PDPH variance / HACCP plan for specialized processes (raw shellfish, sushi, ROP, curing): Philadelphia restaurant guide
Philadelphia Department of Public Health — Office of Food Protection
What it is
Philadelphia's Regulations Governing Food Establishments require a written variance from the Department (§ 46.401) and a HACCP plan (§ 46.1122) before using specialized processing methods such as reduced-oxygen packaging, and a consumer advisory (§ 46.423) on menus for raw or undercooked animal foods like oysters and sushi.
When a restaurant needs it
Serving raw oysters/shellfish, sushi (acidified rice), cured or smoked meats, sous-vide/ROP, or any other process the Food Code lists as needing a variance.
How to apply
Describe the process and submit the HACCP plan/variance request with your plan review to Environmental Health Services; keep shellstock tags per §§ 46.247–46.250.
Documents you’ll need
- Written HACCP plan
- Process description and critical limits
- Shellfish supplier/tag procedures
- Menu with consumer advisory
Good to know
The plan review application asks for your full menu and process descriptions — flag raw/undercooked items and specialized processes there so the variance is handled before the pre-operating inspection.
Official source
PDPH — Regulations Governing Food Establishments (§§ 46.401, 46.423, 46.1122) · PDPH — Plan review (where to submit)
Answer a few questions about your space and get every permit in order, with a timeline, a cost range, walkthroughs, and every application filled in for you to sign with Open.
Last reviewed 2026-10-06. Guidance only, not legal advice.