Reduced oxygen packaging (ROP) HACCP plan

What counts as reduced oxygen packaging?

The Food Code defines ROP broadly: any packaging that reduces oxygen below normal atmospheric levels. In a restaurant that typically means chamber or edge vacuum sealers, but it also includes modified atmosphere packaging, cook-chill bags and sous vide. If you seal TCS food (meat, poultry, cooked vegetables, cooked grains, dairy, cut leafy greens, etc.) in a bag with the air pulled out and keep it more than 48 hours, assume ROP rules apply.

What does Food Code §3-502.12(B) require?

A food establishment that packages TCS food using ROP must implement a HACCP plan containing the information in §8-201.14(C) and (D), and the plan must:

• Identify the food to be packaged.
• Keep the packaged food at 41°F or below and make sure it meets at least one barrier: water activity of 0.91 or less; pH of 4.6 or less; a meat or poultry product cured at a USDA-regulated plant and received intact; or a food with a high level of competing organisms such as raw meat, raw poultry or raw vegetables.
• Label the package prominently on the principal display panel, in bold type on a contrasting background, with instructions to keep at 41°F or below and to discard within 30 days of packaging if not served or consumed.
• Limit refrigerated shelf life to 30 calendar days from packaging to consumption (frozen time excluded) or the original manufacturer's date, whichever comes first.
• Include operating procedures: no bare-hand contact with ready-to-eat food; a designated work area with separation of raw and ready-to-eat food; access to the equipment limited to trained staff; cleaning and sanitising procedures for food-contact surfaces.
• Describe the training programme for the person responsible for ROP.
• Be provided to the regulatory authority before you start (§8-201.13(B)).

What are the special cases for fish, cheese and sous vide?

Fish. Under §3-502.12(C), fish may only be ROP-packaged if it is frozen before, during and after packaging and labelled to stay frozen. Clostridium botulinum type E grows at refrigeration temperatures in fish.

Cook-chill and sous vide. Section 3-502.12(D) sets separate conditions: cook to §3-401.11 limits, cool per §3-501.14, then hold at 41°F or below for up to 7 days, or cool to 34°F within 48 hours of reaching 41°F and hold there for up to 30 days from packaging. See the sous vide HACCP plan guide.

Cheese. Section 3-502.12(E) allows ROP of certain commercially manufactured hard, semisoft and pasteurised process cheeses with a 30-day use-by date.

The 48-hour exception. Under §3-502.12(F), no HACCP plan is required if the packaged TCS food is always labelled with production time and date, held at 41°F or less, and removed from the package within 48 hours of packaging.

Anything outside these conditions, longer shelf life, fish not kept frozen, food without one of the listed barriers, needs a variance under §3-502.11(D), which in turn needs a HACCP plan under §8-201.13(A).

Which CCPs go in an ROP plan?

1. Receiving: cold TCS food at 41°F or below (§3-202.11).
2. Packaging: food meets the barrier criterion and is labelled; done in the designated area by trained staff.
3. Cold holding: 41°F or below, checked and recorded at a set frequency.
4. Shelf life: used or discarded within 30 days of packaging (or the earlier manufacturer date).

Corrective actions should cover the food (discard if held above 41°F for an unknown time, discard if past date, re-label if label is missing and the date is known) and the cause (repair the cooler, retrain staff).

How long do I keep ROP records?

Keep the cold holding log, the packaging log (product, date, quantity, initials) and corrective action records. For cook-chill and sous vide, §3-502.12(D)(3) requires records be kept at least 6 months; it's sensible to keep all ROP records that long.

How do I start an ROP plan?

Select "Reduced oxygen packaging" in the builder and it will add the steps, hazards and limits above, plus a regulatory note on variances.