HPA Micro Guidelines For RTE Foods
HPA Micro Guidelines For RTE Foods
Summary: These guidelines for the microbiological quality of ready-to-eat foods Key words:
represent a revision and expansion of guidelines first published by the PHLS in food
September 1992 and revised in March 1996. The latest guidelines incorporate food inspection
many of the constructive comments received from food examiners and other food microbiology
guidelines
microbiologists within and outside the PHLS and from environmental health officers
throughout the United Kingdom. This document reviews the changes and the
reasons they were made and sets out the new guidelines. It also clarifies the role of
food examiners in interpreting the microbiological results of formal samples.
The Food Safety Act 19904 established the role of the food examiner to perform the statutory function of microbiological examination
of food. The qualifications and experience needed for registration as a food examiner are detailed in the Food Safety (Sampling and
Qualifications) Regulations 19907. Food examiners, therefore, are the individuals to whom an enforcement officer must submit any
samples taken for examination for enforcement purposes (that is, formal samples the results of whose examination may be introduced
as evidence in legal proceedings under the Food Safety Act). The aims of this provision in the Act are to ensure that the microbiological
examination of food is performed to a high standard and, by specifying their required qualifications, to ensure the competence of food
examiners asked to give evidence during any legal proceedings. PHLS and other laboratories that are designated as official testing
laboratories8 that examine food samples must have designated food examiners. When required, food examiners are expected to be
witnesses of fact in respect of any examination that has been conducted, including their results.
When it is appropriate to do so, the food examiner may also interpret the results of the examination of formal food samples by
reference to the provisions of the Food Safety Act 19904 dealing with microbiological quality. The Food Safety Act 1990 (Chapter 16) 4,
however, contains specific wording with regard to foods of an unacceptable microbiological quality. A food fails to comply with the
Food Safety Act 1990:
if it is unfit for human consumption (Section 8(2)(b)), or
if it is so contaminated that it would not be reasonable to expect it to be used for human consumption in that state (Section 8(2)(c)).
Also, under Section 14 of the Act, it is an offence to sell any food which is not of the nature or substance or quality demanded by the
purchaser.
The PHLS guidelines have no statutory standing and are not directly linked to the Food Safety Act 1990 4. They therefore deliberately
avoid the use of any of the above terms. It is the enforcement officer, assisted by legal advice, who is responsible for deciding under
which section of the Food Safety Act a prosecution should be instituted. The food examiner may include the precise wording from the
Act on a report or certificate of examination or may choose to express a personal opinion in different words. Food examiners should
be prepared to express an opinion on the results of examinations whenever they feel in a position to do so. The opinion should be
phrased in a form that is supportive to the enforcing authority in cases of prosecution.
The degree of involvement of the food examiner as an expert will depend on personal experience and the level of expertise with
respect to the matter in issue. In some instances, food safety proceedings will require the additional specialist knowledge of an
expert of national repute and long experience in this subject. If he/she is suitably qualified to express an opinion based on experience,
the food examiner can provide evidence as an expert witness.
(ACFDP) has prepared this current revision, which is microbiological quality (box 2) – related to the actual
based on both the experience gained of the aerobic colony count, number of indicator organisms,
appropriateness of the guidelines in practice and a and the presence/number of pathogens determined
reassessment of the microbiological results for a wide by the microbiological examination of the food.
variety of ready-to-eat foods held in the PHLS data bank. The microbiological limits given in table 1 are not
This data bank includes microbiological results from statutory standards. They are guidelines only.
PHLS national and local surveys, joint Local Authority Revisions will continue to be made at intervals as
Coordinating Body on Food and Trading Standards experience is gained of their value in practice and as
(LACOTS)/PHLS coordinated food surveillance additional information becomes available. The
projects 3, and the UK contribution to the European guidelines may not apply to every food type contained
Community Coordinated Food Control Programme3. within a food category; interpretation should also be
The purpose of these guidelines, therefore, is to based on knowledge of the product components and
help food examiners (box 1)4 and environmental health the production process. Food microbiologists should
officers to determine the bacteriological quality of undertake laboratory tests appropriate both to the type
various ready-to-eat foods at the point of sale and to of food sample submitted and to the processing it has
indicate the level of contamination that is considered received. The guidelines are applicable only when an
to represent a significant potential risk to health. The appropriate range of indicator and pathogen tests has
guidelines are not intended to be prescriptive and have been undertaken.
no legal standing in their own right. They are also
intended to reflect the increasingly high quality Aerobic colony count
achieved by most of the ready-to-eat food industry in The term aerobic colony count (ACC) has replaced the
the UK. They represent the collective experience of previous name ‘aerobic plate count’ and more
the PHLS, which currently examines over 190 000 food accurately describes the test undertaken. There are
samples per year. This body of information is now enough microbiological data on the foods listed in
being collated to provide an evidence base for table 2 to permit them to be classified on the basis of
quantitative microbiological risk assessment5 and for their ACC. If a specific ready-to-eat food is not
the implementation of hazard analysis of critical included in table 2, food examiners and
control points 6 systems for food safety. microbiologists should use their own judgment to
assess where a product would fit – based on the type
The new guidelines of product, the processing it has received, and the
As in the previous guidelines1,2 the new guidelines potential for microbial growth during storage.
identify five categories of food (table 1). The categories When unsatisfactory aerobic colony counts are
are based solely on expected aerobic colony counts, encountered microbiologists should attempt to identify
according to the type of food product and the the microorganisms that predominate. From these
processing it has received. There are four grades of results, and additional detailed information about the
Unacceptable/
Food category potentially
(see table 2) Criterion Satisfactory Acceptable Unsatisfactory hazardous*
* Prosecution based solely on high colony counts and/or indicator organisms in the absence of other criteria of unacceptability is unlikely to be successful.
Guidelines for aerobic colony counts may not apply to certain fermented foods for example, salami, soft cheese, and unpasteurised yoghurt. These
foods fall into category 5. Acceptability is based on appearance, smell, texture, and the levels or absence of indicator organisms or pathogens.
On occasions some strains may be pathogenic.
§ Not applicable to fresh fruit, vegetables and salad vegetables.
¶ Relevant to seafood only.
# If the Bacillus counts exceed 104 CFU/g, the organism should be identified.
** Not detected in 25g for certain long shelf-life products under refridgeration
NA Not applicable
food sample, it should be possible to provide a more Enterobacteriaceae is well defined taxonomically and
helpful interpretation of high aerobic colony counts. methods for their enumeration are based on common
properties10,11. Furthermore, the methods also detect
Indicator organisms important non-lactose fermenting organisms such as
Enterobacteriaceae salmonellas. The criteria listed for Enterobacteriaceae
The test for Enterobacteriaceae has replaced the tests do not apply to fresh fruit and vegetables or to
for coliforms that traditionally have been used as sandwiches containing salad vegetables because fresh
indicators of hygiene and contamination after fruit and vegetables often carry high levels of these
processing. The major problems with the coliform tests organisms as part of their normal flora.
are the variability in definition of the term coliforms (they
are defined usually by the method used for their Escherichia coli (total) and Listeria spp (total)
detection) and the fact that only lactose fermenting The criteria for E. coli (total) and Listeria spp (total)
organisms are detected9. In comparison the family have been modified. Quantitative levels in the
BOX 2 Grades of microbiological quality
The terms used to express the microbiological quality of the ready-to-eat foods are:
Unsatisfactory test results indicating that further sampling may be necessary and that environmental health officers may wish to
undertaken a further inspection of the premises concerned to determine whether hygiene practices for food production or
handling are adequate or not.
Unacceptable/potentially hazardous test results indicating that urgent attention is needed to locate the source of the problem;
a detailed risk assessment is recommended. Such results may also form a basis for prosecution by environmental health departments,
especially if they occur in more than one sample. Food examiners will wish to draw on their own experience and expertise in
determining the advice and comments they wish to give and they will be required to do this if invited to give an expert opinion
during legal proceedings.
TABLE 2 Colony count categories for different types of counts of Listeria spp in previous versions of the
ready-to-eat foods guidelines1,2 excluded L. monocytogenes. This has been
Food
changed to include L. monocytogenes and hence the
group Product Category term is fully inclusive of all Listeria spp. The reasons
for this are because of the changes to the quantitative
Meat beefburgers 1 criteria for L. monocytogenes explained below and to
brawn 4
faggots 2 represent what happens in practice when examining
ham raw (Parma/country style) 5 food samples by the standard method. Although
kebabs 2 Listeria spp. other than L. monocytogenes are rarely
meat meals (shepherds/cottage
pie, casseroles) 2 implicated in illness they are indicators for the likely
meat pies (steak and kidney, pasty) 1 presence of L. monocytogenes and so concerns
meat, sliced (cooked ham, tongue) 4 described below about the presence of low levels
meat, sliced (beef, haslet, pork, poultry) 3
pork pies 1 of L. monocytogenes in certain products also apply
poultry (unsliced) 2 to other species of Listeria.
salami and fermented meat products 5
sausages (British) 2
sausages (smoked) 5
Pathogens
sausage roll 1 Salmonella, campylobacter, and E. coli O157
scotch egg 1 It is the opinion of the ACFDP that ready-to-eat
tripe and other offal 4 f o o d s s h o u l d b e f re e f r o m S a l m o n e l l a s p p ,
Seafood crustaceans (crab, lobster, prawns) 3 Campylobacter spp, and E. coli O157 and other
herring/roll mop and other raw Ve r o c y t o t o x i n p ro d u c i n g E . c o l i ( V T E C ) .
pickled fish 1 Appropriate control measures during production,
other fish (cooked) 3
seafood meals 3 adequate hygiene standards, and appropriate cooking
molluscs and other shellfish (cooked) 4 during final preparation should ensure that the end
smoked fish 4 products are free from viable organisms and that the
taramasalata 4
foods are therefore of good quality.
Dessert cakes, pastries, slices, and Ready-to-eat foods containing salmonellas or other
desserts - with dairy cream 3 pathogens may not always cause illness but there is
cakes, pastries, slices, and desserts
- without dairy cream 2 good microbiological and epidemiological evidence
cheesecake 5 that small numbers of pathogens in foods have caused
mousse/dessert 1 illness12. The ACFDP takes the view that there is no
tarts, flans, and pies 2
trifle 3 justification for processed ready-to-eat foods being
contaminated with these organisms and that their
Savoury bean curd 5
presence, even in small numbers, results in such foods
bhaji (onion, spinach, vegetable) 1
cheese-based bakery products 2 being of unacceptable quality/potentially hazardous.
fermented foods 5
flan/quiche 2 Vibrio species
homous, tzatziki, and other dips 4
mayonnaise/dressings 2 Microbiological criteria for Vibrio cholerae have also been
pâté (meat, seafood, or vegetable) 3 added to the guidelines because the European
samosa 2 Commission has made several decisions in response
satay 3
spring rolls 3 to the isolation of this organism from various ready-
to-eat foods, mainly fishery products and fruits and
Vegetable coleslaw 3 vegetables, imported into countries of the European
fruit and vegetables (dried) 3
fruit and vegetables (fresh) 5 Union13-16. V. vulnificus, although a pathogenic vibrio,
prepared mixed salads and crudités 4 is a rare cause of foodb orne disease and h a s
rice 3 therefore not been included in this version of the
vegetables and vegetable meals (cooked) 2
guidelines. The quantitative microbiological quality
Dairy cheese 5 levels for V. parahaemolyticus in seafood have been
ice cream, milk shakes (non-dairy) 2 retained for further assessment.
ice lollies, slush, and sorbet 2
yoghurt/frozen yoghurt (natural) 5
Listeria monocytogenes
Ready-to-eat pasta/pizza 2 The quantitative microbiological quality levels for
meals meals (other) 2
L. monocytogenes have been modified and the
Sandwiches with salad 5 classification of ‘unsatisfactory’ is now not applicable in
and filled without salad 4 this case. Some quality standards require a zero level
rolls with cheese 5
for L. monocytogenes at the production stage of a food17,
thus 102 CFU/g at point of sale/consumption represents
unacceptable/potentially hazardous column (table 1) a potential risk to health. Counts of this level may also
have been deleted because a prosecution based solely indicate a significant failure of hygiene standards in the
on indicator organisms in the absence of other criteria preparation and /or storage of such foods. None of the
of unacceptability is unlikely to be successful. Total figures within the guidelines can be said to carry an