Query Regarding Reduced Oxygen Packaging

I have a query regarding Reduced Oxygen Packaging ... If one were to vacuum pack fresh-cut vegetables with no gas flush would absolute compliance to the FDA Food Code requirements for MAP be required? ... If we were to just pull a "partial" vacuum with no change in the oxygen concentration would we really need to comply to all MAP requirements? ... We claim no extended shelf-life, product is consumed within 24 hours and we only use vacuum packaging for certain customers at their request ... They find the packaging more convenient for storage.

We pack in bulk for food service and packages are unlabeled.

Our operation is very small and only vacuum pack for about 2 hours/day ... Employees are un-skilled and any "sophisticated" system would be difficult to implement and enforce.

Our local health department requires full compliance; Detailed Labeling, Training Program, Seal Integrity Testing ... They require us to limit access to the operation to specially trained personnel ... Even the person who sticks a thermometer in the chilling flume must be qualified ... We're lucky if they recognise numbers.

We have developed a HACCP plan, detailed procedures, GMP training, etc.

Any advice would be appreciated.

Mark

Dear ozmutant,

I'm not in USA so uncertain about requirements of Food Code however I guess you do realise that you are handling a food category which is typically classified as high risk.? I daresay this is the reason why the regulatory authorities are particularly sensitive and (perhaps) particularly regarding a product which has acquired a distinctly negative history in recent years with respect to health-related incidents.

I appreciate your frank process information although I'm afraid that the details possibly emphasise why any regulatory body may consider that specific control measures are in fact essential.

Hopefully someone with more specific local knowledge will comment further.

Rgds / Charles.C

Dear ozmutant,

I'm not in USA so uncertain about requirements of Food Code however I guess you do realise that you are handling a food category which is classified as high risk.? I daresay this is the reason why the regulatory authorities are particularly sensitive and (perhaps) particularly regarding a product which has acquired a distinctly negative history in recent years with respect to health-related incidents.

I appreciate your frank process information although I'm afraid that the details possibly emphasise why any regulatory body may consider that specific control measures are in fact essential.

Hopefully someone with more specific local knowledge will comment further.

Rgds / Charles.C

Charles.C

Thanks ... Actually I am quite familiar with the requirement here in the Us as well as elsewhere (Have worked in Australia (my home), New Zealand, Malaysia, Mexico and Canada ... Just looking for a way around it ... The local health department has no experience with MAP/ROP and there are no other operations using the technology within their jurisdiction (They refuse to familiarize themselves by looking at operations in nearby jurisdictions) ... I dread the "battle" to maintain compliance once implemented.

I don’t have direct experience, but applying logic to your query I would say if you are not making any claims that your product is MAP you should not need to comply the FDA Food Code requirements for MAP. If you decide to make the claim you will need to comply. Are there any commercial benefits to going the whole hog?

Welcome to the forums Ozmutant.