CONSULTATION ON DRAFT FOOD (AMENDMENT NO. Y) REGULATIONS 2023 (PROPOSED MICROBIOLOGICAL STANDARDS FOR NON-READY-TO-EAT (NON-RTE) FOOD)

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

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)

Table 3 — Blood-cockles and Oysters