Consultation on Proposed Amendments to the Food Regulations Regarding Microbiological Standards for Ready to Eat (RTE) Food

Agri-Food & Veterinary Authority

Agri-Food and Veterinary Authority - Regulatory Programmes Department

Consultation Period: 22 Aug 2017 - 23 Oct 2017
Status: Closed - Summary of Responses
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Responses To Comments Received From The Public Consultation On Proposed Amendments To The Food Regulations Regarding Microbiological Standards For Ready-To-Eat (RTE) Food

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.

Issue I

Four companies expressed support for the proposed definition; of which one was a major food retailer, two were food manufacturers, and the last was a food ingredient supplier.
Four companies sought clarification on the scope of the proposed definition. AVA has responded to the companies on the scope of the proposed definition with details in Table 1 of the Annex.

Issue II

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.

Issue III

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.

Others

Units for microbiological limits
One company and a foreign government suggested the inclusion of Most Probable Number (MPN)/g, in addition to Colony Forming Unit (CFU)/g. AVA responded that the unit of CFU/g count is currently being adopted in the major developed countries (such as Australia, New Zealand, Canada, and United Kingdom) as well as in other countries such as Hong Kong. Taking reference from these countries, AVA would be standardizing the units to CFU/g for consistency and clarity.

Rationale for testing TPC and indicator organisms in RTE food
Two foreign governments queried on the rationale for conducting tests for TPC and indicator organisms in RTE food. AVA has responded that the proposed standards are applicable not only to pre-packaged foods, but also to RTE foods served at food and beverage (F&B) outlets and food services. As the local population largely eats out and, in addition, food sold at these outlets may be cooked in advance and subjected to further handling (such as cutting, chopping, mixing) without a kill step before serving, TPC and indicator organisms serve as useful hygiene indicators for verifying the operator’s hygiene practice.

Pathogen tests
Three foreign governments commented that the listed pathogens may not be relevant for all RTE food, and queried on the rationale for testing the listed pathogens in RTE food. Two companies commented that it would be costly for companies to test for all of the pathogens specified in paragraph 7 of the consultation paper. Two other companies sought clarification on the type of pathogen tests to be conducted for RTE food.

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.

Conclusion
AVA appreciates the time taken by individuals and organisations to submit feedback and comments which have contributed to the decision making process, and would like to encourage all food industry members to actively participate in future calls for comments.

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.

ANNEX

Table 1: AVA’s response to queries on proposed definition

Table 1

Table 2: AVA’s response to queries on product classification for total plate count limits

Table 2

Detailed Description

Aim

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.

Background

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.

Proposed amendments

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.

5 Total plate count (TPC) is used as an indicator of bacteria load in a sample. It depends on the method of processing of the food, as well as the duration of processing. Other factors include handling and storage of the food, as well as the microbial load in the raw ingredients used to produce the food. Hence it is not appropriate to impose the same limit for TPC for all types of RTE foods. AVA therefore proposes the following TPC limits for RTE food, which takes into consideration the intrinsic properties of the food as well as its manufacturing process:

Type of Food
6 Indicator organisms have been used to assess the microbiological status of food, and they have become important components of the microbiological testing programs of both industry and regulatory agencies. Some commonly used indicator organisms are the coliforms and Escherichia coli. AVA proposes to adopt the following microbiological standard for coliforms and Escherichia coli in RTE food. The proposed limit of 102 cfu/g for Escherichia coli is consistent with the limits established by Australia, Canada, Ireland, New Zealand, and the UK.

Type of Food
7 As the presence of foodborne pathogens in RTE food poses a significant health risk, AVA proposes to establish a zero tolerance for most pathogen species in RTE food. Exceptions to this are Coagulase-positive Staphylococcus aureus, Clostridium perfringens, Bacillus cereus and Vibrio parahaemolyticus, where low numbers in RTE products represent a low risk to healthy individuals.

Pathogens
Request for comments

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.


Procedure and timeframe for submitting views and comments

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:

Mail:
Regulatory Programmes Department
Agri-Food & Veterinary Authority of Singapore
52 Jurong Gateway Road
#13-01 Singapore 608550 (Attention: Ms Leong Ai Ling)

Email: 

1 “Ready-eat-eat food” means food intended by the producer or the manufacturer for direct human consumption without the need for cooking or other processing effective to eliminate or reduce to an acceptable level the microorganisms of concern (Source: HK Centre for Food Safety “Microbiological Guidelines for Ready-to-Eat food in General and Specific Food Items” and UK Health Protection Agency “Guidelines for Assessing the Microbiological Safe of Ready-to-Eat Foods Placed on the Market”)