HACCP plan for a sushi restaurant: rice, raw fish and the numbers to write down
A sushi restaurant plan covers two separate hazards: the rice, which must be made acidic enough that bacteria cannot grow in it, and the raw fish, which must be handled so parasites are killed and the fish stays cold. Many health departments ask for a written plan for the rice, and some for the whole sushi process. The limits are local, so the plan is built around the number your county gives you.
This guide explains what each part of the plan contains, shows how the rows look for rice and for fish, and gives a daily log. It is a how-to, not legal advice: call your health department before you serve. For the general method behind any restaurant plan, read HACCP plan for a restaurant first. If your kitchen also vacuum seals or cooks in bags, that is a separate process: see the sous vide HACCP plan guide.
Why sushi gets its own plan
Most restaurant food is made safe by cooking. Sushi is the exception, and it has two problems that cooking never fixes:
- Cooked rice is a temperature-controlled food. In the Food Code, plain cooked rice is a food that must be held hot (135°F or above) or cold (41°F or below). Sushi rice sits at room temperature for hours because cold rice goes hard and dry. The safe way to do that is to acidify it with vinegar, so the pH is too low for bacteria to grow, and to treat that pH as a critical control point.
- Raw fish carries parasites and is not cooked. The Food Code section on parasite destruction (3-402.11) requires fish served raw to be frozen first, unless the fish is of a kind the Code exempts [1].
That is why county health departments publish their own sushi templates [2][3][4]. Your plan will look like one of them with your menu in it.
Part 1: the sushi rice plan
What is the pH number?
The number is not the same everywhere. The county plans we reviewed say:
| Place (document) | What it says |
|---|---|
| San Luis Obispo County, CA | Target pH below 4.4; critical limit not above 4.6 [3] |
| San Francisco, CA | Template uses pH 4.1 or less [2] |
| Washoe County / Northern Nevada | Vinegar solution added to bring rice to pH 4.2 or less [4] |
4.6 is the figure the FDA uses to separate acid foods from low-acid foods in its rules. Your regulator may be stricter. Write the number your health department gave you, and ask for it in writing.
How do I get there?
Mix a vinegar solution (rice vinegar, sugar, salt) in a measured ratio per measured amount of cooked rice. The ratio is your recipe, and it goes in the plan with the batch size. Mix the batch the same way each time, weigh or measure, and test it. Some counties ask for a first pH test by a certified laboratory and a new one when the recipe changes and once a year [4]. A pH meter or test strips with the right range do the daily check; the meter needs calibrating with buffer solutions.
Rice rows for the plan
| Step | Hazard | Critical limit | Monitoring | If it fails |
|---|---|---|---|---|
| Cook rice | Spore-forming bacteria survive | Cooked through; rice not left sitting hot in the pot too long | Cook checks each batch | Discard if left out |
| Add vinegar mix | Growth if not acid enough | Recipe ratio per batch (written) | Measure by cup or scale; second person checks | Re-make batch |
| Check pH | Growth if above limit | Your local limit (for example 4.1, 4.2 or 4.6) | Test every batch after mixing, record | Add more vinegar solution and re-test, or discard |
| Hold for service | Growth over time | Within hours set in the plan; covered, clean container | Time stamp on the container | Discard past the time |
| Leftover rice | Growth overnight | Discard, or as your plan states | Check at close | Discard |
Plans commonly ask for rice records to be kept for a stated period (two years in one county document we saw [4]). Ask what yours is.
Part 2: the raw fish plan
Parasite destruction
The Food Code sets three ways to freeze fish served raw [1]:
- −4°F (−20°C) or below for 7 days in a freezer.
- −31°F (−35°C) or below until solid, and stored at −31°F or below for 15 hours.
- −31°F or below until solid, and then stored at −4°F or below for 24 hours.
Most restaurants do not freeze the fish themselves. They buy fish frozen by the supplier and keep a letter or invoice statement that says how it was frozen. That paper goes in the plan. Some fish are exempt from freezing: certain wild tuna species, and some farmed fish under conditions the Code lists [1]. The San Francisco template lists the freezing step as its own critical control point and exempts tuna [2]. If you buy fish and are not sure which category it is in, ask the supplier in writing.
Raw fish rows for the plan
| Step | Hazard | Limit | Monitoring | If it fails |
|---|---|---|---|---|
| Receive | Warm fish, no proof of freezing | 41°F or below (or frozen); supplier letter on file | Probe one fish; file the letter | Refuse the fish |
| Store | Growth | 41°F or below, or frozen as bought | Read the unit at open and close | Move, discard if over 4 hours |
| Thaw | Growth while thawing | In the cooler, not on the counter | Date and time label | Discard if left out |
| Slice and serve | Cross-contamination | Clean board and knife, gloves, small batches | Cook checks on the line | Sanitise, discard |
| Menu | Customers not told | Consumer advisory printed on the menu (Food Code 3-603.11) | Manager checks the menu on each reprint | Reprint |
If you serve raw oysters or other shellfish, keep the supplier's tags for 90 days, as the Food Code asks [1].
Other things an inspector reads in a sushi plan
- Handwashing and gloves. Rolling by hand is a hand-contact job. Say when gloves change.
- Cross-contamination. Cooked items (tamago, eel, shrimp) are on a separate board from raw fish.
- Allergens. Fish, shellfish, soy, sesame, eggs and wheat are all in a sushi menu. List them.
- Ice and display cases. The sushi case should hold at 41°F or below; log it like any other cold unit. See cold holding temperature.
- Time as a control. If any item sits out under the four-hour rule, the Food Code needs a written procedure and a mark of when it came out [1].
A daily sushi log
| Date | Rice batch / size | Vinegar mix | pH reading | Time made | Discard by | Case temp | Initials / action |
|---|---|---|---|---|---|---|---|
| 11/05 | Batch 1, 4 kg | per recipe | 4.1 | 10:30 | (plan hours) | 38°F | MK / ok |
| 11/05 | Batch 2, 4 kg | per recipe | 4.8 | 3:00 | (plan hours) | 39°F | MK / above limit; more vinegar, re-tested 4.2, ok |
The second row is what an inspector wants to see once in a while: a miss, caught and fixed. A log with every row perfect looks written in one sitting. Our temperature log sheet guide covers the case and walk-in readings, and the free temperature logs give you those pages to print.
How to write the plan, in order
- Call your health department. Ask for their sushi template and the pH limit.
- List every sushi item and sort it: raw fish, cooked fish, vegetarian, rice only.
- Write the rice recipe with measurements and batch size.
- Buy a pH meter or strips, calibrate, and test three batches. Keep the results.
- Collect the supplier letters for freezing.
- Fill the two tables above with your numbers.
- Print the logs. Train staff and write the date.
- Send the plan to the department before opening the sushi line.
Common mistakes
- Judging the rice by taste. Sour is not a pH. Measure.
- Changing the recipe and not the plan. More sugar, less vinegar, a bigger batch: each can move the pH.
- No supplier letter for the fish. The freezing step is only proved by paper.
- A missing consumer advisory. Add it to every menu, including the online one.
- Rice kept overnight. Follow the plan: discard, not refrigerate and re-use, unless your approval says otherwise.
- Copying another county's pH. Use yours.
Questions
Does a sushi restaurant need a HACCP plan?
For the rice, often yes: many health departments require a written plan or an approved procedure for acidified sushi rice. For the fish, they require the freezing proof and the menu advisory. Ask yours.
What pH should sushi rice be?
The limit is set locally. Plans we reviewed use 4.1, 4.2 or a target below 4.4 with a limit of 4.6. Use your department's number.
Can I leave sushi rice out at room temperature?
Only under an approved process: the rice is acidified to the pH limit, held for the hours the plan states, and discarded after. Otherwise it follows the usual hot or cold rule.
Do I have to freeze fish for sushi?
For most raw fish, yes, to the Food Code times and temperatures, usually done by the supplier. Certain tuna species and some farmed fish are exempt under conditions [1].
How often do I test the rice pH?
Every batch is the safest default. Some counties ask for lab tests at the start, after a recipe change, and yearly [4].
Is a sushi HACCP plan the same as a general restaurant plan?
It is a process plan inside it. The rest of the kitchen still needs holding, cooking and cooling controls. See HACCP plan for a restaurant.
Want the walk-in, the sushi case and the line covered while you write the rice recipe? Print the free temperature logs first.
Sources
- FDA Food Code (parasite destruction 3-402.11, consumer advisory 3-603.11, shellfish tags), U.S. Food and Drug Administration
- Sushi HACCP template, City and County of San Francisco
- HACCP plan for sushi rice, San Luis Obispo County
- Sushi rice HACCP worksheet, Northern Nevada Public Health
Related: all food safety guides.