The Agri-Food and Veterinary Authority (AVA) initiated a public consultation exercise for the period 22 August 2017 to 23 October 2017 on proposed amendments to the Food Regulations regarding microbiological standards for ready-to-eat food. Concurrently, we have also notified the WTO of the proposed amendments via notifications G/TBT/N/SGP/39 and G/SPS/N/SGP/59. Feedback was sought from stakeholders on the following:
I. Whether the proposed definition of RTE food in paragraph 4 accurately describes such food. If not, please propose an alternative definition and provide supporting information in the form of authoritative references for your proposed definition.
II. Whether the 5 categories of RTE food under paragraph 5, accurately describe all the categories of RTE food available on the market. If not, please propose additional or alternative categories and provide supporting information in the form of authoritative references for your proposal.
III. Whether the RTE food products imported / manufactured by your company are able to comply with the proposed limits for total plate count, indicator organisms and pathogens.
Two companies expressed support for the proposed total plate count limits for the 5 proposed categories of ready-to-eat food. One of the two companies also proposed to expand the descriptor for “solid food” for Category 1 products to include “semi-solid food”. A foreign government also sought clarification on the limits for “solid-liquid food” under Category 1. AVA has clarified that “semi-solid food” and “solid-liquid food” would be captured under “solid food”, with a limit of 102 cfu/g.
12 companies and 1 foreign government sought clarification on the classification of various types of RTE food products under the total plate count (TPC) categories. Of these 12 companies, eight were food manufacturers, one was a food handler, two were local food importers and the last was a food testing laboratory. AVA has responded to the companies on the classification of the food products with details in Table 2 of the Annex.
Three companies expressed concern that TPC would not be applicable to cut fruits, fruit juices and food with live cultures. AVA explained that total plate count is an indicator of bacteria load in a sample. As certain RTE food products (such as cut fruits, fruit juices and food with live cultures) contain a naturally high microbial load, it would not be practical nor appropriate to impose a TPC limit for these products.
Two companies commented that sweetened condensed milk, condensed creamer and condensed filled milk may not be able to comply with the proposed TPC limit of 1000 cfu/g under category 2(a). AVA responded that based on surveillance data, more than 90% of these products available for sale in Singapore were able to comply with the proposed limit, and that the proposed limit was reasonable and appropriate.
Five companies (two local food importers and three food manufacturers) responded regarding their ability to comply with the proposed limits for total plate count, indicator organisms and pathogens. All were supportive of the proposed amendments and informed AVA that the RTE food products imported or manufactured by their companies were able to comply with the proposed limits.
AVA responded that all RTE foods should be free of any pathogens. As food consumed in Singapore comprises composite dishes and may be consumed without all components being fully cooked, it is important to impose limits for pathogens. The list of pathogens in the proposed standards are known hazards in RTE food in the local context. AVA also clarified that the intention was not to require traders to test for all of the specified pathogens. The type of pathogen tests to be conducted would be dependent on the characteristics and risk profile of the RTE food product intended for sale in Singapore.
Two companies suggested for the limit of <200 cfu/g for Bacillus cereus to be increased. AVA has informed the companies that the proposed limit is realistic and is a safeguard to protect the health of consumers in Singapore.
Following this consultation, AVA will be further reviewing the microbiological standards, taking into consideration the comments received by stakeholders. A second round of consultation will be conducted in mid-2018 and stakeholders will be invited to provide comments.
Table 1: AVA’s response to queries on proposed definition
Table 2: AVA’s response to queries on product classification for total plate count limits
1 The Agri-Food and Veterinary Authority (AVA) is seeking feedback from stakeholders on proposed amendments to the Food Regulations concerning the microbiological standards for ready-to-eat (RTE) food.
2 Regulation 35 of the Singapore Food Regulations specifies that food that is ready for consumption should not be contaminated with Escherichia coli exceeding prescribed limits or with any pathogenic microorganisms. The Eleventh Schedule specifies the total count and coliform count for different categories of food. Details of the current microbiological standards can be found in the ANNEX.
3 As part of efforts to align Singapore’s regulations to international standards and ensure legislation is adequate to protect public health in the area of food safety, AVA, in consultation with National Environment Agency (NEA), conducted a review of the existing microbiological standards for RTE food, taking into consideration international standards, changing food production and consumption patterns, as well as the local situation.
4 AVA proposes to adopt the following definition for RTE food, taking reference from the United Kingdom (UK) and Hong Kong (HK) guidelines for RTE food1,
“Food intended by producer or the manufacturer for direct human consumption without the need for cooking or other forms of processing effective to eliminate or reduce to an acceptable level the micro-organisms of concern”.
This definition aims to provide clarity to the food industry on the type of food products that are considered to be “ready-to-eat” and for which the microbiological standards under the Food Regulations will be applicable.
AVA invites views and comments on:
i. Whether the proposed definition of RTE food in paragraph 4 accurately describes such food. If not, please propose an alternative definition and provide supporting information in the form of authoritative references for your proposed definition.
ii. Whether the 5 categories of RTE food under paragraph 5, accurately describe all the categories of RTE food available on the market. If not, please propose additional or alternative categories and provide supporting information in the form of authoritative references for your proposal.
iii. Whether the RTE food products imported / manufactured by your company are able to comply with the proposed limits for total plate count, indicator organisms and pathogens.
All submissions should be clearly and concisely written, and should provide a reasoned explanation for any proposed revisions.
Submissions should reach AVA no later than 12:00 p.m., 23 October 2017, through mail, or email, to the following addresses: