UPDATE - FSA Guidance on CI Botulinum & Vac Packed Meat
VACUUM PACKING GUIDANCE REGARDING NON-PROTEOLYTIC CLOSTRIDIUM BOTULINUM
As mentioned in the updates last Friday (11th December) FSA has revised and reissued their guidance for C botulinum in vac packed and modified atmosphere packed foods.
The headlines from the guidance and press release are:
The guidance has been revised in December 2020 to no longer apply to VP/MAP chilled fresh beef, lamb and pork only*, as described in the section Chilled fresh beef, lamb and pork. The guidance explains that if a food business chooses to apply the guidance for chilled fresh beef, lamb and pork a 13 day maximum shelf-life may be applied.
*Fresh beef, lamb or pork which is without added ingredients or further processing beyond cutting, packing, chilling, freezing and quick-freezing.
This guidance does apply to any beef, lamb or pork that is further processed such as minced**, cooked or mixed with any other ingredients such as herbs, spices or curing salts.
**Your minced meat temperatures should be within the legal limits – which are 2°C for fresh, and -18°C for frozen anyway.
In 2020 the FSA/FSS undertook a review of available evidence on the shelf-life of VP/MAP chilled fresh beef, lamb and pork and concluded that it was not proportionate to continue to specifically reference VP/MAP chilled fresh beef, lamb and pork in the guidance on non-proteolytic C. botulinum. The research and evidence review did not identify any report of an outbreak of foodborne botulism linked to VP/MAP chilled fresh beef, lamb and pork over several decades either in the UK, including before the guidance was issued, or internationally.
The FSA’s review of the best practice guidance, which aims to reduce the risk of foodborne botulism, found no evidence of outbreaks related to these products globally.
So it seems that, despite fresh meat not being covered by the guidance, it contains an awful lot of information on fresh meat!
Now, here is the paragraph that doesn’t seem to make much sense:
FBOs producing the specific VP/MAP chilled fresh beef, lamb and pork which is outside the scope of this guidance will be responsible for identifying and applying a safe shelf-life in relation to non-proteolytic C. botulinum in line with their existing food safety management systems, in the same way they do for other types of food.
They then go on to reference two very specific papers that go into detail regarding setting shelf lives for all chilled foods in relation to C botulinum. This appears to be a paradox, as they have already said that there have been no reports of outbreaks of foodborne botulism linked to VP fresh meat.
Even if you did follow that process, challenge testing rears its head – and this would, in theory, mean inoculating the product with the bacterium that produces the deadliest toxin known to man, or screening for it, neither of which we would be recommending!
So, it is our combined view that, provided all your regular shelf life testing is in order, that, on the FSA’s own acknowledgement that there have not been any recorded outbreaks of foodborne botulism linked to fresh meat, you can consider the risk (that is the likelihood of botulism happening against the seriousness of it if it did happen) as zero – as it is not likely to happen.
Job done, move on – let’s see what the next problem we have to face is.
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Finally, after FOUR long years, FSA have capitulated and admitted that guidance that they put in place, without being able to explain WHY they put it in place as there was no discernible risk in the first place, needs to be withdrawn.
The bottom line here is that the 3°C or 10 days guidance for vac-packed fresh meat that kicked off some of the most risk-averse and business-crippling enforcement by FSA staff in their history, especially in cutting plants and wholesalers, is in the bin.
It led to customers and businesses further down the supply chain insisting on the same even though you never had issues with the shelf lives you were putting on your product, as well as public humiliation of some very reputable businesses, and the elevation of some of the proponents of the bullying enforcement to even higher positions in the Agency.
The cost of complying to that guidance at all stages of the food chain, whether it be on-costs, or direct losses, is incalculable, and no doubt runs into hundreds of millions, at no cost to the FSA.
They are saying in the press release that the change applies now, but they are also advising that the new guidance (which we assume will be based on your own current food safety management systems) will be issued next week.
We’ll let you know as soon as we see it…
…and any apology they might issue - but don’t hold your breath on that one!
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