Coliform limits for frozen product with cream - USA

I doubt you'll find any referance to a specific number...............coliform is usually only used as a sanitation indicator

May depend on what the specific product is, eg -

coliform dairy products.pdf   180.5KB   47 downloads

coliform ice cream.pdf   10.19KB   40 downloads

coliform, ice cream,HK.pdf   13.96KB   26 downloads

May depend on the specific Process, eg -

USA coliforms cream pies.pdf   142.56KB   25 downloads

PS - 10,000 cfu/gram sounds high for coliforms. Can you provide a link ?

These are a pdf version micro -limits ready to eat food there is spec <10.000
Our spec is less than <1000

Perhaps you could provide a link or attach a copy of the reference to 10,000 cfu ?

yr spec seems a lot higher than the figure (50 cfu) in my attachment in Post 6 ?

https://www.ncbi.nlm...ooks/NBK221566/

https://pdfs.semanti...65d405171b1.pdf

Dose FDA or USDA has any limits ? 

https://www.ncbi.nlm...ooks/NBK221566/

 

https://pdfs.semanti...65d405171b1.pdf

 

Dose FDA or USDA has any limits ? 

Hi miniac,

Sorry but I could not see any numerical coliform limits for cream-related products in yr links ?.

What is the specific US name of the Product you seek limits for ? Cream-type pie ? Frozen Dessert ?

Please go on page 166 , and go back to page 165 . Frozen dessert , and on the page 165 you will find that the spec 10(-4)

I enclose a pdf of yr 1st link,

NAP safe food.pdf   6.96MB   26 downloads

pgs 165-166 hv no coliform data.

search for "dessert" has 2 hits = no coliform data.

2nd link (pdf) has no coliform data at all.

But there are not formal spec , dose USA have a formal spec ?

No, the USA does not have a requirement set through FDA or USDA for coliform levels. Also, I think you may be confused on the difference between coliforms and enterobacteriaceae. Enterobacteriaceae is used as an indicator organism for Salmonella, and coliforms are often used as an indicator organism for E coli, and general cleanliness. Many producers and customers in the USA have set a coliform level of 1000 or less or even 10 or less for some RTE products.  

As per Posts 10/6, it may depend on what the Product actually is.

hmm Is that no strange ? that we do not have any set limits in USA ( we all can do validation studies ). 

our spec is less than <1000, however I want increase the limit for 10000 ( but this will be done only under concession 

10,000 CFU/g is very high for an RTE product. I could see some issues with customers rejecting that specification in the United States. 

hmm Is that no strange ? that we do not have any set limits in USA ( we all can do validation studies ). 

our spec is less than <1000, however I want increase the limit for 10000 ( but this will be done only under concession 

Shouldn't you be trying to find ways to lower your specs? Why are you trying to increase them?

I'm not being sarcastic, I'm genuinely curious. 

Look at FDA CFR's standard of identity.  Frozen dairy dessert.

hmm Is that no strange ? that we do not have any set limits in USA ( we all can do validation studies ). 

our spec is less than <1000, however I want increase the limit for 10000 ( but this will be done only under concession 

You are going to be hard pressed to increase it to 10,000 CFU for coliform unless it is considered a "raw product" that will be pasteurized.  Even then, it is suspect.  FDA doesn't have coliform limits, but California State has limits if there is dairy production in that state.  750 CFU is the max for raw milk, which is pretty high in my experience for raw milk.  

https://www.cdfa.ca...._standards.html

A frozen dessert, you really should be targeting less than <10 CFU.  There really should be no reason you have more than that in your product unless you have suspect raw materials, suspect process, and/or suspect GMP's.

If I was your customer I wouldn't accept the 1,000 limit you have now, let alone 10,000....that's a red flag in my opinion.

Hi miniac ,

As I understand yr product (post 5) is "pastries with the cream or custard" (="XYZ"). (Unknown as to whether all baked together or cream added later).

From FDA website -

Definitions:
Frozen desserts—Ice cream, frozen custard, French ice cream, French custard ice cream, frozen dietary dairy dessert, frozen yogurt, dietary frozen dessert or low fat frozen dairy dessert, ice
milk, freezer-made milk shakes, fruit sherbet, water ices, quiescently frozen confections, quiescently frozen dairy confections, whipped cream confections, bisque tortoni, mellorine
frozen desserts, and products which are similar in appearance, odor or taste to the products or are prepared or frozen as such products are customarily prepared or frozen, whether made
with dairy or nondairy products.

The term does not include commonly known or designated bakery products as frozen cakes and pastries, cream pies and fillings and toppings, meringue
pie fillings and toppings, cream and ice box pies, fruit and custard pie fillings, Boston cream pie fillings, cream puff fillings and custards, eclair and Napoleon fillings, and custards or similar
products.

 

FDA - Frozen Dessert Testing Fact Sheet.pdf   403.54KB   19 downloads

I deduce XYZ is not a "Frozen dessert (FD)" ?

The micro. requirement for FD is given as -

Test Standards:
Standard Plate Count, or SPC, shall not exceed 50,000 cfu/gm (cultured product is exempt)  
Coliform Group Count shall not exceed 10 cfu/gm except in product to which fruit, nuts or
bulky flavor is added after pasteurization when the count may not exceed 20 cfu/gm

 

However It appears there is no official FDA Standard for your product,  "XYZ".

The debate over appropriate Coliform levels for XYZ seems to have a long history.

You can indeed find historical support for a coliform (rejection) limit of 10,000 cfu/gram, eg ICMSF,1982)/IFST,1997 (attached, cfp1,cfp2) but  I anticipate such proposals for currently discussed  products are obsolete. (the limit is also discussed in attachment cfp4).

cfp1 - sampling-testing of foods, ICMSF,Clark,1982.pdf   510.8KB   12 downloads

cfp2 - micro.criteria for foods,IFST,1997,Stannard.pdf   2.59MB   14 downloads

The most comprehensive review of US commercial cream filled pastries I could find (which included coliform data) is also old (1976)(attached, cfp3) and supported the (much lower) proposed limit (50cfu/gram) in my post 6.

cfp3 - Cream filled pastries, USA,,Bryan,1976.pdf   823.87KB   12 downloads

This limit afaik was never generally implemented probably for reasons such as noted in this later Canadian review (1983)(attached,cfp4) -

The m values [50,000/50] for ACC and coliforms are based on the microbial limits proposed by the Food and Drug Administration (1,12), that were later withdrawn because of industry pressure (2,3,4), but are consistent with desirable manufacturing practices.

cfp4 - cream-type pies, Canada,Todd,1982.pdf   386.85KB   13 downloads

It's not my Product area but the "general" impression I get is that the coliform level should, maximally, be <100 cfu/gram for cream filled items as being discussed. This is a GMP "limit".

So I suggest you exercise caution over increasing any limit over 1000 cfu/gram which already looks to be on the high end.

PS - above was posted before I saw Ryan's Post.

To be, or not to be, a Frozen Dessert. That is the Question.  :smile:

Our coliform specs (for our liquid milk plant and dry milk powder plant) are set by the Pasteurized Milk Ordinance (PMO) for our state. You can find your PMO on your state's Department of Agriculture website.  

Our coliform specs (for our liquid milk plant and dry milk powder plant) are set by the Pasteurized Milk Ordinance (PMO) for our state. You can find your PMO on your state's Department of Agriculture website.  

I'm not sure if the above is relevant but thanks anyway.

I guess a coliform spec for whipped cream might be relevant.