A juice processor's HACCP plan is required by law, under 21 CFR part 120, and it turns on one number: the process must achieve at least a 5-log reduction, a 100,000-fold cut, in the most resistant pathogen likely in the juice, for the whole shelf life. A juice maker who sells only directly to consumers is a retail establishment and outside the rule; selling to a café or grocer makes you a processor. The plan sits on sanitation SOPs covering eight areas, a written hazard analysis, and critical control points with limits, monitoring, corrective actions, verification and records, written by someone trained in juice HACCP. Records are kept a year for refrigerated juice. In the example below, a cold-pressed green juice going wholesale comes down to two critical control points: high pressure processing and cold holding. Below are the rules, the hazard analysis, the plan, a week of records, and a free worksheet.
The short version
- Juice HACCP covers any juice sold as such or used in beverages, made by a processor.
- A retail establishment selling only directly to consumers isn't a processor; wholesale makes you one.
- The process must achieve a 5-log reduction in the pertinent microorganism, applied to the juice itself.
- Sanitation SOPs cover water, food contact surfaces, cross-contamination, hand washing, contaminants, toxic compounds, employee health and pests.
- A trained person writes the hazard analysis and plan, and reviews the records.
- Records: 1 year for refrigerated juice; 2 years or the shelf life for frozen or shelf-stable.
- TaroStack keeps each load's HPP cycle and cold readings on its batch record. More below.
The rules
| Rule | What 21 CFR part 120 says |
|---|---|
| Who | Processors of juice sold as such or used as an ingredient in beverages |
| Not a processor | A retail establishment: one that provides juice directly to consumers and doesn't sell to other businesses |
| 5-log | Control measures that consistently produce at least a 5-log reduction in the pertinent microorganism, for the shelf life |
| Pertinent microorganism | The most resistant microorganism of public health significance likely to occur in the juice |
| Sanitation | A sanitation SOP covering eight areas, monitored and recorded |
| The plan | Specific to each location and type of juice; hazards, CCPs, critical limits, monitoring, corrective actions, verification, records |
| Training | The person who writes and reviews the plan completes juice HACCP training, or is qualified by experience |
| Records | Name, date, time and initials; kept 1 year for perishable or refrigerated juice, 2 years or the shelf life for frozen or shelf-stable |
The rules are 21 CFR part 120, with the 5-log requirement in 120.24. Juice sold untreated must carry FDA's warning statement; what that means for a direct seller is in how to start a juice business. This is general information, not legal advice.
An example: the hazard analysis
Windward Roots, the made-up taro business on Oʻahu I use in these examples, wants to sell its 16 oz green juice of cucumber, celery, apple, kale, lemon and ginger to a grocer, so it sends sealed bottles to a toll processor for high pressure processing:
| Step | Hazard | Reasonably likely? | Control | CCP? |
|---|---|---|---|---|
| Receiving produce | Pathogens on produce; patulin in damaged apples; stones | Yes | 5-log at CCP 1; tree-picked apples, culled | No |
| Cold storage | Growth of pathogens | No | Cooler log, prerequisite program | No |
| Washing and sorting | Soil, stones, damaged fruit | No | Wash and cull | No |
| Pressing | Contamination from equipment | No | Sanitation SOP | No |
| Bottling and capping | Contamination, cap fragments | No | Sanitation SOP | No |
| High pressure processing | Pathogens surviving | Yes | Pressure and hold time from the validation | CCP 1 |
| Cold storage and shipping | Growth, including C. botulinum, in low-acid juice | Yes | 41°F or below from HPP to the grocer | CCP 2 |
HPP doesn't destroy bacterial spores, and a green juice of cucumber, celery and kale can be low in acid, so cold holding and the shelf life are what keep C. botulinum in check. How a batch's yield moves its cost is in batch costing example.
The plan
| CCP | Critical limit | Monitoring | Corrective action | Verification |
|---|---|---|---|---|
| CCP 1 High pressure processing | Pressure and hold time at or above the validated minimum (example: 87,000 psi for 180 seconds) | The HPP cycle record for each load | Reprocess, or hold and discard; find the cause | Cycle records reviewed before release; the processor's validation on file |
| CCP 2 Cold holding | 41°F or below from HPP to delivery | Cooler and truck thermometers, twice a day and each delivery | Hold and assess warm bottles under the plan; fix the cooler | Thermometers checked monthly; records reviewed weekly |
The HPP numbers are an example; the real ones come from the toll processor's validation for this juice and bottle. How a monitoring record is kept is in HACCP record keeping form example.
A week of records
| Date | Lot | CCP | Reading | Limit | OK? | Action |
|---|---|---|---|---|---|---|
| Oct 5 | GJ-1005 | HPP hold time | 180 s | 180 s or more | Yes | |
| Oct 5 | GJ-1005 | HPP pressure | 87,000 psi | 87,000 psi or more | Yes | |
| Oct 5 | GJ-1005 | Cold holding | 38°F | 41°F or below | Yes | |
| Oct 6 | GJ-1005 | Cold holding | 44°F | 41°F or below | No | Door left open overnight; bottles held and assessed; door alarm fitted |
| Oct 6 | GJ-1005 | Cold holding | 37°F | 41°F or below | Yes |
Get the worksheet
Download the juice HACCP plan worksheet. Four sheets: the hazard analysis, the HACCP plan with a place to sign, a monitoring log that checks each reading against its limits, and a read-me. It's a worksheet to organize your own plan, not a plan to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Every load has an HPP cycle record, every day has cold readings, and every bottle has to be traceable to its load when the grocer or an inspector asks. A binder of cycle printouts gets thick fast.
How TaroStack does it
TaroStack keeps each load's HPP cycle and cold readings on its batch record.
Readings on the batch. Fields of your own on the batch record hold the HPP pressure, hold time and cycle number, and printable batch-record forms carry a sign-off for the review before release.
Held until reviewed. A batch can be held, kept out of what can be sold, until its cycle record is reviewed.
Where it went. Each grocer's order records the lots it got, so one recall report shows every store a load reached.
| The job | Binder | In TaroStack |
|---|---|---|
| A load's HPP cycle | A printout filed by date | Fields on the batch record |
| A load waiting for review | A note on the cooler | A hold until released |
| Which stores got a load | Invoices | One recall report |
Lots, batches and orders 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.