The Food Standards Agency FS512511 Proposals to test food businesses' proposed alternative controls

Descriptions

The Food Standards Agency (FSA) FS512511 The E. coli O157 cross-contamination guidance was developed in response to the Public Inquiry into the outbreak of E. coli O157 in South Wales in September 2005 with a total of 157 cases, 31 people admitted to hospital and the death of a five-year old boy. The Public Inquiry, chaired by Professor Hugh Pennington, was carried out over a three-year period and represented a detailed investigation into the circumstances surrounding the outbreak. The final report, published in 2009, identified that the root cause of the outbreak was cooked meats that had become contaminated with E. coli O157 and sold to different establishments including local schools. The report also identified a number of failures in the systems of control that contributed to the outbreak with specific reference to a failure to ensure that critical procedures, such as cleaning and the separation of raw and cooked meats were carried out effectively. The findings mirrored the ones of an inquiry into the E. coli outbreak in Scotland, the largest in the UK (in which 21 people died), where cross-contamination between raw and ready-to-eat foods had also been identified as the source of the outbreak. The guidance is based on the findings of both Public Inquiries and on a number of independent scientific studies that highlight the difficulty of relying on procedural controls to address the risks associated with cross-contamination, particularly indirect cross-contamination. Scientific evidence to support the guidance can be found in Q20 of the E. coli Q and A document. For these reasons the principle of separation when handling raw and ready-to-eat foods was considered to be the safest control measure. In particular that the dual use of complex equipment, such as vacuum packing machines, slicers and mincers, should never be considered safe. The guidance was produced upon the following principles that were subject to a formal public consultation in 2010: Separation of equipment and staff involved in handling raw food from staff that handle ready-to-eat food (RTE) Cleaning and disinfection Personal hygiene and handling practices Management of controls (documenting procedures, record keeping, training and supervision) These principles received overwhelming support during consultation. In February 2011 the FSA published the guidance and an additional fact sheet aimed specifically at small businesses to summarise its content. Formal evaluation of the guidance was conducted in 2012 and discussed at the FSA Board meeting in November, 2012. Following this a review of the guidance is now planned to start in April 2013, which will be informed by the establishment of a stakeholder drafting group, including trade associations, enforcement officers and FSA officials. In 2012 the Government's Focus on Enforcement campaign in England asked small food manufacturers to report on their experiences of working with national regulators and local authorities as part of a review. The review was aimed at micro and small food businesses employing up to 50 employees. A representative mix of businesses from both high and low-risk food and drink manufacturing sectors took part. Those eligible for comment included, but were not limited to, butchers, bakers, cheese makers and confectioners including those manufacturing ice cream. Along with comments submitted on the website, 17 businesses and trade associations participated in the review field work which ran for 5 weeks from 1.5.2012. Concerns were raised during the review about the E. coli O157 cross-contamination guidance, in particular the use of separate complex equipment as a control measure. The FSA remains committed to the position that the dual use of complex equipment for raw and ready-to-eat food cannot be regarded as safe practice, and this position is underpinned by recommendations based on the evidence assessed during two Public Inquiries, which is further supported by scientific evidence . However, in response to this review the FSA has outlined that it will identify and independently test the alternative controls to cross-contamination proposed by stakeholders. This work will ensure that any potentially unnecessary burdens on businesses can be identified, and if possible minimised, while maintaining the effectiveness of public health protection.