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Proposal for a New Zealand Standard for the Production of Uncooked Comminuted, Fermented Meat

2 Background

What are the risks associated with UCFM products?

UCFM products primarily contain beef and pork meat, salt, nitrite, glucose, spices, seasonings, and ideally a starter culture. The ingredients are mixed and comminuted (reduced in size) to produce a “batter”. The mixture is then stuffed into a casing, fermented, dried, and sometimes smoked, to achieve the desired end product. An example of these products is salami.

It has been established that STEC bacteria can be present in the raw meat going into fermented meat products, and although at low levels, the fact that it is there, and that the dose required to cause infection is very low, means it is a problem for New Zealand. These products rely on a reduced pH and water activity for microbial stability and if the required parameters are not met during production the bacteria won’t be controlled and the risk of it being present in the finished product is high.

STEC bacteria are a diverse group of Escherichia coli serotypes, the best known of which are Escherichia coli O157:H7 and Escherichia coli 0111. The clinical consequences of infection may be serious, including kidney and other systemic failures, resulting in long hospitalisations, life-long ongoing illness, and sometimes even death. Between 1998 and 2005, there were between 70 and 100 cases of STEC illness in New Zealand per year (for 2005, the total number of cases (being 92) gave a rate of 2.5 cases/100,000 head of population) (Gilbert et al, 2006).

Over the 1994 Christmas holiday period, the South Australia, Victoria and New South Wales states of Australia experienced an outbreak associated with UCFM products, which is commonly known as the ‘Garibaldi Incident’. One 4 year old child died and many were hospitalised after eating Garibaldi brand smallgoods, in particular Garibaldi's fermented meat product mettwurst. Most of the people hospitalised were children, whose immune systems could not cope with the effects of the food poisoning.

The Emergency Management Australia (EMA) Disasters Database, provides information about what the subsequent investigation and court cases identified, it states that the company was found:

• To have failed to adequately sterilise machinery,

• To have mixed older meat with fresh meat,

• To have failed to notify the Health Department (South Australia) of the possible contamination of the product with salmonella after it was detected in their production facility. 

As a consequence of the ‘Garibaldi Incident’ the Australia New Zealand Food Standards Authority (now Food Standards Australia New Zealand – FSANZ) developed a processing and food hygiene standard (Part 1.6.2 of the FSC), this standard is applicable only in Australia as it is outside the scope of the Joint Australia New Zealand Food Standards setting system.

A risk profile on STEC in UCFM products, completed for NZFSA by the Institute of Environmental Science & Research (ESR) (Gilbert et al, 2006), concluded that:

• The current rate of STEC infection in New Zealand is approximately 2 notified cases per 100,000 population (all cases sporadic, no widespread outbreaks),

• There is potential for the presence of pathogenic STEC in raw meat in New Zealand, which could then be used as an ingredient in the production of UCFM,

• The majority of UCFM imported into New Zealand will be from Australia where all UCFM products are required to meet the FSANZ standard,

• The consumption of UCFM is low in comparison with other meat types (both in terms of servings and weight).

The risk profile also stated that:

“As was concluded for Australia [FSANZ risk assessment P251], the risk is low but the consequences, particularly for susceptible groups, such as young children, are severe. Given the potential for exposure, on the basis of the observed prevalence of STEC in red meat in New Zealand, the risk needs to be managed by an appropriate measure.”

A survey in Toronto in 1994-1995 (Gilbert et al 2006 quote “Lee and Styliadis, 1996”) found that UCFM products made in small deli-type establishments were more likely to be left constantly unrefrigerated, and have a higher pH and water activity than products made at larger commercial plants. This suggested that product from smaller processors of UCFM might pose a greater risk to consumers.

Although there have not been any cases of STEC illness attributed to the consumption of UCFM products in New Zealand to date, NZFSA has identified a potential risk through the lack of understanding by UCFM producers of the controls required during production of UCFM.

Why have UCFM products emerged as an issue in New Zealand?

During assessment and registration of Dual Operator Butchers (DOBs) risk management programmes (RMPs under the Animal Products Act 1999) in 2005, NZFSA identified that in a number of cases essential processing parameters that ensure microbial safety of UCFM products were not being carried out. Further investigations revealed limited technical knowledge and adherence to current available standards. NZFSA has continued to register DOBs RMPs but has put on hold the processing of UCFM products under the programmes until the operators can demonstrate sufficient hazard control.

In addition to DOBs, there are other food businesses that may be currently preparing these products. Those that could potentially be involved are likely to fall into the following groups:

• Retail butchers and retail operators who are regulated by the Food Hygiene Regulations,

• Retail butchers and retail operators who are exempt from the Food Hygiene Regulations due to having an approved Food Safety Programme (FSP) in place,

• Secondary processors who have a registered RMP or an approved FSP in place,

• Secondary processors who are regulated by the Food Hygiene Regulations.

NZFSA recognise that many of the secondary processors may already follow the PQIP 07 Code of Practice or FSANZ standard Part 1.6.2 for UCFM production therefore it is likely that the group of operators that present the greatest concern of uncontrolled UCFM production will be those registered under the Food Hygiene Regulations. This may include small boutique delicatessen operations.

The following list provides examples of the food safety issues identified, which caused concern for NZFSA:

• Starter cultures were not used, nor understood,

• Commercial premixes were used without knowledge of their composition nor was guidance provided from suppliers as to appropriate use and expected final result,

• Premixes containing acidulant, if any, were often used solely for flavouring, not for microbial control, as in fermentation,

• Operators were unaware of critical product or process parameters,

• Fermentation and maturation was often occurring under ambient conditions, with process timing and outcome, dependant on the conditions at that time,

• Operators were not aware of the microbiological conditions of raw materials or final products.