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  #1 (permalink)   Report Post  
Julia Altshuler
 
Posts: n/a
Default selling home made wine herb vinegars

Work at the new wine and cheese shop continues apace. I'm growing more
confident at recommending cheeses to go with particular menus. I'm more
relaxed around my bosses. They're nice people. I worry, however, about
some of their decisions. Too often, employees are doing nothing though
begging for tasks to complete. For example, a few days ago, the owner
wanted us to organize the whole store differently. Instead of having
the wines on the shelves according to country of origin, he wanted them
arranged by grape. This was a good move. It will make it easier for
the customers and employees. But instead of counting up how many
bottles he had in each category and moving the bottles in an organized
fashion, we ended up with 3 days (and counting) of a store in complete
disarray with bottles all over the floor, the counters, and in every
cart and basket. Then, he'd leave or get distracted while the employees
had asked him point blank what to move next so we could be working while
he was gone. We ended up doing nothing even with bottles everywhere!


Now for the question. We're doing wine tastings, and we often have wine
leftover. I suggested turning the wines into specialty vinegars. I've
done this home. It is a simple matter of combining the wine with apple
cider vinegar (the stuff from the health food store with the live mother
of vinegar, not the distilled) and garlic and herbs and maybe some
fruits like blueberries. There are recipes all over the web. Would it
be O.K. to sell this at the store? We don't need a special permit or
anything, do we, as long as the ingredients are listed on the bottle?


--Lia

  #2 (permalink)   Report Post  
Bob (this one)
 
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Julia Altshuler wrote:

> We're doing wine tastings, and we often have wine
> leftover. I suggested turning the wines into specialty vinegars. I've
> done this home. It is a simple matter of combining the wine with apple
> cider vinegar (the stuff from the health food store with the live mother
> of vinegar, not the distilled) and garlic and herbs and maybe some
> fruits like blueberries. There are recipes all over the web. Would it
> be O.K. to sell this at the store? We don't need a special permit or
> anything, do we, as long as the ingredients are listed on the bottle?


You likely don't need any federal permits from FDA or USDA unless
vinegar production comes under their aegis. Google their manuals to
check. You may well need something from state or local health
department; a guess. You're getting into a tricky place with using
alcoholic liquids as a base. I suspect you may have to prove that the
alcohol is all gone before being able to sell it. If it were just
infused vinegars, no issue. But *making* it from an alcohol-containing
base might be problematic or at least red-tape-filled.

Pastorio

  #3 (permalink)   Report Post  
zxcvbob
 
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Bob (this one) wrote:
> Julia Altshuler wrote:
>
>> We're doing wine tastings, and we often have wine leftover. I
>> suggested turning the wines into specialty vinegars. I've done this
>> home. It is a simple matter of combining the wine with apple cider
>> vinegar (the stuff from the health food store with the live mother of
>> vinegar, not the distilled) and garlic and herbs and maybe some fruits
>> like blueberries. There are recipes all over the web. Would it be
>> O.K. to sell this at the store? We don't need a special permit or
>> anything, do we, as long as the ingredients are listed on the bottle?

>
>
> You likely don't need any federal permits from FDA or USDA unless
> vinegar production comes under their aegis. Google their manuals to
> check. You may well need something from state or local health
> department; a guess. You're getting into a tricky place with using
> alcoholic liquids as a base. I suspect you may have to prove that the
> alcohol is all gone before being able to sell it. If it were just
> infused vinegars, no issue. But *making* it from an alcohol-containing
> base might be problematic or at least red-tape-filled.
>
> Pastorio
>



I don't think there will be a problem from the revenuers cuz the excise
tax has already been paid on the wine, and that's the main thing they
are interested in -- so they have do real reason to hassle you over
minor details. Expect trouble even if you are perfectly legal if you
were making the wine or somehow buying it without paying tax.

Also, the vineger should be well under 0.5% ABV when it's done,
therefore USDA considers it nonalcoholic.

I think the county health dept. is gonna by the biggest obstacle.

Best regards,
Bob <-- not a food lawyer
  #4 (permalink)   Report Post  
Louis Cohen
 
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Default

I don't know anything about the permits and labeling, but it's a great idea.
We make our own red wine vinegar at home.

I guess you would have to start batches, let them ferment, and then sell
them, rather than just running a continuous jug (add on top, draw off the
bottom continuously, as we do at home).

--
----------------------------------------------------------------------------
----
Louis Cohen
Living la vida loca at N37° 43' 7.9" W122° 8' 42.8"


"Julia Altshuler" > wrote in message
news:dLl9d.220078$3l3.137829@attbi_s03...
> Work at the new wine and cheese shop continues apace. I'm growing more
> confident at recommending cheeses to go with particular menus. I'm more
> relaxed around my bosses. They're nice people. I worry, however, about
> some of their decisions. Too often, employees are doing nothing though
> begging for tasks to complete. For example, a few days ago, the owner
> wanted us to organize the whole store differently. Instead of having
> the wines on the shelves according to country of origin, he wanted them
> arranged by grape. This was a good move. It will make it easier for
> the customers and employees. But instead of counting up how many
> bottles he had in each category and moving the bottles in an organized
> fashion, we ended up with 3 days (and counting) of a store in complete
> disarray with bottles all over the floor, the counters, and in every
> cart and basket. Then, he'd leave or get distracted while the employees
> had asked him point blank what to move next so we could be working while
> he was gone. We ended up doing nothing even with bottles everywhere!
>
>
> Now for the question. We're doing wine tastings, and we often have wine
> leftover. I suggested turning the wines into specialty vinegars. I've
> done this home. It is a simple matter of combining the wine with apple
> cider vinegar (the stuff from the health food store with the live mother
> of vinegar, not the distilled) and garlic and herbs and maybe some
> fruits like blueberries. There are recipes all over the web. Would it
> be O.K. to sell this at the store? We don't need a special permit or
> anything, do we, as long as the ingredients are listed on the bottle?
>
>
> --Lia
>



  #5 (permalink)   Report Post  
nancree
 
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Default

zxcvbob > wrote in message >...
> Bob (this one) wrote:
> > Julia Altshuler wrote:
> >
> >> We're doing wine tastings, and we often have wine leftover. I
> >> suggested turning the wines into specialty vinegars. I've done this
> >> home. It is a simple matter of combining the wine with apple cider
> >> vinegar (the stuff from the health food store with the live mother of
> >> vinegar, not the distilled) and garlic and herbs and maybe some fruits
> >> like blueberries. There are recipes all over the web. Would it be
> >> O.K. to sell this at the store? We don't need a special permit or
> >> anything, do we, as long as the ingredients are listed on the bottle?

> >
> >
> > You likely don't need any federal permits from FDA or USDA unless
> > vinegar production comes under their aegis. Google their manuals to
> > check. You may well need something from state or local health
> > department; a guess. You're getting into a tricky place with using
> > alcoholic liquids as a base. I suspect you may have to prove that the
> > alcohol is all gone before being able to sell it. If it were just
> > infused vinegars, no issue. But *making* it from an alcohol-containing
> > base might be problematic or at least red-tape-filled.
> >
> > Pastorio
> >

>
>
> I don't think there will be a problem from the revenuers cuz the excise
> tax has already been paid on the wine, and that's the main thing they
> are interested in -- so they have do real reason to hassle you over
> minor details. Expect trouble even if you are perfectly legal if you
> were making the wine or somehow buying it without paying tax.
>
> Also, the vineger should be well under 0.5% ABV when it's done,
> therefore USDA considers it nonalcoholic.
>
> I think the county health dept. is gonna by the biggest obstacle.
>
> Best regards,
> Bob <-- not a food lawyer

-------
CAUTION! Vinegars with herbs in them can breed nasty things,
(botulism) and should be kept refrigerated.
Nancree


  #6 (permalink)   Report Post  
Julia Altshuler
 
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nancree wrote:

> -------
> CAUTION! Vinegars with herbs in them can breed nasty things,
> (botulism) and should be kept refrigerated.
> Nancree



Is that true? This whole subject got started with my boss when he asked
me about botulism in garlic infused oils. I told him that there was
nothing to worry about as long as they were refrigerated. That made me
think of the herb vinegars, and he loved the idea. I came home, checked
my information on the web and realized that I was dead wrong. Herbs and
garlic in OIL can be a big problem because the oil presents an anerobic
environment. VINEGAR added to the oil turns it into salad dressing, and
turns the environment into an acidic one that's not conducive to
botulism. I printed out a few web pages to show him (and asked my
question about labeling here). I intend to correct my mistake with him
today. (I hate being wrong.) I only learned all this in a few minutes
of web research last night and want to get it right. If anyone has any
information on dangers of botulism in herb infused vinegar, let me know
before I head into work today. This isn't a question of what's safe to
do at home. I've thrown garlic in vinegar plenty of times at home and
not died of it. I need to know if it is safe to sell to the public.
The safety standards get a lot higher in that situation.


--Lia

  #8 (permalink)   Report Post  
Bob (this one)
 
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Julia Altshuler wrote:

> nancree wrote:
>
>> -------
>> CAUTION! Vinegars with herbs in them can breed nasty things,
>> (botulism) and should be kept refrigerated.
>> Nancree


THIS IS ABSOLUTELY *NOT* TRUE.

> Is that true? This whole subject got started with my boss when he asked
> me about botulism in garlic infused oils. I told him that there was
> nothing to worry about as long as they were refrigerated.


Not true, either. Refrigeration will retard development. Bringing them
out to use will warm them. They're safe (if they still have solids in
them) for no more than 2 weeks.

> That made me
> think of the herb vinegars, and he loved the idea. I came home, checked
> my information on the web and realized that I was dead wrong. Herbs and
> garlic in OIL can be a big problem because the oil presents an anerobic
> environment.


Exactly, but refrigeration will retard growth.

> VINEGAR added to the oil turns it into salad dressing, and
> turns the environment into an acidic one that's not conducive to
> botulism.


Not safe, either. You can't count on the vinegar reaching all spores.
They're all around us all the time and demand the right conditions to
develop. The chances are reduced in a salad dressing, but it isn't
absolute.

> I printed out a few web pages to show him (and asked my
> question about labeling here). I intend to correct my mistake with him
> today. (I hate being wrong.) I only learned all this in a few minutes
> of web research last night and want to get it right. If anyone has any
> information on dangers of botulism in herb infused vinegar, let me know
> before I head into work today. This isn't a question of what's safe to
> do at home. I've thrown garlic in vinegar plenty of times at home and
> not died of it. I need to know if it is safe to sell to the public. The
> safety standards get a lot higher in that situation.


You can infuse fresh ingredients in vinegar with no fear of botulism.
I've sold thousands of bottles with exactly those conditions. The FDA
inspectors didn't even want to look at them. Just my oils and fruit
juice curds.

Pastorio

  #10 (permalink)   Report Post  
Melba's Jammin'
 
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In article <Hgv9d.144755$wV.131610@attbi_s54>, Julia Altshuler
> wrote:

> nancree wrote:
>
> > -------
> > CAUTION! Vinegars with herbs in them can breed nasty things,
> > (botulism) and should be kept refrigerated.
> > Nancree

>
>
> Is that true?


No.
--
-Barb, <www.jamlady.eboard.com> Updated 10-04-04; Sam I Am!.
"Peace will come when the power of love overcomes the love of power."
-Jimi Hendrix, and Lt. Joe Corcoran, Retired; St. Paul PD, Homicide Divn.



  #11 (permalink)   Report Post  
The Joneses
 
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Julia Altshuler wrote:

> nancree wrote:
> > -------
> > CAUTION! Vinegars with herbs in them can breed nasty things,
> > (botulism) and should be kept refrigerated. Nancree

>
> Is that true? This whole subject got started with my boss when he asked
> me about botulism in garlic infused oils. I told him that there was
> nothing to worry about as long as they were refrigerated. (snipped
> comments)


> not died of it. I need to know if it is safe to sell to the public.
> The safety standards get a lot higher in that situation.
> --Lia


Lia - have you thought of selling a "kit"? or offering recipe handouts to
your customers for free? Have classes and charge for that. And last I
heard, that refrigerated oil-infused herb/garlic mix should be used within a
week. Adding vinegar of course, changes everything.
Edrena


  #12 (permalink)   Report Post  
The Joneses
 
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Default

Julia Altshuler wrote:

> nancree wrote:
> > -------
> > CAUTION! Vinegars with herbs in them can breed nasty things,
> > (botulism) and should be kept refrigerated. Nancree

>
> Is that true? This whole subject got started with my boss when he asked
> me about botulism in garlic infused oils. I told him that there was
> nothing to worry about as long as they were refrigerated. (snipped
> comments)


> not died of it. I need to know if it is safe to sell to the public.
> The safety standards get a lot higher in that situation.
> --Lia


Lia - have you thought of selling a "kit"? or offering recipe handouts to
your customers for free? Have classes and charge for that. And last I
heard, that refrigerated oil-infused herb/garlic mix should be used within a
week. Adding vinegar of course, changes everything.
Edrena


  #13 (permalink)   Report Post  
PENMART01
 
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> Melba's Jammin' writes:
>
>>(nancree) wrote:
>>
>> CAUTION! Vinegars with herbs in them can breed nasty things,
>> (botulism) and should be kept refrigerated.

>
>That'd be olive oil, not vinegar.


In vodka is good too... don't even need to cook with it, just slurp it down
straight. I have a bottle of vodka abrewin' right now with a goodly dose of
caraway seeds, gettin' ready for cold season.


---= BOYCOTT FRANCE (belgium) GERMANY--SPAIN =---
---= Move UNITED NATIONS To Paris =---
*********
"Life would be devoid of all meaning were it without tribulation."
Sheldon
````````````
  #14 (permalink)   Report Post  
Scott
 
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In article >,
The Joneses > wrote:

> Lia - have you thought of selling a "kit"? or offering recipe handouts to
> your customers for free? Have classes and charge for that. And last I
> heard, that refrigerated oil-infused herb/garlic mix should be used within a
> week. Adding vinegar of course, changes everything.


Yes... and no. If you simply add vinegar to an oil/herb infusion ("salad
dressing") you can't be sure of proper acidity, both from lowered pH and
from evenness mixing.

--
to respond, change "spamless.invalid" with "optonline.net"
please mail OT responses only
  #15 (permalink)   Report Post  
Nancy Dooley
 
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Default

> -------
> CAUTION! Vinegars with herbs in them can breed nasty things,
> (botulism) and should be kept refrigerated.
> Nancree



It's flavored oils, not vinegars, that need to be refrigerated.

N.


  #16 (permalink)   Report Post  
Bob (this one)
 
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The Joneses wrote:

> Julia Altshuler wrote:
>
>>nancree wrote:
>>
>>>-------
>>>CAUTION! Vinegars with herbs in them can breed nasty things,
>>>(botulism) and should be kept refrigerated. Nancree

>>
>>Is that true? This whole subject got started with my boss when he asked
>>me about botulism in garlic infused oils. I told him that there was
>>nothing to worry about as long as they were refrigerated. (snipped
>>comments)

>
>>not died of it. I need to know if it is safe to sell to the public.
>>The safety standards get a lot higher in that situation.
>>--Lia

>
>
> Lia - have you thought of selling a "kit"? or offering recipe handouts to
> your customers for free? Have classes and charge for that. And last I
> heard, that refrigerated oil-infused herb/garlic mix should be used within a
> week. Adding vinegar of course, changes everything.


Actually, it may or may not. Likely not.

It would be very good if the guesswork stopped and some responsible
science were applied. People's health and very lives are at stake in
this discussion.

Pastorio


  #17 (permalink)   Report Post  
Mark Thorson
 
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Default

Julia Altshuler wrote:

> We're doing wine tastings, and we often have wine leftover.
> I suggested turning the wines into specialty vinegars.


Instead of reprocessing the wine into a new product,
how about just pouring all the leftover wine into one
great big container and selling it cheaply for cooking
purposes. If people wanted to make vinegar with
that, so be it. You could provide recipes for doing that,
without doing it yourself. Other uses would be marinades
and salad dressings. You could also sell kits and instructions
for how to build a small distiller, but of course that would
be in another part of the store. :-)






  #19 (permalink)   Report Post  
Julia Altshuler
 
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I've thought about this (and thank everyone for their answers) and
realize my real question. Most foods in a supermarket need to have one
of those nutrition labels on the side of the box that says how much carb
and sodium and fat is in a portion. Exceptions are foods in their
natural state with only one ingredient, like an apple or a tilapia
fillet. Alcohol in bottles is another exception, like the wine we sell.
Restaurants don't have to provide a nutrition box on food served at
the table. We do sell packaged gourmet items like fancy mustards and
crackers, and they all have the nutrition box. We sell cheese cut off
the wheel at the point of purchase. That has no nutritional
information. We sell dips that we buy from some local distributor that
we portion into smaller containers. Those don't have the nutritional
label, but maybe they should. I'm wondering if vinegar made from wine
would need the label, and, if it did, would we need to hire a lab to
provide the info, or would common sense be good enough.


Either way, I gave my boss the information about botulism in garlic
infused oil and a few recipes for herb vinegars. He thanked me.


I love the idea of selling kits and handing out recipes. It was one of
the things I mentioned when I interviewed. Right now, however, we have
more good ideas than we have space and organization to handle. We've
got all this merchandise, no clear idea of where it all should go, and
no way of communicating with the whole staff what everything is and how
it might be marketed. So one of us tells the customers about one sort
of cheese and one wine. The next recommends something different. I'm
always making suggestions about which fancy marinade to put on dinner.
My co-worker is better at selling wafers. I'd love to pair wines and
cheeses with a particular recipe plus serving suggestions, but there'd
be no place to put the display, and no one else would know what it was
about. That will all have to wait until things settle down a bit.


Selling cheap cooking wine or vinegar is out of the question.
Everything we sell is upscale; the more expensive the better. Catering
to the cost-conscious crowd is out of keeping with the whole vision for
the store.


--Lia

  #20 (permalink)   Report Post  
Bob (this one)
 
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Default

Julia Altshuler wrote:

> I've thought about this (and thank everyone for their answers) and
> realize my real question. Most foods in a supermarket need to have one
> of those nutrition labels on the side of the box that says how much carb
> and sodium and fat is in a portion. Exceptions are foods in their
> natural state with only one ingredient, like an apple or a tilapia
> fillet. Alcohol in bottles is another exception, like the wine we sell.
> Restaurants don't have to provide a nutrition box on food served at the
> table. We do sell packaged gourmet items like fancy mustards and
> crackers, and they all have the nutrition box. We sell cheese cut off
> the wheel at the point of purchase. That has no nutritional
> information. We sell dips that we buy from some local distributor that
> we portion into smaller containers. Those don't have the nutritional
> label, but maybe they should. I'm wondering if vinegar made from wine
> would need the label, and, if it did, would we need to hire a lab to
> provide the info, or would common sense be good enough.


Neither. It depends on how much of it you sell in a year's time
whether nutrition labelling is needed. Check the FDA requirements for
nutrition labeling (they're online along with their entire manual)

Pastorio



  #21 (permalink)   Report Post  
Julia Altshuler
 
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Bob (this one) wrote:

It depends on how much of it you sell in a year's time whether
> nutrition labelling is needed. Check the FDA requirements for nutrition
> labeling (they're online along with their entire manual)



Thanks. I've got some reading to do. This is what I'm looking for, right?


http://vm.cfsan.fda.gov/label.html


--Lia

  #22 (permalink)   Report Post  
Julia Altshuler
 
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Hahabogus wrote:
> Julia Altshuler > wrote in


>>Selling cheap cooking wine or vinegar is out of the question.
>>Everything we sell is upscale; the more expensive the better. Catering
>>to the cost-conscious crowd is out of keeping with the whole vision for
>>the store.


>
> Did he say CHEAP! he must of meant lovingly mixed by hand, blended together
> for best taste and results. Possibly a real money maker.



No, saying CHEAP was my poor choice of words. I see what you mean.

--Lia

  #23 (permalink)   Report Post  
Bob (this one)
 
Posts: n/a
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Julia Altshuler wrote:

> Bob (this one) wrote:
>
>> It depends on how much of it you sell in a year's time whether
>> nutrition labelling is needed. Check the FDA requirements for
>> nutrition labeling (they're online along with their entire manual)

>
> Thanks. I've got some reading to do. This is what I'm looking for, right?
>
> http://vm.cfsan.fda.gov/label.html


Yeah. Wear big boots when you start slogging through it.

Pastorio

  #24 (permalink)   Report Post  
Frogleg
 
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On Fri, 08 Oct 2004 11:57:27 GMT, Julia Altshuler
> wrote:

>If anyone has any
>information on dangers of botulism in herb infused vinegar, let me know
>before I head into work today. This isn't a question of what's safe to
>do at home. I've thrown garlic in vinegar plenty of times at home and
>not died of it. I need to know if it is safe to sell to the public.
>The safety standards get a lot higher in that situation.


To go back to the original question, check with your local health
department. Rules for selling food can be highly complex and
localized. I believe one of the reasons the personal chef business
arose is because one cooks in the customer's kitchen, avoiding the
complication of having to have an 'approved' facility of one's own. I
had to research regs for farmers' mkt operations, and homemade pickles
are allowed (in Virginia), so I'd guess that 'homemade' vinegar would
pass, too. In Virginia, anyhow.

What you want to do is find out the rules *first* rather than deal
with a legal complication later.
  #25 (permalink)   Report Post  
Bob (this one)
 
Posts: n/a
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Frogleg wrote:

> On Fri, 08 Oct 2004 11:57:27 GMT, Julia Altshuler
> > wrote:
>
>
>>If anyone has any
>>information on dangers of botulism in herb infused vinegar, let me know
>>before I head into work today. This isn't a question of what's safe to
>>do at home. I've thrown garlic in vinegar plenty of times at home and
>>not died of it. I need to know if it is safe to sell to the public.
>>The safety standards get a lot higher in that situation.

>
>
> To go back to the original question, check with your local health
> department. Rules for selling food can be highly complex and
> localized. I believe one of the reasons the personal chef business
> arose is because one cooks in the customer's kitchen, avoiding the
> complication of having to have an 'approved' facility of one's own. I
> had to research regs for farmers' mkt operations, and homemade pickles
> are allowed (in Virginia), so I'd guess that 'homemade' vinegar would
> pass, too. In Virginia, anyhow.


In Virginia, infused vinegars are permitted. "Homemade" vinegars made
from alcoholic bases are not permitted without FDA and Virginia
Department of Agriculture and Consumer Services approval (VDACS). Ask
me how many inspectors I've talked with...

Pickles, jams and jellies, breads and pastries (unless they contain
eggs in which case there are other regs), and some fresh foods if
refrigerated (and there's a long list of what can and can't). Some
foods like popcorn and candies. Hot foods prepared for immediate
consumption. Lots of howevers in all that tangled mess of rules.

> What you want to do is find out the rules *first* rather than deal
> with a legal complication later.


Very wise suggestion. I can attest to the wisdom, having not done it
that way because I thought I knew what I was getting into from the
restaurant background. Totally different criteria and I ran afoul of a
few rules. Fortunately, no repercussions because as soon as I found
out what I was doing against the rules, I fixed it. Could have been
bad, though.

Pastorio



  #26 (permalink)   Report Post  
Frogleg
 
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On Mon, 11 Oct 2004 11:16:08 -0400, "Bob (this one)" >
wrote:


>In Virginia, ...


>Pickles, jams and jellies, breads and pastries (unless they contain
>eggs in which case there are other regs), and some fresh foods if
>refrigerated (and there's a long list of what can and can't). Some
>foods like popcorn and candies. Hot foods prepared for immediate
>consumption. Lots of howevers in all that tangled mess of rules.


I went ballistic when I read that egg exception. How can you have
"baked goods" without eggs? However, it refers to "baked goods with
*fillings* containing eggs." So cookies or cakes with eggs in the
recipe is OK. I can't think of an pastry "filling" that contains un-
or partially cooked egg, but there must be some.

I also found it interesting (and disappointing) that fish must be sold
whole, not gutted. The vendor can't even offer to gut it for the
customer at the point of sale. If anyone "lays a knife to" fish, it
must be in an approved facility. Or the buyer's kitchen.
  #27 (permalink)   Report Post  
Frogleg
 
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On Mon, 11 Oct 2004 11:16:08 -0400, "Bob (this one)" >
wrote:


>In Virginia, ...


>Pickles, jams and jellies, breads and pastries (unless they contain
>eggs in which case there are other regs), and some fresh foods if
>refrigerated (and there's a long list of what can and can't). Some
>foods like popcorn and candies. Hot foods prepared for immediate
>consumption. Lots of howevers in all that tangled mess of rules.


I went ballistic when I read that egg exception. How can you have
"baked goods" without eggs? However, it refers to "baked goods with
*fillings* containing eggs." So cookies or cakes with eggs in the
recipe is OK. I can't think of an pastry "filling" that contains un-
or partially cooked egg, but there must be some.

I also found it interesting (and disappointing) that fish must be sold
whole, not gutted. The vendor can't even offer to gut it for the
customer at the point of sale. If anyone "lays a knife to" fish, it
must be in an approved facility. Or the buyer's kitchen.
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