Dear All,
Maybe you guys are already exhausted with this topic however being somewhat microbiologically inclined I did some more digging into what is in truth the culmination of many years of EU's considerings on this subject (you can see my micro.crit. thread upload if you are historically interested, nudge, nudge). Presumably UK readers will know this finalised 2006 rule actually goes back textually to at least 2004 (EC No. 852/2004).
Other than the EU 2006 regulation itself, one key link is -
EXPLANATORY MEMORANDUM TO THE FOOD HYGIENE (ENGLAND) REGULATIONS 2006
http://www.opsi.gov....20060014_en.pdf
This gives a (long) summary of the justifications for the changes -
Some of the stated benefit is here -
5.3 If the microbiological criteria are considered as an integral part of a HACCP based system, then it is possible to equate the benefit of the Microbiological Criteria Regulation with that of the food hygiene legislation. This work has shown that the precise effect the new proposals, including the food hygiene legislation, would have on the level of food poisoning is difficult to predict or to measure, but work carried out on behalf of the Agency provides some information. Work undertaken by a consultant economist on Indigenous Foodborne Disease (IFD) in England and Wales, found that the estimated total cost in 2000 was £1,366 million. This comprised the basic costs to the health service, loss of earnings etc. of £164 million, and costs of pain, grief and suffering of £1,202 million. When applied to the UK as a whole, these figures indicated costs of £1,534 million per year. Therefore, even a further minimal incremental reduction in the incidence of foodborne illness of between 1% and 5% would result in further benefits in the region of £15.3 million to £76.5 million per year. This work indicates that benefits are likely to build up cumulatively over a number of years as both business and enforcement authorities improve the way in which the regulations are applied and checked. Any resulting improvement in food safety management will mean that the overall food hygiene position would be improved and the incidence of disease should improve as a consequence of this. An indicative figure of 3% was included in the regulatory impact assessment 13for the purpose of the cost/benefit analysis. This figure would seem reasonable set against the confirmed reduction (in the number of laboratory-reported cases of the five foodborne disease pathogens monitored) of 15% seen in the first three years of the Agency's Foodborne Disease Strategy, (2000-2003).
Costs are given in another link -
http://www.food.gov....2004riafull.pdf
'The main costs of the new regulations will be due to the extension of the last two principles of HACCP, verification and documentation, in catering and retail industry. Currently these businesses are only required to implement the first five principles of HACCP including identifying potential hazards and measures for their control, determining critical control points (CCP), establishing critical limits for each CCP, establishing a monitoring system and establishing corrective actions when monitoring indicated any CCP is not controlled.
A commissioned study of the cost of implementing the last two principles of HACCP in the retail and catering sectors estimates that the set up costs are very small. The running costs of verification and documentation are estimated at £96 million each year. Year one costs amount to £132 million.'
(details are given and the result is 'The break-even point, when costs are equal to benefits is after about five years.')
Note - presumably "validation" is understood. 
This does appear to be saying that a lot of HACCP should have been in motion already across the board (as also indicated in Annex F this document), I'm not sure if this applied to the pie shop et al ?. Would have been useful to see the same detail in the costs as for the benefits. A suggestion that perhaps HACCP had not happened so uniformly in practice is in the later part of the previous link -
7.2 It is anticipated that the greatest additional costs to food businesses will be associated with the introduction and implementation of a risk based approach to food safety management, e.g. procedures based on HACCP principles or GHP as required by the EU food hygiene legislation. Many businesses are already testing products as part of current EU legislation, because of specifications from customers or as part of industry specific guidelines and standards. It is expected that the new legislation will have a greater financial burden on small and medium sized businesses that might not have an established food safety management plan. However, the Regulation is flexible in its approach in terms of the sampling and testing frequency, permitting alternative methods and means to demonstrate compliance depending upon the local risk. The introduction of the Regulation will also complement other Agency initiatives such as those designed to assist small businesses in complying with Regulation (EC) No 852/2004 through the production of Agency guidance. These initiatives have been developed to allow businesses to manage food safety and protect consumers whilst at the same time avoiding unnecessary burdens on business. Whilst assistance is planned for these businesses, there remain additional financial implications to ensure understanding and compliance.
There are comments in various positions that detailed microbiological testing may not be mandated if certain conditions are fulfilled and this is re-stated / amplified in this CFA guide -
The Micro Criteria Regulation - what does it all mean to manufacturers?
http://www.chilledfo...1055_101CMS.ppt.
However it seems possible to me that the essential 'prerequisite Principles' were perhaps not yet implemented at the pieshop (amongst others also perhaps) so there was no way out except the full system startup + micro.testing. I have some reservations that these products are as completely straightforward as we are saying in that they are RTE after all so that post-process contamination / temperature control is not inevitably non-trivial IMO (not to mention left-overs) although I think Martin did say that the visible conditions were excellent. I also do believe that such pies have a good track record.
One wonders if such small-enterprise demises will occur in significant numbers in 2006.
Rgds / Charles.C
PS the analysis cost of salmonella testing is also detailed in first link (claimed max BP10??) but I thought there was quite enough content already. 
added - one significant omission that I should have included is that I saw no explanation at all for the choice of level of microbiological testing, this step remains a mystery. I'm surprised nobody seems to have vocally questioned this aspect (perhaps they have but internally as in 3rd link above).
(after some further thought, the selection of pathogens as such is probably unavoidable from a legalistic point of view if one is to make a decision for specific safety reasons however the sample size / frequency remains arbitrary and, for the values used, if negative proves what ?)
Edited by Charles.C, 26 September 2006 - 05:40 PM.
