Second Public Consultation on Microbiological Standards for Ready to Eat Food

Regulatory Administration Group - Agri-Food & Veterinary Authority

Consultation Period: 22 Oct 2018 - 21 Nov 2018

Status: Closed - Summary of Responses

Consultation Outcome

RESPONSE TO COMMENTS RECEIVED FROM THE SECOND PUBLIC CONSULTATION ON PROPOSED AMENDMENTS TO THE FOOD REGULATIONS REGARDING MICROBIOLOGICAL STANDARDS FOR READY-TO-EAT (RTE) FOOD

The former Agri-Food and Veterinary Authority (AVA), now the Singapore Food Agency (SFA), initiated a second public consultation exercise for the period 22 October 2018 to 21 November 2018 on proposed revised amendments to the Food Regulations regarding microbiological standards for ready-to-eat (RTE) food. (The first public consultation was held from 22 August 2017 to 23 October 2017.) Concurrently, then-AVA had also notified the World Trade Organisation (WTO) of the proposed amendments via notifications G/TBT/N/SGP/39/Add.1 and G/SPS/N/SGP/59/Add.1.

Feedback was sought from stakeholders on the proposed revised amendments to the definition of RTE food, removal of limits for total plate count from the Food Regulations, replacement of coliform limits with Enterobacteriaceae limits, and the revised format of listing for pathogens.

Definition of RTE

Three companies expressed support for the proposed revised definition of RTE food:

Food that is made available for sale for direct human consumption without the need for cooking or any other form of processing to eliminate, or reduce to the standards specified in the Eleventh Schedule, any pathogenic or other micro-organisms of concern in food; and includes concentrated food (e.g. beverages, cup noodles and fruit juice cordials, squashes and syrups) which have to be reconstituted or diluted with fluids before consumption, chilled or frozen cooked products (e.g. chicken wing, pizza and instant meal) which may be re-heated before consumption.

Two companies proposed to exclude “chilled and frozen cooked food that requires reheating” from the definition of RTE food, citing examples of frozen cooked food (for example, pizza) which require reheating for longer periods of time for the purpose of cooking and elimination of the associated pathogens. One company also highlighted that from the preparation instructions provided on the labels of frozen food, it is not possible to differentiate between reheating and cooking of such foods. SFA had taken these comments into consideration and will refine the definition of RTE food to exclude “chilled and frozen cooked food that requires reheating”.

Two other companies sought clarification on whether noodles which require cooking before consumption as well as salads labelled with “wash before consumption” would be regarded as RTE. SFA had responded that raw ingredients or food that are meant for further cooking before consumption would not be regarded as RTE food. However, salads that are labelled with “wash before consumption” would be regarded as RTE food.

Removal of total plate count limits from the Food Regulations

There were no objections received on the proposal to remove the limits for total plate count from the Food Regulation, although one company sought clarification on whether testing for total plate count would still be required if the limits were removed from the Regulations, and another company asked if SFA would be publishing guidelines for total plate count.

SFA had responded that it will no longer be a legal requirement for companies to comply with the limits for total plate count for RTE food if the limits are removed from the Regulations. However, companies may wish to check for total plate count as part of their internal process control. SFA had also informed that there are no immediate plans to publish guidelines for total plate count, but may consider doing so in future.

Replacement of coliform limits with Enterobacteriaceae limits

Three companies and a foreign government commented that Enterobacteriaceae is naturally present at high levels in RTE fruits and vegetables, cheeses (including ripened cheese) and fermented food, and proposed to exclude these food products from the Enterobacteriaceae limit as testing will not be useful to indicate their hygiene status. SFA noted the comments and will exclude a number of these food products from the Enterobacteriaceae limit. One company also commented that it would be costlier to test for Enterobacteriaceae, as compared to coliform.

Revised format of listing for pathogens

There were no objections received on the proposed revised format of listing for pathogens.

Other comments received

(a) On units for the proposed microbiological limits

One company proposed to use MPN/g to enumerate the food pathogen Vibrio parahaemolyticus, based on the International Organization for Standardization (ISO) Standard 21872-1:2017, instead of Colony Forming Unit per gram (cfu/g) as proposed in the consultation document. SFA noted the comment, but will adopt cfu/g as the unit for testing of V. parahaemolyticus, in line with countries such as Australia, New Zealand, Canada, Ireland and the United Kingdom.

(b) Pathogen limits

One company suggested for the limit of <200 cfu/g for Bacillus cereus to be increased to <500 cfu/g. SFA had informed the company that the proposed limit is realistic and is a safeguard to protect the health of consumers in Singapore. Another company sought clarification on whether the proposed amendments will include microbiological standards for norovirus in RTE food. SFA has responded that microbiological standards for norovirus in RTE food had not been considered in this round of amendments.

Conclusion

SFA appreciates the time taken by individuals and organisations to submit feedback and comments which have contributed to the decision-making process, and would like to encourage all food industry members to actively participate in future calls for comments.

Detailed Description

Aim

The Agri-Food and Veterinary Authority (AVA) is seeking feedback from stakeholders on proposed revised amendments to the Food Regulations concerning the microbiological standards for ready-to-eat (RTE) food, following the first public consultation.

Background

2 AVA initiated the first public consultation exercise on proposed amendments to the Food Regulations regarding microbiological standards for RTE food from the period 22 August 2017 to 23 October 2017. Feedback was sought from stakeholders on the following:

I. Whether the proposed definition of RTE food accurately describes such food.

II. Whether the 5 categories of RTE food accurately describe all the categories of RTE food available on the market.

III. Whether the RTE food products imported / manufactured by companies are able to comply with the proposed limits for total plate count, indicator organisms and pathogens.

The consultation document is available for viewing at the following website:

https://www.reach.gov.sg/participate/public-consultation/agrifood-veterinary-authority-of-singapore/regulatory-programmes/proposed-amendments-to-the-food-regulations-regarding-microbiological-standards-for-rte-food

3 At the close of the first public consultation, AVA received comments on I, II and III. The summary of comments received, together with AVA’s response, can be downloaded from the REACH portal:

https://www.reach.gov.sg/participate/public-consultation/agrifood-veterinary-authority-of-singapore/regulatory-programmes/proposed-amendments-to-the-food-regulations-regarding-microbiological-standards-for-rte-food

4 Arising from the comments received, AVA has further reviewed the proposed microbiological standards for RTE food, and proposes the following revisions, taking into consideration the comments received.

Proposed revised amendments

5 AVA proposes to revise the definition of RTE food as follows (refer to right hand column of table below), to provide greater clarity on the type of food products that are considered to be “ready-to-eat” and for which the microbiological standards under the Food Regulations would be applicable.

6 AVA proposes to remove limits for total plate count (TPC) from the Food Regulations, taking reference from the practices in Australia, Canada, United Kingdom, Ireland, and Hong Kong, which have published guidelines for the industry, rather than legislate the TPC limits. This is also consistent with the Codex Principles and Guidelines for the Establishment and Application of Microbiological Criteria related to Foods (CAC/GL 21-1997), which does not specifically indicate that total plate count is suitable as a mandatory microbiological criterion.

7 In the case of indicator organisms, AVA proposes to replace the coliform limits with Enterobacteriaceae limits, taking reference from the microbiological standards in Australia, New Zealand, the European Union and Hong Kong. Enterobacteriaceae is a large group of biochemically and genetically related bacteria that are useful indicators of the general hygiene status of a food product. Their presence in high numbers (>104 per gram) in heat-treated food indicates inadequate cooking or post-processing contamination.

There are no proposed changes to the microbiological standard for Escherichia coli count in RTE food from the first public consultation. The revised table for indicator organisms is as follows:

8 AVA proposes to only list those pathogens with specified limits (refer to table below). There are no quantitative changes to the limits from the first consultation. As in the first consultation, pathogens other than the ones listed in the table below, whether or not commonly associated with the RTE food, should not be detected in 25 grams of the RTE food.

Request for comments

AVA invites views and comments on the proposed revised amendments in paragraphs 5 to 8 above.

Procedure and timeframe for submitting views and comments

All submissions should be clearly and concisely written, and should provide a reasoned explanation for any proposed revisions.

Submissions should reach AVA no later than 12:00 p.m., 21 November 2018, through mail, or email, to the following addresses:

Mail:

Regulatory Programmes Department

Agri-Food & Veterinary Authority of Singapore

52 Jurong Gateway Road

#13-01 Singapore 608550 (Attention: Ms Leong Ai Ling)

Email:

leong_ai_ling@avagov.sg