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bottling Hot Fill/ Hold Time

So Im filling out my forms to submit my hot sauce to my PA, and I have some questions regarding the time it takes to cool down to 180 degrees. Ill include a pic of what its asking.

My questions are: is there a right/wrong answer to this? Why is this important? Isnt it always going to be the same if you heat to 200 and let it drop to 180? How long does it take you all? Not that its a big deal, Ill be testing tomorrow, Im just curious.
 

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If you don't get a good answer here, it would be great if you asked your PA and posted the reply back here. I also don't understand the point here - bacterial killing is a function of time x temp and at 180 degrees you need only a few seconds if pH is less than 4 (though I'm sure any good regulatory agency would insist on more than this to be safe). 
 
But by their logic if your last container was still super hot (lets say 200 deg) and it took 5 minutes to get to 180, your hold time should be 5 min, even though that is way more than enough. OTOH, if your last container was 181 deg and went down to 180 in 10 sec, that would mean a hold time of 10 sec that might be really pushing the boundaries of safety?
 
Source of time/temps for bacterial killing: https://foodsafety.wisc.edu/business_food/files/Lethality_TimeTemp.pdf
 
Also, is an instrument that can punch a hole though a sealed bottle cap something that all commercial hot sauce producers should be expected to own?
 
The standardhot fill hold does not require punching a hole etc.

All my recipes are
Put heated 200f sauce in bottle
Cap
Immediately INVERT
Keep inverted for 3 minutes

The punching a hole thing is probably for line filling in jars or cans.
 
in the previous post, I was typing on the kindle which is a PITA so I didn't explain a lot.  In case you haven't submitted your samples yet, or for others who may read this-
 
I would suggest writing up your recipes and processes using the HFH method of processing and let them come back to you if they want something further.  
 
Here is a basic outline of how the PA's like the recipes presented-
 
Recipe Ingredients- Everything noted by WEIGHT, including liquids if you can.  But don't worry too much about the liquids if they are in cups or gallons.
All the other ingredients should be by gram weight.  Don't say "bring to boil", make note of temperature "bring up to 212F and gently simmer for 20 minutes".  Don't just say 1# carrots, note if they are fresh, frozen, canned, dried.
 
___________________________________________________
(random made-up recipe)
454g fresh trimmed carrots
250g fresh trimmed onions
25g dried habanero powder
20g fresh peeled garlic
15g frozen shredded ginger in water
1 cup pineapple juice(bottled)
2 cups apple cider vinegar
10g sea salt
 
 
Process-
wash/peel fresh carrots and dice using food chopper
wash/peel fresh onions and dice using food chopper
peel fresh garlic
 
Add fresh vegetables, ginger, salt, juice and vinegar to stock pot.  Simmer at 212F for 45 minutes.
Run everything through a blender until smooth.
Return to clean stock pot and bring up to 200F.
Hold at 200F for 15 minutes.
 
Using a ladle and funnel, fill bottles one at a time, cap and immediately invert for 5 minutes or more.
 
____________________________________________________________________________
 
 
The PA may come back and want further explanation of an ingredient or process.  They may want a list of what is in the bottled pineapple juice.  Usually, if you have run your process by your local inspector, there won't be much to figure out.
 
This also brings up a side note-
If something like a bottled juice is used, make sure you are happy with the product and that you can get it and use it for a long time.  Whatever the ingredients listed on the label of the juice are, they have to be printed on the sauce label.  If the juice changes, the ingredients may change, which could be  problem if the label doesn't list something.
 
Good Luck and Have Fun!!!
hope this helps~
SL 
 
 
 
 
 
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