Hot sauce does not have to be hot packed?

AJ Drew

AJ Drew

Learn something new everyday.  Evidently, there is no FDA rule about hot packing or even cooking commercial hot sauce.  In fact, one of the best known hot sauces in the United States is neither hot packed nor even cooked.  This confuses the hell out of me. 




 
 
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Reading what Hot Pepper and Lucky Dog posted, I am starting to think what Lucky Dog said might be right about a publicity stunt.  I don't remember which threat of a shut down lined up perfectly with the introduction of those mini bottle key rings, but I do remember stocking up and yes... buying those key ring bottles.

Thinking maybe as consumers we are easily manipulated.
 
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ajdrew said:
Learn something new everyday.  Evidently, there is no FDA rule about hot packing or even cooking commercial hot sauce.  In fact, one of the best known hot sauces in the United States is neither hot packed nor even cooked.  This confuses the hell out of me. 




 
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I'm late to the game, but I decided to chime in on this as I didn't see a definitive answer:

Cleanliness & packing procedures are usually regulated by your States Department of Agriculture under the guidance of the FDA.  Also the basics of the rules of condiment preparation are actually clearly defined under CFR 114.80(a), for all condiments and acidified foods - and no specific callout needs to be made for "hot sauce", as all condiments fall into this area. The exact information you are looking for can be found here: http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/AcidifiedLACF/ucm222618.htm
 
Furthermore the procedures vary for packing types (Glass vs PETE vs HDPE) and is really what determines the overall process required. So again, FDA defaults to local enforcement points - as environmental contamination conditions and flora and fauna vary based on geography.
 
Department of Agriculture is ALWAYS the main point of consult for food manufacturing:
As I alluded to - each state has specific Department of Agriculture rules on contamination prevention due to environmental factors based on geography. Also HACCP management procedures of processing establishments & clean kitchens (http://www.fda.gov/Food/GuidanceRegulation/HACCP/), and what constitutes a food processing establishment is controlled at a local level (sometimes even at a County level, in extreme cases at a CITY level).
 
So - while the FDA guidelines are intentionally open ended in areas, your local Department of Agriculture will NOT BE.  They are actually the ones that will carry out inspections and certifications at a local level.  You should always contact your local DoA and request a rules package & overview for food processing and distribution.
 
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Good Post, HotMaple.
 
It seems that every processing situation is different depending on where the product will be marketed (in state only, accross state lines, etc) the recipe of the product, the process of the product....It all comes down to the AHJ (authroity having jurisdiction).  For most situations it will be the state DoA that will do the initial review, but there are situations where the state does not have to be involved and its at the county level, such as if a person were only selling at a FM. 
 
Where I live, if I only sell retail at the FM, I need a county license and my facility (whether home based or a shared use community kitchen) would be county inspected.  If I only sell wholesale, I need to be state DoA licensed.  If I sell at both the FM and wholesale...you guessed it...I need BOTH licenses and BOTH inspections!!!  :banghead:
 
Depending on the recipe, it may not even need a PA review, but that is up to the AHJ.  If they can look at the recipe and see that it is 3/4 vinegar, they may not require a PA review or hot packing. 
 
 
disclaimer about selling hot sauces from a home based business-aka the Pickle Bill-  it is up to the AHJ to make the determination of what can be processed from a home kitchen.  The Pickle Bills started because it's pretty difficult to screw up a pickle and make it dangerous if using established recipes.  Hot Sauces are not that simple and usually incorporate more ingredients and less vinegar and in most cases are not allowed under the Pickle Bill.  Most sauces we here on THP work with need to be Hot Packed and that is not allowed under the Pickle Bill.  But I think it is still possible to do a home based hot sauce under the Pickle Bill if it has enough vinegar. 
 
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Hotmaple, once thought I would like to make sauces.  Then ran frightened due to all the talk of FDA.  If its dealing with the state dept of Agriculture I might actually think on it again.  I already deal with them much.  Great agency, especially when combined with our state university.

Thank you much for clearing that up.  Thought I had to deal with damned Yankees or something.
 
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ajdrew said:
Hotmaple, once thought I would like to make sauces.  Then ran frightened due to all the talk of FDA.  If its dealing with the state dept of Agriculture I might actually think on it again.  I already deal with them much.  Great agency, especially when combined with our state university.

Thank you much for clearing that up.  Thought I had to deal with damned Yankees or something.
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Yeah - I say go for it!  If you go that route you'd never ever have to deal with the FDA... and if you really ever did need an FDA label eventually (only reason would be because you start selling a LOT of sauce) -- there are lots of companies that'll even do that for you so you don't have to deal with them direct (like CoPackagers), some probably even local to your state.

 
 
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