Sous vide and vacuum packing in a restaurant: the Food Code rules, a HACCP plan outline and the logs

A vacuum sealer and a circulator fit in a corner of the counter, and once they're there it's tempting to start bagging short ribs on a Monday for the weekend. The health code sees it differently: taking the air out of a bag removes one of the things that keeps Clostridium botulinum and Listeria monocytogenes in check, so the Food Code puts reduced oxygen packaging under its own rules, and most of it needs a written HACCP plan your health department sees before you start.

This post covers which kind of packing needs what, the parts of the HACCP plan, the shelf-life choices for sous vide and cook-chill, Florida's approval step, and the logs to print.

General information, not legal advice. Your state or local health department enforces its own edition of the Food Code, and its rules can differ. Section numbers and quotes below are from the FDA Food Code 2026 unless a Florida source is named.

What counts as reduced oxygen packaging

The Food Code's definition covers taking oxygen out of a package, or replacing it, for a food where C. botulinum or Listeria need control in the packaged form. It lists five kinds (§1-201.10(B), "Reduced oxygen packaging"):

• Vacuum packaging: air removed and the package hermetically sealed.
• Modified atmosphere packaging and controlled atmosphere packaging: the air in the package replaced or controlled.
• Cook-chill packaging: cooked food "hot filled into impermeable PACKAGING", sealed, then rapidly chilled.
• Sous vide packaging: raw or partly cooked food sealed in the bag, then cooked in it.

Why it matters: in a sealed bag, "time/temperature becomes the critical controlling factor" for those two bacteria, and "Non-proteolytic C. botulinum spores are able to germinate and produce toxin at temperatures down to 3ºC (38ºF)" (Annex 3, § 3-502.12). For a bag of sous vide pork, keeping it cold is the whole safety margin.

Which path is yours

Two notes on that table. The 48-hour exception is often all a small kitchen needs: bag the portions in the morning, label them with the time and date, and they're out of the bag by the next day's service. And soft cheeses are out on purpose: Annex 3 says "Soft cheeses such as Brie, Camembert, Cottage, and Ricotta may not be packaged under reduced oxygen".

Sous vide and cook-chill: the rules in §3-502.12(D)

If you cook in the bag (sous vide) or fill the bag while the food is hot (cook-chill), the Food Code adds these on top of the plan:

1. Your business only. The food is prepared and eaten on your premises, or off them "within the same business entity with no distribution or sale of the PACKAGED product to another business entity or the CONSUMER" (§3-502.12(D)(2)(a)). So no selling bagged short ribs from the retail fridge.
2. Cooked to the Food Code's temperatures: the times and temperatures in §3-401.11(A), (B) and (C) ((D)(2)(b)). Poultry still has to reach 165°F; a whole roast follows the roast chart. A lower time and temperature from another table is a variance.
3. Sealed before cooking (sous vide), or sealed right after cooking, before the food drops below 135°F (cook-chill) ((D)(2)(d)).
4. Cooled in the sealed bag to 41°F as §3-501.14 requires: 135°F to 70°F within 2 hours, and to 41°F within 6 hours in total ((D)(2)(e)).
5. One of four shelf lives ((D)(2)(e)(i)–(iv)):
6. • cooled to 34°F within 48 hours of reaching 41°F and held there, then eaten or thrown out within 30 days of packaging;
   • held at 41°F or below for no more than 7 days;
   • held at 34°F, then moved to 41°F for no more than 7 days, never past 30 days from packaging;
   • frozen, with no shelf-life limit while frozen.
6. A cooler that watches itself: held in a unit "equipped with an electronic system that continuously monitors time and temperature and is visually examined for proper operation twice daily" ((D)(2)(f)). If you send bags to another location of the same business, they travel with "verifiable electronic monitoring devices" ((D)(2)(g)).
7. Labeled with the product name and the date packaged ((D)(2)(h)).
8. Records of cooling and cold holding, shown to the health department on request and kept at least 6 months ((D)(3)).
9. Written procedures and training: no bare-hand contact with ready-to-eat food, a designated work area with raw and ready-to-eat kept apart, access to the equipment limited to trained people, cleaning and sanitizing steps, and a training program for whoever runs it ((D)(4), (B)(5), (B)(6)).

Florida: a special process, approved first

In Florida, DBPR's Division of Hotels and Restaurants calls this a special process. Its page says "Written approval from DBPR is required BEFORE such operations can be carried out", and that sous vide "requires a HACCP plan and may need a Process Waiver if the sous vide process deviates from the requirements of the Food Code, such as sous vide of fish or cooking sous vide products to temperature/time combinations different than the ones required by the Food Code" (DBPR: Special Process). The same page says the "FSIS/USDA Appendix A tables are considered a validated process that can be used to substantiate a Process Waiver request".

DBPR publishes fill-in templates for the common processes, including a sous vide HACCP plan, its logs and charts and prerequisite policies. Plans and waiver requests go to the special process email address on that page. Its ROP FAQ also spells out the 48-hour exception for Florida: "Removed from the ROP in the establishment within 48 hours of packaging (even if stored frozen)", for raw or cooked TCS food, "no fish/seafood".

DBPR's template is written to the "2017 FDA Food Code 3-502.12", the edition it cites. Use the state's template where you have one; the outline below helps you gather what goes into it.

The HACCP plan outline

The Food Code lists what the plan contains (§8-201.14). Fill in one plan per process, and attach the logs you'll use.

HACCP plan: [sous vide / cook-chill / vacuum packing] · [café or restaurant name]

A. General information (§8-201.14(A)) Permit holder: [legal name] · License or permit no.: [number] · Address: [address] · Contact: [name, phone, email]

B. Foods covered (§8-201.14(B)) [Short ribs, pork belly, chicken thighs, carrots…] · Category: [raw meat / raw poultry / raw vegetables / cooked TCS food]

C. Flow diagram (§8-201.14(C)), with the critical control points marked Receive → cold storage → prep → bag and seal → cook in bag (CCP) → cool in bag (CCP) → label and cold store (CCP) → reheat for service (CCP if hot held) → serve

D. Recipes, materials and equipment (§8-201.14(D)) Recipe for each food: [attach] · Bags: [make, oxygen barrier] · Sealer: [make, model] · Circulator / combi oven: [make, model] · Thermometer: [make, model, thin probe] · Cooler data logger: [make, model] · Blast chiller or ice bath: [describe]

E. Critical control point summary (§8-201.14(E)): one row per CCP

F. Supporting documents (§8-201.14(F)): training program for staff and supervisors · blank copies of every log · anything else the health department asks for

Written procedures (§3-502.12(B)(5)): no bare-hand contact with ready-to-eat food · designated area [where] and how raw and ready-to-eat are separated [how] · who may use the sealer and circulator [names or roles] · cleaning and sanitizing of the sealer, bins and thermometer [steps, how often]

Plan review: at least once a year and whenever the recipe, equipment or process changes. Last reviewed: [date] by [name]

DBPR's own Florida template, for example, lists corrective actions such as "Discard if at greater than 41°F for more than 4 hours" and "Discard if date mark expired or no date mark" for cold storage. Use the actions your health department approves.

The sous vide production log

One line per batch. The Food Code wants cooling and cold-holding records kept 6 months; keep the whole sheet that long.

Sous vide production log · [location] · Thermometer: [ID, last calibrated: date]

Manager review: ………………………… Date: ……………

For the use-by date at 41°F, count the packing day as day 1 and add six more, as DBPR's template does ("7 days if held at 41°F or below (preparation day is day one)").

The bag label

Bold, on a contrasting background, on every bag. §3-502.12(D)(2)(h) asks for the name and the date packaged; the rest makes the rules easy to follow at 7 a.m.

[PRODUCT NAME] Packed: [date] · [time] · [initials] Keep at 41°F or below · Use or discard by: [date] [Moved to 41°F from 34°F on: date]

Twice-daily cooler check

The data logger records; a person still has to look at it twice a day (§3-502.12(D)(2)(f)).

Mistakes we see in the rules

Where Mays fits

• Sensors that watch the cooler all day. Connect Govee Wi-Fi thermometers and Mays records each unit's temperature every five minutes, sets a safe range and alert delay per unit, and creates a task and notifies the people on shift when a unit stays out of range. Set the sous vide cooler's range to match your plan (33 to 41°F, or lower for the 34°F option). Thermometers are part of the Pro plan. See Setting up Govee thermometers and Temperature thresholds and alerts.
• Records an inspector can read. Under Thermometers, download any unit's log as a PDF or CSV, one row per hour, every 4 hours or every reading, with your license number and a pass or fail on each row. Readings are kept for 13 months, past the Food Code's 6 months. Ask your health department whether a Wi-Fi sensor log meets the electronic monitoring your plan describes. See Health-department temperature logs.
• The AM and PM check. Put AM: sous vide cooler logger checked and PM: sous vide cooler logger checked on a Daily checklist template, each with a Number answer for the reading. A Number answer isn't checked against its Min and Max yet, so put the limit in the task name. See Scheduling and assigning checklists.
• The production log as a form. Under Tasks → Types, build a Sous vide batch form with Single choice for the product, Date / time fields for sealed, out of the bath and 41°F reached, Temperature fields with pass ranges for the core temperature and the 2-hour reading, and a Text field for corrective action. Answers land in Tasks → Data with Export CSV. See Building custom forms.
• The plan, the SOPs and the training. Keep the HACCP plan and the written procedures in a Knowledge Base folder for the kitchen, and on Pro, turn them into a Learning module with a quiz for everyone allowed to run the sealer. See Your knowledge base and Creating learning modules.

What Mays doesn't do: it doesn't print bag labels or work out use-by dates, and form formulas work with numbers, not clock times, so a form can't tell you the 2-hour cooling deadline. It doesn't connect to circulators or probe thermometers, and its sensors don't log bags in a vehicle.

Write it, send it, then start the bath

Bag and open within 48 hours, or write the plan first: the foods, the flow, the limits for cooking, cooling and cold storage, the logs and who checks them. Send it to your health department before the first batch, keep a data logger on the cooler, and look at it twice a day.

Start your free trial: 30 days, every module, no card needed. Or book a walkthrough and we'll set up your cooler sensors and logs with you.