- Are ready meals really the same as ready to eat products?
I would argue definitely not - if they require cooking/heating then they are not "ready to eat" in the form you're manufacturing them. The purposes of most of the guidelines on micro for ready to eat foods is that these define acceptable micro limits for immediate consumption with no further preparation by the consumer.
- Should they be heated as per instructions before analysis?
Probably as part of your general validation and for some ongoing verification, but whether this is necessary for every batch is something that you'll need to determine. I'd suggest that your microbiological limits should be established for the "raw" product prior to heating, as these will need to take into account the subsequent microbiological growth that will occur over the shelf life of the product, such that it's still safe (and organoleptically acceptable) when the consumer cooks it according to the recommended instructions even on the last day of life.
- IF the results are high what is the fail criteria?
You're probably going to have to determine this based on the specific nature of your product, expected shelf life etc. Some organisms can readily be killed, some could form toxins that are thermally stable under the expected cooking conditions - it will depend on what your product is/isn't vulnerable to.
We have looked through numerous versions of the UK and Irish guidelines only to not have our questions answered. They suggest that a ready meal is a ready to eat product and should be tested after regeneration. I took this to mean cooking while other colleagues did not.
I have spoken to the lab we use and they don't heat products before analysis and don't have the facilities to do so.
You may be able to find a lab that can do this, but I understand their nervousness to an extent - it's may not be part of their standard methods and thus potentially also outside the scope of their UKAS accreditation, so a test that is normally accredited may not be for this. They may also genuinely not have the facilities, so as Scampi noted, try a few other labs perhaps.
We have also spoken to our local EHO whom said they would suggest the meals should be heated prior to analysis but didn't want to advise either way as that would be up to the lab.
The lab is just a service provider - it is (sometimes unfortunately!) up to us as food businesses to define the service we require from them.
My question is
- Should ready meals in your opinion be heated prior to analysis? If so is this standard lab practice?
I agree with Scampi (this is becoming a common statement!) - you should be doing at least some analysis post-cook if for no other reason than to check the cooking instructions work, but I personally think that you should also be doing routine analysis on uncooked product and have a specification in place for this, since this is what defines the product that you're physically producing.
It may also be the case that cooking could "hide" things that aren't a problem at point of production, but could multiply during shelf life to potentially become problematic.
- If the the counts are higher than >105, which is deemed unacceptable is this a fail?
Unfortunately this is another area that really only your business can define. It is difficult to be specific on this since we don't know the product or what the 105 count is - TVC would obviously be less concerning than B. cereus! Whatever it is, I'd assume that the number is only going to go up through the shelf life.
Thanks in advance for any advice you can provide.