice bath with stirring before refrigerating.
• Cover the surface with plastic wrap in direct contact after the first stage, to avoid a skin without trapping heat.
• Use a blast chiller if you have one.

Log the temperature at the start, at 2 hours and at the end. Our food cooling rules post and the printable cooling log show how.

CCP 3: Cold holding filled products

Filled pastries, cheesecakes and cream pies stay at 41°F or below (Food Code 3-501.16). That applies to display cases too. Many open-front cases struggle to hold 41°F at the front edge, so check product temperature, not just the case thermometer.

If you want to display cream products at room temperature for a short time, that is time as a public health control (3-501.19), which needs written procedures and a 4-hour discard rule. See our time as a public health control guide.

Allergen control in baking

Allergens are one of the biggest risks in a bakery. Wheat, milk, egg, soy, tree nuts, peanuts and sesame are in almost everything, and flour dust travels. FDA's page on food allergies lists the major food allergens, including sesame, which was added by the FASTER Act.

A practical program includes:

• Separate storage. Nuts and peanut products on low shelves or in sealed bins.
• Scheduling. Make nut-free products first, nut-containing products last, then clean.
• Dedicated tools for nut and sesame products, color coded if you can.
• Label checks on every packaged item against the recipe, especially after a recipe or supplier change.
• Staff answers. Counter staff should know which items contain which allergens and should never guess.

Many bakeries treat allergens as a prerequisite program. Some make the final label check a CCP for packaged goods. Either approach can work if it is written and followed. Our full food allergen control plan goes deeper.

Prerequisite programs for bakeries

These are not CCPs but the plan depends on them:

• Pest control. Flour and sugar attract pests. Keep service records and sealed bins.
• Cleaning and sanitizing mixers, piping tips, sheet pans and slicers. See our sanitation SOP guide.
• Personal hygiene and handwashing. The Food Code calls for at least 20 seconds of scrubbing and washing.
• Supplier approval for eggs, dairy and nut products.
• Date marking of ready-to-eat TCS foods held more than 24 hours, up to 7 days at 41°F (3-501.17). See date marking under the Food Code.
• Thermometer calibration. Keep a calibration log.

Records a bakery should keep

| Record | When | Who | |---|---|---| | Cooking log for custards and creams | Each batch | Pastry cook | | Cooling log | Each batch | Pastry cook | | Cold holding log for display and walk-in | Every 4 hours or as your plan sets | Shift lead | | Receiving log | Every delivery of TCS goods | Receiver | | Allergen changeover and label check | Each changeover or new label | Supervisor | | Thermometer calibration | Daily or weekly per plan | Shift lead | | Corrective action log | Whenever a limit is missed | Person on duty |

You can download printable versions from free logs, or use the restaurant temperature log for holding checks.

Corrective actions for bakery CCPs

Write them before you need them.

• Cooking temperature not reached: keep cooking until it is, then record the final reading.
• Cooling stage 1 missed (not at 70°F by 2 hours): the Food Code allows you to reheat to 165°F and restart cooling, or discard. Custards often do not survive reheating well, so discarding is common.
• Cooling stage 2 missed: discard, or follow your health department's direction.
• Cold holding above 41°F: check how long. Product above 41°F for an unknown time should be discarded. Fix the unit and move product to working storage.
• Allergen label wrong: pull the product, relabel or discard, and find out how it happened.

See HACCP corrective actions examples for more wording you can adapt.

Verification for a bakery plan

Verification shows the plan works. Practical steps:

• A manager signs all logs each week.
• Spot-check temperatures in the display case against the case gauge.
• Watch the cooling process once a month and compare to the log.
• Review the plan when you add a product, change a recipe, or change suppliers.
• Review after any complaint or illness report.

HACCP verification and record keeping explains how to set up a review schedule.

Common gaps in bakery HACCP plans

• Listing bread as a CCP product. That clutters the plan. Focus on TCS items.
• No cooling procedure for custards. This is the most common real risk.
• Display cases assumed to be cold. Check the product.
• Allergen info kept only in the baker's head. Write it down and keep it at the counter.
• Overnight proofing of filled items. If a filled dough sits warm for hours, add that step to the flow and the hazard analysis.
• Seasonal products added without review. Pumpkin pie, eggnog fillings and holiday cheesecakes are TCS foods. Add them to the plan before the season starts.

Bakery plans for wholesale and farmers markets

If you sell at farmers markets or to other businesses, your situation may change.

• Cottage food laws in some states let home bakers sell non-TCS items without a commercial kitchen. TCS products like cream pies are usually excluded. Our cottage food HACCP plan post covers this.
• Wholesale sales to restaurants and stores may need a different license and possibly a preventive controls plan if FDA registration applies.
• Catering of bakery items to events adds transport and holding steps. See HACCP plan for catering.

A sample bakery HACCP plan summary

Here is how the CCP section of a small retail bakery's plan might read once it is filled in. Your numbers and products will differ, and the critical limits must match the code your health department enforces.

| CCP | Product family | Critical limit | Monitoring | Corrective action | Records | |---|---|---|---|---|---| | 1. Cook | Custards, quiche fillings | Final temperature as set in the approved plan, per Food Code 3-401.11 | Probe each batch at end of cook | Continue cooking, recheck | Cooking log | | 2. Cool | Custards, creams, cooked fillings | 135°F to 70°F in 2 h; to 41°F in 6 h total | Probe at start, 2 h, end | Reheat to 165°F and restart, or discard | Cooling log | | 3. Cold hold | All TCS finished products | 41°F or below | Product probe every 4 h | Assess time out, discard or move | Holding log |

Keep the summary to one page. The detailed procedures sit behind it, and an inspector can flip to them when needed. For a full worked version for a restaurant, see the HACCP plan example.

Worked example: cheesecake

Cheesecake shows how the pieces connect. Cream cheese, eggs and sugar are mixed and baked in a water bath. The eggs are the main biological hazard at the cooking step, so baking is a CCP. A baked cheesecake is dense and holds heat for a long time, which makes cooling the step most likely to go wrong.

A realistic procedure:

1. Bake until the center reaches the temperature in your plan. Probe the center, not the edge.
2. Cool on a rack at room temperature only as long as needed to handle the pan safely, then move to a walk-in on an open rack, not stacked.
3. Check the center temperature at 2 hours. It must be at 70°F or below.
4. Check again before 6 hours total. It must be at 41°F or below.
5. Date mark if held more than 24 hours, and use within 7 days at 41°F.

If the 2-hour check fails often, the fix is usually smaller pans, a blast chiller, or cutting the cake into portions earlier. Write the fix into the plan so the next person does it the same way.

Thermometers and equipment for bakeries

Bakeries rely on oven settings and timers more than probes. That works for bread, but TCS products need actual product temperatures. The Food Code requires food temperature measuring devices to be accurate to plus or minus 2°F in the range of use (4-203.11). A thin-tip digital probe works well for custards and cheesecake centers.

Useful equipment for a bakery plan:

• A calibrated digital probe thermometer, plus a spare.
• Shallow hotel pans or sheet pans for cooling creams.
• An ice bath setup or a blast chiller.
• An appliance thermometer in each refrigerator and display case.
• Labels for date marking and allergen identification.

Calibrate probes with the ice point method and log it. FSIS describes the ice water method on its kitchen thermometers page.

Writing your bakery HACCP plan

Pull it together in this order:

1. Product list sorted into TCS and non-TCS, with the basis for each non-TCS call.
2. Flow diagrams for each TCS product family.
3. Hazard analysis tables.
4. CCPs with critical limits, monitoring, corrective actions and verification.
5. Prerequisite programs, with allergen control written out in full.
6. Record forms.
7. Training records.

The HACCP plan template gives you the full structure, and the worked example shows a finished plan for a restaurant that you can compare against.

Training bakery staff

Bakeries often have early shifts with one or two people on site, so procedures have to work without a manager standing over them. Train each person on the products they make: the cooking temperature for custards, how to set up cooling, how to read and record a probe temperature, and what to do if a number is wrong. Keep a one-line training record for each topic with the date and both signatures. Repeat the training when you add a product or change a recipe. Our HACCP training guide has a simple sign-off sheet you can copy.

Build your bakery plan in the builder

The HACCP builder lets you select cooking, cooling and cold holding processes, fills in the Food Code limits with section numbers, and prints the logs you need. You can add custards, quiche and filled pastries as separate menu items under the same process. The first process is free; the Plan Pack covers all of them for a one-time price. The output is a draft for your health department to review and approve.

Frequently asked questions

Does a retail bakery need a HACCP plan?

Not always. Under the FDA Food Code, a HACCP plan is required for specific special processes or when you request a variance. Many retail bakeries are not required to have one, but using HACCP for custards and fillings is good practice, and some health departments ask for it.

Is bread a TCS food?

Plain baked bread is generally not a TCS food. The Food Code defines TCS food using pH, water activity and product tables, and dry, baked bread usually falls outside it. Fillings, toppings and cream-based items often fall inside it.

What temperature should custard be held at?

Custards and cream fillings are TCS foods, so cold holding is 41°F or below under Food Code 3-501.16. After cooking, they must cool from 135°F to 70°F within 2 hours and to 41°F within 6 hours total.

Are allergens a CCP in a bakery?

They are usually handled as a prerequisite program with labeling, storage and changeover controls. Some bakeries treat label checks as a CCP. Wheat, milk, egg, tree nuts, peanuts, soy and sesame are all common bakery allergens.