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Simplifying Food Regulation

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Best pH Meters for Food Processing
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Our Picks: Best pH Meters for Food Processing

The Basics: pH Meters

pH meters are a common tool in the food processing context.

Since acidity is often used as a means to preserve foods, a pH meter is required to confirm that the correct level of acidity is achieved in the product.

A pH meter measures the acidity of a substance on a scale from acidic to alkaline (a.k.a. basic).

pH is typically measured on a numeric scale from 1 -14 but it can also be measured using a color gradient.

Whether you’re taking pH readings so you can test a chemical concentration or as part of your HACCP plan.

pH range is measured from 0 (acidic) to 14 (alkaline)

pH range is measured from 0 (acidic) to 14 (alkaline)


Do I need a pH Meter?

You need a pH meter if the following circumstances apply:

  • You produce one of the following types of food:

    • Acidified food

    • Fermented food

    • Low-acid-canned-food

  • You use chemicals whose concentrations require testing using a pH meter.

  • You produce a product that uses acid or fermentation as a means of preservation.


Considerations When Choosing a pH Tester

  • Accuracy: Do you need accuracy to 0.1 or 0.02? This is probably the biggest factor in what you should buy.

  • Calibration: Is it easy to quickly re-calibrate (you’ll probably have to calibrate your device before each use if you are recording your results for a HACCP/Food Safety Plan).

  • Portability: Does your pH meter need to be portable or can you choose a plug-in bench top model? Note that smaller, more portable pH testers tend to be less accurate.


Handheld pH Meter

What’s it for: Taking pH measurements when you need accurate results and portability. Perfect for the food processor who needs to take pH readings for a HACCP / food safety plan.

Pros:

  • Higher degree of accuracy (typically 0.01-0.03) than pen-style models. Accurate enough for all food processing applications.

  • Portable

  • Replaceable electrode.

Cons:

  • Two-hand operations is slightly less convenient than pen-style.

Why We Picked Our Winner:

  • High degree of accuracy (Accurate ±0.01)

  • Automatic temperature compensation

  • We’ve been using this model for 3 years with continued accurate results.

  • Extremely long battery life from a single 9V battery

  • Durable construction. Trust us, we’ve dropped it.


Pen-Style pH Meter

What’s it for: Taking multiple readings across different areas in a food production space with reasonable accuracy (0.1±). Pen style pH testers are a good place to start if you need reasonable accuracy and are on a budget.

If you need a pH meter as part of your HACCP or Food Safety Plan, consider a more accurate tester see our Handheld and Benchtop choices below.

Pros:

  • Remarkable portability. Slip it into your pocket.

  • Reasonably good accuracy for an entry-level price point.

Cons:

  • Accuracy of ± 0.1 isn’t sufficient for many food processors.

  • There are lots of cheap pen-style pH testers on the market which are prone to inaccurate results. Consider our pick for Pen Style pH tester

  • You’ll want to keep buffering solutions with your pH meter so that you can calibrate it. So even if you have a very tiny pH meter, you’ll need to haul around these accessories with you if you want accurate readings.

Why We Picked Our Winner:

  • Extremely portable

  • Fully waterproof (this helps in a food processing context).

  • Best tested accuracy and reliability among the pen-style models we tested. Accurate to ± 0.1

  • Affordable price point ~($50)


Basic: pH Test Strips

Overview: Test strips are best for simple measurements that do not require a high degree of specificity. You might use a test strip to get a general sense of pH or if you’re only doing occasional tests and will be happy with a general result.

Pros:

  • Easy use — just dip and compare the strip with the color key on the packaging.

  • No calibration required

  • Small size for on-the-go testing

Cons:

  • Not as accurate as electric pH meters

  • Reactive paper shows the pH of whatever it contacts — whether that’s what you' want to test or not.

  • Typically has a maximum 2 year shelf life. After this time accuracy may vary.

Our Choice:

We prefer Hydrion because they’re the most reliable test strip on the market. They’re a little pricier, but you won’t risk buying an expired test strips like some other producers offer. It’s the most accurate test strip on the market. If you want accurate readings then stick with reputable brands.


 
Supplemental Registrations and Notifications

Products Requiring Supplemental Registrations & Notifications

Specific product types require additional registration beyond a Food Facility Registration. They include:

  • Acidified Foods & Low-Acid-Canned-Foods

  • Infant Formula

  • New Dietary Ingredient

  • Shell Egg Producer

Acidified Foods & Low-Acid-Canned-Food Registration

This category of foods includes many fermented foods, sauces, salsa, and other food that are kept shelf-stable in a sealed container.

A commercial processor created Acidified Foods (AF) or Low-Acid-Canned-Foods must file with the FDA. Their filing will include the following information:

  • Establishment details

  • List of food processed

  • Processing method

If you are unsure whether this definition applies to your product, check out the glossary below or this guidance document from the FDA:


Infant Formula Registration

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If you produce or distribute infant formula, then you must register prior to introducing your product to interstate commerce.

**Note that some of these filings must be made 90 days prior to the product entering interstate commerce so that the FDA may have the chance to respond**

This registration will require the following information:

  • Establishment details

  • Product Details

    • name and description

    • An explanation of why it is a new infant formula

    • The quantitative details of the product

    • A description of any reformulation of the product or change in process.

    • Assurance that the infant formula will not be marketed unless in meets FDA criteria.

For specific details about infant formula registrations, click here

New Dietary Ingredients

Dietary supplements that contain a "new dietary ingredient" (anything not marketed before 1994) must notify the FDA about those ingredients. This notification includes information that the new ingredient will be safe to consume as prescribed by the product label.

**Note that this filing must be submitted 75 days prior to the product entering interstate commerce so that the FDA may have the chance to respond**

This notification will contain the following information:

  • Your personal details

  • The name of the new dietary ingredient

  • A description of the supplement that contains the new product

    • Levels of the new ingredient in the product

    • Ordinary conditions of use

    • History or evidence of safe use (i.e. scientific literature, historical evidence, etc.)

Consider consulting this FDA resource about New Dietary Ingredients in Dietary Supplements

Shell Egg Producers

Producers of shell eggs (i.e. an egg hatchery or poultry house) must register the details of their facility. This is due to the high frequency of food borne illnesses associated with shell eggs, largely due to temperature abuse and the transportation of this product. This registration will require the following details:

  • Establishment details

  • Dates/Size of operations

  • Owner information

For more information about requirements for shell egg producers, click here


 
Acidified Food Regulation (Subpart 114)

What you Need to Know:

If you are unsure of whether your product is an acidified food, see Introduction to Acid Foods

  • If you produce an acidified food, you must conduct additional filings with the FDA (free)

  • Producers of acidified foods must complete the "Better Process Control School" or an equivalent training course (available online)

Required Registrations/Filings for Acidified Food Producers

If you produce an acidified food, you must register your facility and file each acidified foods you process with the FDA.


Food Canning Establishment Registration

Paper Form: Food Canning Establishment Registration

Paper Form: Food Canning Establishment Registration

If you produce an acidified food, you must register the location where you produce that food. This filing is in addition to the normal food-facility-registration.

This filing simply notifies the FDA that acidified foods (which can be higher-risk food products) are being produced at this location. Completing this registration will not trigger an inspection.

File Electronically:Food Canning Establishment Registration (Form 2541).

File in Paper: Food Canning Establishment Registration (Form 2541)

If you have addition questions about completing Form 2541 see Instructions on Registering a Food Canning Establishment


Food Process Filing for an Acidified Food

Paper Form: Food Process Filing for an Acidified Food (Form 2541e)

Producers of acidified foods must file a scheduled process for each acidified product that they produce. If a salsa company produces 5 SKUs that are all acidified foods, then they must submit 5 process filings, one for each SKU.

There is no requirement to file for products that do not fit the definition of an "acidified food".

File Electronically:Food Process Filing for an Acidified Food (Form 2541e)

File in Paper:Food Process Filing for an Acidified Food (Form 2541e)

If you have questions about the filing process, see Instructions on filing Form 2541e


Requirements for Processing Acidified Foods

Always follow your scheduled process and contact your process authority if something goes wrong.

Process and Controls

Scheduled Process

  • The manufacturer must follow a scheduled process.

  • The schedule process must be established by a person who as expert knowledge about the acidification and processing of acidified foods.

Processing Operations

  • The food must be thermally-processed (i.e. a heat-based kill step) to eliminate bacteria capable of reproducing in the finished product. Preservatives may be used in lieu of thermal processing for controlling the growth of microorganisms that are not harmful (i.e. spoilage bacteria that would ruin the food but not cause illness in humans).

  • Keep your production records onsite (digital is fine) for at least 3 years.

Source: §114.80 (a) (1)

Acidification Procedures

Some acceptable methods used to acidify foods include:

  • Blanching ingredients in acidified solutions

  • Immersing blanched ingredients in acidified solutions

  • Directly adding a measured amount of acid solution into a batch of food.

  • Directly adding a measured amount of acid into individual containers during product.

Source 114.80 (a) (3)

Measuring pH

  • The equilibrium pH of the final product must be below 4.6 and it must reach this within the timeframe set in the scheduled process.

  • The pH of the product must be measured and recorded to maintain control throughout the process. If the final pH of the product is ≥4.0, then a potentiometric pH meter must be used (these are more accurate). If the final pH is <4.0, any type of pH meter may be used.

  • pH readings should be taken at a temperature of 20ºC-30ºC (68º-86ºF). Optimal temperature for pH test accuracy is 25ºC (77ºF).

Source 114.80 (a) (1) & (2)

For a full explanation of pH and testing methodology, see §114.90

Containers and Coding:

  • You must test and examine your containers to confirm that they protect your final product from leakage or contamination

  • Each container must be labeled with a code that specifies the following:

    • Where the product was packed

    • The contents of the container

    • The date of packing

    • The code must be changed for each personnel shift, at minimum.

Deviations from Scheduled Process

If the equilibrium pH is measured at >4.6 the processor must take one of the following steps:

  • Fully reprocess the food using a process approved by a process authority (this can be simply re-processing according to your usual method)

  • Thermally process the food as a low-acid-canned food

  • Set aside the food for evaluation by a process authority

  • Destroy the food.

Make a record of this incident, regardless of the outcome.


FAQ

Do I need to register my facility and products if I operate outside the US?

If you produce a product that meets the definition of an "acidified food" for consumption inside the US, then you must register your facility (Form 2541) and each of your acidified food products (2541e).

Processors located outside the US must also complete these registrations if their food will be exported for consumption inside the US.

Wholesalers, importers, distributors and brokers are not required to register and file processes

Source

Does compliance with Subpart 114 exempt me from other requirements?

A business operating under Acidified Food Regulations ( Subpart 114 ) is still subject to the requirements in Subpart 117 B: Current Good Manufacturing Processes as it relates to determining whether a product is adulterated.

 
Introduction to Acid Foods
Foods with a pH of &lt;4.6 are called "Acid Foods" Some types of acid foods, such as acidified foods, are subject to specific regulation.

Foods with a pH of <4.6 are called "Acid Foods" Some types of acid foods, such as acidified foods, are subject to specific regulation.

What are Acid Foods?

Acid Foods: A food with a natural pH of ≤4.6. There are many naturally acidic foods, including apples, yogurt, peaches, onions, tomatoes, strawberries and lemons.

"Acid Foods" as a general group are not regulated, although certain sub-groups of acid foods are.

Types of Acid Foods

There are two main types of acid foods

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Acidified Food: These are low-acid foods that has been acidified by adding something acidic so that the end product is ultimately acidic has an equilibrium pH of ≤4.6) . This includes foods such as: dill pickles, hot sauce, and pickled fish.

The FDA does not include the following to be Acidified Foods:

  • Carbonated Beverages

  • Jams, jellies & preserves

  • Naturally acid foods like peaches and most fruit juices

  • Foods with a water activity of ≤0.85

  • Foods which are stored under refrigeration

  • Fermented foods (i.e. kimchi, sauerkraut, natto)

The FDA regulates acidified foods in 21 CFR Part 114.

Formulated Acid Foods: These are composed mostly of acid foods to which a small amount of low-acid ingredients are added (generally less than 10% by weight). The low proportion of low-acid ingredients means that the pH doesn't change significantly from the pH of the dominant ingredients. Examples include:

  • Barbecue Sauce

  • Salad Dressings

  • Marinades

Use this key to determine if your food is an acidified food.

FAQ

Is my product an Acidified Food?

Consider this flow chart to determine if your product is regulated by the FDA as an Acidified Food:

Click to enlarge

What's the difference between an acidified food and a formulated acid food?

The difference between these two types acid foods depends on the proportion of low acid and high-acid ingredients in each product:

Acidified foods are typically low acid foods with an added acid (which acidifies the low acid food.)

Formulated Acid foods are composed mainly of high acid foods with a small amount of low acid foods added.

Formulated Acid Foods

In order to qualify as a "formulated acid food", the low-acid ingredients must not significantly shift the pH of the product from the natural pH of the high-acid ingredients.

For a food product whose equilibrium (final) pH is <4.0, then a shift of up to 0.4 is considered insignificant.

For a food product whose equilibrium (final) pH is >4.0, then a shift of up to 0.1 is considered insignificant.:

Example #1:  Ned's BBQ Sauce.

Ingredients by weight: Tomato paste (93%), Sugar (5%), Spices (2%)

Ned's BBQ Sauce Equilibrium pH: 3.9

pH of only High-Acid Ingredients: 3.6

Change between high-acid ingredients and final product = 0.3

Since the equilibrium pH of Ned's BBQ Sauce is below 4.0, only an increase of 0.4 or more would be considered significant. Since the low-acid ingredients only increase the pH by 0.3, this change is considered insignificant.

Outcome: Ned's BBQ Sauce is a Formulated Acid Food. It is not subject to 21CFR Part 114



Example #2: Ned's Marinade

Ingredients by weight: Tomatoes (60%) Onion (10%) Vinegar (20%) Sugar (7%) Spices (3%)

Ned's Marinade Equilibrium pH: 4.2

pH of only High-Acid Ingredients: 4.0

Change between high-acid ingredients and final product = 0.2

Since the equilibrium pH of Ned's BBQ Sauce is above 4.0, an increase of above 0.1 would be considered significant. Since the low-acid ingredients increase the pH by 0.2, this change is considered significant.

Outcome: Ned's BBQ Sauce is an acidified food. As a result, it is subject to The regulations in 21 CFR Part 114.