Sushi HACCP Plan Guidelines

HACCP Plan for Sushi - Introduction

Sushi products currently fall under the regulatory rules of local State Health Departments and the United States Food & Drug Administration’s Seafood Hazard Analysis and Critical Control Point (HACCP) program. This plan guidance page will walk through the basics of developing a HACCP plan in order to achieve compliance with both State and Federal entities.

Types of companies that would use this plan would be:

  • Restaurants in house
  • Restaurants that retail products

Types of food products that would use a version of this guidance would be:

  • Fish based sushi with rice

Why HACCP / Food Safety Plan?

The HACCP Plan is not a stand alone program, but rather part of a larger food safety system. The foundational programs that are part of the food safety system are frequently termed prerequisite programs. The term was coined to indicate that they should be in place before HACCP based systems are implemented in order to effectively manage risk from food borne hazards. The Current Good Manufacturing Practice (GMP) regulations address requirements for many prerequisite programs. USDA section 402(a)(3) outlines the conditions and practices the regulated food industry must follow for processing safe food under sanitary conditions, including personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, warehousing and distribution, and defect action levels considerations. Elements of GMPs that are not covered in the HACCP are still required by regulations.

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Process Flow

The process flow of a food safety plan (HACCP or Preventive Controls) is the center of a food product’s food safety story. It tells how a company makes it’s products and also what hazards and controls are associated with each step. Here’s an example process flow for sushi:

Potential Hazards


Suggested Standard Operating Procedures (SOPs)

SOPs are related to both GMPs and Controls of Hazards in the Food Safety Plan. SOPs define the specific steps of how GMPs and Controls of Hazards mitigate food safety hazards and define a repeatable process.

  • Using and Calibrating Thermometers
  • Transporting Food to Remote Sites
  • Cooling Potentially Hazardous Foods
  • Cleaning and Sanitizing Food Contact Surfaces
  • Storing and Using Poisonous or Toxic Chemicals
  • Preventing Cross-Contamination During Storage and Preparation
  • Receiving Deliveries
  • Cleaning Building and Facility
  • Allergen Control Program
  • Washing Hands – To prevent foodborne illness by contaminated hands
  • Employee Illness Program
  • Using Suitable Utensils When Handling Ready-to-Eat Food

Suggested Testing For Sushi

Cooling validation test:

  • Lower temperature of item from 135° Fahrenheit to at 70° Fahrenheit within 2 hours or less AND/OR
  • Lower temperature of item from 70° Fahrenheit to at 38° Fahrenheit within 4 hours or less

Suggested Logs and Records

Monitoring records and logs must include the actual values or observation that document the actual implementation of a Food Safety Plan . For example, if a temperature is being measured, the actual temperature must be recorded rather than a check mark indicating that the temperature complied with the critical limit. To comply with regulations, information must be recorded at the time it is observed.

Here are suggested record and log types to use:

  • Customer Complaints
  • Corrective Action Forms
  • Employee Training
  • Food Safety Quarterly Audit
  • Food Safety Checklist
  • Raw Materials/Receiving Log
  • Worker Illness Log
  • Freezer Log
  • Thawing Log
  • Refrigerator Log
  • Acidified Rice (pH) Log
  • Assembly Log
  • Shipping Temperature Log

Suggested Supply Chain Documents

The safety of your product depends on much more than just what you control within your own facility. Use of an ingredient that has a history of association with a specific hazard may require a supply chain program as a control within your food safety program. Companies may have extensive supplier programs that encompass much more than food safety elements to manage their supplier expectations and performance.

Here is a list of suggested documents to obtain from your supply chain:

  • Food Safety HACCP or Preventive Controls Plan for each product
  • Food Defense/Business Continuity Plan
  • Validation of each product and/or process and Ready-To-Eat statements (if applicable)
  • Certificates of Analysis (COA)
  • Third Party Audit Certificate, Report & Corrective Actions
  • Product Specification
  • 100g Nutritional Information
  • Allergen Grid / Statement
  • SDS / MSDS Statement
  • GMO / Non-GMO Statement
  • Country of Origin

Additional Components for Compliance (Recommended)

The following associated food safety components are recommended to achieve compliance with State and Federal rules and regulations.

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