Analysis of Submissions: Proposal for a New Zealand Standard for the Production of Uncooked Comminuted Fermented Meat (UCFM)

Analysis of Submissions: Proposal for a New Zealand Standard for the Production of UCFM

No.

Clause

Submission comment¹

NZFSA Response

Discussion document

Part 2

Background

1

We agree that the group of operators that present the greatest concern of uncontrolled UCFM production will be those registered under the Food Hygiene Regulations, but believe that there are also a number of small backyard operators who are currently not registered at all. Virtually all of this product is not sold through normal retail channels, but is sold via craft stalls, car boot sales, etc.

Given that the risk associated with these operators is likely to be equal too or even greater than those operators who are currently registered under the Food Hygiene Regulations, we are unsure how is it proposed to monitor and control these activities, even if a standard for production of UCFM is imposed.

It is illegal to trade homekill and recreational catch.

The Animal Products Act 1999 specifically prohibits the selling or trading of homekilled and recreationally caught meat, such as wild game animals. As these are not subject to any standards no assurances can be given as to the safety of the product. Further guidance is available at: http://www.nzfsa.govt.nz/animalproducts/publications/manualsguides/homekill/homekill.pdf

NZFSA’s Compliance and Investigation Group maintains oversight over the domestic food supply, in addition to the groundwork still carried out by Health Protection Officers (HPOs) employed by district health boards, and Environmental Health Officers (EHOs), with action taken on complaints and in relation to compliance and enforcement.

4

NZPIB fully supports the development of a standard for the production of uncooked comminuted, fermented meat (UCFM) based on risk management principles. As this category of product is uncooked it represents a high risk category if there are not adequate process and input controls in place for shiga toxin-producing Escherichia coli (STEC) organisms. We believe that the development of a standard is an appropriate approach to assure the production of safe UCFM by responsible operators.

1. We fully support that such a standard, if implemented will be enabled by law under both the Food Act 1981 and the Animal Products Act 1999. However we are unsure if this regulatory approach will actually impact on all current production of UCFM products, as we are aware that there is ‘craft’ production of these products. Some of these ‘craft’ producers may not even be registered under the Food Hygiene Regulations. Is NZFSA aware of ‘craft’ production, and how does it envisage educating and ensuring compliance among ‘craft’ producers in the short term? How will ‘craft’ producers fit in under the proposed Domestic Food Review?

2. NZFSA would be aware of the level of attention the New Zealand pork industry has afforded to the safe production of UCFM over recent years. Among other things the industry has considerable experience with the application of predictive modelling techniques and also challenge studies. NZPIB was actively involved in the application of the Tom Ross model with UCFM processors and was involved in the set up and evaluation of some of the earlier challenge trials, and standardising a challenge trial protocol. We recommend that NZFSA communicate directly with the PPA in particular to ensure that the proposed standard reflects the current state of knowledge.

3. We are unclear as to the specific meaning of 4. i., and in particular how the recommended good manufacturing practice relates to the proposed standard requiring monitoring and recording of pH and water activity. Is the recommended good manufacturing practice included by way of example of monitoring frequency and end points?

As NZPIB’s role in respect of UCFM is a support one, as covered in the Introduction, we endorse the submissions of the PPA and Retail Meat New Zealand Inc (RMNZ). Each of these submissions considers the review from the experienced perspective of these two key groups in the New Zealand pork, including processed pork supply chain. Our organisations maintain ongoing communications in matters of common concern.

1. It has come to NZFSA’s attention that the possibility of meat entering the food chain at fairs, food stalls and the like from unregulated sources. In response to this NZFSA is working on guidance material to be posted on the website, outlining the requirements, i.e. Source from a registered supplier, always check that your meat supplier is registered as either:

- A meat processor or a Dual Operator Butcher operating a registered Risk Management Plan (RMP); or

- A local butcher registered with their Territorial Authority (TA) or operating a registered Food Safety Programme (FSP).

2. Regulatory requirements in this area will be clarified under the Domestic Food Review.

3. Please note that the box under 4.i.i is guidance only, and is an example of an acceptable way of meeting the requirements of the standard.

Part 3

Current Risk Management Controls

1

Note that it is now Retail Meat New Zealand Inc that facilitates PQIP 07 and works closely with the various industry sectors, not The New Zealand Pork Industry Board as stated.

Noted

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The Pork Industry Board is no longer involved in facilitating PQIP 07. The Pork Processors Association now undertakes this function, and works closely with Retail Meat New Zealand, Pork Industry Board, and other organisations when required.

Noted

Part 4

Risk Management Options

1

We agree with NZFSA that Option 3, a regulatory standard is the most feasible, practical and effective measure to manage the risks associated with production of UCFM.

As outlined above, we are concerned, however, as to how it is proposed to monitor and control the activities of small backyard operators who manufacture UCFM but are currently not registered at all.

It is illegal to trade homekill and recreational catch.

The Animal Products Act 1999 specifically prohibits the selling or trading of homekilled and recreationally caught meat, such as wild game animals. As these are not subject to any standards no assurances can be given as to the safety of the product. Further guidance is available at: http://www.nzfsa.govt.nz/animalproducts/publications/manualsguides/homekill/homekill.pdf

NZFSA’s Compliance and Investigation Group maintains oversight over the domestic food supply, in addition to the groundwork still carried out by Health Protection Officers (HPOs) employed by district health boards, and Environmental Health Officers (EHOs), with action taken on complaints and in relation to compliance and enforcement.

Homekill is outside the scope of regulated product. Persons who use the services of homekill providers do so at their own risk

Part 6

Proposed standard development

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NZFSA has identified the potential risk associated with manufacturing UCFM. This is largely attributed to the lack of understanding by UCFM producers of the controls required to produce safe UCFM products. For this and other reasons, NZFSA are proposing to introduce standards for the processing of UCFM products.

We support NZFSA’s proposal to implement standards for UCFM. Unfortunately, there are two groups of UCFM producers that could potentially undermine the wider goal of rolling out standards for producers of UCFM products.

• As noted above, Dual Operator Butchers can continue to produce UCFM within an unregulated environment. Even though the Proposal suggests that smaller processors of UCFM pose the greater risk to consumers, the Animal Products Act 1999 effectively allows this practice to carry on unabated.

As noted above, if NZFSA are serious about developing standards that ‘protect public health’, then the proposed standards need to be applied consistently across all producers of UCFM.

• The number of farmers markets operating through New Zealand is increasing and this trend is likely to continue. We have no problems with meat and meat products being sold through stalls provided they have approved food safety programmes to do so.

Proposed standards need to also capture this group if stall operators are manufacturing UCFM. As most stall operators are craft businesses, we doubt they are even aware of the potential risk associated with UCFM, and the need to implement standards for UCFM in due course.

The territorial authorities should take a more proactive role in applying Regulations under the Food Act 1981 when it comes to the sale of meat and meat products through farmers markets. Experience to date suggests that the territorial authorities are failing to apply the Food Act in this regard. Given the risks associated with UCFM we would be very concerned if these products were being sold through farmers markets without an approved food safety programme.

UCFM produced within an unregulated environment or through farmers markets can not be overlooked by NZFSA, and should be included within the scope of participants needing to meet the proposed standards being developed for UCFM.

As NZFSA have already noted in the Proposal, New Zealand is vulnerable to a serious outbreak of illness related to the consumption of UCFM which potentially threaten the country’s reputation as a supplier of safe food products. For this reason any operator/person producing UCFM needs to comply with an approved food safety programme

It is illegal to trade homekill and recreational catch.

The Animal Products Act 1999 specifically prohibits the selling or trading of homekilled and recreationally caught meat, such as wild game animals. As these are not subject to any standards no assurances can be given as to the safety of the product. Further guidance is available at: http://www.nzfsa.govt.nz/animalproducts/publications/manualsguides/homekill/homekill.pdf

It has come to NZFSA’s attention that the possibility of meat entering the food chain at fairs, food stalls and the like from unregulated sources. In response to this NZFSA is working on guidance material to be posted on the website, outlining the requirements, i.e. Source from a registered supplier, always check that your meat supplier is registered as either:

• A meat processor or a Dual Operator Butcher operating a registered Risk Management Plan (RMP); or

• A local butcher registered with their Territorial Authority (TA) or operating a registered Food Safety Programme (FSP).

If stall operators are selling meat products then as a minimum they must be operating according to the requirements of their local authority.

5

We are pleased to see the development of such a standard and believe it is the best option of this type of product. We also believe that it is appropriate to base this standard on 1.6.2 Processing Requirements. As the transition period cannot be defined at this stage it may be appropriate to include “Food Control Plan” under 4(b). This would ensure that standard is in line with the direction of the Domestic Food Review should the standard come into force during the transition.

When the new Food Act is promulgated, terminology will change according to any relevant consequential amendments/

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Appendix A – Regulatory Impact Statement and Business Compliance Cost Statement

Regulatory Impact Statement – Industry (Page 21) Point 3.

1

We agree that “if a significant outbreak of illness associated with the consumption of UCFM was to occur, all UCFM producers could be impacted negatively, due to a potential reduction in consumer confidence in, and purchasing of, UCFM products”

We believe that the impact is of such an outbreak is likely to be wider than all UCFM producers, however, given that the “Garibaldi Incident” in Australia not only resulted in a substantial decrease in Mettwurst sales (40% reduction), but also resulted in a reduction in all processed meat sales, affecting the wider meat processing sector.

Noted.

Estimated Compliance Costs

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One-off Costs

Purchase of new equipment

1. The proposal outlines some of the ‘new equipment’ required under the proposed standards. This could represent a considerable investment for some operations. For instance we have been advised that the water activity meter is extremely expensive – upwards of $5,200.

One of the goals of the Domestic Food Review is to keep compliance cost down wherever possible. We would hope the same logic applies for the UCFM standards, and that NZFSA is open to considering other equivalent testing methods on the basis of good science.

Staff training/competency

2. What is NZFSA’s expectation of the kind of training that would be required by the staff?

Most butchers operating within New Zealand have completed a National Certificate in Meat Retailing, or a Trade Certificate. These include food safety based unit standards/qualifications.

Apart from food safety related unit standards/qualifications, what other types of training would staff be required to complete, if at all?

Ongoing Costs

Microbiological Testing

3. There is reference to Microbiological Testing, but no indication of how often producers are expected to undertake ongoing microbiological testing as part of the verification process. On what basis will this be determined? Will industry be invited to make comment?

Staff training/competency

4. As stated above we are unsure what additional, ongoing staff training/competency skills would be required by NZFSA. Once a person has completed a unit standard/qualification, they are qualified. They can’t be retrained in qualifications that they have already achieved. Further clarification and consultation is needed in respect of ongoing staff training/competency.

1. Agree – water activity meters are expensive, but the standard does not require every batch to be tested for water activity, only that the process is validated via water activity (by testing on-site or otherwise), and also allows for equivalence to water activity to be used, ie weight loss over time, or oven drying.

2. Training requirements will be aligned with those developed under the Domestic Food Review.

3. Specific training courses have not been decided upon.

4. The standard states 4d(i) “the frequency of checks is to be determined by the manufacturing company”

5. Therefore the operator will determine a testing frequency which will be reviewed by NZFSA upon submission of the RMP or FSP.

6. Training requirements haven’t been detailed, however ongoing training will relate to new staff entering the business and the requirements for refresher courses where necessary.

Draft New Zealand standard for the production of uncooked comminuted, fermented meat

Part 4

Standards for processing UCFM

2&3

c. ii. & iii.

In determining the Escherichia coli count of ingoing meat into UCFM production, ‘adequate data’ needs to be collected. The amount of data required to be collected has not been identified and we seek clarification on how this will be determined

This is volume dependant and is up to the operator to determine an appropriate testing level.

NZFSA proposes producing guidance to clarify this requirement.

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d. i.

Under this section ‘frequency of checks is to be determined by the manufacturing company’. We are not against this, but we wish to know how this would be actually determined and on the basis of what science

It was decided against mandating minimum testing limits as this would put too greater requirement on small manufacturers.

NZFSA will look into what guidance can be provided to clarify this requirement.

1

e

Point e states “Validation may be achieved by the use of predictive modelling or challenge studies”.

While we support the use of predictive modelling as an indicative tool for validation, we believe that there needs to be standardisation of the predictive model used, for example, Tom Ross Model, to ensure that there is consistency in the predictive outcomes being generated.

Our experience with the use of predictive modelling shows that there are some limitations in accuracy of the predicted outcomes, particularly where products of different diameters are produced, for example biersticks vs slicing sticks.

We believe therefore, that challenge trials are the most accurate method of validation of the process, and as such, we support this as the preferred method of validation.

Noted.

The manufacturer will be given the option to use the most appropriate tool in validating the process.

2&3

i. i.

The standards recommend that water and pH be tested every 12 hours over the first 48 hours. The critical control point for salamis in the Tom Ross Model, which has been used in the past, is to reach a pH of <5.3 in 72 hours and have a final pH and aW of 5 and 0.95 respectively.

On the basis of this we question the relevance of testing 12 hourly, particularly if NZFSA have no criteria for pH and aW on what is to be achieved in each 12 hour period.

This box illustrates one acceptable means in meeting the requirement of the standard, other means may be employed if there is sufficient justification.