ROP Packaged Food Must

VACUUM PACKAGING REQUIREMENTS

California Health and Safety Code Section 114419 (b) (2) requires retail food facilities thatutilize a reduced oxygen packaging (ROP) method for potentially hazardous foods to submit a Hazard Analysis Critical Control Point (HACCP) plan to the California Department of Public Health (CDPH) for review and approval. This document addresses the elements that must be included in HACCP plans submitted to CDPH when a retail food facility is utilizing vacuum packaging for foods other than cheese and for foods that have not been processed using sous vide or cook-chill methods. Please see the separate requirements for utilizing reduced oxygen packaging methods for cheese products and for sous vide/cook-chill operations.

A HACCP plan is a written document that delineates the formal procedures for following the Hazard Analysis Critical Control Point principles developed by the National Advisory Committee on Microbiological criteria for foods. A HACCP plan is developed using the following 7 steps:

1.Completion of a hazard analysis identification by identifying the likely hazards to consumers presented by a specific food.

2.Determination of critical control points in receiving, storage, preparation, display, and dispensing of the food.

3. Setting of measurable critical limits for each identified critical control point.

4. Developing and maintaining monitoring practices to determine if critical limits are being met.

5. Developing and utilizing corrective action plans when failure to meet critical limits is detected.

6.Establishing and maintaining a recordkeeping system to verify adherence to the HACCP plan.

7.Establishing a system of audits to verify that the HACCP plan is being followed as written. Record keeping should be as simple as possible to facilitate accurate data collection by the designated food worker. Records to be kept as part of the HACCP system include:

a. HACCP plan and supporting documentation used in developing the plan

b. Records of CCP monitoring

c. Records of corrective action

d. Records of verification activities including:

• Receiving Logs,
• Damaged and Discarded Product Log,
• Daily Storage Temperature Log,
• Thermometer Calibration Log,
• Food worker Training Records

HACCP plans submitted to CDPH for review and approval must address the 7 steps identified above and must also include the following information:

1. A list of specific foods that will be vacuum packaged on-site.
2. Description of the methodology to maintain the vacuum packaged foodat 41ºF or below
3. Identification of a 2nd barrier to control the growth and toxin formation of Clostridium botulinum and the growth ofListeria monocytogenes to include one (or more) of the following:

1. Food has a Aw of 0.91 or less,
2. Food has a pH of 4.6 or less,
3. Food is a meat or poultry product cured at a USDA regulated food processing plant that is received in an intact package,
4. Food is raw meat, poultry, or vegetables. Note: fish may only be vacuum packaged if the fish is frozen before, during, and after vacuum packaging.

1. If food product is prepared andvacuum packaged on-sitefor retail sale, description of how the food packaging will be prominently and conspicuously labeled on the principal display panel in bold type on a contrasting background with consumer instructions to:

1. “Maintain product at 41°F or below” and
2. A “use by” date of no more than 14 days from date of packagingor the date the product was vacuum packaged
3. Freeze, consume, or discard the product by the use by date or within 14 days of the package date

1. If the food product is prepared and vacuum packaged on-site for on-site consumption, a description of how the food will be labeled with the package date or use by date to ensure that the product is frozen, consumed, or discarded within 14 days from date of packaging.
2. If a food product is a cured meat or poultry product processed at a USDA regulated food processing plant received in an intact package and is repackaged via vacuum packaging on-site, a description of how the following requirements will be followed:

1. If for retail sale, package label must indicate use by date of no more than 14 days from date of repackage or the original manufacturer’s use by date, whichever comes first, andinclude instructions to consume, freeze,or discard the product by the end of the 14-day period.
2. If for on-site consumption, package must be labeled with either

1) package date or 2) use by date or original manufacturer’s use by/sell by date if manufacturer’s “use by date” occurs prior to 14 days after vacuum package date andproduct must be frozen, consumed, or discarded as per the date coding on the package

1. Description of the standard operational procedures that:

a. Prohibit bare hand contact with ready-to-eat food prior to being vacuum packaged,

b.Identify a designated vacuum packaging work area,

c.Delineate measures to prevent cross contamination between raw and ready-to-eat foods prior to and during vacuum packaging,

1. Delineate cleaning and sanitizing procedures for food contact surfaces and the vacuum packaging machine,
2. Limits access to the vacuum packaging area to trained staff thatis familiar with the hazards associated with the operation.
3. Assure each ROP food is stored in accordance with a “First-in/First-out” storage rotation procedure and is discarded in accordance with the HACCP plan.

15. Description of the training program for the employees responsible for the preparation of the foods that are to be vacuum packaged and the operation of the vacuum packaging machine including a food employee and supervisory training plan that addresses the food safety issues of concern.

16. A flow diagram of the specific food for which the HACCP planis requested, identifying critical control points and providinginformation on the following:

a. Ingredients, materials, and equipment used in the preparationof that food.

b. Formulations or recipes that delineate methods and proceduralcontrol measures that address the food safety concerns involved.

17. A statement of standard operating procedures for the planunder consideration including clearly identifying the following:

a. Each critical control point.

b. The critical limits for each critical control point.

c. The method and frequency for monitoring and controlling eachcritical control point by the food employee designated by the personin charge.

d. The method and frequency for the person in charge to routinelyverify that the food employee is following standard operatingprocedures and monitoring critical control points.

e. Action to be taken by the person in charge if the criticallimits for each critical control point are not met.

f. Records to be maintained by the person in charge todemonstrate that the HACCP plan is properly operated and managed.

18. Record retention procedures to ensure that

a. Applicable HACCP training is provided anddocumented for food employees who work in the preparation of food forwhich an HACCP plan has been implemented. Training given to foodemployees shall be documented as to date, trainer, and subject.

b. The person operating a food facility pursuant to a HACCP has designated at least one person to be responsible forverification of the HACCP plan. Training for the designated personshall include the seven principles of HACCP and the contents of theHACCP plan. HACCP training recordsof the designated person shall be retained for the duration ofemployment, or a period of not less than two years, whichever isgreater.

c. Critical limit monitoring equipment is suitable for itsintended purpose and is calibrated as specified by itsmanufacturer. All calibrationrecords must be maintained for a period not less than two years.

d. All other records need to be kept on site for at least 90 days after consumption of the food prepared pursuant to the HACCP plan to demonstrate that the HACCP plan has been followed as written.

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