Dressing and Oil

Dressing: Sauces for salads are often called dressings. In Western culture, there are three basic types of salad dressings.

  • Vinaigrette, usually mixture or emulsion of salad oil and vinegar, often flavored with herbs, spices, salt, pepper, sugar, and other ingredients
  • Creamy dressings, usually mayonnaise-based, which may also contain yogurt, sour cream, buttermilk, or milk
  • Cooked dressings, which resemble creamy dressings, are usually thickened by adding egg yolks and gently heating

Oil: Cooking oil is purified fat of plant origin, which is usually liquid at room temperature. Edible vegetable oils include: olive oil, palm oil, soybean oil, canola oil, pumpkin seed oil, corn oil, sunflower oil, safflower oil, peanut oil, grape seed oil, and sesame oil.  There are a myriad culinary uses for fats and oils including cooking, tenderizing,  and adding richness, texture, and flavor to foods.

Food Safety Considerations: It is important to keep food safety in mind when storing vegetables such as garlic, mushrooms, chili peppers, or herbs in oil. Historically, two outbreaks of botulism in the 1980s prompted the FDA to issue ruling that removed any commercial vegetable-in-oil products that lacked acidifying agents from store shelves. A following mandate was issued for the addition of acidifying agents such as phosphoric or citric acid to be added to vegetable-in-oil products.  These low acid foods can be a source of Clostridium botulinum bacteria, which are found in soil, water, and air. Oil has an oxygen‐free environment which is perfect for growth of the Chlostridium bacteria. For this reason, herbs and vegetables packed in oil must be stored correctly to prevent botulism food poisoning. Mayonnaise-based dressings have been exempt from the acidified food regulations primarily to the bactericidal effect of acetic, lactic, and citric acids that is added in the formulation of mayonnaise. (Smittle, R.B, 2000).
*Acidification of homemade herb or vegetable-in-oil mixtures is not  recommended until further research is conducted. Instead, it is recommended to store these type of homemade products in the refrigerator and consume them within three weeks (Oregon State University, 2010).

For more information on acidified foods see Title 21 of the Code of Federal Regulations, Part 114 and Part 108.

Good Agricultural Practices (GAP), Good Handling Practices (GHP): Acidification cannot take the place of proper sanitation and care in manufacturing. The manufacturer must therefore adhere to the highest standards of cleanliness and product protection. These standards are covered under regulation: 21CFR110, often referred to as “Good Manufacturing Practices.”

Oil infusion recipes can still be tasty and safe as long as the following precautions are clearly stated and adhered to:

  • Wash all soil-contaminated produce before adding it to an oil infusion
  • Add an acidifying agent such as lemon juice or vinegar to the recipe at the rate of one tablespoon per cup of oil
  • Keep oil infusions refrigerated in order to retard the growth of any microbes
  • Discard infusions after one week, or sooner if apparent cloudiness, gas bubbles, or foul odor develop
  • When in doubt, throw it out

Distribution Method (Expand All | Collapse All)

The pH level of your dressing or oil will affect regulations you are expected to follow if you are selling a shelf stable product. Utilizing Colorado laboratories that test pH, you can obtain a statistically accurate measure of the equilibrium pH of your product (samples from multiple batches are tested; this helps to verify consistency among batches).

You are selling your product at a farmers’ market, CSA, roadside stand, or other direct to consumer outlet


Licensing:
Dressing or oil you have produced

  • If you are selling dressing or oil that you have produced using products you have grown, you will need a Retail Food Establishment License, issued by your county health department. You may also need additional licensing and your processing facility may require inspection from your county health department. If you sell at farmers’ markets or other direct to consumer outlets in different counties, you should check with the health department in each county where you sell your product direct to consumers. Although not mandatory at this time, you may also register your processing facility with the Colorado Department of Public Health and Environment.
  • Additional requirements if you are selling acidified shelf stable products: If you have produced your dressing or sauce  and it is is acidified, i.e. it has a finished equilibrium pH of 4.6 or below and a water activity  greater than 0.85, you will need to register with the Food and Drug Administration (FDA). All commercial processors, when engaging in the manufacture, processing, or packing of low acid or acidified foods,  must register with the FDA using Form FDA 2541 (Food Canning Establishment Registration; 21 CFR 108.25). This form must be filed no later than 10 days after the firm engages in operations.  Federal Regulations require each establishment be registered and scheduled processes be filed with the Food and Drug Administration for each product, product style, container size and type, and processing method. The form and instructions are available online. In addition to registering with the FDA you must attend a training course in order to process acidified foods. The training course is offered by a variety of universities, it lasts about a week long and is called “better process control”. University of Nebraska and New Mexico State are the closest in-person programs, or you can take the course online through the University of California Extension.

Dressing or oil produced by someone else

  • If you are selling shelf-stable dressings or oil produced by someone else, you are exempt from licensing but must purchase from a licensed wholesaler. If you are selling fresh dressing produced by someone else that must be kept under refrigeration, you will need a Retail Food Establishment License.

Labeling: General labeling requirements.

Sales Tax Liability: General sales tax information.

Weights and Measures: If you are selling your product by weight, you must follow the Colorado weights and measures requirements.

You are selling your product to a store, restaurant, food cart, K-12 school, university, hospital, or other retail food establishment


Licensing: To sell dressing or oil that you have produced using products you have grown, you must first register with the Colorado Department of Public Health and Environment (CDPHE) as a wholesale food manufacturing facility. Once you have registered your food manufacturing business, you may be inspected by CDPHE.  Some manufacturing processes require specific certification and/or training that must be completed before you can manufacture an acidified food or process seafood products. If you are interested in doing either of these, you should first contact the Division of Environmental Health and Sustainability at (303) 692-3620 for further information and visit wholesale food program information and requirements.

Additional requirements if you are selling acidified shelf stable products:

  • If your dressing or oil is acidified, i.e. it has a finished equilibrium pH of 4.6 or below and a water activity greater than 0.85, you will need to register with the Food and Drug Administration (FDA). All commercial processors, when engaging in the manufacture, processing, or packing of low acid or acidified foods,  must register with the FDA using Form FDA 2541 (Food Canning Establishment Registration; 21 CFR 108.25). This form must be filed no later than 10 days after the firm engages in operations.  Federal Regulations require each establishment be registered and scheduled processes be filed with the Food and Drug Administration for each product, product style, container size and type, and processing method. The form and instructions are available online. In addition to registering with the FDA, you must attend a training workshop. The training course is offered by a variety of universities, it lasts about a week long and is called “better process control”. University of Nebraska and New Mexico State are the closest in-person programs, or you can take the course online through the University of California Extension.

Note that if you are selling at farmer’s market and as a wholesaler, you will need a to obtain a retail food establishment license and register as a wholesale food manufacturer.

Labeling: General labeling requirements.

Sales Tax Liability: General sales tax information.

Weights and Measures: If you are selling your product by weight, you must follow the Colorado weights and measures requirements.

Related Links:

References:

  • Smittle, R.B. 2000. Food Protection. Microbiological safety of mayonnaise, salad dressings, and sauces produced in the United States: A Review. 63(8):1144-53.