CFG
28/06
Letter dated 1 November
2006 from Foodaware to Sarah Butler, Microbiological Safety Division,
Food Standards Agency:
Dear Ms Butler
FSA consultation on the ACMSF draft report on safe cooking
of burgers
We are sorry that this response has been delayed and is submitted
after the closure of the consultation. We hope that it will nevertheless
be valuable for the FSA to have these consumer views as part of the
record.
1. Reiteration of advice to consumers
Foodaware supports the ACMSF recommendation that the existing advice
for safe cooking of burgers should remain at 70°C for 2 minutes
and, that consumers and caterers should be reminded of the advice
‘to follow manufacturers’ instructions and to observe
that burgers are piping hot throughout, thoroughly cooked until the
juices run clear and there are no pink bits inside.’ The draft
report from the ACMSF provides no evidence that this should be changed.
Indeed, it cites only 1 outbreak of E. coli 0157 since 2000 associated
with eating burgers which involved a family of 5, and the Committee
concluded that the evidence that the advice is working is strong.
Consistent messages are necessary to ensure they are learnt, remembered,
and routinely applied by all those cooking meat products, and particularly
minced beef products which pose a higher risk of food poisoning. It
would also, as suggested, be useful to reiterate that a change in
colour is an unreliable indicator of safe cooking and that it does
not necessarily mean that burgers are cooked properly.
While the ACMSF also suggests that advice should be given to consumers
and caterers encouraging the use of temperature probes to check whether
burgers are fully cooked, domestic practice in the UK differs from
that in the USA and Canada and we consider this
advice to be unrealistic for domestic consumers. It would perhaps
be more realistic to emphasise the value of such probes in catering
environments, and public events where untrained volunteers are barbecuing
burgers for sale.
2. Modelling
The details of the data modelling approach, which we understand form
the basis for regulations in the USA and Canada and considered by
the ACMSF working group, are extremely technical. We do not have the
expertise to comment on their validity. However, we have, on a number
of occasions, supported the use of risk-based assessment in food businesses
and a rigorous application of HACCP principles. Therefore, we accept
that such an approach to setting time/temperature limits could be
valid.
3. Contamination of meat in the UK
The ACMSF conclude that contamination rates are low (para. 28) but
they acknowledge that there has been little recent work done in this
area in the UK. The industry should be encouraged to fund some work
in this area so that there is a better understanding of the microbiological
status of raw burgers since they pose a higher risk of bacterial infection
than whole meat products.
4. Protecting consumers of cooked burgers
from catering outlets
We note that in the ACMSF evidence (para. 73) there have been no recent
outbreaks of E. coli associated with eating burgers outside the home
and this is reassuring. We note that the Working Group considered
that the current UK guidance of 70°C for 2 minutes may be excessive
and that at least one fast food outlet has argued that this affects
the quality of the end product. There does not appear to be any evidence
in the report, however, that this has affected sales or levels of
consumption in the UK. The argument has been based on inconsistency
between North American and UK legislative requirements.
In principle, we are unhappy that pressure from an individual company
with significant commercial interest should have brought about this
review in an area where consumer protection should be paramount, and
where no evidence from other companies or catering outlets seems to
have been considered. The recommendation in para. 76 of the ACMSF
report is that ‘consideration could be given to the use of lower
time/temperature combinations where producers can demonstrate the
safety of their products using risk assessment approaches with associated
effective process control’. We consider it is absolutely essential
that if the FSA decides to allow individual companies to move away
from the existing requirements, this should only be on the basis of
prior assessment of the risk management system in place, regular independent
monitoring and prompt reporting of any failures in control to the
Competent Authority. Adequate staff training and the importance of
effective time/temperature control will be an essential if changes
are approved. We believe that such obligations would be consistent
with the UK’s obligations under EU laws on food hygiene and
microbiological criteria. The FSA should also continue to conduct
research on risks to human health from E. Coli and monitor incidents
of food poisoning associated with meat products to ensure that there
are no untoward effects on human health from the introduction of any
change in policy on the heat treatment of cooked meat products.
Yours sincerely
Susan Knox
Chairman
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