MEAT HYGIENE SECTION
TRADER NOTICE REF MHS 6 /2006
SUBJECT:
IMPLEMENTATION OF COMMISSION REGULATION
ON MICROBIOLOGICAL CRITERIA FOR FOODSTUFFS.
TO THE MANAGEMENT
AT MEAT PROCESSING ESTABLISHMENTS
Background
Commission Regulation (EC) No. 2073/20051 harmonises the microbiological criteria
for foodstuffs and came into effect on 1 January 2006.
The Regulation applies to all Food Business Operators (FBOs) involved in the
processing and distribution of Food (fresh meat, meat preparations, minced meat,
meat products) [NB – Primary Production and Retail not included]. The
microbiological criteria have been adopted in accordance with the procedure referred
to in Article 14(2) of Regulation 852/2004 giving rise to the Commission Regulation
on Microbiological Criteria in Foodstuffs. The criteria outlined in the Regulation are
based on scientific risk assessment and are necessary to protect public health.
Food Business Operators (FBOs) are obliged to comply with the microbiological
criteria requirements as referenced under Regulation (EC) No 178/20022 of the
European Parliament and of the Council and Article 4.3 (a) of Regulation (EC) No
852/20043 [H 2].
Information Links
DAF
http://www.agriculture.gov.ie/index.jsp?file=trade_exports/app_meat_est/index.xml
1
OJ L 338 of 22.12.2005, p. 1
OJ L 31 of 1.2.2002, p. 1
3
OJ L 226 of 25.6.2004, p. 3
2
FSAI
http://www.fsai.ie/publications/leaflets/new_food_law/new_food_law_micro_criteria.
pdf
EU Commission
http://europa.eu.int/comm/food/food/biosafety/salmonella/microbio_en.htm
National Food Centre – Teagasc
http://www.teagasc.ie/publications/2003/microbiologicaltesting.htm
The Commission Regulation lays down the microbiological criteria for certain microorganisms and the implementing rules to be complied with by FBOs when
implementing the general and specific hygiene rules referred to above.
The Competent Authority shall verify compliance with the rules and criteria laid
down in this Regulation without prejudice to its right to undertake further sampling
and analyses for the purpose of detecting and measuring other micro-organisms, their
toxins or metabolites, either as a verification of processes, for food suspected of being
unsafe, or in the context of risk analysis.
Testing against the criteria should be undertaken by FBOs when validating and
verifying the correct functioning of their HACCP based procedures. In general these
should be in proportionate to the risk associated with the foodstuff and the nature and
size of the business.
The Regulation also allows flexibility in relation to the analytical reference method
and the sampling plan. Alternative analytical reference methods are acceptable once
they have been validated, certified or authorised under the provisions of the
Regulation. The number of sample units in the sampling plan can be reduced if the
FBO can demonstrate that effective HACCP based procedures are in place.
Some Useful Definitions
Chapter 1 of Annex 1 to Regulation 2073 / 2005 includes explanatory references to 26
food categories. However for the purposes of this Trader Notice the definitions
specified below are referenced as key definitions.
“microbiological criterion” means a criterion defining the acceptability of a product,
a batch of foodstuffs or a process, based on the absence, presence or number of microorganisms, and/or on the quantity of their toxins/metabolites, per unit(s) of mass,
volume, area or batch.
“food safety criterion” means a criterion defining the acceptability of a product or a
batch of foodstuff applicable to products placed on the market.
These criteria define the acceptability of a foodstuff in terms of its microbiological
safety. They are applicable to foodstuffs placed on the market and through their shelf
life. If a sample is unsatisfactory for a food safety criterion, the product or batch of
foodstuff should be withdrawn or recalled from the market.
“process hygiene criterion” means a criterion indicating the acceptable functioning of
the production process. Such a criterion is not applicable to products placed on the
market. It sets an indicative contamination value above which corrective actions are
required in order to maintain the hygiene of the process in compliance with food law.
These criteria indicate if the production process is operating in a hygienic manner.
They are applicable to foodstuffs at various stages throughout their production
process. If a sample is unsatisfactory for a process hygiene criterion, improvements in
production hygiene should be undertaken.
General Requirements
FBOs shall ensure that foodstuffs comply with the relevant microbiological criteria
set out in Annex I of the Regulation.
FBOs responsible for the manufacture of foodstuffs shall conduct studies in
accordance with Annex II of the Regulation in order to investigate the compliance
with the criteria throughout the shelf-life. In particular, this applies to ready-to-eat
foods that are able to support the growth of Listeria monocytogenes and that may pose
a Listeria monocytogenes risk for public health. It is recognised that there may be an
issue of resources for some FBOs (especially SMEs) and the Regulation allows for
collaboration between FBOs in conducting these studies.
Sampling
The sampling rules are laid down in Annex I of the Regulation, including sampling
plans and general rules for sampling and preparation of samples
It also includes sampling in slaughterhouses and at premises producing minced meat
and meat preparations, sampling frequencies for carcases, minced meat, meat
preparations and mechanically separated meat.
The sampling plans and methods in Annex I shall be applied as reference methods.
The Regulation requires that samples shall be taken from processing areas and
equipment used in food production, when such sampling is necessary for ensuring that
the criteria are met. FBOs manufacturing ready-to-eat foods which may pose a
Listeria monocytogenes threat for public health, shall sample processing areas and
equipment for Listeria monocytogenes as part of their sampling scheme.
Testing
FBOs shall perform testing as appropriate against the microbiological criteria set out
in Annex I of the Regulation when they are validating or verifying the correct
functioning of their procedures based on HACCP principles and good hygiene
practice.
FBOs shall decide the appropriate sampling frequencies, except where Annex I
provides the appropriate sampling frequencies, in which case the sampling frequency
shall be at least that provided for in Annex I.
FBOs shall make this decision in the context of their procedures based on HACCP
principles and good hygiene practice, taking into account the instructions for use of
the foodstuff.
The frequency of sampling may be adapted to the nature and size of the food business,
provided that the safety of foodstuffs will not be endangered.
Unsatisfactory Results
When unsatisfactory results are obtained from testing against food safety criteria set
out in Chapter I of Annex I, the product or batch of foodstuffs shall be withdrawn or
recalled.
In the event of unsatisfactory results as regards process hygiene criteria, the actions
laid down in Annex I, Chapter 2 shall be taken. These include improvements in
slaughter hygiene and review of process controls, origin of animals and biosecurity
measures in the farms of origin.
Trend Analysis
FBOs shall analyse trends in the test results and when a trend towards unsatisfactory
results is observed, they shall take appropriate actions without undue delay to remedy
the situation in order to prevent the occurrence of microbiological risks.
Process Hygiene Criteria
The Process Hygiene Criteria for carcases of food animals and also minced meat,
meat preparations and mechanically separated meat are laid down in Chapter 2 of
Annex I of the Regulation.
The criteria in relation to carcases are similar to the existing regime laid down in the
European Communities (Fresh Meat and Poultry Checks on General Hygiene)
Regulations, 2003 for which the National Food Centre provided a Guidance Note
(June 2003 Note No: NFC/Meat/1/2003).
However, there is one significant difference in relation to carcases in that
Salmonella is now included as an indicator of process hygiene.
The criteria that apply to minced meat and meat preparations are similar to those laid
down in the 2nd and 3rd Schedule to the European Communities (Minced Meat and
Meat Preparations) Regulations, 1996. The criteria applying to minced meat now also
apply to mechanically separated meat.
Food Safety Criteria
Listeria monocytogenes in ready-to-eat foods able to support its growth
The limit is absence in 25 g and applies before the food has left the immediate control
of the FBO who has produced it and who is unable to demonstrate to the satisfaction
of the Department that the product will not exceed the limit of 100 cfu/g throughout
the shelf life.
Salmonella in Minced meat, Meat Preparations, Mechanically Separated Meat
and Meat Products from Poultry Meat Placed on the Market and Intended to be
Eaten Cooked
The limit is absence in 10g (and absence in 25g for poultry products from January 1 st
2010) and applies to products placed on the market during their shelf life. If any one
of the 5 units comprising the samples taken (n=5) are positive (c=1 or more), the
product or batch must be withdrawn or recalled from the market.
(i) Labelling Requirements
When the above requirements for Salmonella (c=0) have been met, the batches of
those products placed on the market must be clearly labelled by the manufacturer in
order to inform the consumer of the need for thorough cooking prior to consumption.
(ii) Unsatisfactory results
In the event of unsatisfactory results (c=1 or more), the product or batch of foodstuffs
shall be withdrawn or recalled in accordance with Article 19 of Regulation (EC)
178/2002. However, products placed on the market which are not yet at retail level
and which do not fulfill the food safety criteria, may be submitted to further
processing by treatment eliminating Salmonella. This treatment may only be carried
out by FBOs other than at retail level.
The FBO may use the batch for purposes other than those for which it was originally
intended, provided that this use does not pose a risk for public or animal health and
provide that this has been decided within the procedures based on HACCP principles
and good hygiene practices and authorised by the Veterinary Inspector.
In the case of Mechanically Separated Meat (MSM), produced in accordance with the
provisions of Regulation (EC) 853/2004, with unsatisfactory results in respect of
Salmonella, may be used in the food chain only to manufacture heat-treated meat
products in approved establishments.
(iii) Transitional Derogation – Special Mark
A transitional derogation until the end of 2009 is provided for under Article 8 of
Regulation 2073 / 2005 for batches of products which do not comply with the above
requirements (n=5, c = 0). Member States availing of this derogation shall guarantee
that the appropriate means, including labelling and a special mark, which cannot be
confused with the identification mark are in place to ensure that the derogation applies
only to the products concerned when placed on the domestic market and that products
dispatched for intra-Community trade comply with the above requirements (n=5,
c=0).
The batches of these products must be clearly labelled by the manufacturer indicating
the need for thorough cooking prior to consumption.
Member States also must undertake that when testing against the Salmonella criterion,
no more than one out of five sample units shall be found to be positive (n=5, c=1)
for the results to be acceptable as regards the Transitional Derogation.
Salmonella in Meat Products intended to be eaten raw, excluding products where
the manufacturing process or the composition of the product will eliminate the
Salmonella risk.
The limit is absence in 25g and applies to products placed on the market during their
shelf life.
Requests from the meat processing sector for this transitional arrangement should be
forwarded to Meat Hygiene Section, Meat Hygiene and Animal By Products Division,
Agriculture House, Kildare Street, Dublin 2.
Sampling Frequencies for Carcases, Minced meat, Meat Preparations and
Mechanically Separated Meat.
Sampling shall be conducted at least once a week.
In the case of E coli and TVCs (Minced Meat and Meat Preparations only) and
Enterobacteriaceae and TVCs (carcases), the frequency may be reduced to fortnightly
testing if satisfactory results are obtained for 6 consecutive weeks.
In the case of (minced meat, meat preparations and carcases), the frequency can be
Salmonella reduced to fortnightly if satisfactory results have been obtained for 30
consecutive weeks.
Amendment of SOP
Plant Management should amend the relevant SOP and make the amended SOP
available to the Veterinary Office. Auditable records must be kept to provide evidence
of compliance with the legislation.
Copies of this trader notice may be printed from the Department’s website www.agriculture.gov.ie - select heading “AGRI FOOD INDUSTRY ”, scroll down to
“TRADE AND EXPORTS”, select “APPROVED MEAT ESTABLISHMENTS”,
select “Trader Notices”.
Signed Liam Walsh
__________________________
Liam Walsh
Assistant Principal Officer
Meat Hygiene Section
Meat Hygiene and Animal By Products Division
Agriculture House
Phone Dublin 01 – 6072830
3 August 2006
The Department of Agriculture and Food does not guarantee the accuracy of the
information provided, nor does it accept responsibility for any use made thereof.
Users should therefore take all necessary precautions before using this information,
which they use entirely at their own risk.