16 replies to this topic

[Simon]

I found this reference document from New Zealand Food Safety Authority. It's from 1995 but hopefully it's still valid.

These criteria are formulated as a guide to indicate when food can be considered unacceptable or unsafe.

Microbiological Reference Criteria for Food

Regards,
Simon

[Tony-C]

Thanks Simon

It looks very useful

Regards,

Tony

[Charles.C]

The current equivalents are accessible via the anzfa website although they are not always too easy to locate.
Can observe that some of the requirements are quite tough as compared to UK (now maybe less so after merging with Australia).
The document gives a pointer to one of the key authorities on this subject - International Commission on Microbiological Specifications for Foods (ICMSF).

Rgds / Charles.C

[a_andhika]

Dear Simon,

Thank you. It helps me on determining criteria for baby food

Dear Charles C., I cant find the "current equivalents" on ANZFA and NZFSA site. The document on the NZFSA site is the same like Simon's. Do you have another link?

Nevertheless, I found another document about micro limit:
http://www.foodstand...ts_edit0702.pdf

Regards,


Arya

[Tony-C]

Can observe that some of the requirements are quite tough as compared to UK (now maybe less so after merging with Australia).

Rgds / Charles.C

UK standards are dictated by the EU and as I have indicated in other forums some of the standards are ridiculous such as < 1,000 E.coli in ready to eat fruit and vegetables.

It costs a lot of money for this sort of bureaucracy - we should expect better. The NZ stuff looks much more sensible as usual.

Regards,

Tony

[Charles.C]

Dear Tony,

The NZ stuff looks much more sensible as usual.

Unfortunately I hv to agree and disagree with this bold statement. Several years ago, FAO published an evaluation of EC area official national import regulations and the conclusion was a huge percentage of the microbiological criteria were simply unjustifiable on (various) technical grounds. One of the prime recommendations was a shift to HACCP based systems. The EC trend has, i think, followed this guidance logic where possible. There are a few publications relating to the current revamp of the EU criteria which amplify that the numbers are intended to be risk justifiable when interpreted within the overall HACCP oriented framework. "Justifiable" will mean different things depending on yr specific opinion of course. I agree with you it would certainly be interesting to see the basis for the 1000/g figure for a product which is going to be directly consumed (?). But the opposite situation is equally valid IMO. Historically, IMEX, the NZ limits have sometimes been criticised for occasional perceived unreasonables, usually in the opposite direction to yr EC comments. Not that this makes them unique of course. Having occasionally seen the published risk assessment background to the Australian values, hv to admire the frankness of their tech. details although they are often only briefly posted from memory. Some of their published detailed risk analyses are also minor masterpieces IMO. I suspect a close look at the (combined) anzfa data will show a significant dilution of the 1995 figures. I might be wrong of course.

As another example of what I regard as a positive understanding of sampling / assessment limitations, I always admired the Canadian system where the importer has an automatic option of requesting a resampling of a lot and a joint "observation" by a supplier's representative. Having once had a whole container load (not to Canada) of valuable product rejected / destroyed due to one (suspiciously) outlier datum for a factor (Staph.aureus) falling 10pct outside a "M" limit can make you quite sceptical, especially when no recourse is possible. All these aspects are examined in detail in the various ICMSF presentations. The factors involved are also re-stated quite emphatically (and warningly) in the much-quoted Codex hygiene document. This whole regulatory issue can become even more risk complex when "species" like Non Cholera Vibrios are involved, it is understandable that authorities often initially rush to the Precautionary Principle. Unfortunately "initially" can sometimes become a standardised result if unchallenged.

Rgds / Charles.C

[Tony-C]

Dear Tony,
Unfortunately I hv to agree and disagree with this bold statement. Several years ago, FAO published an evaluation of EC area official national import regulations and the conclusion was a huge percentage of the microbiological criteria were simply unjustifiable on (various) technical grounds.
Rgds / Charles.C

Dear Charles

We will agree to disagree. I don't see anything unreasonable in the NZ documents and I have already highlight my concerns with some of the EU limits.

Of course limits should be HACCP based but a lot of HACCP validation comes from such regulatory requirements.

I understand your point regarding rejected loads, I used to put SMP and Butter in 20 tonne lots into Intervention. 1 sample failure led to rejection. Also I had one customer, that shall remain nameless, that rejected three 20 tonne tankers of powder in a row for high TVC's. On investigation we found nothing wrong. Eventually they owned up to using the wrong dilution factor and were reporting results 1000 times higher than actual.

Regards

Tony

[AS NUR]

thanks arya and simon.. thats great doc.

[Charles.C]

Dear Arya,

I am no authority on the anzfa maze of regulatory criteria but this link appears to be the nearest current prime one which I could find (I daresay you've seen it already ).

http://www.nzfsa.gov...which-micro.htm

No problem for anyone to further update/corrrect me. Various caveats as to which anzfa countries are in accordance with these documents and their separate relevance to imported goods is occasionally visible. Another reason to be cautious about current info.when using. BTW, I noticed this fascinating text in yr link –

In this user guide, the ‘old Code’ means Volume 1 of the Food Standards Code (the
Australian Food Standards Code). The ‘new Code’ means Volume 2 of the Food
Standards Code (the Australia New Zealand Food Standards Code). The ‘New Zealand
regulations’ means the New Zealand Food Regulations 1984.
In adopting the new Code in November 2000, the ministerial council agreed to a two-year
transition period. After this, the new Code will replace both the old Code and the New
Zealand regulations.
During this two-year phase-in period, foods in Australia may comply with either the old Code
or the new Code (but not a combination of these). In New Zealand, foods may comply with
the old Code or the new Code or the New Zealand regulations (but not a combination of
these).
After this, the old Code and New Zealand regulations will be repealed and all food sold in
Australia and New Zealand will have to comply with the new Code.
The new Code will mean changes in the way manufacturers and retailers make and present
food for sale.
The Australia New Zealand Food Authority (ANZFA) has developed this user guide, in
consultation with Australian and New Zealand government and industry representatives, to
help manufacturers and retailers interpret and apply Standard 1.6.1 – Microbiological Limits
for Food in the new Code. The guide may also be used by food officers to help interpret food
standards in the new Code.
This user guide, unlike the standard itself, is not legally binding. If in any doubt about
interpreting the standards, you should seek independent legal advice.
As well as complying with food standards requirements, you must also continue to comply
with other legislation. In Australia, this legislation includes the Trade Practices Act 1974, the
Imported Food Control Act 1992, and State and Territory Fair Trading Acts and Food Acts.
In New Zealand, this legislation includes the Food Act 1981 and Fair Trading Act 1986.

All very clear !


In the top link, Paragraph 2 is Simon’s link; 1,3,4 all seem to be identical links ! These are all referenced to be 2001 as you say but in fact there is a (strangely undated??) revision number on the individual section contents. After all, science does change it’s mind occasionally. An ingeniously evasive presentation. It is the up-to-date current search for specific items which often tends to be the hardest IMEX. Not sure about present methodology but the data (for Australia) tended to be split into two levels (again, the regulations for imports are probably different) – (a) a fully implemented official set (I guess equivalent to the one referenced in above link as revision 103 and (b) a subset of additional “guidelines” (and products perhaps) which were utilised in “certain” other situations. I think set (b) also used to be published online somewhere but currently I don’t know, sorry. Additionally, various excellent, detailed stakeholder risk evaluations hv been carried out on many of these mic.criteria for a wide range of products but often only appear for a short time to enable comments / updates (there is another section on the site somewhere which groups these documents, some searching is required). A superb parallel set of mic. procedures is also issued by anzfa but unfortunately not for free (many libraries stock them).

As you can see, the 1995 document tried to generalise criteria for items like RTE foods etc but if you look into the lower details you will see the problem illustrated, eg compare spc for 5.8, 5.23c, and 5.26d.

The above main link also contains an interesting RTE, guideline sub link which appears to be based on the UK/RTE regulations (ca 2000) –

http://www.foodstand.....icro exam.pdf


Nowadays, I think only product- by -product mic. limits are presented. If you compare the 1995 / “2001” data, can see that a considerable reduction in the number of parameters is also occurring, this is analogous to the EC trend. Unfortunately, IMEX, buyers often do not suscribe to this lean philosophy.

Have only touched the aspect of mic. criteria here but space/time does not permit much more. Personally, I wud still recommend an initial perusal of the ICMSF books on this subject, they start from 1986 but a huge amount of their comments are still current and very readable. A considerable quantity of Books 1 and 2 is now on the net if you can find it (also linked on this site, somewhere).

Rgds / Charles.C


added - as an example of (presumably) post 2001 studies, can see this article on a large project published in 2003 (was probably once available on anzfa website but I think no longer) -
Food Control
Volume 14, Issue 6, September 2003, Pages 391-398
Australia New Zealand Food Standards Code
Review of the microbiological standards for foods
Purchase the full-text article
Sally K. Hasella and Mark A. Salter
(a New Zealand Milk, b Food Standards Australia New Zealand)
abstract -

A significant component of the review of the Australian Food Standards Code and the development of joint food standards with New Zealand was the review of microbiological criteria. The outcome of the review was the retention of a number of standards where qualitative risk assessments supported their continuation. Other standards were withdrawn because they could not be justified as supporting a public health objective, being more relevant to quality and spoilage issues. However some new standards were adopted and an additional category of microbiological guidelines was developed to assist with the identification of food not being produced in a satisfactory manner. Work from the review is still ongoing including more quantitative risk assessments being undertaken, such as for Listeria monocytogenes

[Tony-C]

Dear Arya,

I am no authority on the anzfa maze of regulatory criteria but this link appears to be the nearest current prime one which I could find (I daresay you've seen it already ).

http://www.nzfsa.gov...which-micro.htm


The above main link also contains an interesting RTE, guideline sub link which appears to be based on the UK/RTE regulations (ca 2000) –

http://www.foodstand.....icro exam.pdf

Rgds / Charles.C

Hi Charles

Only the NZ links on your first link page work.

The second link doesn't work.

Do you have another link to the documents you're refering to?

Thanks

Tony

[Charles.C]

Hi Tony,

I'm bit confused. All the links seem to work for me. My posted 2nd link is actually on the page of my 1st link under "Guidance" section - there are 4 links numbered 1,2,1,2 respectively, I copied the 3rd one. Hv deleted my original posted 2nd link and repeated the exercise, can you try gain ?

Rgds / Charles.C

added - perhaps my english was unclear , my posted 2nd link was not to the UK document (this is linked here in various places) but, as noted above, just a re-statement of one of the links contained in my top posted link. Any clearer ? If you were seeking the UK document link, I can dig it up but you probably know it already ?

[Tony-C]

Hi Charles

That works now. Thanks for sorting that out.

Regards,

Tony

[a_andhika]

Nicely put there Charles, I have no chance on arguing that (and probably the authors too).

Hummm, but I wonder, why Yeast/Mold standard was seldom mentioned on the micro references? Coz not a pathogenic or serious one?


Regards,

Arya

[Tony-C]

Hummm, but I wonder, why Yeast/Mold standard was seldom mentioned on the micro references? Coz not a pathogenic or serious one?
Regards,
Arya

Some moulds are pathogenic but this is probably viewed as being covered off by the legal limits for mycotoxin and aflatoxin levels.

Regards,

Tony

[a_andhika]

Some moulds are pathogenic but this is probably viewed as being covered off by the legal limits for mycotoxin and aflatoxin levels.

Regards,

Tony

Good point. However, if the mould content in a RTE food is quite high -lets say more than 1.0^3- but the level of mycotoxins and aflatoxins are low, can we assured that the RTE food is safe?


Regards,

Arya

[Simon]

Wow I'm really please that document I posted created so much great discussion.

[Lexter Cruz]

Good Morning to everyone!

 

First of all i want to extend my apology for posting this question if this question should not be posted in this topic area.

Currently we are implementing volume check for every batch of prepared diluent and liquid right after sterilization process. I admit that we use this to monitor the efficiency and performance of our autoclave and for validation purposes of prepared diluent and liquid media.

Now i want to know is if there is a scientific of more establish basis for setting up the tolerance + or - volume of a diluent or liquid media after sterilization.

Can any one give me link and or scientific basis for the given tolerance.

 

Thanks and more power!