Issue View | Council III | 2016 Scribe Packet
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Issue Number: Council III 035
This issue was submitted for consideration at a previous biennial meeting, see issue: 2014, III-023 ; new or additional information has been included or attached .
Revise Food Code to be Consistent with FSIS Requirements and Guidance
Issue you would like the Conference to consider
The Food Safety Inspection Service (FSIS) and Food and Drug Administration (FDA) are submitting a joint issue to revise the Food Code to be consistent with FSIS Requirements and guidance. In this proposal FSIS and FDA are recommending adding a new definition in Chapter 1 to the 2013 FDA Food Code for the term INTACT MEAT and to revise the minimum time and temperatures in § 3-401.11 Cooking for meat and poultry products to reflect FSIS cooking guidance. Making the Food Code instructions consistent with FSIS regulatory framework and cooking guidance will decrease confusion and help ensure that the products are cooked properly to destroy pathogens that could cause foodborne illness.
FSIS previously submitted this issue in 2010, and the conference recommended that FSIS and FDA work together to bring a proposal to the 2014 meeting to harmonize cooking times and temperatures. The issue was also submitted in 2014, and no action was taken because the conference said that there was no specific request at that time. Since 2014, FSIS and FDA have worked together to develop a joint issue to provide specific recommendations to harmonize the cooking times and temperatures.
Public Health Significance
The FDA Food Code § 3-401.11(A)(1) applies to fish and meat, including game animals, and specifies that the products can be cooked to 63°C (145°F) for 15 seconds. This time and temperature combination is only appropriate for intact portion cuts of meat, because the contamination is expected to be on the outside of the product, so the product should be safe if the external surface is cooked to 145°F (National Advisory Committee on Microbiological Criteria for Foods, 1997). Although there are exceptions in § 3-401.11(A)(2) for non intact products (mechanically tenderized, injected, or comminuted), it is not clear that the instructions in § 3-401.11(A)(1) only apply to intact products. Therefore FSIS and FDA recommend a new definition for the word INTACT MEAT as follows:
"Intact meat" means a cut of whole muscle(s) MEAT that has not undergone comminution, injection, mechanical tenderization, or reconstruction.
Adding this new definition to the FDA Food Code will clarify which instructions apply to intact meat and which apply to non-intact meat. Making these clarifications would alleviate confusion and ensure that retailers cook meat products using the proper times and temperatures to ensure food safety.
Section 3-401.11(A)(2) applies to mechanically tenderized meats and specifies that they should be cooked at 68°C (155°F) for 15 seconds. However, according to the FSIS Guidance on Safe Cooking of Non-Intact Meat Chops, Roasts, and Steaks, non-intact products should be held at 68°C (155°F) for 17 seconds. Other time and temperature combinations in the table in § 3-401.11(A)(2) would also provide a 5-log reduction of Salmonella in these products. Therefore, FSIS and FDA recommend that the time the product is held is increased from 15 seconds to 17 seconds to be consistent with the table, and the other time and temperature combinations from the table in the FSIS guidance are provided in the Annex.
Section 3-401.11(A)(3) applies to poultry products and recommends that they are cooked at 74°C (165°F) or above for 15 seconds. According to the FSIS guidance in the Time-Temperature Tables for Cooking Ready-to-Eat (RTE) Poultry Products, poultry products can be cooked to 74°C (165°F) instantaneous to achieve a 7-log reduction of Salmonella. Therefore, FSIS and FDA recommend deleting the 15 second dwell time from the minimum criteria specified in that subparagraph and changing it to instantaneous. This change is also consistent with CFP Issue # 2002-I-33, which recommended that USDA and FDA work together to establish instantaneous cooking temperatures for animal products that have minimum dwell time of 15 seconds. In addition, FSIS and FDA recommend that retailers have the option of cooking poultry products using the additional time and temperature combinations in the FSIS poultry tables and adding this information in the Food Code Annex.
Section 3-401.11(B) applies to roast beef, corned beef and other products and indicates that they should be cooked using the time and temperature combinations in the table titled "Oven Temperature Based on Roast Weight." These time and temperature combinations are from FSIS Appendix A and achieve a 6.5-log reduction of Salmonella, however only some of the time and temperature options have been provided. FSIS and FDA recommend that all of the time temperature options from Appendix A are provided in the Annex.
NACMCF, 1997. Recommendations for Appropriate Cooking Temperatures for Intact Beef Steaks & Cooked Beef Patties for the Control of Vegetative Enteric Pathogens. U.S. Department of Agriculture, Food Safety and Inspection Service, Washington, DC.
FSIS Guidance on Safe Cooking of Non-Intact Meat Chops, Roasts, and Steaks, found at: http://www.fsis.usda.gov/wps/wcm/connect/bb25d746-dcb0-4d1b-8833-c4bf1ceb1140/5-log-Temperature-Time-Table-Salmonella.pdf?MOD=AJPERES
Appendix A. Compliance Guidelines for Meeting Lethality Performance Standards For Certain Meat And Poultry Products, found at: http://www.fsis.usda.gov/wps/wcm/connect/212e40b3-b59d-43aa-882e-e5431ea7035f/95033F-a.pdf?MOD=AJPERES
Time-Temperature Tables for Cooking Ready-to-Eat Poultry Products, found at: http://www.fsis.usda.gov/wps/wcm/connect/9ab2e062-7ac8-49b7-aea1-f070048a113a/RTE_Poultry_Tables.pdf?MOD=AJPERES
Recommended Solution: The Conference recommends...
that a letter be sent to FDA recommending that the 2013 FDA Food Code be modified to reflect the following (language to be added is underlined):
Provide a new definition in Chapter 1 Purpose and Definitions for the term INTACT MEAT to read: "Intact meat" means a cut of whole muscle(s) MEAT that has not undergone comminution, injection, mechanical tenderization, or reconstruction.
Clarify which criteria apply to INTACT MEAT (cook to 145°F for 15 sec internal temperature).
Revise the minimum cooking temperature that applies to mechanically tenderized and injected meats, from 155°F for 15 seconds to 155°F for 17 seconds.
Revise the minimum cooking temperature that applies to poultry from 165°F for 15 seconds to 165°F instantaneous.
Provide additional time/temperature combinations from Appendix A, the FSIS Guidance on Safe Cooking of Non-Intact Meat Chops, Roasts, and Steaks and the Time-Temperature Tables for Cooking Ready-to-Eat Poultry Products in the Food Code Annexes.