CFA in summer 2016 brought together a group of trade associations in response to the Food Standard Agency’s (FSA) amended guidance to the ’10 day rule’. In its response to the proposed amendment of the guidance, according to the group, threatens to compromise food safety and the viability of huge sectors of the food industry.
- What is the 10 day rule?
The ’10-day rule’ is peculiar to the UK. It limits the shelf life of vacuum packed and MAP chilled foods to 10 days unless additional hurdles to the growth of non-proteolytic Clostridium botulinum are used. It was first set out non-statutory UK guidance published by ACMSF in 1992, revised by ACMSF in 1995, reviewed by ACMSF in 2006 resulting in the 2008 edition.
- What happened in 2016-17?
In summer 2016 the Food Standards Agency (FSA) issued amended draft guidance which impacted negatively on the viability of £billions worth of foods from meat, dairy and fish to multicomponent chilled food, whilst compromising food safety and failing to recognise work including that on risk assessment it had funded in 2005-6 (project B13006), which had been endorsed by ACMSF.
- What is wrong?
The changes proposed to the guidance by FSA and since published in January 2017 go beyond routine updating and clarification and give rise to a number of concerns. They compromise food safety by the required laboratory approach, do not reflect modern manufacturing methods or risk assessment, or recent research including SUSSLE projects. Also, no Impact Assessment was carried out by FSA.
- What have we done?
CFA in 2016 drew together a group of seven trade associations (British Meat Processors Association, Provision Trade Federation, Seafish, International Meat Trade Association, National Association of Catering Butchers, National Federation of Meat and Food Traders) and the Institute of Food Research (IFR, now Quadram Institute Bioscience), formed a strong consensus and made a detailed submission to FSA.
- What do we want?
Industry and IFR requested that the document be withdrawn from the Internet, enforcement activity be put on hold pending a more substantive technical review in which the scientific evidence base for change can be properly evaluated, and a full impact assessment be carried out.
The group has offered assistance with the review, either through the reconvening of a working group similar to that which developed the original guidance on the basis of advice from the Advisory Committee on the Microbiological Safety of Food, or in the context of a new ACMSF report.
Update July 2018: Indsutry Shelf Life Guidance Published
In July 2018, a consortium of UK food industry (CFA and BRC) and UK and Australian research organisations (Leatherhead Food Research, Meat & Livestock Australia and Quadram Institute Bioscience) issued Guidelines for Setting Shelf Life of Chilled Foods in Relation to Non-proteolytic Clostridium botulinum, designed to ensure that sufficient information is provided by FBOs and laboratories to arrive at valid decisions regarding the shelf life of chilled foods in relation to non-proteolytic Clostridium botulinum. The Guidelines are intended to also support FBOs when challenged by Competent Authorities.