Special Processes - Kimchi

Frequently Asked Questions (FAQs)

Background

The FDA Food Code  (U. S. Food & Drug Administration) identifies cut leafy greens as a potentially hazardous TCS food.  TCS stands for Time/Temperature Control for safety. Foods that are designated TCS food require specific temperature and time controls to prevent the growth of harmful bacteria and the formation of toxins.  Cabbage (including Nappa cabbage) is a leafy green that when cut is designated as a TCS food by FDA.

Why is cabbage considered a TCS food?

Cut leafy greens are designated as TCS food because they readily support the growth of pathogens when they are held with no temperature control after the internal plant fluid and nutrients are exposed by cutting the leaf. Cutting or shredding the cabbage changes the physical properties (i.e., damages the waxy cuticle) and biochemical processes of the leaf.   It also provides opportunities for pathogens (E. coli, Listeria and other microorganism) to become attached in the stomata (the tiny openings on the underside of leaves) and cut edges of leafy greens, which if not handled properly, can make people sick.

What are the Hazards?

Contamination of leafy greens with pathogens can occur in the field, cooling facilities, packing houses, processors, transport vehicles or food establishments. Regardless of where or how contamination occurs, refrigeration at 41ºF (5ºC) or less in food establishments, will prevent the growth of pathogens that may be present on cut leafy greens.  Cabbage, like other leafy greens, becomes a potentially hazardous food once cut. Regulations require it to be always refrigerated.  It can, however, be held at room temperature up to four hours before being refrigerated, cooked, or served.

What makes kimchi a special process different from the regular rules?

Kimchi is a staple Korean side dish that is made by fermenting vegetables.  The flavor of fermented food is distinctly tart, sour, and savory.   One of the most popular Kimchi is made with Napa cabbage.  The Kimchi making process involves cutting, breaking and damaging the leaves of the cabbage and holding the product above refrigerated temperature (41ºF) for an extended amount of time during the preparation and fermentation process.  The fermentation process involves storing the vegetable at room temperature for an extended period beyond four hours, which is not allowed under regular Food Code rules.   Thus, it must be specifically approved as a “special process” to ensure the kimchi will be safe to eat.

Is there any way for a facility to serve kimchi without a special process approval?

Yes. If a facility purchases commercially prepared kimchi from a licensed food processor, it can be stored and served under the normal regulations. Also, if a facility prepares kimchi with a recipe that keeps the cabbage under refrigeration after preparation and storage, following the normal regulations, a special process approval is not required.   Keep in mind that the fermentation process does not progress under normal refrigeration.

If I want to prepare kimchi under a special process, how do I get started?

The starting point for a special process is to have a recipe. The recipe must be one that has been validated by a scientific laboratory proving that it is safe to eat. In the case of kimchi, it becomes safe to eat if the fermentation process produces enough natural acid to lower the product’s pH to 4.2 or below.  A recipe must have a validation certifying that the product will be at 4.2pH or below.  This recipe can come from an existing facility or product manufacturer, or outside group, if it is accompanied by a validation. If using an outside group’s recipe, the food service facility must follow the recipe exactly, including the ratio of ingredients and times for each step.

What if I want to use my own recipe?

If a facility wants to use their own recipe, they must prepare test batches of kimchi that are not for public consumption.  The kimchi must be sent to a laboratory for validation of pH at 4.2 or below. The facility should have the recipe and validation ready before contacting the Health Department for special process approval. The facility may not serve the kimchi to the public before receiving Health Department approval.

What else do I need besides the approved recipe?

The special process review at the Health Department involves several components as part of a plan review process.  The facility must be able to accommodate this special process.  That means the facility must have ample food preparation space (prep. counters and sinks), refrigerated space, storage space (for ingredients, utensils, and containers) and good sanitation practices to safely prepare and service the kimchi.  Fermenting also requires special food service containers approved for acidic foods.

The plan review will also require the facility to prepare a HACCP plan for the process including how they will follow the validated recipe, monitor and record the process, and correct any problems.

The facility must also have an approved pH meter and related equipment to test every batch of kimchi to ensure it is at the approved pH before refrigeration and service.

For more information

For specific questions or more information, contact the Food Protection Program at 410-313-1772.

*** Translated copy coming soon.***