8 replies to this topic

[AdamR]

Hi,

 

UK temperature control giudance says that raw meat does not fall under the chill holding requirements (doesn't have to be kept below 8°C) because it's going to be cokked at a later stage which will render it safe to eat.

 

I don't undertand why this is the case, becasue isn't it possible for that raw meat could potentially become contaminated with staph aureus during cutting/eviseration, which could then grow on the raw meat if not kept chilled, producing a toxin which is resistant to cooking temperatures?

Any ideas?  Maybe it's because the raw meat would have such a high bacterial load, that it would be too competetive for S. Aureus to grow?

 

 

[Charles.C]

Hi,

 

UK temperature control giudance says that raw meat does not fall under the chill holding requirements (doesn't have to be kept below 8°C) because it's going to be cokked at a later stage which will render it safe to eat.

 

I don't undertand why this is the case, becasue isn't it possible for that raw meat could potentially become contaminated with staph aureus during cutting/eviseration, which could then grow on the raw meat if not kept chilled, producing a toxin which is resistant to cooking temperatures?

Any ideas?  Maybe it's because the raw meat would have such a high bacterial load, that it would be too competetive for S. Aureus to grow?

 

Dear AdamR,

 

UK temperature control giudance says that raw meat does not fall under the chill holding requirements (doesn't have to be kept below 8°C)

 

Is this in MIG somewhere ?

 

Not my area but I  presume there are nonetheless some control requirements ?

 

You are correct that  S.aureus is typically a poor competitor but it can depend on the particular environment also.

 

Rgds / Charles.C

[AdamR]

It's in the "Guidance for Temperature Control Legislation in the United Kingdom: EC Regulation 852/2004, The Food Hygiene Regulations 2006".

 

I know there are temp requirements for raw meat under Regulation (EC) 853/2004, but retailers are exempt from this.

 

Can't understand the logic behind slaughterhouses etc, needing to control the temp of raw meat, but retailers don't?

[Charles.C]

It's in the "Guidance for Temperature Control Legislation in the United Kingdom: EC Regulation 852/2004, The Food Hygiene Regulations 2006".

 

I know there are temp requirements for raw meat under Regulation (EC) 853/2004, but retailers are exempt from this.

 

Can't understand the logic behind slaughterhouses etc, needing to control the temp of raw meat, but retailers don't?

Dear AdamR,

 

Is this what you meant -

 

IX.5

Raw materials, ingredients, intermediate products and finished products likely to support the reproduction of pathogenic micro-organisms or the formation of toxins are not to be kept at temperatures that might result in a risk to health.  The cold chain is not to be interrupted.  However, limited periods outside temperature control are permitted, to accommodate the practicalities of handling during preparation, transport, storage, display and service of food, provided that it does not result in a risk to health.  Food businesses manufacturing, handling and wrapping processed foodstuffs are to have suitable rooms, large enough for the separate storage of raw materials from processed material and sufficient separate refrigerated storage.

 

 

Does it say retailers are exempt from control somewhere ? Or did you mean this -

 

(10)   Food hazards present at the level of primary production should be identified and adequately controlled to ensure the achievement of the objectives of this Regulation.  However, in the case of the direct supply of small quantities of primary products, by the food business operator producing them, to the final consumer or to a local retail establishment, it is appropriate to protect public health through national law, in particular because of the close relationship between the producer and the consumer.

 

 

 

(actually my search engine did not find the word "meat" in the regulation anywhere. Hard to believe. )

 

Rgds / Charles.C

[AdamR]

Hi,

 

This is the section of the guidance document:

 

"Exemptions from Chill Control Requirements

 

iv. Raw food intended for further processing (including cooking) where the

 

processing will ensure that the food is fit for human consumption.

Some foods may support the growth of pathogenic micro-organisms or the

formation of toxins, but this will have no adverse consequences for human

health for products that will be thoroughly cooked or otherwise processed

before consumption. Fresh meat and fish would fall into this category unless

it is intended to be eaten raw, for example as steak tartare, carpaccio, or

sushi, when it would not be exempt from the 8°C requirement."

 

??

[Charles.C]

Hi,

 

This is the section of the guidance document:

 

"Exemptions from Chill Control Requirements

 

iv. Raw food intended for further processing (including cooking) where the

 

processing will ensure that the food is fit for human consumption.

Some foods may support the growth of pathogenic micro-organisms or the

formation of toxins, but this will have no adverse consequences for human

health for products that will be thoroughly cooked or otherwise processed

before consumption. Fresh meat and fish would fall into this category unless

it is intended to be eaten raw, for example as steak tartare, carpaccio, or

sushi, when it would not be exempt from the 8°C requirement."

 

??

Dear AdamR,

 

Thks for the input. Do you hv a link ? The above Guidance quote looks rather  different to the FSA (2007) Guidance document I found (maybe there is a later revision   ) -

 

The temperature of a food may "result in a risk to health" where temperature control is critical to the safety of food. For example, chill holding will not be a requirement where perishable food has been subject to a process that makes is safe to hold at ambient temperatures, e.g. types of canning. Nor will it be a requirement where raw food will be cooked at a later stage to ensure it is fit for human consumption. An exception will be where it is necessary to comply with product specific hygiene regulations that set out specific temperatures at various stages of the food chain, e.g. for some raw meat.

 

 

This is, legalistically, a rather complex subject IMO. It is also possible IMO that some textual formats could be seriously misinterpreted. Personally i find the text in both the above quotes somewhat questionable, probably due to the English phrasing / vagueness rather than by scientific intent.

 

AFAIK, the operationally controlling  primary text in UK is the Food Hygiene (England) Regulations 2006 ?).

 

Relating to exemptions, FHR includes the (more scientifically (?) cautious) text  -

 

(e)   raw food intended for further processing (including cooking) before human consumption,

but  only  if  that  processing,  if  undertaken  correctly,  will  render  that  food  fit  for  human

consumption;

(there is also a considerable body of “legalese” both before and after this extract presumably targeted at further covering backs from a FS, POV).

 

The, "if undertaken correctly" phrase must involve some interesting validation !! Such a caveat was a key aspect in the battle in USA over the safe cooking requirements for hamburgers.

 

By no means disagreeing with your conclusion but it may be necessary to know the detailed interpretation "on the ground" of the formal text. Maybe you already know .

 

For example, another (local) UK Guidance exemption I saw was this one –

 

Raw food intended for further processing (including cooking) which will ensure the food is fit for human consumption:
e.g. fresh meat and fish, except where they are intended to be eaten raw, for example a steak tartar or sushi.

 

 

IMO this could be interpreted as meaning that  "cooking" food in any condition guarantees food safety for the consumer. ?

 

You may recall a quite interesting case involving the (short-lived) display of so-called  “ambient hot-dogs (?)” in the UK not so long ago. This was a kind of related issue overlapping  certain baked goods which have (long established)  special shelf-life permission. The product may well have been "safe" but the text certainly wasn't . There is a substantial thread here discussing this episode and related food oddities.

 

Thks for this interesting starter.

 

Rgds / Charles.C

[AdamR]

Hi,

 

Here's the link for the guidance on the the relevant legislation:

 

http://www.food.gov....ntrolguiduk.pdf

 

It's all a bit confusing!  

[Charles.C]

Hi,

 

Here's the link for the guidance on the the relevant legislation:

 

http://www.food.gov....ntrolguiduk.pdf

 

It's all a bit confusing!  

 

Dear AdamR,

 

Thks for link. AFAIK, this is same FSA (2007) document as I quoted in previous post although I picked a different paragraph (12 as against 34iv).

 

I agree with you that the content is a maze. Some of the sub-paragraphs within a numbered paragraph seem almost self-contradictory to me. Plus the debatable “cooking can repair” type statements as noted in my previous post.

 

Basically the document is attempting to interpret the UK Food Hygiene  Regs (2006)  within the context of the over-riding EC law. It is also trying to specify the necessary “diligence” supporting data if a retailer implements a deviation from the main temperature requirements  and subsequently experiences a problem, ie back-covering.

 

In the general context of yr OP I think para 28 is the Guideline scope –

 

The requirement applies to foods, including raw materials and ingredients, at all stages of preparation, processing, transport, storage and display for sale within the manufacture, retail and catering sectors.

 

 

As you noted, the issue then becomes regarding exemptions.

 

After trudging  through the “Chilled”  paragraphs, I believe that the general tolerance attached to temperature deviations between 8degC and ambient   is (finally) summarised in  FSA’s own Guidance interpretation, para 48,  –

 

The "limited periods" and permitted rises in food temperature for these purposes are not specified in Schedule 4 (the UK Food Safety Regs 2006), but must be consistent with food safety. In normal circumstances, a single limited period of up to two hours outside temperature control is unlikely to be questioned. For longer periods, some justification and a hazard analysis based on the HACCP principles may be expected.

 

 

“Consistent” probably refers to all the textual caveats previously stated, eg in paras 32-47, and 49.  The temperature / time tolerance  looks conceptually similar to the 4hour/2hour rule as implemented in Australia and variations of which can be found elsewhere, (I think). The logic is detailed in this attachment –

 

 the 4 hour-2 hour rule.pdf   499.25KB   72 downloads

 

Rgds / Charles.C

 

PS - Predictably, the USA looks to be a bit tougher in case of a power outage -

http://www.foodsafet...fridg_food.html

[AdamR]

Thanks for that Charles.  Makes a bit more sense now.