HACCP plan for a bakery: which items need one and what to write

Most of what a bakery sells is shelf-stable and needs little control: bread, cookies, plain cakes and fruit pies keep safely at room temperature. A bakery HACCP plan is for the items that do not: cream and custard fillings, cheesecake, meringue, cream cheese frosting, quiche and breakfast sandwiches. Those are TCS foods (time/temperature control for safety) and need cooking, cooling and cold holding limits, plus a plan for raw eggs, raw flour and allergens. This page sorts the menu into the items that need controls and those that do not, then gives worked rows and a daily log.

If you want blank logs first, they are on the logs page. Limits here come from the FDA Food Code; your health department's adopted version may differ, so confirm the numbers before you print the plan.

Does a retail bakery need a HACCP plan?

For an ordinary retail bakery, a written HACCP plan is not usually required by the Food Code. A plan becomes necessary when you do a specialized process (vacuum packing, curing, smoking), when your health department makes it a license condition, or when you sell wholesale to others, where the Preventive Controls rule (FSMA) and customer audits apply. Many small bakeries write one anyway because a plan answers the inspector's real question: "Which of your items can make someone sick, and how do you know they are safe?"

A cottage food bakery working from a home kitchen has its own state rules, often a short list of allowed non-TCS products and labels. This page is for a licensed shop; check your state's cottage food law if you are home-based. For the general way to write a plan, see the HACCP plan for a restaurant guide.

Sort your menu: TCS or not

The first job is a list. Mark each product as one that needs time and temperature control or one that does not. The test is whether it supports the growth of bacteria when left at room temperature, which depends on moisture, acidity and sugar, not on whether it is "sweet".

Edge cases are the ones to settle with your inspector in writing: buttercream, ganache, fruit fillings with low sugar, and cakes with fresh fruit. A rule of thumb many inspectors use is that a high-sugar, low-moisture filling is non-TCS and a dairy- or egg-heavy filling is TCS, but the call is theirs, not ours.

The control points in a bakery

For a retail bakery with a cream and custard line, the plan has seven rows. The rest of the bakery (baked goods that need no control) sits under general good practices: handwashing, cleaning, pest control.

1. Receiving eggs, dairy and filling ingredients
2. Raw eggs in products not baked or cooked
3. Cooking custards and fillings
4. Cooling those fillings
5. Filling and assembly
6. Cold holding in the case
7. Allergens, labels and raw flour

Receiving: eggs and dairy

Eggs and dairy arrive at 41°F or below; shell eggs at 45°F ambient or less are accepted under the Food Code [1]. Use a receiving log and reject warm or cracked eggs. If you make anything with uncooked eggs (some meringues, mousse, royal icing, buttercream made with raw egg whites, tiramisu), use pasteurized eggs. The Food Code requires pasteurized eggs for dishes served to highly susceptible populations and recommends them wherever eggs are not fully cooked.

Cooking custards and fillings

Egg-based fillings are cooked until set. For eggs held after cooking, the Food Code sets a cooking temperature of 155°F, with a short hold time at that temperature; use the number in your jurisdiction's adopted code. If you cook a pastry cream to a full boil, as most recipes do, you pass that limit.

• Limit: filling reaches at least 155°F, or a full boil for starch-thickened cream.
• Monitoring: probe the middle of the pot at the end of cooking. Write the temperature, not "done".
• Corrective action: continue cooking and recheck.

Baked custard items, such as quiche, cheesecake and crème brûlée, should reach 145°F in the center for a short time as a minimum for eggs, or the higher number your jurisdiction sets for held foods. For a cheesecake, the center jiggles; probe it anyway.

Cooling fillings and cooked items

This is the bakery's weak spot. A pot of pastry cream is dense, sugar-rich and full of egg, and it holds heat for hours. The cooling limit is the same as the restaurant rule: 135°F to 70°F in 2 hours and to 41°F in 6 hours in total [1]. Strategies that work in a bakery:

• Spread hot cream on a sheet pan or in a shallow hotel pan, one inch deep.
• Press plastic wrap on the surface to stop a skin, and place the pan on ice or in a blast chiller.
• Stir over an ice bath for pot-sized batches.
• Make smaller batches more often. Cooling a gallon takes much less time than cooling five.
• Log it. The format and a filled-in sheet are in the cooling log guide.

Filling and assembly

Once cooled, the filling is cold-held at 41°F or below. Take out what you need, not the whole tub, and return the rest at once. Fill and decorate in batches that return to the cooler within a set time. Write a working-time limit per batch into the plan (for example 30 minutes, your choice), checked by a timer or a label. If the filling climbs to 50°F in the piping bag, it returns to the cooler first. Use clean piping bags and tips each day; a bag reused all week is a common source of contamination.

Fresh fruit toppings, cut melon and whipped cream follow cold holding. Hard cheese and cured meat on savory pastries follow the same logic.

Cold holding in the display case

A display case is a refrigerator with glass and many open-door moments. Many cases run warm. The limit is 41°F or below for TCS items, measured on the food, not the case dial [1].

• Put a thermometer in the case and probe a sample product at opening, midday and close.
• Keep TCS items on the coldest shelf, usually the back and bottom; keep room-temperature items out of the cold case or visibly separate.
• Do not overfill; air needs to move.
• If the case reads above 41°F, move the product to the walk-in and call for repair. If it was above 41°F for under 4 hours, you may be able to keep the item; over 4 hours, discard.

The cold holding details, including why coolers creep up and a response plan, are in the cold holding temperature guide, and the full log layout in the temperature log sheet guide.

Raw flour and raw dough

Flour is a raw agricultural product. It is not treated to kill germs, and it has been linked to outbreaks of E. coli and Salmonella [2][3]. The risk in a bakery is not from the baked loaf; the baking step kills the bacteria. It is from raw dough and batter that people taste, and from dust and cross-contact.

• Staff do not taste raw dough or batter.
• No raw dough in the case or for children to play with, unless made with heat-treated flour and pasteurized eggs and labeled as safe to eat raw.
• Wash hands and surfaces after handling flour, and sweep rather than blow it around.
• Bake bread and pastry through to a done center. A visual cue is fine, but a probe reading of at least 190°F is a common check for bread (opinion: this is a quality benchmark, not a Food Code limit).

Allergens and labels

Bakeries are the most allergen-heavy kitchens there are. The nine major allergens in U.S. law are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soy and sesame [4]. Wheat and eggs are in nearly everything you bake, and shared mixers, trays and flour dust make cross-contact easy.

• Keep a written ingredient list for every product, updated when a recipe or a supplier changes.
• Label packaged items with the ingredients and the allergens in plain language. Food packed for sale in the shop has to have a label.
• Separate tools for nut products; clean mixers and trays between allergens.
• Train counter staff to say "I don't know, let me check the list", never "I think it's fine".
• Do not promise "allergen free" or "nut free" unless you are certain, and then only for a dedicated process.

Worked plan rows for a bakery

A bakery's daily log

One page per day is enough:

The entries are examples of how rows read, not records. A sheet where something went wrong and was fixed is more believable than a clean one.

A bakery with a coffee counter should also read the cafe and coffee shop plan, and the food safety plan template shows the eight parts a plan needs.

Questions

Does a bakery need a HACCP plan?

Not by default for a retail shop. It is needed for specialized processes, wholesale or when your health department requires it.

Which bakery items need refrigeration?

Cream and custard fillings, cheesecake, cream pies, cream cheese frosting, quiche and sandwiches. Bread, cookies and plain cakes do not.

Is buttercream a TCS food?

Depends on the recipe (sugar, egg, dairy content). Ask your health department and write down the answer.

Do I need pasteurized eggs?

For any recipe where eggs are not cooked through: meringue not baked hard, mousse, tiramisu, raw-egg icing.

Is raw cookie dough safe to taste?

No. Raw flour and raw eggs both carry risk. Do not taste raw dough or sell it unless made with treated flour and pasteurized eggs.

What is the cooling rule for custard?

135°F to 70°F in 2 hours, then to 41°F within 4 more.

Where do I get logs?

Use the free sheets on our logs page and add the item column from the example above.

Sources

1. FDA Food Code 2022 (3-202.11 receiving, 3-401.11 cooking, 3-501.14 cooling, 3-501.16 cold holding, 3-801.11 pasteurized eggs), U.S. Food and Drug Administration
2. Raw dough can make you sick, U.S. Food and Drug Administration
3. Food safety and raw flour, Centers for Disease Control and Prevention
4. Food allergies and the major allergens, U.S. Food and Drug Administration

Eggs in fillings and icings: the HACCP plan for eggs covers storage, pooled and pasteurized eggs.

Related: all food safety guides.