European Commission stakeholder consultation setting microbiological criteria for foodstuffs in community legislation

Additional Comments by Dr Barbara M. Lund, Visiting Scientist, Institute of Food Research in response to a letter from the Food Standards Agency dated 21.1.2003

12 February 2003

SANCO/4198/2001 rev.4. 9.12.2002 and SANCO/4198/2001, rev.5, 3.2.2003

1. Criteria for Listeria monocytogenes

Comment: Under Interpretation of the test results, for food categories 2 and 3, the results are considered satisfactory if all samples tested show < 3m, equivalent to < 300 cfu/g, i.e. a three-fold relaxation of the criteria given in the Table 1. is allowed.

This is allowed in category 2 foods, and it is stated that the criterion can be applied to products ready to be put on the market. This is despite the facts that:

• the foods allow the growth of L. monocytogenes
• the shelf-life is not specified, so the foods may have a very long shelf life
• it has been agreed that at the point of consumption the foods should contain fewer than 100 cfu/g
• there is no certainty that the foods will be tested after they are placed on the market, whereas testing at the end of production should be applied routinely, and is specified in criteria for other pathogens in food categories, in particular in Milk and processed milk products

This is a further example of the point made in my comments dated 6.2.2003, that the criteria at the point of production for ready to eat foods that have been associated causally with listeriosis, or are able to support the growth of L. monocytogenes, are not sufficiently clear or stringent.

Comment: For many of the other criteria given, the limit m is also interpreted as a limit of 3m, giving a three-fold relaxation of the criterion. Most of the criteria have been developed by organisations, who were well aware of the limitation of counting methods, and the relaxation of the criteria by the interpretation that is given needs to be justified.

Comment: Under the Tables of Criteria for certain categories of foodstuffs, consideration should be given to stating tests for Listeria for the food categories to which these apply. This would aim to improve the clarity of the document.

Comment: In Table 2.2, Milk and processed dairy products, row 2 allows a space for including criteria for Salmonella in all processed dairy products. When the criteria for Salmonella have been set, they should be listed under each food category to which they apply.