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Issue Number: Council III 018

Title

Updating ROP Criteria with regard to Cook Chill and Sous Vide

Issue you would like the Conference to consider

Section 3-502.12 Reduced Oxygen Packaging without a Variance, Criteria.

Section 3.502.12 (B)(2) currently specifies four food intrinsic properties that permit ROP without a variance: (a) Has an aw of 0.91 or less, (b) Has a pH of 4.6 or less, (c) Is a cured meat or poultry product, and (d) Is a food with a high level of competing organisms. These criteria were meant to be barriers or hurdles to the growth of psychrotrophic Clostridium botulinum and Listeria monocytogenes. As currently written the first two criteria represent the Aw growth minima for L. monocytogenes and the pH minima for Clostridium botulinum (non-psychrotrophs). For example a food product fully cooked in its bag to proper Food Code temperatures with a pH of 4.9 would not qualify despite destruction of Listeria monocytogenes via cooking and inhibition of psychrotrophic C. botulinum with a pH under 5.0. This issue seeks to clarify this section with regard to ensuring operations have at least one science-based barrier to growth (in addition to refrigeration) individually, of both psychrotrophic Clostridium botulinum and Listeria monocytogenes.

Public Health Significance

When properly performed cook-chill and sous vide processing minimizes many risks of foodborne illness. When performed improperly, these processes may lead to growth of the foodborne pathogens Clostridium botulinum (psychrotrophic strains) or Listeria monocytogenes.

Recommended Solution: The Conference recommends...

that a letter be sent to the FDA recommending that changes be made to the Food Code Section 3-502.12 Reduced Oxygen Packaging without a Variance, Criteria

To:

3.502.12 (B)(2) Except as specified under ¶¶ (C) - (E) of this section, requires that the packaged food shall be maintained at 5°C (41°F) or less and meet at least one of the following criteria for each pathogen: psychrotrophic Clostridium botulinum and Listeria monocytogenes: Pf

(a) Has an aw of 0.91 or less for Listeria monocytogenes or 0.97 or less for psychrotrophic C. botulinum,Pf

(b) Has a pH of 4.6 or less for Listeria monocytogenes or 5.0 or less for psychrotrophic C. botulinum,Pf

(c) Is a meat or poultry product cured at a food processing plant regulated by the USDA using substances specified in 9 CFR 424.21, Use of food ingredients and sources of radiation, and is received in an intact package, Pf or

(d) Is a food with a high level of competing organisms such as raw meat, raw poultry, or raw vegetables; Pf

(e) Is a food that has received a cooking step of 90°C for 10 minutes to destroy psychrotrophic C. botulinum

(f) Is a food that has been ROP packaged and subsequently cooked in the package as specified in FC 3-401 or FC 3-403.11 for Listeria monocytogenes.

(An alternative Table format of the above suggested change is included in the attachment).

Attachments

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