What category and level of risk would Taco Sauce/Salsa fit into?

What category and level of risk would Taco Sauce/Salsa fit into per the SQF Code?

pH is <4.6 = ACID FOOD

Hot fill in plastic gallon jugs

Inverted following capping

Based on Appendix 1 of the SQF Code - Food Sector Categories - would it be FSC 15 - Canning, UHT and Aseptic Operations?  I'm just not sure it fits here based on the description...Applies to the processing, of low acid canned foods, and sterilization (retorting) UHT, or other high temperature or high pressure processes (HPP) not covered elsewhere and the manufacture of the associated hermetically sealed containers.

Would this be considered a high risk food and would then need to be in a segregated area and subject to environmental monitoring?

From the Code:

High Risk Area A segregated room or area where high risk food processes are performed, and which require a higher level of hygienic practice is required to prevent contamination of high risk food by pathogenic organisms.

High Risk Food Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which due to a process type may allow for the survival of pathogenic microbial flora or other contamination which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a
major foodborne illness outbreak.

High Risk Food Process(es) A process that requires specific controls and/or a higher level of hygienic practice to prevent food contamination from pathogens.

11.7.4 High Risk Processes
11.7.4.1 The processing of high risk food shall be conducted under controlled conditions such that sensitive areas in
which high risk food has undergone a “kill” step, a “food safety intervention” or is subject to post process handling,
are protected/segregated from other processes, raw materials or staff who handle raw materials to ensure cross
contamination is minimized.
11.7.4.2 Areas in which high risk processes are conducted shall only be serviced by staff dedicated to that
function.
11.7.4.3 Staff access points shall be located, designed and equipped to enable staff to don distinctive protective
clothing and to practice a high standard of personal hygiene to prevent product contamination.
11.7.4.4 Staff engaged in high risk areas shall change into clean clothing or temporary protective outerwear
when entering high risk areas.
11.7.4.5 Product transfer points shall be located and designed so as not to compromise high risk segregation and
to minimize the risk of cross contamination.

Are you using High Temperature Short Time for pasteurization?  Salsa should be considered a low risk food.  The pH should be fairly low.  I'm guessing well below the 4.6 mark you referenced.  Also if processed properly and with the low pH it is not likely to have micro issues.  Do you test the salsa to verify that?  The only time you have to be careful that you may fall under canning regulations is if you acidify the salsa but again I'm thinking the pH of every ingredient is acidic.  

We do add vinegar, which brings the pH down to less than 4.1.

So is the pH above 4.6 before you add the vinegar?

No.  Before we add the vinegar it is 4.46.

as per SQF code you would be 

18

Preserved Foods Manufacture ElV: Processing of Ambient Stable Products

System elements Module 11: GMP for processing of food products Applies to the processing, transport and storage of all foods preserved under high temperature processes not covered elsewhere, compositionally preserved foods that are not high temperature processed or other alternative acceptable methods not covered elsewhere. Includes dressings, mayonnaise, sauces, marinades, pickled foods, peanut butter, mustards, jams and fillings. Some high risk process knowledge required (ie Better processing school as required by the FDA)

Do not get yourself put into the canning, UHT and aseptic filling category, you do not have the same process or risk as say fluid milk or canned salmon......as long as your pH is below 4.6 AND your shelf stable

What might be causing confusion is the mix of terminology; Acid content (low/high acid) and pH (low/high pH).   

A HIGH acid food will have a LOW pH.

A LOW acid food will have a HIGH pH.

It's an easy mix-up to make, and a fairly common one based on my experience!