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• Proposal P251 - Processing Requirements for Uncooked Comminuted Ferments Meat Products

 

Proposal P251 - Review of processing requirements for uncooked comminuted fermented meat (UCFM) products

( For Australia only )

Initial assessment report -  (prepare a new proposal - s.21)

DEADLINE FOR PUBLIC SUBMISSIONS to the Authority in relation to this matter : 24 APRIL 2002   (see ' Invitation for Public Submissions' for details)

Full Report [ PDF format 41 kb ]

The Australia New Zealand Food Authority (the Authority) has initiated a Proposal to review the Australian Food Standards Code on the above matter.   The Authority's Initial Assessment Report (' the Report' ) provides further detail below.   The Authority now invites public submissions on any issue raised in the Report for the purposes of making a Draft Assessment.

EXECUTIVE SUMMARY

The current Standards (clause 9, Standard 1.6.2, Volume 2 and clause 60A, Standard C1, Volume 1 of theFood Standards Code) for the production of uncooked comminuted fermented meat (' UCFM' ) products require that the production process deliver a 3-log₁₀ reduction of Escherichia coli (E. coli) organisms.   In addition, it requires that the levels of E. coliin the incoming meat are monitored, and the end product is tested for the absence of E. coli organisms. Alternatively the product may be cooked at 65⁰C for at least 10 minutes to ensure it is safe.   It is important to note that Standard 1.6.2 (including clause 9) only applies in Australia and not in New Zealand.   These are considered by New Zealand to be outside the Scope of the Joint Food Standards System as they regarded as hygiene measures for which New Zealand has its own requirements.  

The purpose of the above processing requirements for the production of UCFM products is to protect public health and safety. The Standard was gazetted as an emergency provision in 1995 in response to the outbreak of food-poisoning related to the consumption of mettwurst, a type of UCFM product, produced by the Garibaldi Company in South Australia.

To achieve the specific safety outcome, the above processing requirements are complemented by:

A.  the provisions of microbiological limits that specify the number of liveE. colicells in any UCFM product must be zero per gram (Standard 1.6.1, Volume 2 of theFood Standards Code) or absent in 0.1 gram (clause 60, Standard C1, Volume 1 of theFood Standards Code), and

B.  the ARMCANZ (Agriculture Resources Management Council of Australia and New Zealand) Meat Standards that mandate the hygienic practices for the production, processing and transportation of meat (Australian Standard for the hygienic production and transportation of meat and meat products for human consumption).

A study commissioned by the Meat and Livestock Australia Limited (' MLA' ) (Predicting E. coli inactivation in uncooked comminuted fermented meat products, July 2001, Meat & Livestock Australia) concluded:

• many UCFM processes currently used, either in Australia or overseas, can not comply withthe 3-Log kill requirement; and
  
•  given the inability of most processes currently used in Australia to satisfy therequirement of Clause 60A, that the utility of this prescriptive regulation be reconsidered.

The 3-Log kill requirement refers to 3-log₁₀ reduction requirement of E. coli organisms specified in the Food Standards Code. The study questioned the appropriateness of the 3-log₁₀ reduction requirement due to the relative absence of ongoing disease outbreak, and considered that the requirement is prescriptive, lessens the diversity of UCFM products on the markets, and consequently consumers would lose a range of choice. The study recommended the processing requirement to be reassessed, and that alternative risk management strategies based on food safety outcomes be developed.

At its June 2001 meeting, the MSC recorded its concern about the processing requirement, and in particular that the processing requirement is incapable of auditor verification.

This Proposal will assess the claims made against the processing requirement for their scientific merit (i.e. that the requirements are inappropriate for the UCFM manufacturing processes and have a negative impact on consumer choice) and regulatory merit (i.e. that they are incapable of auditor verification), and particularly the implication of the claims on the safety level of the UCFM products to ensure that protection of public health and safety will be placed at the highest priority as a result of this review. The review will take into consideration:

• the implications of the claims made by MLA and MSC about UCFM product safety, and thus public health and safety;
  
• relevant international approaches;
  
• the wholesomeness of meat as defined in the Australian Standard for the hygienic production and transportation of meat and meat products for human consumption;
  
• the MLA predictive modelling study of E. coli inactivation over the production process of UCFM products;
  
• a microbiological risk assessment- including microbiological limits of the product due to the apparent duplication of two limits for UCFM products, and an analysis of the available data for E. coli organisms in meat before and after processing (from raw meat to end product) collected by the smallgoods industry ;

• the compliance cost to the industry;

• the enforceability of the regulatory measure; and

• the desirability of an outcome based approach in setting food standards.

If necessary, the Proposal will identify alternative regulatory measures that are appropriate to the industry and consumers, and capable of auditor verification to ensure that a high safety level for UCFM products is maintained.

Full Report [ PDF format 41 kb ]