HACCP plan for raw oysters: source, temperature and tags

A raw oyster is never cooked, so a HACCP plan for raw oysters controls four things instead: where the oysters came from, how cold they stay from the dock to the plate, how long you can trace them, and whether the guest was told the risk. Buy only from a certified dealer, receive live oysters at an air temperature of 45°F or less and an internal temperature of 50°F or less, cool them to 45°F within 4 hours, and keep each shellstock tag for 90 days. This page turns those into plan rows, a daily log and the responses for when a delivery fails.

If you want the sheets before the reading, the free temperature logs are on the logs page. The rules below are from the FDA Food Code and the National Shellfish Sanitation Program; your state may be stricter, so check the final numbers with your health department.

Do you need a HACCP plan to serve raw oysters?

Usually not by name. The Food Code does not require a full HACCP plan for a restaurant that buys whole, live oysters and serves them raw, as long as it follows the standard rules for shellstock: approved source, receiving temperature, tags, storage and a consumer advisory. Many kitchens still write one, for three reasons.

Some health departments ask for it. A written plan for raw bar service is a common request at a new-opening review or after a complaint.
A plan is the easiest way to prove the rules. An inspector reads one page and sees the source, the limits and the records, rather than asking six questions.
The risks are real. The CDC estimates that about 80,000 people in the U.S. get a Vibrio infection each year and about 100 die, and raw oysters are a leading food source of it [3]. Norovirus and hepatitis A are also linked to raw shellfish.

A plan is required in some cases: if you hold live shellfish in a display tank with a life-support system, shuck and package oysters for sale, or use any process the code treats as specialized. Ask before you build the tank; it is usually approved separately. For the general way to write a plan, see the HACCP plan for a restaurant guide; this page covers the raw oyster part only.

The hazards a raw oyster plan covers

Oysters feed by filtering seawater, so whatever is in the water ends up in the animal. That sets the hazards.

Hazard	Where it comes from	What controls it
Vibrio parahaemolyticus and Vibrio vulnificus	Warm coastal water; grows fast in oysters left warm after harvest	Certified source, fast cooling after harvest, cold storage
Norovirus, hepatitis A	Sewage-contaminated growing water	Approved harvest areas only, tags to trace
Toxins (paralytic shellfish poisoning and others)	Algal blooms in the harvest area	Closures of the harvest area by the state; you cannot test for it, you rely on the source
Cross-contamination	Shell grit, drips, shared knives	Clean shucking station, sanitized knives, separate storage

None of these can be cooked out of a raw oyster, and none can be seen or smelled. That is why the source row is the most important one in the plan.

Control point 1: approved source

The Food Code says shellfish must come from a source listed by the state shellfish control authority, on the FDA's Interstate Certified Shellfish Shippers List [1]. In practice that means the dealer's certification number is on every tag and every case you receive.

Limit: every container comes from a certified dealer and carries a legible tag or label.
Monitoring: at each delivery, someone reads the tag: harvest area, harvest date, dealer certification number, type of shellfish and quantity.
Corrective action: reject any container without a tag. Do not take "it comes from the usual guy" in place of a tag.
Verification: once a month, check the dealer's number against the current Interstate Certified Shellfish Shippers List.

Never buy oysters from someone who harvests and sells them out of a truck, however fresh. If the tag is missing, the oyster has no legal source in the food chain.

Control point 2: receiving temperature

For live shellstock the Food Code uses a different pair of numbers than for other cold food: an air temperature of 45°F (7°C) or less, and an internal oyster temperature that does not exceed 50°F (10°C) [1]. After receiving, the shellstock goes into cold storage and is cooled to an internal temperature of 45°F or less within 4 hours. Shucked oysters, which are not in the shell, follow the general rule: 41°F or less.

Monitoring: measure the air temperature in the case or truck with a thermometer, and the internal temperature of an oyster with a probe or by laying a calibrated thermometer between two oysters in the case. Record both.
Limit: air 45°F or less; internal 50°F or less.
Corrective action: if the internal temperature is above 50°F, reject the delivery. If the air temperature is above 45°F but the oysters themselves are 50°F or less, accept and move at once to the cooler, and call the dealer.

Also check the oysters themselves. Live oysters should be closed, or close when you tap the shell. A gaping oyster that stays open is dead; discard it. A case that smells of ammonia or of anything other than the sea is a reject.

For the full receiving routine for all foods, with the milk, egg and fish exceptions, see the receiving temperature log guide.

Control point 3: storage and tags

Once the oysters are in the building, three rules protect the trace.

Keep shellstock in its original container with the tag attached until the container is empty. Do not move oysters into a bus tub and throw the tag away.
Keep the tag for 90 days from the date the container is emptied, filed in the order of use, with the date the last oyster from the container was sold or served written on it [1]. If an outbreak is traced to oysters, this is how the health department finds your lot and how you show it came from a legal source.
Store shellstock on ice or in the cooler, drained, cup side down so the liquor stays in the shell. Do not store in fresh water or in melted ice water: fresh water kills the oyster and wipes out the shellfish's usable life. Keep the tag with the case.

Store raw oysters on a shelf below ready-to-eat food, not above it, and keep them away from cooked shellfish so drips do not cross over. Rotate first in, first out by harvest date, not by delivery date.

Control point 4: the shucking station

The oyster is cold and closed until the moment it is shucked, so the risk added in your kitchen is mostly about hands and tools.

Wash and sanitize the knife between batches, and replace a knife that has been dropped.
Rinse shell grit off before shucking, with potable water, so it does not fall into the meat.
Keep the shucked tray on ice, and serve or return the tray to the cooler quickly, and set a counter-time limit in the plan (your health department may name one).
Do not serve an oyster that shows a broken adductor, a dry or sunken look, or a smell.
Staff with vomiting or diarrhea do not shuck. Norovirus on a shucker's hands is a serious route for illness, and the Food Code requires a sick worker to be excluded.

Control point 5: the consumer advisory

The Food Code requires a consumer advisory for any animal food sold raw or undercooked [1]. It has two parts: a disclosure that the item is raw or undercooked, and a reminder that eating raw shellfish may increase the risk of foodborne illness, especially for people with certain medical conditions. The common wording is: "Consuming raw or undercooked shellfish may increase your risk of foodborne illness, especially if you have certain medical conditions." Put it on the menu, tied to the oysters with an asterisk, or on a table card.

Write the placement into the plan so a new manager reprinting the menu does not drop it. The people at highest risk from Vibrio vulnificus include those with liver disease, diabetes or weakened immune systems, which is why the advisory exists.

Worked plan rows

Step	Hazard	Limit	Monitoring	If it fails	Record
Receive shellstock	Unsafe source; temperature abuse	Certified dealer tag on every container; air 45°F or less; internal 50°F or less	Manager reads tag and takes both temperatures at each delivery	Reject without a tag or above 50°F internal	Receiving log
Cold storage	Vibrio growth	Internal 45°F or less within 4 hours; cooler 41°F or less	Cooler checked twice a day; oysters probed at delivery	Move to a working cooler; if above 50°F for over 4 hours, discard	Cooler log
Tag retention	No trace after an outbreak	Tag kept 90 days from the day the container is empty	Weekly check that tags are filed with last-served dates	Re-tag from the delivery invoice and call the dealer	Tag binder
Shucking	Cross-contamination; sick worker	Knife sanitized between batches; ill staff excluded	Cook checks at the start of the shift	Discard the tray and resanitize	Shift check
Menu	Guest not told	Advisory on the menu next to the oysters	Checked at each reprint	Reprint or add a card	Menu file

A daily raw oyster log

A single page covers it. One row per delivery plus a daily line:

Date	Dealer and cert. no.	Harvest area and date	Air temp	Internal temp	Tag on case?	Initials	Action
Nov 3	Example dealer, MA-123-SS	Bay A, Oct 31	41°F	44°F	Yes	MR	None
Nov 5	Example dealer, MA-123-SS	Bay A, Nov 2	49°F	53°F	Yes	MR	Rejected; dealer called; credit agreed

The numbers and the dealer in this example are invented to show how a row reads. Use your own. The second row is what makes the page convincing: a failure with its response.

What if a delivery is late, warm or untagged?

No tag: reject. Photograph the case and note it on the log.
Warm internal temperature: reject above 50°F. Between 45°F and 50°F internal, the code allows you to accept and cool within 4 hours, but ask whether the dealer can show how long the oysters were out of the water.
The cooler went down overnight: if the oysters stayed at 41°F to 45°F, they are fine; if they sat above 50°F for hours, discard them. Check your walk-in cooler log to see what happened.
A guest reports illness: pull the tag for the lot, keep any unsold oysters from that lot, call the health department, and do not throw out the evidence. The tag and the log are your protection.
The state closes a harvest area: your dealer should tell you; if you see a closure notice for the area on your tags, pull that stock from service.

Warm months and the extra state rules

Several states, especially on the Gulf Coast, the Pacific coast and in the Northeast, add rules in the warmer months, when Vibrio grows fastest. These usually set a maximum time from harvest to refrigeration, which is the dealer's responsibility, and sometimes ask restaurants to keep specific records. They change by state and year, so the plan should have a line saying "check [state agency] summer rules each May" and a person who does it. Do not copy another state's numbers into yours.

Where raw oysters fit with the rest of your plan

Raw oysters sit alongside other raw fish dishes. If you also serve raw fish, the freezing step for parasite destruction belongs to that plan; it is covered in the sushi restaurant HACCP plan. Oysters need no such step: they are a different hazard class, so their control is source and temperature. Cooked oyster dishes (grilled, fried, in stew) must reach 145°F, and they should be in the plan too. Your cooler records are in the temperature log sheet guide, and the written plan rows for any kitchen are in the critical control points examples.

Other special processes have their own plans: vacuum sealing if you pack oysters or other seafood in bags, and sous vide for cooked shellfish dishes.

Questions

Is a HACCP plan required to serve raw oysters?

Not in most places for plain live oysters, provided you follow the shellstock rules. A plan is required for tank display, shucking for packaged sale and other specialized processes. Ask your health department.

How long do I keep oyster tags?

90 days after the container is empty, with the last-served date on the tag, in order of use.

What temperature should live oysters be on delivery?

Air temperature of 45°F or less and internal temperature of 50°F or less, then cooled to 45°F within 4 hours.

Can I store oysters in water?

No. Keep them drained, cup side down, on ice or in the cooler. Fresh water kills them.

Does lemon juice or hot sauce kill the bacteria?

No. Acid and hot sauce do not make a raw oyster safe, and the advisory should not suggest they do.

What do I tell guests?

Put the raw-shellfish consumer advisory on the menu next to the oysters. Staff should be able to repeat it.

Where can I get a log?

The free sheets on our logs page include receiving and cooler logs; add the dealer number, harvest area and tag columns above for oysters.