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The scheduled process

What changes force a new filing

Updated

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A scheduled process covers one product, made one way, in one container. Knowing what invalidates it is what keeps a growing range compliant.

The rule

If it changes the product, the process or the container, the scheduled process may no longer apply. The process filing itself is per product, per process and per container size, which is the clearest statement of scope you will get.

Always

A new product, including a new flavor, because a process must be developed and validated for every product variation.

A new container size, because cooling and equilibration depend on volume and geometry.

A change of acid or acid level.

A change in process: hot fill to cold fill, a different cook, a different hold.

The ones people think are safe

A pepper substitution. Different varieties differ in pH and in how readily acid penetrates them, and a formulation validated on one is not automatically valid on another.

Changing the particle size. A chunkier sauce takes longer to reach equilibrium, which is one of the factors the process specifies.

Adding a vegetable. Carrot, onion and fruit all bring their own pH and their own buffering.

A different closure. The container closure is part of what was evaluated.

Scaling the batch, because cooling rate and hold time change with volume.

Building it in

Keep a written record of which scheduled process covers which product and container, with its filing reference, and attach it to the product record rather than filing it separately.

Then make "does this need a new process" a required question in any change. The failure mode is never a decision to skip it; it is a series of small reasonable changes after which nothing being made matches anything that was filed.

One bottle style, four separate filings

Same glass, same closure, same recipe. A separate process filing.
4 oz Amber Glass Boston Round Bottle
4 fl oz · 24-400 · Glass · to 300F
4 oz.
$0.61
each
See it
8 oz Amber Glass Boston Round Bottle
8 fl oz · 28-400 · Glass · to 300F
8 oz.
$0.83
each
See it
6 oz Amber Glass Boston Round Bottle
6 fl oz · 24-400 · Glass · to 300F
6 oz.
Quote
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16 oz Amber Glass Boston Round Bottle
16 fl oz · 28-400 · Glass · to 300F
16 oz.
$1.22
each
See it

References

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.
21 CFR Part 114, Acidified Foods. A finished equilibrium pH of 4.6 or lower, achieved within the time designated in the scheduled process and maintained in all finished foods. ecfr.gov
US Food and Drug Administration. Draft Guidance for Industry, Chapter 16: Acidified Foods. fda.gov
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.