Better Process Control School is the course FDA's rules have in mind when they say the people running an acidified food or low-acid canned food process must work under someone who "attended a school approved by the Commissioner". For acidified foods, hot sauces, salsas, pickled vegetables and the like, 21 CFR 114.10 puts all processing and packaging under the supervision of a person who completed such a school, covering food handling, food protection, personal hygiene and plant sanitation, and pH control and the critical factors in acidification. For low-acid canned foods, 21 CFR 113.10 does the same for retort, aseptic and closure operations, and that person can supervise only the areas the school says they completed. That's why schools offer the course in parts: an acidified foods portion is what a sauce or pickle maker needs; retort and closure portions are for low-acid canners. The training sits alongside the other acidified food rules: FCE registration, a process filing for each product, and pH records for every batch. In the example below, a Roanoke hot sauce maker takes the course before its first batch. Below are the rules, the example, and a free checklist.
The short version
- Better Process Control School is the training FDA's acidified and canned food rules call for.
- Acidified foods: processing and packaging supervised by someone who completed it (21 CFR 114.10).
- It covers food handling, hygiene, sanitation, pH control and acidification's critical factors.
- Low-acid canned foods: retort, aseptic and closure supervisors trained in that technology (113.10).
- Supervisors may supervise only the areas their course covered.
- An acidified foods portion is what sauce and pickle makers need.
- It goes with FCE registration, process filings and pH records.
- TaroStack keeps each batch's pH reading and who took it. More below.
The rules
| Rule | What it says |
|---|---|
| Acidified foods | Operators of processing and packaging systems work under a supervisor who completed a school approved by the Commissioner (21 CFR 114.10) |
| What's taught | Food-handling techniques, food-protection principles, personal hygiene and plant sanitation, pH controls and critical factors in acidification (114.10) |
| Low-acid canned foods | Retort, aseptic, formulating and closure operations under a supervisor trained for that technology (113.10) |
| Limits | The supervisor supervises only the areas the school says they completed (113.10) |
| The rest | FCE registration and a process filing for each product and container size (108.25) |
The registration side is in FCE registration, and the pH side in pH testing for acidified foods. This is general information, not legal advice.
An example: a Roanoke hot sauce maker
Blue Ridge Hot Sauce, the made-up hot sauce maker in Roanoke, Virginia, I use in these examples, makes acidified hot sauces, so the owner took the acidified foods course before the first commercial batch:
| Step | Status |
|---|---|
| Acidified foods course | Completed January 22, 2025; certificate on file |
| Supervisor | The owner supervises every production day |
| A second trained person | To do: the production lead, so a batch can run when the owner is away |
| Low-acid canned foods portions | Not needed: no low-acid canned products |
| Process authority | Scheduled processes for each sauce, February 2025 |
| FCE registration and filings | Registration March 3, 2025; a filing for each sauce and bottle size |
| pH records | Every batch tested and recorded |
The one gap is depth: with one trained person, a sick day stops production, so the production lead is next on the list. How a process authority sets the recipe is in process authority letter.
Get the checklist
Download the Better Process Control School checklist. One sheet: each requirement, its rule, what it is, whether you need it, the cost, the date done and the renewal date; the status and the total cost fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The course teaches pH control; the rule then wants a pH reading on every batch, taken by someone trained, and kept. A certificate on the wall doesn't keep the readings.
How TaroStack does it
TaroStack keeps each batch's pH reading, and who took it.
Readings on the batch record. Fields of your own on the batch record hold the pH reading, the meter check and the initials of the person who took it, with a sign-off, and printable batch-record forms carry the same fields.
Each batch a lot. A batch records the ingredient lots it used and gets a lot code for the bottles.
Where it went. Each order records the lots it got, so one recall report shows every customer a batch reached.
| The job | Clipboard | In TaroStack |
|---|---|---|
| A batch's pH reading | A clipboard | A field on the batch record |
| Who took the reading | Initials, maybe | Initials and sign-off on the record |
| Which customers got a batch | Invoices | One recall report |
Batches, batch records with fields of your own, lots and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.