HACCP Requirements: When Restaurants Need a HACCP Plan and What It Must Include

HACCP requirements determine when a restaurant or food facility needs a written Hazard Analysis and Critical Control Point (HACCP) plan and what that plan should contain.

HACCP is a preventive food safety system. Instead of waiting for food to become unsafe, HACCP identifies potential hazards and establishes controls to prevent, eliminate, or reduce those hazards to acceptable levels.

Not every restaurant needs a HACCP plan. Whether one is required depends on the type of food operation, the processes being used, applicable regulations, and the requirements of the state or local regulatory authority.

Specialized processes such as certain types of reduced-oxygen packaging, sous vide, curing, smoking for preservation, acidification, and other processing methods may require a HACCP plan, a variance, or regulatory approval.

Quick Answer: A restaurant may need a HACCP plan when it uses a specialized food process that creates hazards requiring additional controls, or when applicable law, a variance, or the regulatory authority requires one.

The FDA Food Code is a model code, so restaurants should also check the requirements adopted by their state and local regulatory authority. FDA Food Code 2022

What Are HACCP Requirements for Restaurants?

HACCP requirements are the rules and procedures that determine when a food business must use a HACCP plan and what that plan should contain.

A HACCP plan is designed around a specific food product and process. It identifies potential hazards and explains how employees will control, monitor, and document those hazards.

Depending on the operation and jurisdiction, HACCP requirements may involve:

• Conducting a hazard analysis

• Identifying critical control points

• Establishing critical limits

• Monitoring critical control points

• Taking corrective action

• Verifying that controls work

• Maintaining records

• Training employees

• Obtaining regulatory approval when required

The FDA’s HACCP guidance identifies seven principles as the foundation of a HACCP system.

---

Does Every Restaurant Need a HACCP Plan?

No.

Most restaurants do not need a specialized HACCP plan simply because they prepare food or serve TCS (time/temperature control for safety) foods.

Routine restaurant food safety is normally managed through practices such as:

• Proper cooking

• Proper cooling

• Hot and cold holding

• Employee hygiene

• Preventing cross-contamination

• Cleaning and sanitizing

• Proper food storage

• Approved food sources

• Employee health policies

HACCP becomes particularly important when a restaurant uses a specialized process that creates food safety hazards requiring additional controls.

For example, certain reduced-oxygen packaging, sous vide, curing, smoking for preservation, acidification, and water-activity processes may have additional requirements.

Because food regulations vary by jurisdiction, a restaurant should determine the applicable requirements before introducing a new specialized process.

---

When Is a HACCP Plan Required?

A HACCP plan may be required when:

• A food code or other applicable law requires one

• A variance is required for the process

• A regulatory authority determines that a specialized process requires HACCP

• A business uses certain reduced-oxygen packaging methods

• A food business performs certain specialized preservation processes

• Federal regulations require HACCP for a particular food industry

The exact requirements can depend on the food, process, equipment, packaging, storage conditions, and jurisdiction.

This means there is no single HACCP rule that applies identically to every restaurant in the United States.

---

What Foods and Processes May Require a HACCP Plan?

There is no single nationwide list of foods that always require a HACCP plan.

In many cases, the process matters as much as the food itself.

For example, a restaurant may prepare chicken using ordinary cooking methods without needing a specialized HACCP plan. The situation may be different if the restaurant uses a specialized packaging or preservation method that creates additional hazards.

Processes that may require additional HACCP controls include:

• Reduced-oxygen packaging

• Sous vide

• Cook-chill

• Curing

• Smoking food for preservation

• Certain acidification processes

• Certain water-activity controls

• Sprouting

• Other specialized processes identified by the regulatory authority

The applicable requirements depend on the process and the rules governing the food operation.

---

HACCP Requirements for Reduced-Oxygen Packaging

Reduced-oxygen packaging (ROP) removes or reduces oxygen around food.

Examples can include:

• Vacuum packaging

• Certain sous vide products

• Cook-chill products

• Other packaging methods that reduce oxygen

Reducing oxygen can create conditions that allow certain microorganisms to grow and produce toxins if the process is not properly controlled.

Depending on the process, HACCP requirements for reduced-oxygen packaging may involve:

• Refrigeration

• Labeling

• Monitoring

• Critical limits

• Employee training

• Equipment

• Sanitation

• Recordkeeping

The FDA Food Code contains specific requirements for certain reduced-oxygen packaging methods.

Does Vacuum Sealing Food Require HACCP?

It can.

Vacuum sealing is a form of reduced-oxygen packaging, but not every vacuum-packaging situation has identical requirements.

The answer can depend on:

• The type of food

• How the food is packaged

• How long it will be stored

• Storage temperature

• Whether the food is cooked before or after packaging

• The applicable food code

• Requirements of the regulatory authority

Restaurants should verify the applicable requirements before beginning a reduced-oxygen packaging process.

---

Does Sous Vide Require a HACCP Plan?

Sous vide can require HACCP controls.

Sous vide commonly involves placing food into a sealed package and cooking it under controlled conditions. Some operations also chill the food after cooking and store it under refrigeration.

Because the process can involve sealed packaging and controlled cooking and cooling conditions, it must be carefully designed and monitored.

Whether a HACCP plan is required depends on the exact process and jurisdiction.

Restaurants planning to introduce sous vide processing should contact the appropriate regulatory authority before starting the process.

---

Does Smoking Food Require HACCP?

Smoking food for preservation may require HACCP controls.

Smoking food for flavor is different from using smoking as a preservation method.

When smoking is used to preserve food, the process can affect temperature, moisture, and microbial growth. For this reason, specialized smoking processes may require additional food safety controls or a HACCP plan.

Restaurants should determine whether their specific smoking process is subject to additional requirements before using it for preservation.

---

Does Curing Food Require HACCP?

Curing food may require HACCP controls.

Curing can involve ingredients such as salt, sugar, nitrite, spices, or curing mixtures.

Because curing changes the characteristics of food and can be used to control microbial growth, some curing processes are subject to specialized food safety requirements.

Check with the appropriate regulatory authority before beginning a specialized curing process.

---

What About Acidification and Water Activity?

Some food processes use pH or water activity (aw) as safety controls.

• pH measures how acidic or alkaline a food is.

• Water activity measures how much available water is present for microorganisms to use.

Certain specialized processes use acidification or water-activity controls to help prevent the growth of harmful microorganisms.

These processes can require specific measurements, equipment, monitoring procedures, and regulatory approval.

A restaurant should not create an acidification or water-activity process based only on a general recipe. The process may need to be evaluated by the appropriate regulatory authority.

---

What Must a HACCP Plan Include?

A HACCP plan should be specific to the food and process being controlled. It should not be treated as a generic checklist that applies to every operation.

A typical HACCP plan may include:

1. Product Description

Describe the food being prepared or processed, including relevant ingredients, preparation methods, packaging, storage, and distribution information.

2. Intended Use

Explain how the product will be used and who is expected to consume it.

3. Process Flow Diagram

Show the steps involved in receiving, preparing, processing, packaging, storing, and serving the food.

A process flow diagram helps identify where hazards may occur and where controls may be needed.

4. Hazard Analysis

Identify biological, chemical, and physical hazards that could occur at each step.

5. Critical Control Points

Identify the steps where a food safety hazard can be prevented, eliminated, or reduced to an acceptable level.

6. Critical Limits

Establish measurable limits that must be met at each critical control point.

Depending on the process, critical limits may involve:

• Temperature

• Time

• pH

• Water activity

• Other measurable controls

7. Monitoring Procedures

Explain what will be monitored, how it will be measured, how often it will be checked, and who is responsible.

8. Corrective Actions

Explain what employees must do when a critical limit is not met.

Corrective actions should address the immediate problem and help prevent unsafe food from reaching consumers.

9. Verification Procedures

Explain how the business will confirm that the HACCP system is working correctly.

10. Recordkeeping

Document monitoring, corrective actions, verification, calibration, training, and other required activities.

How Do These Components Relate to the 7 HACCP Principles?

The seven HACCP principles describe the core HACCP methodology, while a written HACCP plan may contain additional information such as the product description, intended use, and process flow diagram.

The plan provides the structure and documentation needed to apply the seven principles to a specific food process.

---

 

The 7 HACCP Principles

The 7 HACCP principles provide the foundation for developing and maintaining a HACCP system.

1. Conduct a Hazard Analysis

Identify potential biological, chemical, and physical hazards associated with the food and process.

2. Identify Critical Control Points

Determine where hazards can be prevented, eliminated, or reduced to an acceptable level.

3. Establish Critical Limits

Set measurable limits that must be met to keep the process under control.

4. Establish Monitoring Procedures

Determine how and when employees will check each critical control point.

5. Establish Corrective Actions

Decide what employees must do when a critical limit is not met.

6. Establish Verification Procedures

Confirm that the HACCP system is working as intended.

7. Establish Recordkeeping Procedures

Maintain records showing that monitoring, corrective actions, and verification activities are being completed.

The FDA’s HACCP guidance identifies seven principles as the foundation of a HACCP system. FDA HACCP Principles & Application Guidelines

These principles are also covered in AAA Food Handler’s Food Manager Certification Study Guide.

---

HACCP Requirements for Records and Documentation

A HACCP plan is only effective when employees understand and follow it.

Restaurants operating under HACCP controls may need records showing that critical limits are being monitored and corrective actions are being taken when problems occur.

Depending on the process, records may include:

• Temperature logs

• Processing records

• pH measurements

• Water activity measurements

• Monitoring records

• Corrective action records

• Verification records

• Equipment calibration records

• Employee training records

• Sanitation records

Managers should regularly review these records for missing information, repeated problems, or other signs that the process may not be operating as intended.

AAA Food Handler’s Internal Food Safety Audit Guide provides additional information about reviewing food safety procedures and records.

---

What Do Health Inspectors Look For?

Requirements vary by jurisdiction, but a restaurant operating under HACCP should be prepared to demonstrate that required food safety controls are being followed.

Depending on the operation, inspectors or regulatory officials may review:

• The current HACCP plan

• Required approvals or permits

• Critical control points

• Critical limits

• Monitoring records

• Corrective actions

• Verification procedures

• Equipment calibration

• Employee training

• Sanitation procedures

• Process changes

Employees should understand the HACCP procedures rather than relying on a plan that is simply kept in a binder.

For more information about preparing for inspections, see AAA Food Handler’s Restaurant Health Inspection Guide.

---

HACCP vs. Food Manager Certification

HACCP and Food Manager Certification are not the same thing.

HACCP	Food Manager Certification
Focuses on controlling hazards in a specific food process	Focuses on an individual’s food safety knowledge
Process-specific	Person-specific
Uses hazard analysis and critical control points	Demonstrates food safety knowledge through a certification process
Includes monitoring and corrective actions	Helps managers understand and manage food safety
May be required for certain specialized processes	May be required by state or local law

Prepare for your Food Manager Certification with AAA Food Handler’s online training and exam.