Is cole slaw a potentially hazardous food?

The U.S. Food and Drug Administration (2005) classifies plant foods that have been heat-treated as potentially hazardous. Plant foods that are not heat-treated are classified as non-potentially hazardous. A non-potentially hazardous food is not subject to strict temperature controls -- keeping it at 140 degrees F or hotter or at 41 degrees F or colder. The only exceptions are melons, figs, and cut tomatoes, which all must be maintained at 41 degrees F or colder for safety.

Cole slaw, generally made with cabbage, dressing, and other ingredients, is not heat-treated and so would technically not be potentially hazardous. However, there have been several foodborne illness outbreaks linked to eating cole salw so a more critical review of this menu item is needed.

Cabbage can be contaminated with Listeria monocytogenes, more likely than other vegetables. Because cabbage is frequently held for long periods of time at refrigeration temperature, L. monocytogenes can grow. It is unlikely to be a problem but it certainly is more of a risk than other produce items.

To be safe, for the purpose of this HACCP Plan, cole slaw must be viewed as a potentially hazardous food. Thus, strict temperature controls must be implemented for both commercially prepared and product that is made in-house. Cole slaw must be kept cold -- 41 degrees F or colder. If temperature-abused, it must be discarded.