Work continues on building a consortium of European and international industry and the industry Response to the EU’s awaited but undefined proposed changes to Listeria monocytogenes (Lm) legislation (EU Microbiological Criteria for Foodstuffs Regulation 2073/2005) (CFA News #56 and #57).
Potential changes to the regulation include:
- loss of 100 cfu/g as an upper limit and introduction of zero tolerance/not detected in 25g
- requirements to set shelf life by challenge testing and not durability testing.
This is the most important policy matter for the UK industry, which can demonstrate through hard data (epidemiology, food and environmental sampling) that its approach is much more effective from a public health perspective than that in other major European countries and across Europe, the UK listeriosis rate consistently being half that of Europe as a whole.
The latest version of the draft Response summarises how shelf life should be set (knowledge of foods’ physicochemical properties combined with durability studies and a stream of food and environmental data and Supplier Quality Assurance, particularly of RTE components) and how environmental data should be collected and used proactively to identify issues and demonstrate control. It has received support from the food industry in the UK and across Europe, including retailers, food producers and associations. It is vital that not only UK businesses/associations make submissions to the EC, once proposals are consulted on.
As the UK is no longer an EU Member State it has few routes to influence the EU. Despite CFA engagement over nearly two years, FSA has not yet given any firm indication as to how it will respond to the expected EU consultation on changes to current legal requirements.
CFA is rare in having to hand a wealth of data from its members collected over nearly 20 years – its four million datapoints in the last 12 years alone on prevalence and (for foods) counts of Listeria – the largest data set of its type in the world. The dataset is a powerful tool to help demonstrate efficacy of controls in place in the UK industry for RTE chilled prepared foods.
Karin Goodburn explains further: “The UK chilled food sector’s effective implementation of the regulations demonstrates that enforcement, not a change to the law, is required to improve food safety.
“For example if there were mandatory challengetesting this could cost the UK chilled food industry ~£150-£225 million without any food safety benefit where UK industry best practice established over 30 years as set out in the Response, nor the current EU legal position is in place.
“We will continue to challenge promotion of unnecessary expensive testing diverting limited funds from actual food safety controls, and encourage our industry colleagues to do the same. Only by working together with one voice can we stop these unnecessary and potentially dangerous changes to a piece of legislation that when applied as designed has worked well for almost two decades.”
April 2023