Do Restaurants Need a HACCP Plan for Sous Vide?
Sous vide is now common in restaurant kitchens. Proteins are vacuum-sealed, cooked in a water bath at precise temperatures, then chilled and held for service. This is one of the processes the FDA Food Code treats as specialized, because vacuum packaging creates the low-oxygen conditions in which Clostridium botulinum and Listeria monocytogenes can grow.
The short answer is: yes, in most cases. If you vacuum-pack food and hold it, you need a HACCP plan approved by your health department. There is one narrow exception. This guide explains when a plan is required, the limits the Food Code sets, and what goes in the plan.
Why sous vide is a specialized process
When food is sealed in a vacuum bag, the oxygen is removed. That stops spoilage organisms that would normally warn you that the food is old, such as off odors, slime and mold. But the anaerobic conditions allow pathogens to grow:
Clostridium botulinum can grow and produce toxin without oxygen. Non-proteolytic strains can grow at refrigeration temperatures as low as about 38°F (3.3°C).
Listeria monocytogenes grows at refrigeration temperatures and is not inhibited by vacuum packaging.
Spores survive the low cooking temperatures typical of sous vide. Mild cooking does not destroy C. botulinum or Bacillus cereus spores.
The FDA Food Code (2022 edition, the model code most states adopt with their own amendments) therefore controls reduced oxygen packaging (ROP), including sous vide and cook-chill, through section 3-502.12.
When a HACCP plan is required
Under Food Code section 3-502.12, a food establishment that packages time/temperature control for safety (TCS) food using a reduced oxygen packaging method must control the growth and toxin formation of C. botulinum and the growth of L. monocytogenes. It must also have a HACCP plan that contains the information in 8-201.14. That plan is submitted to and approved by the regulatory authority.
Many jurisdictions also require a variance for some ROP processes. A plan is required for ROP done under the conditions in 3-502.12. A variance under 3-502.11 is required for ROP done outside those conditions. See our guide to Food Code variances and reduced oxygen packaging.
The 48-hour exception
The Food Code does not require a HACCP plan when a food establishment uses an ROP method for TCS food that is:
always kept under the control of the person in charge,
held at 41°F (5°C) or less, and
removed from its package within 48 hours after packaging.
This exception allows a kitchen to vacuum-seal prepared food for a short hold, such as marinating proteins overnight or prepping for the next day's service, without a HACCP plan. Once you hold vacuum-packed food beyond 48 hours, a plan is required. A plan is also required if the food leaves your control, for example when you sell sealed packages to customers.
The sous vide and cook-chill holding limits
The Food Code sets specific limits for cook-chill and sous vide food. These are foods cooked in the bag or bagged hot, then chilled.
Cooking
Cook the food to the temperatures and times in the Food Code cooking section 3-401.11, or to a time and temperature your plan validates for the specific food.
Cooling
After cooking, the bagged food is cooled. A common requirement is to cool to 41°F (5°C) within the timeframes in your plan, and then to 34°F (1°C) where required. Most kitchens use an ice bath or a blast chiller. Your plan sets the cooling CCP.
Cold holding
The limits for cold holding are:
At 34°F (1°C) or less: up to 30 days from the date of packaging.
At 41°F (5°C) or less: up to 7 days from the date of packaging.
Frozen: with no shelf-life limit while frozen, provided the food is held frozen until use.
At the end of the holding period, the food must be consumed or discarded.
Monitoring the 34°F hold
When you rely on the 34°F, 30-day limit, the Food Code requires the refrigeration unit to have continuous electronic temperature monitoring. The temperatures must also be verified and documented visually by the person in charge at least twice daily. Plan for a data logger, or a cooler with an alarm and a printout or electronic record.
Labeling
Each package must be labeled with the product name and the date it was packaged. Most plans also require a "use by" or discard date based on the holding temperature.
What goes in the HACCP plan
Food Code section 8-201.14 lists what a HACCP plan must contain. For a sous vide program, that means:
General information: the establishment name, address and contact person.
Categorization of TCS foods on the menu: for example, sous vide beef, chicken and pork, and cook-chill sauces.
A flow diagram for each food or category. It identifies the CCPs, the ingredients and materials, the equipment, and the recipes or procedures.
A supervisory and training plan: how employees are trained in the process and its monitoring, and who verifies the records.
A statement of standard operating procedures. This identifies each CCP, the critical limits, the method and frequency of monitoring, the corrective actions, the records, and the verification procedures.
Any additional scientific data or information that supports the plan. Examples include cooking time and temperature studies for low-temperature cooking, published research on C. botulinum growth, or a process authority's letter.
Typical CCPs for sous vide
Step | Hazard | Critical limit (example) | Monitoring |
Cooking | Survival of vegetative pathogens | Food Code time and temperature, or validated low-temperature time and temperature table | Probe thermometer through the bag, or water bath temperature plus core time |
Cooling | Growth of spore-formers | Cooled to 41°F within the plan's time limit | Time and temperature log |
Cold holding | C. botulinum and Listeria growth | 34°F or less for up to 30 days, or 41°F or less for up to 7 days | Continuous electronic monitoring, checked twice daily |
Discard | Holding beyond limits | Discard at the date on the label | Daily label check |
What your health department will ask for
Expect your health department to ask for:
the written HACCP plan, signed by the owner or manager
the recipes or procedures for each sous vide product
specifications for your vacuum packaging equipment and bags
your cooling equipment and method
your cold holding equipment, and how it is continuously monitored
your labels
your training records
sample monitoring logs
Some health departments have their own submission forms or checklists. Use theirs, and attach the plan.
Once the plan is approved
The work does not stop when the plan is approved:
Follow the plan exactly. If you change a recipe, equipment or holding time, update the plan and resubmit it.
Keep records for each batch: cooking, cooling, cold holding, labeling and discard. The Food Code requires records to be kept for at least 6 months after the last date the food was sold or served.
Calibrate thermometers regularly, and record each calibration.
Review records weekly, and document any corrective actions.
Inspectors check these records on routine inspections. Missing records are a common reason for an approval to be withdrawn.
Get your plan done
Our Restaurant HACCP Plan for Specialized Processes includes everything you need for sous vide and cook-chill:
PLAN 101-RST Sous Vide and Cook-Chill Proteins
SOP 7-104-RST Reduced Oxygen Packaging, Sous Vide and Cook-Chill
a sous vide cooking and cooling log, an ROP labeling and discard log, and a cold holding electronic monitoring verification log
a variance and HACCP plan submission checklist
The package also includes worked plans for vacuum-packed ready-to-eat foods, sushi rice, gravlax and cold-smoked fish, and fermentation.
This guide is based on the FDA model Food Code. Your state or local code may differ, so check your health department's requirements before you submit.
Related guides: Food Code Variances and Reduced Oxygen Packaging; HACCP Programs for seafood, meat and poultry, juice and restaurants.
Official sources: FDA Food Code.
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