How to write a HACCP plan for sous vide

Sous vide is the process that sends more restaurant owners looking for a HACCP plan than any other. This walkthrough follows the order your health department will read the plan in. Every limit comes from the FDA Food Code 2022 with its section number: check your jurisdiction's adopted edition.

Step 0: Do you actually need a plan?

Under §3-502.12(F), a HACCP plan is not required when the reduced-oxygen-packaged TCS food is always labelled with the production time and date, held at 41°F or less, and removed from its package within 48 hours of packaging. If you bag in the morning and serve that evening or the next day, you may be exempt. If you cook, chill and hold bags for days, you need a plan under §3-502.12(D) before you start.

What goes in the general information section?

Business name, address, permit number, person in charge, and a one-line description: "Sous vide chicken breast and pork belly cooked in-house, chilled and held up to 7 days at 41°F; served on premises only." The Food Code's cook-chill/sous vide exemption only covers food consumed on the premises or within the same business entity, with no sale of the packaged product to another business or to consumers (§3-502.12(D)(2)(a)).

How do I list sous vide products and equipment?

For each product: recipe, bag type (food-grade, rated for the cook temperature), vacuum sealer, circulator, chilling method (ice bath, blast chiller) and the storage unit. Section 3-502.12(D)(2)(f) requires the storage unit to have an electronic system that continuously monitors time and temperature, visually checked twice daily.

What does the sous vide flow look like?

1. Receive
2. Cold store
3. Prep and portion
4. Vacuum-pack
5. Cook: CCP
6. Chill: CCP
7. Cold hold with date label: CCP
8. Rethermalise and serve

Which hazards does the analysis need to cover?

The significant hazards are biological:

• Survival of Salmonella, Campylobacter, E. coli O157:H7 at the cook step.
• Germination and growth of Clostridium perfringens and Bacillus cereus during slow cooling.
• Growth of Clostridium botulinum and Listeria monocytogenes during refrigerated storage in the anaerobic bag.

Cross-contamination at packaging is controlled by prerequisite programmes (designated area, cleaning and sanitising, no bare-hand contact with ready-to-eat food).

What critical limits apply to sous vide?

Cook. The food must reach the temperatures and times in §3-401.11(A), (B) or (C). For poultry that's 165°F (under 1 second); for whole-muscle beef and pork roasts you can use the time-temperature table in §3-401.11(B): 130°F for 112 minutes, 140°F for 12 minutes, 145°F for 4 minutes and so on. Lower combinations, such as chicken breast held at 140°F, can be validated but need a variance.

Chill. Cool in the sealed bag per §3-501.14: 135°F to 70°F within 2 hours, to 41°F within 6 hours total.

Store (§3-502.12(D)(2)(e)), choose one:

• cool to 34°F within 48 hours of reaching 41°F, hold at 34°F, use within 30 days of packaging; or
• hold at 41°F or less for no more than 7 days; or
• cool to 34°F then hold at 41°F for no more than 7 days, not exceeding 30 days from packaging; or
• hold frozen.

How should sous vide be monitored?

• Cook: probe the thickest bag per batch (pass the probe through closed-cell foam tape to keep the seal), record temperature and time at temperature.
• Chill: record time and temperature at start, 2 hours and when 41°F is reached.
• Storage: continuous electronic monitoring, visually checked twice daily; label each bag with product and date packaged.

What corrective actions should the plan list?

• Cook limit not met: continue cooking.
• Cooling stage 1 missed: reheat to 165°F and restart, or discard. Stage 2 missed: discard. (These are common industry corrective actions; the Food Code leaves the choice to your plan.)
• Storage above limit or past date: discard; repair unit.
• Torn bag or failed seal: re-bag and re-label if within time limits, otherwise discard.

How do I verify the plan and keep records?

A manager reviews and signs logs weekly; thermometers are calibrated weekly; the plan is reviewed annually and when menu or equipment changes. Keep records at least 6 months (§3-502.12(D)(3)(b)) and make them available to the regulator.

What training does the plan need to describe?

Section 3-502.12(B)(6) and (D)(4) call for a training programme so the person responsible understands the concepts, equipment and procedures. List who is trained and when.

What happens after I submit it?

Send the draft to your regulatory authority before you start (§3-502.12(D)(1)). Expect questions, especially about any time-temperature combination outside §3-401.11.

Shortcut: select "Sous vide" in the builder and it fills in steps 3 to 8 with these limits and citations. Read the sous vide HACCP plan guide for more detail.

General information based on the FDA Food Code 2022, not legal advice.