WHITE PAPER:

Reduced Oxygen Packaging in Foodservice

Environments
Definitions, Benefits, Risks, and Regulatory Compliance for Vacuum Packaging,
Cook-Chill and Sous Vide Methods
Prepared by:
Paula Herald, Ph.D., CP-FS, Technical Consultant
The Steritech Group, Inc.

TABLE OF CONTENTS
Table of Contents........................................................................................................................................... 1
Introduction ................................................................................................................................................. 2
Definition & Benefits of Reduced Oxygen Packaging (ROP) ...................................................................... 2
Methods of ROP ........................................................................................................................................... 3
Vacuum Packaging .............................................................................................................................. 3
Cook-Chill Packaging .......................................................................................................................... 3
Sous Vide Packaging ........................................................................................................................... 3
Modified and Controlled Atmosphere Packaging .............................................................................. 4
Food Safety Risks of ROP ............................................................................................................................. 4
Regulatory Compliance .................................................................................................................................5
ROP Variance Required ................................................................................................................... 6
Vacuum Packaging Variance Not Required .................................................................................... 6
Cook-Chill and Sous Vide Variance Not Required ........................................................................... 7
Operational Procedures for Safety of ROP ......................................................................................... 8
HACCP Plans ....................................................................................................................................... 8
Summary ...................................................................................................................................................... 9
References/Resources ................................................................................................................................. 10

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

INTRODUCTION
Reduced oxygen packaging (ROP) is a method of food processing and preservation that is being used
more frequently at foodservice and retail locations. ROP has many unique benefits, such as shelf life
extension, improved quality, and ease of preparation; however, due to some food safety concerns, it is
imperative that certain requirements are followed.
This paper will address the various types of ROP methods utilized in foodservice establishments, and
the benefits, types of packaging, food safety risks, and regulatory compliance requirements for each
type.
DEFINITION & BENEFITS OF REDUCED OXYGEN PACKAGING (ROP)
ROP is a term used to describe a variety of processing and preservation methods that involve the
reduction of oxygen in a package of food, usually a plastic pouch. The oxygen level in the atmosphere is
approximately 21%. Any food packaging method that reduces the level to below 21% is classified as
ROP. In many instances, mechanical means of removing oxygen are used. Simply squeezing out the air
in a re-sealable zipper storage bag of food or portions wrapped in plastic wrap are not considered ROP.
The most significant benefit of ROP is the shelf life extension of food products due to the prevention of
growth of spoilage microorganisms, typically pseudomonads, yeasts and molds, which can cause
sliminess, off-odors, off-flavors, and texture changes. Spoilage microorganisms are aerobic (require
oxygen) and are unable to multiply within the packaged ROP products because this type of packaging
creates an anaerobic environment (without oxygen).
Benefits of ROP are listed below:

Extension of product shelf life

Ease of preparing large batches of food
Portion control
Product consistency
Moisture retention for product texture and taste
Fewer equipment and utensils used when preparing for service

All of these benefits make ROP advantageous for a foodservice facility due to economic cost savings that
may result from this process batch preparation, less food waste, decreased time for food preparation,
and improved product quality.

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

METHODS OF ROP
The most common ROP methods are described below.
Vacuum Packaging
Vacuum packaging is one of the most common types of ROP utilized in foodservice and retail
operations. This method involves placing a food portion into a plastic bag, removing as much of the air
(oxygen) from the bag with an industrial vacuum packaging machine as possible, and then hermetically
sealing the bag. A hermetic seal does not allow air to enter nor to escape, making the seal airtight.
Products packaged this way appear to be shrink-wrapped with the plastic film conforming to the
shape of the food inside. The plastic film barrier prevents the entry of moisture or oxygen. The film or
packaging materials must be approved for food use so that hazardous materials do not migrate from the
packaging materials into the food. These types of films have low oxygen permeability; for example, 10100 cubic centimeters of oxygen per square meter in twenty-four hours. This is typical of a 2.0 mil
polyester packaging material. The mil designation of the packaging material refers to the thickness,
with 1.0 mil being 1/1000th of an inch. This is a standard designation used in the industry to describe
packaging material properties.
A foodservice establishment may receive a variety of products from suppliers in vacuum packaged form,
but foodservice establishments are to limited vacuum packaging of raw meat, raw
poultry, or raw vegetables; fully cooked, smoked, cured meats processed at a USDA
inspected facility; hard cheeses; and frozen fish. Most often foodservice operations utilize this
method for preparing individual portions and for extension of shelf life.
Cook-Chill Packaging
Cook-Chill is a process frequently used in foodservice kitchens that routinely cook large batches of
products, especially commissaries, schools, hospitals, and prisons. In this process, hot, cooked food is
filled into a bag, air is removed from the headspace by manually squeezing out most of the air, and then
it is sealed with a plastic or metal closure or heat sealed. Even though there may be an air space left in
the bag, there is a reduced oxygen level in the food as the cooking process drives out oxygen.
Immediately, the bags are rapidly cooled to 41F or below and stored refrigerated or sometimes frozen.
In order to facilitate proper cooling, the thickness of the bags when lying flat should be no more than 2
inches in depth unless a tumble chiller or controlled ice bath slurry is used as the cooling method.
Products such as soups or sauces in the closed plastic bags are usually rethermalized in hot water baths
and then served.
Sous Vide Packaging
Sous vide has been used by chefs for approximately 40 years. The French term sous vide translates to
under vacuum. This specialized ROP process involves a pasteurization or cooking step that reduces
the microbial load, but is not sufficient enough to make potentially hazardous foods shelf-stable. In this
process, raw ingredients or those with minimal preparation such as searing or flash grilling are

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

placed into a vacuum package, sealed with a vacuum applied, and then heated to either partially or fully
cook the product, sometimes at low temperatures for long times. The package then must be rapidly
cooled or frozen. The product is reheated in the package prior to service or hot holding. This method is
popular among chefs to promote consistency in the quality of entrees and a quality characteristic that
might not be achieved by other cooking methods. For example, raw steaks or cuts of meat are cooked
longer and at lower temperatures to enhance tenderness and flavors.
Modified and Controlled Atmosphere Packaging
Modified atmosphere packaging (MAP) and controlled atmosphere packaging (CAP) are both methods
in which the air within a package is modified. MAP is achieved by flushing the package and food
contents with a specific mixture of gases, such as nitrogen, carbon dioxide and/or carbon monoxide, to
replace oxygen and achieve extended shelf life, enhance color of raw meats, or as a filler gas to protect
produce. CAP is a process in which a specialized compound, such as an iron powder that reacts with
oxygen in the package, is added to the package or embedded in the packaging film to scavenge the
oxygen or otherwise continually control the environment in the package.
These two methods are not routinely used in foodservice establishments, but are often used in food
processing plants for foods produced for retail sale such as produce items, boiled eggs, or raw chicken.
They are presented here for informational purposes.

FOOD SAFETY RISKS OF ROP

The ROP process also comes with some very significant food safety risks and concerns. While the
reduced oxygen environment is beneficial in preventing the growth of aerobic spoilage organisms, it is
an environment perfect for the growth of anaerobic bacteria, most significantly, the deadly pathogen
Clostridium botulinum. This organism causes botulism, a severe food poisoning caused by the
production of a neurotoxin that can cause paralysis and death. While heat treatments of products in
cook-chill or sous vide may kill vegetative cells of spoilage organisms, C. botulinum is produced when
heat-resistant spores grow and produce the deadly neurotoxin without any visible or odorous signs of
spoilage or contamination. Some strains of Clostridium botulinum can grow slowly at refrigeration
temperatures, especially the E strains found in fish and seafood, and some B strains.
The other pathogen of concern in ROP foods is Listeria monocytogenes, a bacterium that can survive
and grow in a reduced oxygen atmosphere and at refrigeration temperatures. This foodborne pathogen
causes flu-like symptoms, but in the young, elderly and immunocompromised can cause a more serious
illness and even death. L. monocytogenes can also cause miscarriage in pregnant women. This
microorganism grows well in the absence of competing microorganisms without any visible colors,
slime formation or odors that are signs of microbial growth caused by bacteria, yeast, and molds.
Other pathogenic microorganisms that could grow slowly in ROP products, especially if there was
temperature abuse, include Bacillus cereus, Salmonella species, Staphylococcus aureus, and Vibrio
parahaemolyticus.

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

How are these food safety risks controlled in ROP foods? These processes are based upon the use of
various barriers or hurdles that control pathogenic growth. A barrier or hurdle controls or
eliminates pathogens from multiplying. Examples of barriers and hurdles are found in Table 1: Reduced
Oxygen Packaging Barriers and Hurdles to Food Safety.
TABLE 1: Reduced Oxygen Packaging Barriers and Hurdles to Food Safety
Barrier or Hurdle

Contribution to Food Safety

Heat process (barrier)

Pasteurization, reduction of vegetative cells of

pathogens and spoilage organisms

Refrigeration (hurdle)

Slows growth of any microorganisms

Acidification (hurdle)

Reduces pH to prevent growth of pathogens

Lowering water activity (Aw) (hurdle)

Reduces available water for bacterial growth

Short shelf life (hurdle)

Limits the time any microorganism have to

grow

When used in combination, these barriers and hurdles provide greater inhibition for the growth of
pathogens. Two hurdles in combination basically become a barrier to microbial growth.
Foodservice operators need to be educated about the proper use of these control measures to protect
their guests from foodborne illnesses.
REGULATORY COMPLIANCE
The U.S. Food and Drug Administration (FDA) Food Code has very specific regulations governing ROP
in foodservice. These regulations can be found in sections 3-502.11 and 3-502.12. The 2013 FDA Food
Code requirements specific to vacuum packaging, cook-chill, and sous vide in a foodservice
establishment are summarized below. The Food Code 2013 is being presented to give the most current
information available.
Many states have adopted a Food Code version and have established their versions of these guidelines
for foodservice establishments. Note that your operations must be in compliance with the regulations
currently adopted in your jurisdiction. The requirements are specific to time/temperature control for
safety (TCS) foods. A non-TCS food would be exempt from these requirements. To determine if a food is
a TCS or non-TCS food, please reference Section 1-201.10B of the FDA Food Code Section for a decision
tree and tables. Water activity (Aw) and acidity (pH) are used to determine if a food is a TCS food or
non-TCS food. The Food Code tables to be used are specific for sous vide and cook-chill (Table A) and
for vacuum packaging (Table B).

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

ROP Variance Required

Section 3-502.11D Variance Requirement requires that a variance from the regulatory authority be
obtained if ROP methods of packaging food are used if there is no control of C. botulinum toxin
production and growth of L. monocytogenes as specified in section 3-502.12 Reduced Oxygen
Packaging Without A Variance. These would be potentially hazardous or TCS foods such as cooked
foods or soft cheeses, which do not have multiple barriers or hurdles as described below. Scientific
evidence and support from a process authority, in addition to a HACCP (Hazard Analysis Critical
Control Points) plan, might be required to gain a variance. A processing authority is someone that has
years of experience in ROP and can assist with scientific data to substantiate food safety of a process
requiring a variance.
Vacuum Packaging Variance Not Required
Section 3-502.12A-C describes the criteria for ROP TCS foods that would not require a variance because
they have two barriers to food safety.

Control the growth and toxin formation of C. botulinum and the growth of L. monocytogenes
Must have a HACCP plan that identifies the food to be packaged
Must be refrigerated at 41F or below (primary barrier) AND meet at least one of the following
criteria (secondary barriers):
Water activity (AW) of 0.91 or less
pH less than 4.6
Cured meat from USDA processing plant received in an intact package OR
Raw meat, raw poultry, or raw vegetables with a high level of competing microorganism
Shelf life limited to 30 days or less (14 days in the 2009 Food Code)
Retail packaged products must be prominently labeled with instructions to keep refrigerated at
41F or below and to consume within 30 days of packaging date or discard (14 days in the 2009
Food Code)

Because raw fish species may have C. botulinum strains capable of growing at refrigeration
temperatures, section 3-502.12C specifies that fish must be frozen before, during, and after any ROP
method. Otherwise, fish may not be packaged with ROP.
There are also restrictions on what kind of cheese may be packaged with ROP. Only hard cheeses,
pasteurized process cheese, or semisoft cheeses are allowed. Additionally, the following are required:

Commercially processed with no ingredients added

HACCP plan
Labeled with use by date 30 days or less from original manufacturers use by date

Table 2: Food Products That Can and Cannot Be Vacuum Packaged lists some examples of TCS foods
that can and cannot be packaged using vacuum packaging. A variance would be required for those foods

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

in the CANNOT column. A foodservice establishment would need to have scientific evidence that the
products are safe to be ROP.
TABLE 2: Food Products That Can and Cannot Be Vacuum Packaged
CAN

CANNOT (unless they have variance)

Raw meats, raw poultry

Cooked fresh bratwurst (uncured)

Marinated raw meats or raw poultry

Uncured luncheon meats (roast beef, turkey,

chicken, pork)

Smoked turkey, bacon, kielbasa, corned beef, ham

(must be received from a USDA-regulated facility)

Cooked poultry (not smoked) or meat

Hard cheeses (Asiago, Cheddar, Monterey Jack,

Parmesan, pasteurized processed cheese, Gouda,
etc.)

Soft cheese (Brie, Camembert, cream cheese,

cottage cheese, cheeses with ingredients such as
vegetables or meat)

Fish (only if frozen before, during, and after

packaging)

Fish raw, cooked

Pickled foods

Hard boiled eggs

Raw vegetables

Cooked vegetables

Cook-Chill and Sous Vide Variance Not Required

Cook-Chill and sous vide ROP process requirements are detailed in Section 3-502.12D and are as
bulleted below:

Must have a HACCP plan for the process

Prepared and consumed at the establishment or off premises but at the same business entity; no
distribution or sale to other businesses or consumers permitted for sous vide and cook-chill
packaged products
Cooked so that the minimum raw animal foods reach minimum internal cook temperatures as
required in Section 3-401.11
Protected from any cross-contamination before and after cooking
For sous vide, food must be placed into the oxygen barrier package and sealed BEFORE cooking
Sous vide foods must be fully cooked to minimum temperature in Food Code section 3-401.11;
otherwise, processes in which foods are cooked to lower temperatures must obtain a variance
For cook-chill, food must be placed into the packaging immediately AFTER cooking and sealed
prior to the food falling below a temperature of 135F
Sous vide and cook-chill products must be first cooled to 41F or below within a total of 6 hours
with the temperature first being reduced from 135F to 70F within 2 hours and to 41F within a
total of 6 hours AND as permitted in the 2013 Food Code:
o Cooled to 34F within 48 hours of reaching 41F, held at 34F until consumed which
must be within 30 days of the packaging date or discarded OR

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

Held at 41F for 7 days or less at which time it must be consumed or discarded (2009
Food Code limits shelf life to 72 hours)
o Sous vide or cook-chill product held frozen after being chilled to 41F or below without
shelf life limitations as long as it is held frozen until prepared for consumption
o A fourth method included in the 2009 Food Code permits cooling to 38F within 24
hours and then holding for 72 hours
Packages must be held in refrigeration units equipped with an electronic system that monitors
the time and temperature and is checked twice a day for proper operation; storage in ice is often
suggested to maintain temperature control
Transport to off-site locations within the same business entity must have electronic devices to
monitor temperatures during transport
Packages must be labeled with the product name and package date
Records must be maintained to confirm the cooling and cold holding temperatures as part of
HACCP plan; these should be available for regulatory agency inspection upon request; records
must be held for 6 months
Training program for employees that ensures they are knowledgeable about the procedures and
safe operation for processes
o

Operational Procedures for Safety of ROP

All of the ROP processes require that proper food safety and sanitation procedures are fully executed in
the facility before, during, and after the reduced oxygen packaging. This is very critical to maintaining
the safety of these special processes. The FDA Food Code, Section 3-502.12B (5-6), requires:
No bare hand contact with ready-to-eat foods
Workspaces for ROP processes must be designated; have physical barriers or methods to
separate raw foods from ready-to-eat foods, and have limited access to processing equipment
only to trained employees that are aware of the hazards of ROP processing
Cleaning and sanitizing procedures are defined for food contact surfaces
Training program for employees that are responsible for ROP processes that ensures they
understand the requirements for safe operation and the proper use of equipment and facilities
HACCP Plans
All TCS foods packaged using a ROP method require a HACCP plan (Section 3-502.12B). The 2013 Food
Code has added an exception to this requirement as when a TCS food is ALWAYS labeled with
production time and date, held at 41F or less during refrigerated storage, and then removed from the
package within 48 hours of packaging. In this situation, a HACCP plan is not required (3-502.12F). The
FDA Food Code outlines specific information to be included in HACCP plans (Section 8-201.14D):

TCS on the menu are identified in categories (soups and sauces, salads, proteins, etc.)
Flow diagram of food category with CCPs that also includes ingredients, materials and
equipment used in the process and the control measures that control food safety hazards
Training for employees in safety of food preparation
Identification of: CCPs, Critical Limits for CCPs, Monitoring (what, who, when, how);

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

Corrective actions and documentation

Scientific data about supporting the food safety of the process

An example of CCPs and their critical limits that would be relevant to a cook-chill ROP process to
address the food safety hazards in chicken soup is presented below:

CCP1 - Cooking to proper internal temperature for chicken - 165F minimum

CCP2 - Bagging/Filling chicken soup at temperature above 135F
CCP3 - Cooling from 135F to 70F within 2 hours and from 135F to 41F or below in a total of
6 hours; Alternately, cool from 41F to 34F within 48 hours and hold at 34F for maximum of
30 day
CCP4 - Storage - 34F for 30 days maximum
CCP5 - Reheating to 165F for 15 seconds; soup may be reheated in bag or in a stock pot
CCP6 - Hot holding at 135F or above for service; soup would be removed from bag for hot
holding

All HACCP records for heating, cooling, reheating, and hot holding must be retained for a minimum of
60 days.
SUMMARY
Reduced oxygen packaging of food can be beneficial to the quality, shelf life, and processing efficiencies
of a foodservice establishment. However, if done incorrectly, ROP can cause hazardous food safety
issues that can cause sickness and even death. To effectively use ROP, it is critical that all workers
involved in the ROP process understand the approved methods, regulatory requirements, and
appropriate barriers to prevent the growth of L. monocytogenes and growth and toxic production of C.
botulinum. ROP also requires commitment and investment in proper processing and monitoring
equipment and development of HACCP programs.

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

REFERENCES/RESOURCES
Utah State University Cooperative Extension. ROP Q and A (based on FDA Model Food Code 2009).
Retrieved from http://extension.usu.edu/rfsc/htm/rop/rop-q-and-a/ on January 2, 2014.
U.S. Department of Health and Human Services, Public Health Service, U.S. Food and Drug
Administration. (2013). Food Code: 2013 Recommendations of the United States Public Health
Service Food and Drug Administration. Retrieved from
http://www.fda.gov/downloads/Food/GuidanceRegulation/RetailFoodProtection/FoodCode/UCM
374510.pdf on January 2, 2014.

Steritech White Paper:

Reduced Oxygen Packaging in Foodservice Environments

10