New York

Regarding the process, I presume that you are talking about a “cold-fill” dressing. With FSMA and the process documentation requirement for a “kill step”, cold-fill salad dressings have become more challenging for small-scale producers that can’t afford a custom challenge study for their product. If you plan to hot-fill your item, process documentation is more straightforward.

Public-domain challenge study results are available if your product meets the following criteria.

1. maximum equilibrium pH 3.5 or less: 0.1% sodium benzoate (with some amount of an “inhibitory acidulant”)
2. maximum equilibrium pH 3.8 or less: 1.5% acetic acid (30% of 5% vinegar) (with or without benzoate)

I’m not citing the reference here, because you really should consult a process authority to review your formula and process carefully and help you with the filing. Each of these carries a minimum hold time (usually days) and minimum hold temperature (often 50°F)

Note that these are critical limits. Your process should have operating limits that make it such that you NEVER exceed the critical limits.

Note also that the “inhibitory acidulant” is listed as acetic acid. To get the required amount, you need to use 20 times that amount as 5% vinegar (distilled, cider, or balsamic).

Note also that 0.1% sodium benzoate is both a critical minimum and a legal maximum. Use of 0.1% benzoate is a common practice, and in practice, firms often use more. I don’t know how the FDA sorts that out in the field.

To document your process, you will need the following:

1. documentation of actual amounts used – each batch, actual numbers and lot information, with batchmaker’s initials, not just a checklist
   1. vinegar
   2. benzoate
   3. total batch size, checked against batch production and explanation of differences
2. process hold time and temperature – each batch
   1. time is easy – when it was released for shipping minus when you bottled it
   2. temperature, if required for the process, is a minimum, e.g. 50°F. You don’t need a continuous chart recorder, but you do need some kind of record that you checked periodically and had no reason to believe that it was any lower than the minimum in-between readings
3. finished equilibrium pH measurement – each batch
4. benzoate measurement – third party lab periodiucally

I presume that you will need a commercial kitchen and licenses. Someone in NY will better be able to answer this.

• This reply was modified 6 years, 2 months ago by  David Crabill.