Hi David,
You may be interested in these (2016) comments from the FSAI’s RTE Foods Microbiological Guidelines in which they have taken issue with the HPA’s Guidelines (vis-a-vis EC) for various Micro. Species/Groups/Food Categories –
(Extracted from Introduction)
While the Food SafetyAuthority of Ireland’s (FSAI’s) Scientific Committee endorsed the use of the UK’s 2009 guidelines, they also provided a Scientific Opinion (Appendix 2) on the appropriate microbiological guidelines to set for coagulase-positive staphylococci, E. coli and Enterobacteriaceae, for which there was a discrepancy between guideline limits set in the first edition of Guidance Note No.3 and in the UK document, and legal process hygiene criteria set in Commission Regulation (EC) No 2073/2005, as amended.
(Extracted from Scientific Opinion)
3. Enterobacteriaceae
Discrepancy: Guideline limits for ready-to-eat foods sampled at point-of-sale [ie HPA] are considerably more lenient than the legal limits applicable during manufacturing [ie EC] for six categories of food (Table 5).
1. Pasteurised milk and other pasteurised liquid dairy products (food category: 2.2.1)
Etc
Question: Is it appropriate to set Enterobacteriaceae guidelines for the six food lists and if yes, what should these guidelines be?
Proposed answer: No.
Limits for Enterobacteriaceae at retail level should not be set for these six food categories. Enterobacteriaceae are a broad group which can be used to assess the general hygiene status of a food product. Unlike E.coli, Enterobacteriaceae are not a clear indication of faecal contamination and there is no level of Enterobacteriaceae which can be classified as hazardous.
(There is a similar but “inverse” criticism for E.coli, but in this case FSAI have quantitatively modified the HPA values)
FSAI,GN 3 Rev 2, 2016.pdf 291.82KB
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