Is bagging FOOD cold without a vacuum considered ROP?

This question comes up often.  ROP requires HACCP.  No ROP, no HACCP.

First, a common item exclusion for a different reason.  All acid foods pH ≤ 4.2 are non-TCS.  As a non-TCS food, no HACCP.  So, cold bagging dressings, acidic sauces, etc does not require HACCP because its non-TCS.

What about cold bagging TCS foods, like proteins?  The answer from FDA is no vacuum or removal of air, not ROP, no HACCP.  Read their interpretation carefully.

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