Listeria Micro Criteria Policy - Chilled Food Association

Listeria and Zero Tolerance

After several years of campaigning, CFA helped secure agreement at the December 2008 meeting of the United Nations FAO/WHO Codex Alimentarius Food Hygiene Committee to reject zero tolerance as the sole regulatory approach for Listeria monocytogenes (Lm).

For the average healthy person the risk of becoming ill with listeriosis from food is very small and scientific evidence has shown that Listeria are consumed commonly with no ill effects. Because of this, EU legislation supports a risk-based policy allowing up to 100 colony-forming units of Lm/g (with certain exceptions) present in food at the end of its shelf life. In contrast, the US, traditionally, has favoured a zero tolerance approach for Lm for all foods. This means that the presence of any amount of the bacteria is not permitted.

But this target is impossible to achieve consistently as Lm is ubiquitous in the environment. In addition, the US chilled food market is very different from the UK where manufacturers apply shorter shelf lives than elsewhere in the world. In the US, as a result of the zero tolerance policy, there is relatively little testing for Lm in foods.

CFA has consistently argued that the best way to control Lm is through monitored preventative measures and appropriate controls and, in December 2008, the United Nations FAO/WHO Codex Alimentarius Committee on Food Hygiene, at its meeting in Guatemala, adopted this approach with the US finally agreeing to abandon its rigid adherence to the zero tolerance policy. The agreement prevents many hundreds of unnecessary product recalls every year in the UK alone saving hundreds of millions of pounds Sterling, protecting reputations, the continued risk basis of EU regulation and food safety.

CFA played an instrumental role in bringing about this agreement by providing the European Commission (EC) and FSA with scientific and practical data supporting the demonstrable validity of the 100cfu/g limit within a controlled shelf life. As part of this work CFA made extensive input into two EU-level shelf life guidance documents which were agreed by the EC in November 2008 in support of the EU position at the UN.