I think a lot of the BRC's thought process was around how foodstuffs enter the area though which was why David Brackston was confused by my question I think. His view was "as the cheese blocks were washed in, there was no issue as the washing in process is assumed to be effective" forgetting the milk used to make cheese before it goes into those plastic wrapped block hasn't undergone a 70degC 2min treatment. I also sense the hands of a few lobbyists on those BRC flow diagrams on what should and shouldn't be high care / high risk. There are some processes which should definitely be high care at least IMO which the BRC have been a bit slow to adopt.
As for FDA's views on the subject, I'm less experienced on that sadly and will have to bow to your superior knowledge.
Yes, i agree with a lot of yr comments. I guess it's 5 years since the original zone diagram surfaced. Surely long enough for a BRC review ?.
IMO BRC could usefully issue a compilation of cases/"solutions" which have been demonstrated to be specific exceptions (or "subtleties") to their zoning chart(s). Sort of extension to the aging, but still readable, F048.
Regarding USA, I am for sure no expert either. Hence my numerous "??"s in previous post.
Afaik, the quotations below illustrate the nature of the UK/US divergences but the underpinning micro.details/opinions get, rapidly, very intricate. The overall issue seems to have been progressively (UK) catalysed due commercial interest in so-called "rare" burgers, eg see the 2015 FSA file attached below which contains some quite carefully couched FS (risk) opinions.
31. The USDA FSIS publishes consumer advice regarding the minimum temperature requirements for cooking a variety of raw products (Anon 2006a).
It recommends that all burgers (comminuted, reformed beef patties) are cooked to achieve a inimum temperature of 160°F (71.1°C) and, whilst this same temperature is also advocated for pork and egg dishes, higher temperatures are recommended for chicken breasts and whole chicken (165°F/75.3.°C). In addition, advice to consumers is to use a thermometer to check the temperature rather than rely on visual appearance due to concerns over the potential for the burger to appear cooked even though lethal temperatures may not have been reached.
32. Meat and poultry products cooked in official establishments in the USA are subject to specified legislative requirements. Fully cooked beef patties (burgers) must meet the following emperature/time requirements;
66.1°C (151°F) for 41 seconds, 66.7°C (152°F) for 32 seconds, 67.2°C (153°F) for 26 seconds, 67.8°C (154°F) for 20 seconds, 68.3°C (155°F) for 16 seconds, 68.9°C (156°F) for 13 seconds and 69.4°C (157°F) for 10 seconds (Anon 2006b). In contrast no temperature/time requirements are specified for cooked beef, roast beef and cooked corned beef products, where the requirements specify that a process must be applied to ensure that a 6.5-log 10 reduction of Salmonella is achieved (or a process that achieves an equivalent probability that no viable Salmonella organisms remain in the finished product) (Anon 2006c). Similar requirements exist for fully cooked poultry products except that they must achieve a 7-log reduction in Salmonella spp. (Anon 2006d). Risk assessments were conducted when establishing these minimum process requirements which took into account an estimate of the “worst case” raw product, i.e. highest levels of Salmonella contamination and the probability distribution of survival in the finished product given different lethal processes (Anon 1998).
(FSA, 2007) (2017 figures not checked for any changes)
The scientific support for RTE products should be sufficiently related to the process, product, and hazard identified in the hazard analysis. For thermal lethality treatments (i.e., cooking), establishments can use scientific support that demonstrates reduction in one pathogen to support that another pathogen would also be reduced.
For example, although establishments may identify several biological hazards (i.e., Salmonella, Listeria monocytogenes (Lm), and E. coli O157:H7) that are addressed by a lethality treatment, Salmonella is generally considered the reference organism for lethality for most RTE meat and poultry products because: (1) It is prevalent in raw poultry, beef, and pork; (2) it causes a high incidence of foodborne illness; and (3) foodborne illness associated with Salmonella is severe (66 FR 12593). In addition, FSIS recommends that establishments use Salmonella as an indicator of lethality because it tends to be more heat resistant than other pathogens. Therefore, if an establishment’s scientific support demonstrates that its lethality treatment achieves sufficient reduction in Salmonella, it does not need to provide additional support that adequate reduction in other pathogens such as Lm or E. coli O157:H7 is achieved.
FSA risky foods,2015.pdf 340.24KB