5 replies to this topic

[kianhoe1130]

Hi guys, i have question regarding on setting a microbiological limit for my company new products.

 

Product criteria
- Marinade powder (mix of dry spice, salt, starch and flour)

- Not RTE (need to be cooked after marinade)

- can be use as wet marinade or wet rubs (for preparations, marinade powder must mix with liquid before apply to the food)

- Product is store in room temperature, shelf life around 1 to 2 year

 

I did not find any regulations that have similar category for our products (maybe i mislook). My concern is that our company want to make sure our products is safe for consumers. So is there any suggestion or opinion on setting the limit for microbe? Does we need to set microbe limit based on the supplier raw material specification (microbe limit)? 

 

 

[Tony-C]

Hi kianhoe1130,

 

 

Welcome to the IFSQN forums.

 

You should certainly consider raw material specifications when establishing a micro limit. What micro results are you getting on your product?

 

Regarding published limits, first of all you need to consider relevant legislation in your country of manufacture and sale.

 

If there is nothing relevant then refer to CODEX Guidelines/Standards:

Codex Committee on Spices and Culinary Herbs (CCSCH) - Related Standards

PRINCIPLES AND GUIDELINES FOR THE ESTABLISHMENT AND APPLICATION OF MICROBIOLOGICAL CRITERIA RELATED TO FOODS

 

Failing that look at relevant published research/technical information such as:

The microbiological quality of commercial herb and spice preparations used in the formulation of a chicken supreme ready meal and microbial survival following a simulated industrial heating process

‘As shown in this study, subjecting these condiments to heat processing treatments typically applied during manufacture of chilled ready meals, may not inactivate certain microbial species’

 

I would think that you need to ensure that your customer clearly understand that your product for further processing and this should be included in product specifications and on the product label.

 

Kind regards,

 

Tony

[GMO]

 

I would think that you need to ensure that your customer clearly understand that your product for further processing and this should be included in product specifications and on the product label.

 

 

I came to say the same thing.  There have been various incidents and recalls with products not designed for consumption without cooking then implicated in food safety incidents.  At some point someone might take your lovely seasoning and decide if they mix it with cream cheese it would make an awesome dip!  Not suggesting that you have to account for every incidence of consumer misuse, it may not be possible to do so but for this reason and the fact that how the spices are cooked does greatly impact how readily the pathogen(s) will be killed.  

 

I know that I am UK and EU focused in my outlook and this is not relevant legislation for your market unless you're exporting to the EU but if there is no relevant legislation, the EU organisation called the CBI (Centrum tot Bevordering van de Import uit ontwikkelingslanden or the centre for the promotion of imports from developing countries) has helpfully produced a guide to the likely contaminants and controls for sale of herbs and spices on the EU market.  As a whole the EU is relatively risk averse and preventive in nature so it's possibly not a bad thing to look at.  There are also some helpful links to other documents including codex and "typical" results seen including where failures are most common:

 

What requirements must herbs and spices meet to be allowed on the European market? | CBI

 

Bacterial contaminants

The EU regulation on microbiological criteria for foodstuffs lays down the microbiological criteria for certain micro-organisms and the rules that food business operators need to comply with. It does not set specific limits for herbs and spices.

The most common type of bacterial contaminant in spices and herbs is salmonella. Salmonella must be completely absent in spices and herbs. It is usually transmitted via contaminated irrigation water, manure, hands or animals if products are dried outside. In 2023, more than 17% (43) of all 248 issues reported in the RASFF database related to salmonella. 

Black pepper from Brazil is still the largest contributor to the salmonella issues subgroup, but the number of salmonella issues caused by Brazilian black pepper went down drastically from 45 in 2022 to 20 in 2023. This was largely due to a 36% lower export volume to Germany, which has always been the main country reporting these issues in RASFF. Origin countries for which the number of reports increased substantially were Egypt (from 3 in 2022 to 6 in 2023) and Turkey (from 1 to 5). 

Another relevant contaminant limit for herbs and spices is for Bacillus cereus, which is limited to 100cfu/g. Too high levels have been found several times in recent years, mainly in ground spices.

[kianhoe1130]

You should certainly consider raw material specifications when establishing a micro limit. What micro results are you getting on your product?

 

Hi Tony, thanks for your reply.

 

Below are the micro results that we plan to test and the maximum limit that we hope to achieve:
- Total plate count (max 50,000 cfu/g or maybe higher due to the raw mat supplier specification)

- Coliforms (max 100 cfu/g)

- Yeast and mold (max 1000 cfu/g)

- salmonella (not detected / 25g)

Now, the problem is setting limit for total plate count, according to American Spice Trade Association (ASTA), it state that it is normal for some spice typically have highest aerobic plate count usually in excess of 10^6 cfu/g (some of the raw material specification also fall on this level). At the sametime, the current production step for the marinade products didn't include any heat treatment or lethal step to further control the microbe population. In this cases, how should we set the micro limit, should we first undergo lab test for the products sample and then decide the micro limit based on the result?

[MDaleDDF]

Hi Tony, thanks for your reply.

 

Below are the micro results that we plan to test and the maximum limit that we hope to achieve:
- Total plate count (max 50,000 cfu/g or maybe higher due to the raw mat supplier specification)

- Coliforms (max 100 cfu/g)

- Yeast and mold (max 1000 cfu/g)

- salmonella (not detected / 25g)

Now, the problem is setting limit for total plate count, according to American Spice Trade Association (ASTA), it state that it is normal for some spice typically have highest aerobic plate count usually in excess of 10^6 cfu/g (some of the raw material specification also fall on this level). At the sametime, the current production step for the marinade products didn't include any heat treatment or lethal step to further control the microbe population. In this cases, how should we set the micro limit, should we first undergo lab test for the products sample and then decide the micro limit based on the result?

Those look fine imho.  For a non RTE product.   We make a couple marinades here, and my numbers are higher than that on plate count, off the top of my head.   Never had any blowback from auditors.

As far as customers using it inconsistent with labeling like GMO said, that is a real issue, and people do that for sure, but it is what it is.   As long as your labels are clear it needs to be cooked, you're about as covered as you can be.

[GMO]

 

As far as customers using it inconsistent with labeling like GMO said, that is a real issue, and people do that for sure, but it is what it is.   As long as your labels are clear it needs to be cooked, you're about as covered as you can be.

 

Yep but if you are able to use heat treated spices, I genuinely would.  It reduces the risk of pathogen presence at least.  Even if someone is a bit of a numpty.