Sous vide HACCP plan: what to write down and what the health department wants to see
If you cook food in a sealed bag and then chill it or hold it for later, most health departments want a written HACCP plan before you start. The plan names the process, the cooking time and temperature, how fast the bag must chill, the storage limit, the label, and what you do when a number is missed. Without it, a bag of food that looks fine can still hold a toxin that cooking later will not remove.
This guide is for a restaurant kitchen with a water bath or combi oven and a vacuum sealer. It covers why sous vide is treated differently, what the plan has to contain, a worked example, a daily log, and the mistakes that get plans sent back. It is not legal advice; the rules are set by your state or county, so the last step is always a call to your health department. For the wider picture of a restaurant plan, see our HACCP plan for a restaurant guide.
Why sous vide needs a written plan
In the FDA Food Code, packaging food with most of the air removed is called reduced oxygen packaging, or ROP. Vacuum sealing, cook-chill and sous vide are all ROP. Section 3-502.12 of the Food Code sets the conditions, and state health guidance we reviewed (Oregon, Minnesota, Nevada counties) says cook-chill and sous vide need a HACCP plan [1][2][3].
The reason is two bacteria that do well without air:
- Clostridium botulinum. Its spores survive ordinary cooking. In a sealed bag with no oxygen and no competing bacteria, some types can grow and make a toxin. Cooking after the toxin is made may not destroy it. The non-proteolytic types can grow at refrigerator temperatures, which is why chilling alone is not enough.
- Listeria monocytogenes. It grows slowly in the cold, so a bag kept for days or weeks gives it time. Contamination after cooking, at opening, slicing or re-bagging, is the usual route.
Health departments often describe the safe approach as two barriers: refrigeration is the first, and a second one, such as a short shelf life, a low storage temperature, or a pH or salt level, adds protection. The plan is how you show which barriers you use.
Do I need a variance as well?
A variance is a separate approval from the health department to do something the Food Code does not allow on its own. Some jurisdictions allow sous vide with an approved HACCP plan only. Others also want a variance for certain ROP uses, such as keeping bagged raw fish or extended shelf life. Rules differ by state and sometimes by county, and they change when a state adopts a new Food Code edition [1].
One commonly seen carve-out: where food is cooked in the bag and removed from the bag within a short time (some guidance says 48 hours) and served, a full plan may not be required. Do not assume it applies; ask. Write down who you spoke to and the date.
Ask your health department these questions before you buy equipment:
- Do I need a HACCP plan, a variance, or both for sous vide and cook-chill?
- Do you have a template or worksheet? (Several counties publish one [3][4].)
- What is the longest I may keep a cooked bag, and at what temperature?
- What training or certification must the person running the process hold?
- Will you inspect the setup before I serve food made this way?
What the plan has to contain
Review checklists from state agencies (for example Texas and Nevada [3][5]) ask for roughly the same pieces. Plan for these sections.
1. Menu items and the process flow
List each food made this way, such as salmon, short rib, egg bites, duck leg, and draw the path as a short list: receive, store, portion, season, seal, cook, chill, store, reheat or finish, serve. Keep raw and cooked bags on separate shelves, and say so.
2. Equipment
The vacuum sealer, immersion circulator or combi oven, the chilling method (ice bath, blast chiller), the refrigerator, and the thermometers. A plan should name the thermometer that checks the bath (a probe in the water, not the circulator's display alone) and the one that checks the food. Say how you calibrate: ice water should read 32°F.
3. Hazards
Spore-forming bacteria, Listeria, Salmonella and others in raw meat and poultry, parasites in raw fish if the bag is not cooked fully, and allergens in marinades. State them plainly. A plan that lists only "bacteria" will be sent back.
4. Critical control points and limits
The control points in a sous vide plan are usually these. The numbers in the limit column must come from your regulator or from published time-temperature tables, not from this page.
| Step | Limit (examples) | Where the number comes from |
|---|---|---|
| Receiving raw food | 41°F or below; fish kept as the regulator directs | Food Code cold holding; local ROP rules for fish |
| Cooking in the bag | A written time and core temperature per food and thickness | Food Code 3-401.11 and the USDA FSIS time-temperature tables for lower temperatures held longer [6] |
| Chilling after cooking | A stated number of hours to reach 41°F or lower, usually by ice bath or blast chiller | Your health department's ROP or cook-chill guidance [1][3] |
| Cold storage | At or below the temperature the regulator names, with a maximum days | Local rule or variance conditions |
| Reheating and finishing | 165°F for food held hot, or the temperature your plan approves for serving at once | Food Code reheating rules |
| Opening the bag | Clean hands, clean tools, serve or discard the same day | Prevents Listeria getting in after cooking |
5. Monitoring
Who checks what, and when. Typical: the cook logs the bath temperature at the start and at the end of each batch, the core temperature of the thickest bag at the end, the minute the bag went into the ice bath and the minute it reached 41°F. The cooler is read twice a day.
6. Corrective actions
What staff do when a number is missed. Examples: if the bath fell below the limit mid-cook, restart the time or discard, as your plan states; if the bag did not chill in time, discard it; if a bag in storage is puffed or leaking, discard it unopened. "Throw it out" is a fine corrective action; write it in.
7. Labels and shelf life
Every bag carries the product name, the date cooked, the date to use by or discard, and "keep refrigerated" (or the temperature). Staff should never have to remember a date.
8. Training and verification
Name who is trained to run the process, with the date. Verification: calibrating thermometers, a manager reviewing the logs weekly, and, in some places, lab tests or an annual review with the inspector.
A worked example: salmon fillet, cooked in the bag, chilled, served within the week
This shows the shape of a row. Every number marked "per plan" is the one your health department approves. We do not invent them here.
| Step | What staff do | Limit | If it fails |
|---|---|---|---|
| Receive | Check the fish is cold, check the tag; store at the fish storage temperature | Per plan (fish is often held colder than 41°F in ROP rules) | Refuse delivery |
| Portion and seal | Gloves, clean board, seal with the vacuum sealer; label with date | Sealed within time per plan | Re-seal or discard |
| Cook | Bath at set temperature (probe in water); log start time; check core | Time and core temperature per plan | Extend time and re-check, or discard |
| Chill | Ice bath, log time in and time at 41°F | Hours to 41°F per plan | Discard |
| Store | Date label, shelf dedicated to cooked bags; read cooler twice a day | Storage temperature and use-by per plan | Move, check readings, discard if over use-by |
| Finish | Open bag, sear or reheat, serve at once | Reheat temperature per plan | Reheat again or discard |
For a short rib or duck leg the same table works with a longer cook time and a lower chill hour limit, because a big bag chills slowly. Thick bags are the usual cause of a missed chill step: use a shallow bag shape, a slurry of ice and water rather than ice alone, or a blast chiller.
A daily sous vide log
Print a page like this and clip it next to the bath. One row per batch.
| Date | Food and batch | Bath temp | Start / end time | Core temp | Into ice / at 41°F | Use-by on label | Initials / action |
|---|---|---|---|---|---|---|---|
| 11/05 | Salmon, 12 bags | (plan value) | 2:00 / 3:10 | (plan value) | 3:12 / 4:05 | (plan value) | JR / none needed |
| 11/05 | Short rib, 6 bags | (plan value) | 9:00 / 4:00 | (plan value) | 4:02 / 7:50 | (plan value) | JR / bags 5-6 slow to chill; discarded, shallower bag next time |
The second row shows the point of the corrective-action column: a missed number, what happened to the food, and what changes. For the habit of recording at the time, not at the end of the week, see the restaurant temperature log sheet guide. The free temperature logs cover the walk-in and the hot line that sit around this process.
Mistakes that get a sous vide plan sent back
- A generic template with a different food. A plan for chicken breast when you cook beef and eggs. Edit every line to your menu.
- Display temperature only. The circulator's screen is not a calibrated reading. Record a thermometer reading.
- No chill record. The cook step feels safe; the chill step is where the plan fails. Log the times.
- Thick bags in a small ice bath. They chill in hours, not minutes. Test with a probe.
- Open-ended shelf life. "Keep until used" is not a use-by date.
- Raw and cooked bags on one shelf. Separate them, cooked above raw.
- Starting before approval. Serving first and asking later is how a plan becomes a citation.
Questions
Is sous vide legal in a restaurant?
Yes, in every US state, with conditions. Most want a written HACCP plan, and some also want a variance. Ask your local health department which applies.
Do I need a HACCP plan for vacuum sealing food?
Often yes for cook-chill and sous vide, and for packaging raw food and keeping it for days. Some places exempt short holds where the bag is opened the same service. Check locally.
What temperature must sous vide food chill to?
41°F is the baseline in the Food Code for cold holding. ROP rules often require a stated time to reach it and a lower storage temperature. Use your health department's number.
How long can I keep a sous vide bag?
The longest allowed is set by your regulator or variance, not by what looks fine. Write the date on the bag and in the plan.
Can I use a free sous vide HACCP template?
County templates from health departments are the best start because the inspector wrote them. Replace the example foods with yours and fill every number from your own approval.
Does the plan cover the rest of my kitchen?
No. It covers the sous vide process. The walk-in, the hot line and cooling still need their own checks; see hot holding temperature and cold holding temperature. A kitchen that also serves raw fish for sushi needs a second process plan: HACCP plan for a sushi restaurant.
If you would rather not start from a blank page, start with the free temperature logs and ask us about a plan built from your menu.
Sources
- FDA Food Code (sections 3-502.11 and 3-502.12, reduced oxygen packaging), U.S. Food and Drug Administration
- Sous vide fact sheet, Oregon Health Authority
- Reduced oxygen packaging guide, Minnesota Department of Health
- Sous vide and reduced oxygen users guide, Boulder County Public Health
- HACCP review checklist, Texas Department of State Health Services
- Safe minimum internal temperature chart, USDA Food Safety and Inspection Service
Related: all food safety guides.