Better Process Control School
Updated
Alongside the scheduled process and the filings there is a personnel requirement, and it is the one small producers discover last.
A person, not a document
Processing of acidified foods must be supervised by a graduate of a Better Process Control School acidified foods course.
So the operation needs a qualified person present and responsible, not merely a correct process on paper. For a one-person business that person is you.
What the course covers
The microbiology that makes the 4.6 threshold meaningful. Acidification and equilibrium. pH measurement and instrument control. Container closure and its evaluation. Record keeping and process deviations.
It is genuinely useful rather than a formality, and producers often come out of it understanding for the first time why their scheduled process says what it says.
Several universities run it, in person and online, over a few days.
Who needs it
Whoever supervises the processing. If you make the product, that is you. If you hire somebody to run production, the supervision requirement follows the role rather than the ownership.
If a co-packer makes your product, their supervisor holds it, which is one of the genuine advantages of contracting out. It does not remove your responsibility as a brand owner for what is made on your behalf.
Getting it done
Do it early, before the first commercial batch rather than after an inspector asks. It is a few days and a modest fee.
And do it before you finalize the scheduled process if you can, because you will ask the process authority better questions afterwards and you will understand what the answers mean.
Keep the certificate with your records. It is one of the first things anybody auditing an acidified foods operation will ask for.