Consultation on Draft Food (Amendment No. Y) Regulations 2023 (Proposed Microbiological Standards for Non-Ready-To-Eat Food)
Last updated 18 December 2024
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Singapore Food Agency
Consultation Period: 15 Feb 2023 - 18 Apr 2023
Status: Closed
Detailed Description
Consultation On Draft Food (Amendment No. Y) Regulations 2023 (Proposed Microbiological Standards For Non-Ready-To-Eat (non-RTE) Food)
Aim
1. The Singapore Food Agency (SFA) is seeking feedback from stakeholders and interested parties on the proposed microbiological standards for non-ready-to-eat (non-RTE) food, which is targeted to come into effect in the fourth quarter of 2023.
Background
2. Non-RTE food refers to food which is not included in the definition of RTE food1 under Regulation 35 of the Food Regulations.
3. Certain non-RTE food such as raw meat, seafood and eggs may become contaminated with various pathogens during primary production and/or processing, and these pathogens may subsequently be transmitted to humans through consumption of contaminated food.
4. Although non-RTE food are typically consumed cooked, certain products such as bivalve molluscan shellfish and shell eggs are frequently consumed undercooked by consumers, while others may be directly used by consumers without further heating (e.g. pasteurised egg products in mayonnaise). If the pathogen loads in such non-RTE foods are not reduced to safe levels, their presence could pose a food safety concern due to the low infective doses as well as the high severity of disease caused by a number of these pathogens.
5. SFA currently adopts a set of microbiological standards for non-RTE meat and meat products which can be found on our website2. These standards are subjected to regular review based on the latest scientific evidence, data as well as international practices and guidelines to protect consumers from foodborne pathogens and meet the changing needs of the food industry. These proposed changes are part of our regular review process.
6. In our review, SFA considered a variety of factors including the nature (e.g. occurrence and severity) of the pathogenic microorganisms, local consumption patterns as well as global and local clinical data. We have also taken reference from principles adopted by Codex and the International Commission on Microbiological Specifications for Foods (ICMSF) for establishing microbiological standards, as well as standards/guidelines from the major developed countries, namely Australia, Canada, the European Union, Japan, New Zealand and the United States, with adaptation to Singapore’s context.
Proposed Changes to Existing Standards
7. Based on the review, SFA proposes the following changes to the existing microbiological standards for non-RTE food (Table 1). A detailed comparison of the existing and proposed microbiological standards can be found in Annex A.
Table 1: Summary of Proposed Changes to Existing Microbiological Standards
S/N | Proposed Change | Rationale |
|---|---|---|
1 | Removal of microbiological standards for hygiene indicator microorganisms (e.g. Total Plate Count, Escherichia coli Count, Coagulase positive Staphylococcus aureus Count) across all product categories, with the proposed standards to focus on pathogens only. | Most countries set and enforce microbiological standards only for pathogens in their legislation. Where microbiological standards for hygiene indicator microorganisms are set, these standards are used to recommend improvements in production hygiene, and not used to reject lots / consignments of finished product. |
2 | Standardisation of the number of sampling units (n) to 5, except for small consignments (defined in paragraph 9) where 1 sampling unit will be taken. | Improves sampling accuracy, reducing the chances of false results. |
3 | Inclusion of standards for emerging pathogens which are known to pose significant food safety concern, such as non-O157 Shiga-toxin producing Escherichia coli and Vibrio vulnificus. | To protect consumers from emerging pathogens based on the latest scientific evidence and trends. |
4 | Removal of standards for pathogens-product combinations which are not known to pose significant food safety concern, including Listeria monocytogenes in meat and meat products, and Escherichia coli O157:H7 in meat and meat products (excluding non-intact beef products) and egg products. | Allows SFA, overseas authorities and the industry to focus their efforts and resources on areas of higher food safety concern as only microorganisms deemed to be of high food safety concern are included in the standards. |
Proposed Microbiological Standards for Non-RTE Food
8. The proposed microbiological standards for the various non-RTE product categories are in Tables 2 to 6 below. The parameters used to set the standards (n, c, m, M) are defined in Annex B, while the test methodology used by SFA for the various testing parameters are listed in Annex C.
9. In Tables 2 to 6 below, “small consignment” means —
(a) for a consignment of shell eggs, a consignment that does not exceed 10,000 shell eggs; and
(b) for a consignment of any other article of food, a consignment that does not exceed 100 kg or 50 units of the article of food.
Table 2 — Beef Products (non-intact3)
Pathogen | n | c | m | M |
|---|---|---|---|---|
1. Escherichia coli O157:H7 | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
2. Non-O157 Shiga-toxin producing Escherichia coli (O26, O45, O103, O111, O121, O145) | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
Table 3 — Blood-cockles and Oysters
Pathogen | n | c | m | M |
|---|---|---|---|---|
1. Salmonella spp. | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
2. Shigella spp. | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
3. Vibrio cholerae | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
4. Vibrio parahaemolyticus | 5 (except for a small consignment, one) | 2 (except for a small consignment,0) | 100 colony forming units in one g | 1000 colony forming units in one g |
Table 4 — Meat and Meat Products4
Pathogen | n | c | m | M |
|---|---|---|---|---|
1. Salmonella Enteritidis | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
2. Salmonella spp. (except for Salmonella Enteritidis, Salmonella Typhi, Salmonella Paratyphi A and Salmonella Paratyphi B) | 5 (except for a small consignment, one) | 1 | Not detected in 25 g | Not detected in 25 g |
3. Salmonella Typhi | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
4. Salmonella Paratyphi A | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
5. Salmonella Paratyphi B | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
Table 5 — Pasteurised Poultry Shell Eggs and other Pasteurised Egg Products
Pathogen | n | c | m | M |
|---|---|---|---|---|
1. Listeria monocytogenes (for any pasteurised liquid egg product) | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
2. Salmonella spp. | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
Table 6 — Raw Poultry Shell Eggs and other Raw Egg Products
Pathogen | n | c | m | M |
|---|---|---|---|---|
1. Salmonella Enteritidis | 5 (except for a small consignment, one) | 0 | Not detected in 25 g | Not detected in 25 g |
Request for comments
10. SFA invites views and comments on the proposed microbiological standards for non-RTE food in Tables 2 to 6 above. Should you disagree with the proposed microbiological standards for non-RTE food, please propose alternative microbiological standards and provide supporting information for your proposal.
Procedure and timeframe for submitting views and comments
11. All submissions should be clearly and concisely written and should provide a reasoned explanation for any proposed revisions.
12. Submissions should reach SFA no later than 12:00 p.m. (Singapore time; UTC+8), 18 Apr 2023, through email with the subject title “Proposed Microbiological Standards for Non-RTE Food”, to the following address: adeline_yong@sfa.gov.sg
Have any thoughts and views on this?
1 RTE food means “any article of food that is made available for sale for direct human consumption without the need for cooking or any other form of processing to eliminate, or reduce to a microbiological standard specified in the Eleventh Schedule, any pathogenic or other micro-organism of concern in the article of food”, and “includes cup noodles, fruit juice cordial, squash or syrup, powdered beverages and other concentrated food which are meant to be reconstituted or diluted with fluids before consumption”.
2 https://www.sfa.gov.sg/regulatory-limits/limits-for-incidental-constituents-in-food
3 “Non-intact”, for a beef product, means a beef product that has been, or will be, subject to a process (for example, injection with a solution, mechanical tenderisation or comminution) that allows pathogens to penetrate below the beef product’s exterior surface into the beef product’s interior.
4 Meat and meat products include poultry, beef, pork, lamb, amphibian, reptile, venison, game.
Annex A - Detailed Comparison of Existing and Proposed Microbiological Standards [PDF, 136 KB]
Annex B - Parameters of Sampling Plan Used to Set Microbiological Standards [PDF, 99 KB]
Annex C - Methodology for Testing Parameters [PDF, 33 KB]
Food (Amdt_NRTEmicrobiologicalstds) Regs2023 - (v01.13) [PDF, 103 KB]