HACCP? Yes/No/Maybe (delete where appropriate)

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1 HACCP? Yes/No/Maybe (delete where appropriate) 1

2 Background NZIFST Conference 1979 Dr Florian Majorak (FDA) - paper on HACCP HACCP didn t really get going until 1990s, with Garibaldi mettwurst outbreak the catalyst (early Australia s Jack-in-the-Box) Led to the requirement by the FSIS that there be a CCP for E. coli O157 on the slaughter floor Context for today is: HACCP in the Australian meat industry and management of the Top Seven STECs Point-of-Entry (PoE) testing in USA looms large 2

3 June 4, 2012 game echanger 3

4 History soy Howard Bauman 1959 call from the Quartermaster Food and Container Institute of the US Armed Forces Can Pillsbury produce foods for consumption in the zero gravity of space capsules? HACCP borne out of cost of testing space foods In fact, a large part of the production.. had to be utilised for testing, leaving only a small portion, hence the enormous costs of production HACCP in full swing at the Pillsbury Co. 4

5 History early beginnings of HACCP principles 1930s early beginnings of HACCP Wilson (UK), Prescott & Meyer (USA) developed Longitudinally Integrated Safety Assurance (LISA) Based on Wilson s Triad: 1. Hygiene status of raw materials 2. Pasteurisation 3. Preventing adverse post-process events Aimed specifically at improving food safety of milk 5

6 Milk problems before pasteurisation Cheltenham/Moorabbin outbreak (early-1943), >400 ill, >20 dead Pasteurisation of milk involves every ml receiving a heat treatment of at least 72 C for at least 15 seconds Milk is squeezed between heat exchanger plates to ensure heat gets to every part of the milk, then sent through a holder tube at 72 C for 15 seconds Provides kill of 1,000,000,000,000 Salmonella /ml of milk Any problems: Diversion valve operates and milk back to raw milk tank Alarm sounds No milk can proceed until the pasteuriser is back in operating condition - CCP 6

7 Milk pasteuriser Diversion valve Holder tube 7

8 History - what is a CCP? 1997: Codex Committee on Food Hygiene (CCFH) publishes guidelines and applications based on the seven HACCP principles An important advance tightened the definition of CCP: Codex: Prevent, eliminate or reduce hazard to an acceptable level 8

9 HACCP - problem or solution? We ve now had at least 15 years of being serious about food safety (in the wake of Garibaldi) HACCP-based food safety plans implemented in the processing sector, followed by the food service sector - but very patchy So should we see a difference in foodborne illness rates in Australia as HACCP kicks k in? Our big 2 are Campylobacter (ca 16,000 cases/y) and Salmonella (ca 9,000 cases/y) /) 9

10 Australia s s leading notifications 140 Cases/100, Salmonella Campy

11 where none exists Problems occur when a CCP must be found where none exists e.g. slaughter and dressing of meat destined from grinding : Jack-in-the-Box hamburger outbreak in USA, >700 ill, 171 hospitalised, 4 deaths deliberate undercooking was cause. 1994: FSIS declare E. coli O157 an adulterant in meat for grinding and adopt a zero tolerance policy Establishments in all countries supplying the US market test each lot of production for O157 - detection leads to the lot being withdrawn from the export chain Each establishment must say they have a CCP on the slaughter/dressing floor 11

12 g g y g floor CCP Milk, faeces, ingesta are monitored as one of 10 defect categories Depending on the kill, as few as 20 sides may be monitored (reduced level monitoring) at the MHA stand a tiny proportion of the kill How effective is ZT monitoring? Can hardly be a CCP is the hazard prevented, eliminated or reduced to an acceptable level? Who knows? It s never been validated Plant Slaughter floor Boning room A 17/ /51866 B 35/17682 (0.2) 2/7141 C 36/36558 (0.1) 10/19759 (0.05) D 36/53808 (0.07) 115/55935 (0.2) E 108/78276 (0.1) 53/85760 (0.06) 12

13 Testing - HACCP comes full circle Testing of raw meat for grinding is now a disposition CCP Part of Regulatory HACCP, Market access HACCP To accommodate those who deliberately undercook hamburgers, every supplier to, and in, the USA must test every lot Huge testing - HACCP comes full circle designed to reduce testing! 13

14 Company A? Interventions Log reduction Hide wash and sanitise Steam vacuum Pre-evisceration acid rinse Thermal pasteurisation Carcase wash Hot acid rinse 1.0 Chilled carcase acid rinse

15 Company A? Company A has interventions i validated d by university i studies Company A recalls 8,000t ground beef (single recall) Reasons: Inactivation validated in university studies do not guarantee day-to-day running Loading of E. coli O157 sometimes too great for the system Take home: At the moment there is no food safety CCP in the slaughter/dressing process we can t prevent ent or eliminate STECs Zero tolerance for STEC means there can be no acceptable level. 15

16 Could hot water pasteurisation ever become a CCP? Requirement 1: Validate the process Process requirement: Inactivate highest level of O157 likely to occur Fegan et al. (2005) measured 750,000/g O157 in faeces For safety we should think about inactivating 10,000,000 O157 cells Makers of equipment claim log 3-4 reduction so 1,000-10,000 cells will remain at the end of the slaughter floor Keeping the carcase surface at >80 C for at least 5 seconds might do it Requirement 2: Operating and monitoring Need milk monitoring: Temperature < set point = diversion i of carcases to pre-pasteurisation i Quick test to guarantee heating process has been delivered (phosphatase test in milk) 16

17 Company A: ESAM after pasteurisation and boning room ZTs room ZTs Pasteurising mostly delivers no/very few generic E. coli at ESAM sites But should we worry about ZTs in boning room? 17

18 Conclusions Current CCP (trimming ZTs) is a food safety furphy Full complement of interventions might work: Steam vac hide opening cuts Pasteurisation/organic acid washes Organic acid at entry to boning room Would require validation that it delivers 7-log reduction (could be done on a whole-of-industry of basis) Monitoring could be based on generic E. coli (not detected) at sites of microbiological concern NOT ESAM SITES Disposition a final alternative If only product with no generic E. coli at high-contamination sites is sent to USA would we need to test for the Top Seven? 18

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