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
Detailed Description


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.

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.

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:

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


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”)