What is a HACCP Plan and when is one required?

Hazard Analysis Critical Control Point (HACCP) Plans are written operational plans for specific food processes that have elevated food safety risks. These plans outline the specific hazards related to a food process and how they will be monitored and controlled. Resources on this site have been designed to help operators determine if they need a HACCP Plan and provide access to the documents required for submission of HACCP Plans to Northern Nevada Public Health for approval.  All HACCP plans must be submitted with the applicable Waiver and HACCP Plan Review Application or HACCP Plan Review Application and associated fee.

The following activities require a HACCP Plan AND waiver:

  • Smoking of the food for preservation of the food rather than as a method of flavor enhancement;
  • Curing food;
  • Use of food additive components such as vinegar (e.g., acidification of sushi rice, canning, pickling, etc.);
  • Reduced Oxygen Packaging (ROP) if an additional barrier in conjunction to refrigeration does not exist, or if control for C. botulinum and L. monocytogenes as outlined in Section 050.340(D) of the Food Regulations does not exist:
    • Cook Chill or Sous Vide,
    • Controlled Atmosphere Packaging,
    • Vacuum Packaging,
    • Modified Atmosphere Packaging, or
    • Sous Vide;
  • Molluscan shellfish life-support system;
  • Custom processing of animals;
  • Sprouting of beans/sprouts; or
  • Preparing food by another method that is determined by Northern Nevada Public Health to require a waiver.

The following activities require ONLY a HACCP Plan:

  • ROP with one of the following additional barriers in conjunction to refrigeration:
    • Water activity of 0.91 or less,
    • pH of 4.6 or below,
    • Meat or poultry cured at a USDA regulated facility, or
    • High level of competing organisms (raw meats, poultry, or raw vegetables);
  • ROP packaging using Cook Chill or Sous Vide process that controls for C. botulinum and L. monocytogenes by meeting all the criteria outlined in Section 050.340(D) of the Food Regulations;
  • ROP of commercially manufactured cheese that:
    • Meets the Standards of Identity for Hard cheese, Pasteurized process cheese or Semisoft cheese as specified in 21 CFR 133.150, 133.169 and 133.187 respectively, and
    • Meets all criteria outlined in Section 050.340(E) of the Food Regulations;
  • Fish that is frozen before, during and after ROP packaging;
  • Unpasteurized, unpackaged juice for highly susceptible populations;
  • Operating a Food Processing Establishment that produces potentially hazardous foods;
  • Certain instances when operating an Outdoor Food Establishment or an Uncategorized Food Establishment; and/or
  • Packaging juice in a retail food establishment (direct consumer sales) with 5-log reduction without the use of a warning label as per Section 050.280 of the Food Regulations.

For additional information and guidelines on writing your HACCP plan, check out our HACCP Resources Page.

Contact us at foodsafety@nnph.org 

Last modified on 08/15/2023