Chiktay, Marinades and Clostridium botulinum: Low-Acid Food Controls Your PCP Must Prove

In August 2026, Quebec's Ministry of Agriculture, Fisheries and Food, known as MAPAQ, warned the public not to eat several products prepared and sold by a specialty grocer in Quebec City. The products were a Creole style spice marinade and various kinds of chiktay, a traditional marinated cod packed in glass jars. The reason was not an allergen or a labelling technicality. MAPAQ said the products had not been prepared and packaged in a way that ensured their safety, that they could favour the growth of Clostridium botulinum, and that the labels were missing the mandatory Keep Refrigerated statement. No illnesses were reported, which is the good news. The warning is one of a recurring cluster of near identical Quebec notices on marinated and spice based products, and that pattern is the real story.

For anyone who manufactures marinated fish, oil based sauces, acidified vegetables, or any low-acid food that sits in a sealed jar or pouch, this is a warning worth reading closely. Botulism is rare, but it is one of the few food safety hazards that is routinely fatal, and it is almost always the result of a control that was never designed or validated in the first place. This article explains where Clostridium botulinum grows, the three ways a processor can control it, what a scheduled process and a process authority actually are, and what your Safe Food for Canadians Regulations preventive control plan has to prove before your product reaches a shelf.

Executive summary

Clostridium botulinum is a spore forming bacterium that produces a deadly toxin in low-acid, low-oxygen foods held without adequate control. Marinated fish, garlic or herbs in oil, and vegetables in sealed jars are classic higher risk products. Control comes from one of three validated routes: a thermal process that achieves commercial sterility, acidification to an equilibrium pH of 4.6 or below, or refrigeration backed by a Keep Refrigerated label and, usually, a second barrier. A preventive control plan that names the hazard and proves the control is what stands between a small manufacturer and a recall.

Clostridium botulinum grows in moist, low-acid (pH above 4.6), low-oxygen conditions. A sealed jar of marinated fish is close to an ideal environment for it.
The spores are widespread in soil and survive ordinary boiling. Only a validated thermal process, acidification, or the right combination of barriers reliably controls the hazard.
Refrigeration alone is often not enough. Canada already forced garlic in oil products to add a second barrier such as acidification after refrigeration proved insufficient.
Under the Safe Food for Canadians Regulations, a licensed manufacturer must identify Clostridium botulinum as a biological hazard where it applies and document a control, not rely on a recipe.
The missing Keep Refrigerated statement in the Quebec warnings is not a minor label defect. When refrigeration is the safety barrier, the label is part of the control.

What happened in Quebec, and why it keeps happening

MAPAQ issued public warnings in August 2026 about a Creole spice marinade and several varieties of chiktay, marinated cod in glass jars, prepared and sold by Rose-Marie Epicerie multiculturelle inc. in Quebec City. The agency said the products were not prepared and packaged in a way that ensured their safety, could support Clostridium botulinum growth, and lacked the required Keep Refrigerated statement. No illnesses were reported. Similar Quebec warnings on other spice and marinade products point to a pattern, not a one off.

The common thread in these warnings is a small manufacturer relying on a recipe rather than a validated process. Chiktay is a marinated fish product. Fish is a low-acid food, oil and a sealed jar create a low-oxygen environment, and unless the product is either acidified to a safe pH, given a validated heat process, or kept genuinely cold with a label that says so, the conditions favour Clostridium botulinum. The absence of a Keep Refrigerated statement tells inspectors that the manufacturer may not have identified refrigeration as a required safety control at all. Even a business that qualifies for the SFCR small business exception from a written plan must still make safe food. The exception can remove the paperwork requirement, never the hazard.

It is worth being precise about jurisdiction, because it changes who inspects you. MAPAQ is Quebec's provincial food authority and it regulates food prepared and sold within the province. A business that ships food across provincial or international borders, or that operates a federally registered establishment, falls under the Canadian Food Inspection Agency and the Safe Food for Canadians Regulations. The science of botulism control is identical either way. What differs is which regulator writes the warning and which set of records they ask to see.

Where botulism grows: pH, water activity and oxygen

Clostridium botulinum needs several conditions together: a low-acid food with a pH above 4.6, enough available water, a low-oxygen environment, and time at a temperature that allows growth. Remove any one of these and the hazard is controlled. That is the entire logic of low-acid food safety. Acidify the food below pH 4.6, reduce water activity, introduce oxygen, apply heat that destroys the spores, or hold the food cold enough for long enough, and you break the chain.

Health Canada draws the line at a pH of 4.6. High-acid foods, with a pH below 4.6, include most fruit, jams, pickles and properly acidified products. The natural or added acid prevents botulism growth, and a boiling water process is enough. Low-acid foods, with a pH above 4.6, include most vegetables, meat, poultry, seafood and mixtures such as a meat and vegetable sauce. For these, the temperature needed to destroy botulism spores can only be reached with pressure, because the spores survive ordinary boiling. A borderline food such as tomato needs added acid to be treated safely as high-acid. The table below sets out the conditions that allow or prevent growth.

Factor	Allows Clostridium botulinum	Controls it
Acidity (pH)	Low-acid, pH above 4.6	Acidified or high-acid, equilibrium pH 4.6 or below
Oxygen	Low-oxygen, such as a sealed jar, can, pouch or oil layer	Aerobic, product exposed to air
Water activity (aw)	Moist food, aw above 0.85	Dried or formulated to aw 0.85 or below
Temperature and time	Warm or room temperature storage	Validated heat process, or reliable refrigeration where that is the barrier
Spores	Survive ordinary boiling at 100 C	Destroyed by a validated thermal process, for example a pressure or retort process reaching about 121 C

The three control routes for low-acid foods

A processor has three legitimate ways to make a low-acid product safe from Clostridium botulinum. First, apply a thermal process that achieves commercial sterility so the product is shelf stable. Second, acidify the product to an equilibrium pH of 4.6 or below and validate that it stays there. Third, keep the product refrigerated as the controlling barrier and label it clearly, usually with a second hurdle as well. Whichever route you choose, it has to be validated and documented. A recipe is not a control.

Each route carries different obligations. The table sets them out.

Control route	How it works	What you must prove
Thermal process to commercial sterility	Heat destroys spores so the sealed product is safe at room temperature	A scheduled process set by a process authority, heat penetration data, container closure control, and process records for every batch
Acidification to pH 4.6 or below	Added acid lowers the equilibrium pH so spores cannot grow	Validated equilibrium pH, an acidification procedure, pH monitoring records, and control of any low-acid components
Refrigeration plus labelling	Cold slows or stops growth of the surviving hazard	That refrigeration genuinely controls the hazard, a Keep Refrigerated label, a justified shelf life, and usually a second barrier such as acidification

The Quebec products appear to have relied on none of these in a validated way. A marinated fish in a sealed jar that is neither acidified below pH 4.6, nor thermally processed to commercial sterility, nor labelled and controlled as a refrigerated product, has no proven barrier against Clostridium botulinum. That is precisely the gap MAPAQ described.

Scheduled process and the process authority

A scheduled process is the specific combination of heat, time, acidity and other factors, established by a qualified process authority, that has been shown to make a particular product in a particular container safe. A process authority is a person or organization with the expertise and equipment to establish and validate that process. For low-acid and acidified foods in sealed containers, this is not optional expertise. It is the core of the control, and inspectors expect to see the documented process behind your product.

In Canada, the Canadian Food Inspection Agency publishes preventive control guidance on the commercial sterilization of low-acid foods in hermetically sealed containers, including retort systems, heat penetration studies, and the visual examination of commercially sterile low-acid and acidified foods. For fish specifically, which is what chiktay is, CFIA maintains dedicated fish preventive control guidance. There is even specific guidance on hermetically sealed glass container defects, because a jar that does not seal correctly defeats the process no matter how good the heat step was.

The United States framework makes the same point in regulation. Low-acid foods packed in hermetically sealed containers fall under 21 CFR Part 113, and acidified foods under 21 CFR Part 114. Both exist for one reason, to prevent an environment in which Clostridium botulinum can grow. A US processor of these foods must register the establishment, file the scheduled process, and operate under a qualified process authority, often after formal process control training. Whether you sell into Canada, the United States or both, the expectation is the same: a validated process, established by someone qualified, documented and followed for every batch.

Keep Refrigerated: the label that was missing

When refrigeration is the barrier that keeps a food safe, the Keep Refrigerated statement is part of the control, not a courtesy. If the product leaves the manufacturer and sits at room temperature because nothing on the label told the retailer or consumer to chill it, the control has failed at the last step. That is why MAPAQ treated the missing statement as a safety issue rather than a labelling nicety.

Canada has been here before, and the precedent is instructive. After botulism cases linked to chopped garlic in oil, Canadian authorities stopped allowing garlic in oil products to rely on refrigeration alone. Those products now have to carry an additional barrier, such as acidification, because refrigeration by itself proved to be an unreliable control for a low-acid food in an oxygen free oil layer. The lesson for any marinade, pesto, infused oil or marinated fish is direct. If your only barrier is cold, regulators may well conclude it is not enough, and you will need a validated second hurdle in the formulation itself.

What a defensible low-acid food PCP must contain

Under the Safe Food for Canadians Regulations, a licensed food business must have a written preventive control plan that identifies the biological, chemical and physical hazards that present a risk of contamination and shows how each is controlled. For a low-acid or acidified product, that means naming Clostridium botulinum as a biological hazard, documenting the control route you rely on, and keeping the monitoring and verification records that prove the control worked.

A plan that survives an inspection ties each element together. The hazard analysis identifies botulinum toxin formation for the specific product. The control measure is the scheduled process, the acidification target, or the refrigeration and labelling regime, with the validation behind it. Monitoring records show pH readings, process times and temperatures, or storage temperatures. Verification confirms the monitoring is being done and the results are within limits. Corrective actions describe what happens when they are not. The same discipline we describe for an SFCR allergen control plan applies here, and it applies whether the hazard is botulinum toxin, an allergen, or a parasite in imported produce. The plan is only as good as what it actually requires you to do and record.

Vacuum packing and reduced oxygen packaging: a rising inspection focus

Reduced oxygen packaging, which includes vacuum packing and modified atmosphere packaging, deliberately removes oxygen to extend shelf life. For a low-acid refrigerated food, that same low-oxygen environment is exactly what Clostridium botulinum prefers, and some strains grow slowly even at refrigeration temperatures. Any processor using vacuum or modified atmosphere packaging for a low-acid product needs a specific control, not just cold storage.

This is a common finding in small and growing operations that adopt vacuum packing to look more professional or to reach new customers, without recognising that they have changed the hazard profile of the product. If you vacuum pack a low-acid food, your preventive control plan has to address the botulism risk directly, usually by combining refrigeration with acidification, salt or water activity control, a validated heat step, or a limited shelf life supported by data. The same rigour we bring to environmental monitoring for ready to eat foods belongs in the design of any reduced oxygen packaged product.

Compliance checklist: low-acid and acidified food control

Use this checklist to test your control of Clostridium botulinum. Any item you cannot tick is a gap to close before your next production run.

Your hazard analysis names Clostridium botulinum as a biological hazard for each low-acid or acidified product, not a generic microbiological line.
You have classified every product as high-acid, acidified, low-acid, or refrigeration dependent, based on measured equilibrium pH and water activity.
For any shelf stable low-acid product, a qualified process authority has established a scheduled process, and you hold the heat penetration and process data.
For any acidified product, you have validated that the equilibrium pH is 4.6 or below and you monitor and record pH for every batch.
For any refrigeration dependent product, the label carries a Keep Refrigerated statement and your shelf life is justified by data, not by assumption.
Where refrigeration is the only barrier for a low-acid product, you have confirmed it is sufficient, or you have added a validated second barrier such as acidification.
Container and seal integrity are controlled and verified, including for glass jars and pouches, so the process cannot be defeated by a bad seal.
Monitoring, verification and corrective action records exist for each control, and staff are trained to keep them.
Traceability records let you trace one step back and one step forward, and you keep them for the period the regulations require.
You have run a mock recall on a low-acid line so you know you can isolate affected lots quickly.

Common mistakes

Treating a family or cultural recipe as a food safety control, without any validated process behind it.
Assuming refrigeration alone controls botulism in a low-acid product sealed in a jar, pouch or oil layer.
Leaving the Keep Refrigerated statement off a product whose safety depends on staying cold.
Grouping Clostridium botulinum under a generic microbiological heading, so the plan looks complete while the real control is missing.
Adopting vacuum or modified atmosphere packaging without redesigning the hazard control for the new low-oxygen environment.
Relying on smell, taste or appearance to judge safety, when botulinum toxin gives no warning signs at all.

Frequently asked questions

What pH stops Clostridium botulinum from growing?

An equilibrium pH of 4.6 or below stops Clostridium botulinum from growing. That is why acidified foods are formulated to reach a finished pH at or under 4.6, and why high-acid foods below that threshold are considered lower risk. A pH just above 4.6 is not close enough. Control depends on validating that the whole product, not just the liquid, sits at or below the target.

Is refrigeration enough to prevent botulism?

Often it is not. Some strains of Clostridium botulinum can grow slowly at refrigeration temperatures, and refrigeration fails the moment the product is left out. Canada already requires garlic in oil products to add a barrier such as acidification rather than rely on cold alone. For a low-acid product in a sealed container, treat refrigeration as one hurdle that usually needs a validated second barrier and a Keep Refrigerated label.

Does chiktay or marinated fish need to be kept refrigerated in Canada?

If refrigeration is the barrier that keeps the product safe, then yes, and the label must say so. Marinated fish in a sealed jar is a low-acid, low-oxygen product. Unless it is acidified to a safe pH or thermally processed to commercial sterility, it depends on refrigeration, and a Keep Refrigerated statement is part of the control. A missing statement was one of the reasons for the 2026 Quebec warnings.

What is a scheduled process and a process authority?

A scheduled process is the validated combination of heat, time, acidity and other factors that makes a specific product in a specific container safe. A process authority is a qualified person or organization that establishes and validates it. For low-acid and acidified foods in sealed containers, regulators in both Canada and the United States expect the process to come from a process authority and to be documented and followed for every batch.

Who regulates low-acid food safety in Canada, MAPAQ or CFIA?

It depends on where the food is made and sold. MAPAQ regulates food prepared and sold within Quebec. The Canadian Food Inspection Agency, under the Safe Food for Canadians Regulations, regulates food that crosses provincial or international borders and federally registered establishments. The botulism science is the same. The difference is which authority inspects you and issues a warning or recall.

How is botulism different from Listeria or Salmonella?

Listeria and Salmonella cause infection and are often controlled by sanitation, environmental monitoring or a kill step. Clostridium botulinum is different because it forms heat resistant spores and produces a toxin in low-acid, low-oxygen foods. You cannot rely on ordinary cooking or cleaning to control it. The control is designed into the product through acidity, a validated heat process, or a proven refrigeration and barrier system.

How MFLRC can help

MF License and Regulatory Consultants works with prepared food, specialty and ethnic food manufacturers across the food and beverage sector to build preventive control plans that actually control Clostridium botulinum. We run gap assessments on low-acid and acidified product plans, coordinate scheduled process and process authority validation, review acidification and pH monitoring, assess labelling including Keep Refrigerated statements, and design mock recalls so your traceability holds up under pressure. Our quality and compliance services and audit services give you a defensible file before an inspector, a retailer or a customer asks for one.

If your product is a marinade, an infused oil, an acidified vegetable or a marinated fish in a sealed jar, and your control is a recipe rather than a validated process, you have a gap. We help you close it before it becomes a warning or a recall.

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Conclusion

The Quebec warnings did not describe an exotic failure. They described a small manufacturer making a traditional product the way it has always been made, in a sealed jar, without a validated barrier against a hazard that gives no warning. Botulism is rare precisely because the controls for low-acid foods are well understood. The businesses that get caught are almost always the ones that treated a recipe as a control and never proved it. A preventive control plan that names Clostridium botulinum, chooses a validated control route, and keeps the records to back it up is not red tape. It is the difference between a product on a shelf and a product in a recall notice.