An Examination of the Acidified Foods Rule with Regard to the Acid versus Acidified Foods Classification
This paper analyzes the Acidified Foods regulation (21 CFR Part 114). The origins of the rule and the types of products it was meant to cover are discussed, and clearer and more meaningful criteria are proposed for making the acid versus acidified food classification. Often the acid versus acidified determination is made by arbitrary decision based on compositional percentages, an approach that may lead products that are very similar to have different designations. Similarly, arbitrary pH shifts are sometimes used as a basis for the acid/acidified food determination without consideration for the food safety implications of the pH changes. The authors contend that the regulation was meant to cover products for which there may be some difficulty in reaching the equilibrium pH. Specifically, the regulation states that acidified foods “may be called, or may purport to be, ‘pickles’ or ‘pickled.’” Pickled products are ones for which, generally, diffusion of the acid into a low-acid particulate is required in order to reach the equilibrium pH. The authors hereby contend that the delay in achieving the equilibrium pH, due to the diffusion process and/or other difficulties in achieving the equilibrium pH, should be the basis for the acid versus acidified foods classification.
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