A deli plans to cook, vacuum-seal, and refrigerate soups using reduced-oxygen packaging without a HACCP plan, relying only on refrigeration to control Clostridium botulinum. Why is this a problem?

Explanation

Reduced-oxygen packaging of food that supports pathogen growth requires an approved HACCP plan or must meet specific Food Code control criteria, because the anaerobic environment can allow C. botulinum to produce toxin if temperature control fails. Vacuum sealing removes oxygen but does not kill spores, and it removes the competing spoilage organisms that would otherwise warn a cook that something is wrong, so a sealed soup is not shelf-stable. The Code regulates ROP rather than prohibiting it, and its ROP provisions apply to the food's ability to support pathogen growth, not to whether the soup happens to contain meat.