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The scheduled process

What a scheduled process is

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Every legitimate hot sauce business in the United States runs on a document many of the people making hot sauce have never heard of. Without it you are not a hot sauce producer, you are somebody selling an unfiled acidified food.

The document your business runs on

A scheduled process is a written procedure, validated by a qualified expert, that specifies exactly how your product must be made so that it is safe.

It is not a recipe and it is not a set of guidelines. It is the legally operative description of your process, and deviating from it has defined consequences rather than being a judgment call.

What it contains

The maximum equilibrium pH, which for an acidified food must be 4.6 or lower, achieved within a designated time and maintained in all finished product.

The critical factors: heat processing where applicable, fill temperature, hold time, any preservatives and their levels, the acidification method, and the container.

And the conditions under which the process was validated, which is what makes the whole thing specific rather than general.

Who can issue one

A qualified process authority. That is a defined role rather than a job title you can assume: a person or institution with the expertise to evaluate and validate a thermal or acidification process.

Several university food science departments and extension food venture centers act as process authorities, and there are commercial ones. You cannot write your own, however well you understand your product.

Why it is per product

This is the part that shapes a business. A process must be developed and validated for every product variation, and the FDA process filing is per product, per process and per container size.

So a second flavor is a second filing. A second bottle size is a second filing. Changing from a 5 oz woozy to an 8 oz bottle is not a packaging decision, it is a regulatory one.

That single fact should govern how wide a range you launch and how early you settle your packaging.

First, whether you need one

Everything on this page assumes your product is an acidified food. Two common cases mean it is not.

A vinegar-forward sauce may be an acid food containing a small amount of low-acid food, which Part 114 excludes by name where the finished pH does not significantly differ from the predominant acid. And a product stored, distributed and sold refrigerated is excluded as well.

Neither is a judgment you make yourself. The process authority reviewing your formula is the one who says which regime you are in, and their letter is what you keep.

It is worth asking the question early, because the answer decides whether the FCE registration and the per-size filings apply to you at all, and those are the two things that most shape how fast you can add a product.

References

21 CFR Part 114, Acidified Foods. Low-acid foods to which acid is added, water activity above 0.85, finished equilibrium pH 4.6 or lower reached within the time designated in the scheduled process. 114.3 excludes carbonated beverages, jams, jellies and preserves, foods stored, distributed and retailed under refrigeration, and acid foods including condiment sauces containing small amounts of low-acid food whose finished equilibrium pH does not significantly differ from the predominant acid. ecfr.gov
US Food and Drug Administration. Draft Guidance for Industry, Chapter 16: Acidified Foods. fda.gov
FDA food canning establishment registration (Form 2541) and scheduled process filing (Form 2541e). One establishment registration plus a separate process filing for each product, process and container size.
Written from published regulation and extension guidance, not from a laboratory of our own. Your scheduled process, issued by a qualified process authority for your product and your container, governs. Nothing on this site is a scheduled process or a substitute for one.