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

3 Current Risk Management Controls

New Zealand does not currently have a specific standard relating to the production of UCFM products. Food businesses in New Zealand currently have to operate in accordance with either the Animal Products Act 1999 or the Food Act 1981.

3.1 Animal Products Act 1999

The following persons must operate a registered risk management programme (RMP) under the Animal Products Act 1999 for the production or processing of animal material or animal product:

• Primary processors of animal material,

• Secondary processors of animal products intended for human or animal consumption, except to the extent that they are subject to the Food Act regime,

• Retail butchers who are dual operator butchers,

• Other persons required to operate under an RMP as specified by Order in Council under section 15 of the Animal Products Act 1999.

An RMP is a documented programme registered under the Animal Products Act 1999 and is designed to identify and control hazards and other risk factors in relation to the production and processing of certain animal material and animal products. An RMP is put in place to ensure that the resulting animal product is fit for intended purpose.

3.2 Food Act 1981

Historically food being sold in New Zealand had to be made in premises that were registered and inspected by local authority Environmental Health Officers (EHO’s). Food premises were inspected for compliance with the Food Hygiene Regulations 1974. Since 1996 food businesses in New Zealand have had the option to develop a food safety programme (FSP) and be exempt from the Food Hygiene Regulations 1974. The process is applicable to any size and type of food business.

An FSP is a documented programme approved under the Food Act 1981, is based on the HACCP system, and is designed to identify and control food safety risk factors in order to establish and maintain food safety. The food safety risk factors may relate to the production, manufacture, preparation, packaging, storage, handling, transport, distribution or sale of food.

3.3 Domestic Food Review

The Domestic Food Review (DFR) is a significant long term project currently being undertaken by NZFSA. Its purpose is to create a food regulatory programme across all sectors of New Zealand’s domestic food industry that promotes and delivers safe and suitable food. It is only the second time in the last 30 years that the Government’s role in the New Zealand domestic food sector has been critically examined at an official level. DFR work to date, has developed a comprehensive package of proposals for the future food regulatory regime. In particular the DFR proposes Food Control Plans (FCPs) which will improve and simplify food safety in New Zealand. The DFR proposes that all ‘Persons’ will have and implement a documented FCP unless agreed alternative mechanisms are in place, e.g. the DFR will accommodate for those businesses that already have HACCP based risk management plans in place, e.g. RMPs.

3.4 PQIP 07 Code of Practice and FSANZ Standard Part 1.6.2

PQIP 07 Code of Practice and FSANZ Standard Part 1.6.2 are the risk management controls most commonly utilised by New Zealand producers of UCFM, but they are not mandatory.

PQIP 07 is an industry devised Code of Practice. The New Zealand Pork Industry Board facilitates PQIP 07 and works closely with the various industry sectors. PQIP 07 involves the application of the international HACCP system and meeting the industry agreed minimum requirements. Manufacturers can obtain a copy and adopt the PQIP 07 Code of Practice by becoming a member of the Pork Processors Association. Accreditation to PQIP 07 requires an independent audit.

FSANZ Standard Part 1.6.2 is applicable only in Australia as it is outside the scope of the Joint Australia New Zealand Food Standards setting system.

Given the ability of STEC to survive in UCFM products, and the suggestion that pathogenic STEC may be more acid tolerant than other strains, FSANZ and the developers of PQIP 07 recognised the importance of understanding and controlling the microbiological quality of ingredient meats, and selecting a process sufficient to kill any STEC present.

Control of pH reduction through the use of starter cultures and the appropriate time/temperature combinations of drying have been shown to be critical for the safe production of UCFM products. These essential requirements result in finished product characteristics that are unfavourable for the growth of harmful pathogens like Escherichia coli O157:H7, and indeed, kill any O157 present.

PQIP 07 Code of Practice and FSANZ Standard Part 1.6.2 require that the production of UCFM must include:

• Implementation of a HACCP based food safety programme, in accordance with Part 3.2.1 of the FSC, that has been verified and audited to ensure effective reduction in number of Escherichia coli in UCFM product to a level specified in Part 1.6.1 of the FSC,

• Meat for the UCFM must be stored by the manufacturer at 5°C or below prior to fermentation,

• The Escherichia coli count of raw material must be known and must be equal to or below the process lethality or validated process. This can be achieved by:

• National Microbiological Database (NMD) if using New Zealand raw meat ingredients; or

• Equivalent data source from country of origin if using imported raw meat ingredients; or

• Adequate data provided by the company supplying the raw meat ingredients; or

• Adequate data obtained by the manufacturing through own microbiological testing of raw meat ingredients.

• No ‘back slopping’, i.e. previously fermented meat must not be used as a starter culture or an ingredient in UCFM (FSANZ Standard only),

• The reprocessing of fully processed compliant product is allowed (PQIP 07 only),

• Fermentation must be initiated through the use of a starter culture,

• The temperature and time of fermentation (and smoking) and maturation/drying steps must be monitored and recorded,

• The pH of fermenting UCFM together with final Aw (water activity) must be monitored and recorded,

• The microbiological standards in Part 1.6.1 of the FSC must be achieved during fermentation and subsequent processes prior to the sale from processing factory.