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Special Processes and HACCP Plans
Retail food establishments need to be aware that certain Special Processes are required to have an approved Hazard Analysis of Critical Control Points (HACCP) plan and/or Variance before being implemented. Special Processes typically involve technologies or equipment seen in commercial food manufacturing, but not at the retail level, and have an increased risk of making someone sick.
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Reduced Oxygen Packaging (ROP)
Using unapproved ROP practices, specifically vacuuming packaging food to extend shelf life, is one of the more common Special Process violations inspectors are finding. Vacuum sealing creates additional illness risks as certain dangerous bacteria thrive in low-oxygen environments. Unlike spoilage bacteria, these pathogens often don't result in an obvious change in color or look of the food. A proper HACCP plan is critical in preventing ROP-related illnesses, such as botulism. Typical ROP processes that require a HACCP plan include:
- ROP fish
- ROP any Time/Temperature Control for Safety (TCS) foods held for over 48 hours
- Cook chill packaging
- Sous vide packaging
ROP of TCS foods, such as raw meats, is exempt from having an approved HACCP as long as they are labeled with production time/date, held at 41°F or less, and removed from packaging in the establishment within 48 hours of packaging.
Other Special Processes Requiring HACCP Plans
- Sushi rice
- Dried beef or beef jerky
- Kimchi
- TCS foods made shelf stable
- Pickling or canning
Talk to your inspector before using a Special Process!
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Unapproved Food Sources
Foods that are used as ingredients or sold at a licensed food establishment MUST come from an approved source. Generally, this means the ingredient shall be sold by or produced at an approved food wholesaler, plant, or establishment. Examples of PROHIBITED sources:
- Sold by another licensed restaurant or retail food established that is not approved to wholesale
- Made or processed in any home kitchen, including foods exempt from licensing:
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Eggs from unlicensed producers (backyard or farm chicken flocks)
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Meat not processed, packaged, and labeled at an approved processing plant
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'Tis the Season for Norovirus
November marks the typical start of the Norovirus season. The CDC estimates that about 50% of all food-related illness are cause by this easily spread virus. Here are a few tips to help protect your customers:
- Make sure employees with vomiting and/or diarrhea are excluded from work and don't return until at least 24 hours after systems resolve.
- Use a Norovirus-killing approved disinfectant to wipe down commonly touched surfaces on a regular basis.
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