Top Editors ... Legislation: Microbiological Criteria

Title: Legislation: Microbiological Criteria
Date: 31/08/2006
Autor: By Kath Veal

The new Microbiological Criteria for foodstuffs harmonise the legislation throughout Europe and lay clear guidelines for food manufacturers

Food borne illness remains a significan! cause of ill health arising from a range of pathogenic micro-organisms, both via purchased foods and poor home hygiene practices. European food safety legislation establishes a framework of controls within which the food ¡ndustry must opérate to reduce the risk of contaminaron of foods.

Updated new Microbiological Criteria for foodstuffs carne into forcé on 1 January 2006 by virtue of Commission Regulation (EC) No. 2073/2005. The Regulation lays down micro-criteria referred to in Regulation 852/2004, clearly setting out food safety requirements for food processing and final product.

Previously, microbiological criteria were only set in EU legislation for certain microbes in certain foodstuffs of animal origin, while some Member States set their own national criteria for other foodstuff-microbe combinations. Regulation 2073/2005 harmonises the criteria that must be met throughout the EU, offering benefits for intra-community trade and third country exporters to the EU.

The criteria are a small but important aspect of the whole hygiene package implemented to protect consumer health by the reduction of food borne disease. They are not intended to signal a retum to end product testing as the means of achieving product conformity, but to set the standard that preventative strategies must achieve.

Do I need to employ a microbiologist?

Throughout the Hygiene Regulations and associated guidance there is emphasis on flexibility in approach to achieving the desired end result-safe food.

It has been clearly stated by the Commission that there is no desire to compel food businesses to comply with rules or implement procedures not relevant or adapted to the specific context for their activity. The legislation leaves room for the judgement of the individual food business whilst making it clear that it is the responsibility of food businesses to ensure food safety throughout the life of their product.

A food business must, however, provide training to its staff which must inevitably include in certain circumstances a clear understanding of the microbiological hazards relevant to the company's particular products.

Food business operators must ensure that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their Job. Training is required in application of HACCP principies for those responsible for maintaining the food safety management system.

What do the different entena mean?

A microbiological criterion is defined in the Regulation as meaning a criterion defining the acceptability of a product, a batch of foodstuffs or a process, based on the absence, presence or number of micro-organisms, and/or on the quantity of their toxins/metabolites, per unit(s) of mass, volume, area or batch.

The criteria are formulated as an objective to be reached - the food business determines the appropriate means of reaching the objective.

The criteria are clearly separated into two types: firstly, food safety criteria, which define the acceptability of a product or batch of foodstuffs and apply to producís placed on the market throughout their shelf life; and secondly, process hygiene criteria, which indícate the acceptable functioning of the production process and apply at specified production stages.

How should the criteria be applied?

The food safety criteria indícate, for the purposes of Regulation 178/2002, when food is unsafe and thus has to be withdrawn/recalled from the market. Samples exceeding the food safety criteria must be reported to the food authority and it is important that businesses are prepared for a product recall.

The process criteria support food safety management systems in providing a means for verifying that HACCP procedures and other hygiene control measures are achieving their desired effect and are adequate to ensure the supply of satisfactory food. Any indications that process criteria are not being met must be investigated and corrective action implemented and documented.

Officers of the competent authority will use the criteria when carrying out official controls under The Official Food and Peed Controls (Regulation 882/2004). Microbiological samples may be taken by officials to monitor and verify food safety management plans, to check food suspected of being unsafe, or in the context of risk analysis, to check monitoring and surveillance systems. The clarity of the criteria removes the need for subjective assessment of whether food is so contaminated as to be deemed unsafe. They clearly indícate the actions required to take in the event of unsatisfactory results.

Must I take samples, and if so, how often?

Food business operators must include sampling and testing plans within their food safety management procedures. There is, however, flexibility on the frequency and manner of testing proportionate to the size and nature of the business. Specific testing frequencies are only laid down for certain producís e.g. carcasses, minced meat, meat preparations and mechanically separated meat.

It is understood that the safety of food is not gauranteed or controlled by micro testing due to the inherent problems of obtaining a representative sample.

Am I responsible for the actions of consumere?

The requirement is that foodstuffs meet the micro criteria throughout their shelf life. The food business is responsible for determining that shelf life based upon their knowledge of the product. Manufacturera must consider, where relevant, cooking instructions as both a food safety step as well as a final operation in achieving the optimum sensory qualities for the product. Instructions for use on foods may well constitute a listericidal process, thus having an impact on food safety. The role of clear storage instructions for foods must also not be overlooked both for consumers and for those involved in the transport and retailing of foods.

Production of pathogen free food makes economic sense for business, is demanded by consumers, and required by law. The Microbiological Criteria provide assistance to industry in assesing their food safety management systems and clearly define for certain pathogens when food is deemed unsafe from a microbiological viewpoint. The Regulation should therefore be viewed positively as an added food safety tool rather than a burden on business. Improving harmonisation in food hygiene is also of benefit in setting a level playing field and allowing for consistency of enforcement. If you do not nave a copy of the Regulations yet, get one!