Acidified Rice

HACCP Plans, Time,

or Temperature
Controls

MN Food Safety Partnership Plus

Sushi /HACCPTraining
April 5, 2011

Options
1. Hot or Cold Holding at proper temperatures

flavor enhancement only,

a HACCP plan is NOT required.

2. Use Time as a Public Health Control

3. Held at room temperature
A HACCP plan is required when additives are used to:
preserve food rather than to enhance flavor, or
render a food NOT potentially hazardous

1. Temperature Control
Rice is cooked, acidified/flavored,
properly cooled, and held cold (41 or
less)
Or
Rice is cooked, acidified/flavored, and
held hot (140 or more)

2. Time as a Public Health

Control
MN Food Code 4626.0410 3-501.19
Time only, rather than temperature
controls (and time).
For ready to eat potentially hazardous
food displayed or held for service for
immediate consumption

2. Time as a Public Health

Control
Must be served or discarded within 4
hours
Must be marked or otherwise identified
with the time to serve or discard
Can not be removed from time control and
returned for use at a later time.
When time expires (or if something doesnt
get marked) food must be discarded

2. Time as a Public Health

Control
Firm must have written procedures to
ensure compliance with the previous
requirements.
Firm must notify the regulatory authority in
writing that they intend to use Time as a
Public Health Control prior to
implementation.

3. HACCP Plan
HACCP plan must comply with MN Food
Code requirements
MN Rule 4626.1735 8-201.14
Contents of HACCP Plan
4626.1730 8-201.13 Subp. 3
Compliance with HACCP Plan

Hazard Analysis, CCPs, Critical Limits

Hazard Analysis must be completed
Bacillus cereus and related toxin formation
must be identified as hazards likely to occur.

Critical Control Point - CCP

The addition of vinegar (acidification step)

Critical Limits
pH must not exceed 4.3

Process Flow
A Flow Diagram that identifies critical
control points must be provided
Ingredients, materials, and equipment
used in product preparation must be
identified.
Strength of vinegar must be identified (%
by volume).

Recipe/Formulation
Must show production/preparation
methods and steps
Must show controls for food safety
concerns in the recipe
Critical control points and critical limits

SOP for the HACCP Plan

HACCP Plan
Firm Name:

Product/Process:

Address:

Approved by:
Date:

Step CCP

Critical
Limit

Monitoring
What

How

Frequency

Corrective
Action
Who

Verification

Records

Establishing the Critical Limit

Achievement of equilibrium pH must be
demonstrated
Equilibrium defined
through trial/laboratory testing procedures
testing must be specific to product and
processes used
documentation must be provided

Establishing the Critical Limit

Target pH must be adjusted to allow for
the accuracy of the pH meter. +/- 0.1
The target pH must be adjusted to allow
for any change in pH over time
as may be demonstrated through the above
equilibrium pH testing

About pH
A change of one unit represents a change
of 10 fold in acidity. That is, a pH of 4.0 is
10 times more acidic than a pH of 5.0.
A pH of 4.3 (minimum required to control
B. cereus) is 3 times more acidic than a
4.6 (required to control C. botulinum).
Each change in pH of .1 is, therefore, very
significant.

FDAs Recommendations on
pH measurement
If the finished equilibrium pH of a food is
above 4.0, the measurement of the
finished equilibrium pH must be made by
a potentiometric method (i.e. a pH meter)
If the finished pH is 4.0 or below, any
suitable method of measuring acidity may
be used (i.e. pH paper)

SOP for pH Measurement:

Follow manufacturer use instructions and
specifications for pH testing and calibration
Temperature has an effect on pH and the accuracy of
pH measurement.
Distilled water can be added to create a slurry to rice to
measure pH
It is imperative that you know the accuracy of the pH
meter (+/- .1, for example).

Calibration of pH Meters
Calibration
Should use standardized buffer solutions of 4.0 and
7.0 (unless otherwise specified by the manufacturer)
be sure buffer solutions have not passed the
expiration date
Some pH meters do an automatic adjustment,
others require a manual adjustment.

Calibration Frequency/Documentation
Daily or Each batch & record results

Ask the firm to demonstrate calibration

Monitoring

What equillibrium pH of rice

How - with xxx brand pH meter
Frequency - for each batch, prior to use.
Who Sushi Chef, PIC, CFM
Person testing the pH of the rice must
understand use of pH meter, calibration

Corrective Actions
If pH is above the critical limit, proper
rework procedures must be provided.
Addition of additional vinegar

Any corrective actions taken must be

documented

Verification
Monitoring/process records should be
reviewed daily or as needed by the PIC.
pH log/ records

pH meter calibration
HACCP plan should be signed and dated
and reviewed at least annually by PIC/
HACCP team members, or when the
HACCP plan is modified.

Records
A pH log for acidified rice must be
maintained and available.
Corrective actions log
A calibration log
Suggested that on-going laboratory test
results are maintained for at least one
year.

Presenter:
Jan Kelly, RS
Food Inspection Supervisor
MN Dept of Agriculture
Dairy and Food Inspection Division
Jan.L.Kelly@state.mn.us
507-747-3052