Andrew M. Cuomo, Governor | Richard A. Ball, Commissioner

Guidelines for Preparation of Sushi Products at Retail

This document is a guideline for the preparation of sushi products in a retail setting where immediate consumption is not likely. Any firm manufacturing a sushi product using acidified rice should first do a hazard analysis of their processing procedures, establish critical control points and follow a HACCP-based plan, which includes appropriate recordkeeping.


  1. Follow written recipe requirements, especially regarding amounts of rice and water weights prior to cooking.
  2. Prepare acidification agent per recipe with target pH of 4.1 or less, but not to exceed 4.6.
  3. Cooked rice shall be placed into a clean container of such depth to promote uniform acidification.
  4. A calibrated pH meter shall be used, according to manufacturer's instructions, to monitor pH in each batch with results properly recorded. In lieu of a pH meter, pH paper can be used if the pH is 4.0 or less.


  1. Use only dedicated food preparation sinks for preparation of ingredients.
  2. Bare hand contact with ready-to-eat food products is prohibited. Sanitary gloves, utensils or other such devices must be utilized. Adequate and properly equipped handwash facilities shall be located in the sushi prep area. Clothing and hair restraints shall comply with New York State Department of Agriculture and Markets Retail Food Store regulations.
  3. All food contact surfaces and utensils shall be maintained in accordance with New York State Department of Agriculture and Markets Retail Food Store regulations.
  4. Ingredients shall come from approved sources. Seafood products, if identified as a parasite hazard, shall be obtained from a supplier who has frozen the product to -4F (-20C) or below internal or external for seven (7) days or -31F (-35C) or below internal for 15 hours. If the species is identified as a histamine producer, documentation from the supplier shall show that temperature control from harvest through delivery was sufficient to prevent decomposition.
  5. Ingredients such as fresh cut vegetables and produce shall be kept refrigerated at 45F or less.
  6. Bamboo mats used for product formation shall be wrapped in plastic wrap and rewrapped within 4 hours or between contact with different species of raw fish.
  7. Products where the internal temperature has been reduced below 45F internally within 4 hours may be handled by the firm as any other refrigerated food.


  1. Records of pH tests, letters of guarantee from suppliers and temperature checks shall be available for inspection.
  2. HACCP plan records regarding critical control points should be maintained.
  3. Standardized formulations that assure the proper pH of all batches must be verified at frequent levels. All formulations and verification records shall be maintained.


  1. Products shall be properly labeled.