MEMORANDUM 2
Submitted by the Advisory Committee on
the Microbiological Safety of Food
1. As Chairman of the Advisory Committee on
the Microbiological Safety of Food (ACMSF), I am grateful for
the opportunity to submit this Memorandum of Written Evidence
to the Food Standards Committee in connection with its examination
of the adequacy, effectiveness and practicability of the proposals
contained in the draft Food Standards Bill (Column 4249). Whilst
I recognise that the Agency will have a very wide remit in relation
to food assurance, this Memorandum focuses on the microbiological
safety of food, reflecting the remit of the Committee which I
chair.
ADVISORY COMMITTEE
ON THE
MICROBIOLOGICAL SAFETY
OF FOOD
2. By way of background, it should be explained
that the ACMF, which is a non-statutory body set up to provide
UK Health and Agriculture Ministers with independent advice, was
established in December 1990, on the recommendation of the Richmond
Committee,1 with the following terms of reference:
to assess the risk to humans of microorganisms
which are used or occur in or on food and to advise Ministers
on the exercise of powers in the Food Safety Act relating to the
microbiological safety of food.
3. The ACMF is concerned with the whole food
chain, from plough to plate, advising specifically on the microbiological
aspects of food safety. The current membership of the Committee
is as Annex A.
THE COMMITTEE'S
REPORTS
4. The Committee publishes Annual Reports, 2,
3, 4, 5, 6, 7, 8. These review the topics which the Committee
has addressed during the reporting period, chart progress on implementing
past recommendations, and summarise on-going and planned future
work. Each Report also contains a Register of Members' Interests.
5. The Committee has also reported to Ministers
on a number of specific topics, viz vacuum packaging and
associated processes,9 Salmonella in eggs,10
Campylobacter,11 VTEC,12 poultry
meat13 and Foodborne Viral Infections.14
Report on Vacuum Packaging and Associated Processes9
6. In this Report, the Committee drew the attention
of industry, enforcement authorities and consumers to the potential
risk from botulism if proper care was not taken over the production
of extended shelf-life vacuum and modified atmosphere packaged
chilled foods. The Report recommended that, in order to prevent
growth of Clostridium botulinum and the production of toxin,
chilled prepared foods with an assigned shelf-life greater than
10 days should contain one or more controlling factors in addition
to chill temperatures. Controlling factors in this context included
heat treatment, acidity and salt levels, and water activity. The
Report made recommendations on the level of such controlling factors.
7. It also recommended that there should be
a comprehensive and authoritative Code of Practice for the manufacture
of vacuum and modified atmosphere packaged chill foods, with particular
regard to the risks of botulism. This should cover, amongst other
things, awareness and use of HACCP—Hazard Analysis Critical
Control Point, the systematic technique for the management of
food hygiene practice in all aspects of the food chain.
Salmonella in Eggs10
8. The Committee's Report on Salmonella
in Eggs assessed the importance of eggs as a source of human Salmonella
infection. The Report contained recommendations on the storage
and handling of eggs and for an industry/retailer Code of Practice
to be prepared and introduced. There were also recommendations
covering the maximum time after laying by which eggs should be
consumed, the refrigerated storage of eggs in the home, and the
use of pasteurised egg for egg dishes intended to be eaten raw
or only lightly cooked.
9. The Report contained an unequivocal endorsement
of the Chief Medical Officer's (COM's) advice that people should
avoid eating raw eggs and that vulnerable groups should eat only
eggs cooked until both yolk and white are solid. The Committee
called upon Government to review the continuing need to compulsorily
slaughter laying flocks infected with Salmonella enteritidis
and to update existing Codes of Practice for the control of Salmonella
in laying flocks. There was a recommendation for periodic surveys
to monitor trends in Salmonella infection in eggs and topics
were identified for future research.
Interim Report on Campylobacter11
10. A major difficulty with Campylobacter
is that most cases are sporadic and unconnected, making it very
difficult to establish the role of different foods. A key thrust
of the ACMSF's Interim Report on Campylobacter was the
need for further research and surveillance on the organism, specifically
in relation to typing, isolation and identification, disease causing
potential, prevalence, transmission and infection—to fill
gaps in the understanding and knowledge of this important food
poisoning pathogen. The Committee also impressed upon industry
and consumers the crucial importance of giving proper attention
to effective temperature control, thorough cooking, the avoidance
of cross-contamination, education and training. It was also recommended
that all sectors of the food industry should adopt a HACCP-based
approach to the control of potential microbiological hazards.
Report on Verocytotoxin—Producing Escherichia
coli (VTEC)12
11. The Committee's VTEC Report contained a
clear warning of the dangers of this group of microorganisms,
including E. coli O157, reflecting their capacity to infect
at low dosage and the particularly harmful effects of the illness
itself. The Report warned of the dangers of VTEC in meat products
and strongly endorsed the COM's advice on the thorough cooking
of burgers.13 It recommended the adoption of a HACCP-based
approach to prevent contamination by, or the survival of, VTEC.
During 1998 the ACMSF amplified its advice on cooking burgers
and this was reflected in revised advice from the CMO.14
12. A strong message from the ACMSF VTEC Report
was that the sale of raw milk to consumers for direct consumption
should be banned in England, Wales and Northern Ireland as it
is in Scotland. The vital importance of carefully controlling
pasteurisation in relation to milk and milk products and the need
to avoid post-pasteurisation contamination were also stressed.
The Report emphasised the importance in public health terms of
good practice in managing outbreaks and the need for thorough
epidemiological investigation. Other recommendations called for
research and surveillance to fill gaps in knowledge and assist
in the development of preventative and control measures.
Report on Poultry Meat15
13. The ACMSF Report on Poultry Meat included
details of surveillance showing that over one-third of retail
chickens sampled carried Salmonella, a situation which
the Committee regarded as unacceptable. The Report took a comprehensive
look at all aspects of the production and handling of poultry
meat from farm to fork and contained recommendations which the
Committee believes will serve as a sound basis for improving the
microbiological status of poultry meat through action at each
stage of the supply chain. A call was made for ambitious but achievable
targets to be set for bringing about improvements and the ACMSF
concluded that it saw no reason in principle why the prevalence
of Salmonella contamination in the finished raw product
should not within the next few years be greatly reduced using
existing available technology. The longer-term aim should be the
effective elimination of poultry meat as a significant source
of Salmonella in the nation's food supply.
14. The Report contained specific recommendations
for improved monitoring and research aimed at widening knowledge
of Campylobacter, improving the design of broiler farm
and hatchery buildings, upgrading feed mills, heat treating poultry
feed, testing broiler flocks for Salmonella, improving
both the machinery and the environment in which birds are slaughtered
and processed, and more informative labelling of raw poultry products.
Particular stress was again laid on the contribution which HACCP
can make to the achievement of significant improvements.
Report on Foodborne Viral Infections16
15. The ACMSF's Report on Foodborne Viral Infections
assesses the significance of viruses as agents of foodborne infection
in humans. The Report makes recommendations on a range of issues
including improved surveillance, detection, reporting and control
of foodborne viral infection; the effective enforcement of Food
Hygiene Regulations17 and the development of more Guides
to Good Hygiene Practice;18 the reduction of pollution-related
illness associated with the consumption of raw or lightly cooked
bivalve molluscan shellfish; and the control of sewage sludge
and the implications of contamination of crops with human waste
material.
16. Our Report also calls for research into
effective food sanitation measures to remove or inactivate foodborne
viruses, and for the maintenance of the research effort aimed
at detecting and isolating viruses in shellfish, on alternative
viral indicators, and on behaviour of viruses during depuration.
The Report also calls for research on the behaviour of viruses
during sewage treatment processes.
ACTION ON
REPORTS
17. It is the Government's practice to issue
formal responses to the ACMSF's Reports.19,20,21,22,23,24 Examples
of developments which have flowed as a direct result of action
recommended by the ACMSF include:
— the publication of Codes of Practice
in a number of important areas, including the manufacture of chilled,
vacuum and modified atmosphere packaged foods; the handling and
storage of eggs from farm to retail; the prevention and control
of Salmonella in broiler flocks; the control of Salmonella
in animal feed raw materials and finished feeds; etc.
— the widespread dissemination, including
through Chief Medical Officer announcements, of the ACMSF's advice
on the consumption of raw and lightly cooked eggs and the proper
cooking of burgers and similar minced meat products;
— enhanced Government research and
surveillance programmes, particularly in relation to Campylobacter,
Salmonella and E. coli;
— the establishment of Campylobacter
reference facilities in England, Wales and Scotland;
— the introduction of a special emphasis
programme to build on the recommendations from our Poultry Meat
Report;
— the implementation of a national
training and certification scheme for the red meat industry;
— the advice provide by the ACMSF to
Ministers in respect of the use of antibiotics as growth promoters
helped with the development of the UK's negotiating position for
the recent EU debate on this subject;
— in line with strong and consistent
ACMSF advice, the Government has increasingly encouraged the adoption
of HACCP principles in food operations.
18. The ACMSF has instituted a review of progress
across all of the subject-specific reports for which formal Government
responses have so far been issued.
CURRENT WORKING
GROUPS
19. The ACMSF Working Group on Microbial Antibiotic
Resistance in relation to Food Safety has completed its work and
has recently submitted its Report to Ministers. The Report is
a comprehensive study of this important topic. It assesses the
risks from antibiotic resistant microorganisms entering the food
chain and considers the need for action to protect public health.
It proposed a new approach to the use of antimicrobials in the
rearing of food animals.
20. A Working Group on Salmonella in
Eggs was set up in 1998 to establish the factors which determine
the presence of Salmonella contamination in or on eggs
and to recommend measures to reduce such contamination and consumers'
exposure to it. The setting up of this Working Group reflects
the results of a study of Salmonella contamination of UK-produced
retail eggs25 showing that the overall contamination rate had
not improved significantly since a familiar survey carried out
in 1991.26, 27
MISCELLANEOUS ADVICE
21. In addition to the advice provided through
its subject-specific reports, the ACMSF also provides assessments
of the human health implications of a range of microbiological
food safety issues referred to it by Government. In the past year,
topics addressed include raw milk, agricultural disposal of sewage
sludge, Mycobacterium paratuberculosis, and infectious
salmon anaemia.
THE FOOD
STANDARDS AGENCY
22. The ACMSF welcomes the Government's intention
to establish a Food Standards Agency and supports the broad thrust
of the draft Bill. We expect the setting up of the Agency to provide
an opportunity both for a fresh start on food safety and to restore
public confidence in the safety of food. The tasks facing the
Agency are complex and diverse. A sustained effort will be required
if meaningful improvements are to be achieved. The Agency will
need to give particular attention to the question of co-ordination
across the UK. The food industry is highly integrated and pathogens
are no respects of geographical boundaries. There could be very
real implications for food safety, if, for example, the establishment
of separate advisory committees in the constituent parts of the
UK give rise to fundamental differences of approach in tackling
food safety issues.
23. The ACMSF recognises that its own position
will change once the Agency is established and that the focus
of the Committee's advice will shift to the Agency. The Committee
will play an important party in support of the new FSA. The ACMSF
has a powerful mix of skills and expertise at its disposal—lay
members, medical, veterinary and microbiological experts, industry
technologists, and public health and enforcement specialists.
Microbiological safety is not a mater for microbiology experts
alone. Matters such as kitchen layout, cooking, personal hygiene
or factory operations can be vital and we benefit from experienced
advice. Our Reports, which contain advice and recommendations
of a scientific and practical nature, reflect this mix. The ACMSF
has also agreed a number of measures designed to provide greater
public access to our deliberations and recommendations. We are
confident that we will successfully align our advisory work with
the needs of the proposed new Agency.
March 1999
REFERENCES
1. The Microbiological Safety of
Food. Parts I and II. Report of the Committee on the Microbiological
Safety of Food (Sir Mark Richmond). London:HMSO, 1991.
2. Advisory Committee on the Microbiological
Safety of Food (1993). Report of Progress 1990-92. HMSO, London.
3. Advisory Committee on the Microbiological
Safety of Food (1994). Annual Report 1993. HMSO, London.
4. Advisory Committee on the Microbiological
Safety of Food (1995). Annual Report 1994. HMSO, London.
5. Advisory Committee on the Microbiological
Safety of Food. Annual Report 1995. Department of Health, Wetherby.
6. Advisory Committee on the Microbiological
Safety of Food. Annual Report 1996. Department of Health, Wetherby.
7. Advisory Committee on the Microbiological
Safety of Food (1998). Annual Report 1997. Department of Health.
8. Advisory Committee on the Microbiological
Safety of Food. Annual Report 1998. In preparation.
9. Advisory Committee on the Microbiological
Safety of Food (1992). Report on Vacuum Packaging and Associated
Processes. HMSO, London.
10. Advisory Committee on the Microbiological
Safety of Food (1993). Report on Salmonella in Eggs. HMSO,
London.
11. Advisory Committee on the Microbiological
Safety of Food (1993). Interim Report on Campylobacter.
HMSO, London.
12. Advisory Committee on the Microbiological
Safety of Food (1995). Report on Verocytotoxin-Producing Escherichia
coli. HMSO, London.
13. Department of Health Press Notice
of 14 February 1991. Sir Donald Acheson's advice on cooking beefburgers.
14. Department of Health. Press Release
98/316 of Friday 31 July 1998. Revised Guidance on Safe Cooking
of Burgers.
15. Advisory Committee on the Microbiological
Safety of Food (1996). Report on Poultry Meat. HMSO, London.
16. Advisory Committee on the Microbiological
Safety of Food. Report on Foodborne Viral Infections; 1998. London
: The Stationery Office.
17. The Food Safety (General Food
Hygiene) Regulations 1995. SI 1995 No. 1763.
18. Department of Health. EC Food
Hygiene Directive. A template. Industry Guides to Good Hygiene
Practice. Wetherby: Department of Health, 1994.
19. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Report on Vacuum Packaging and Associated Processes.
Recommendations and Government's response. Ministry of Agriculture,
Fisheries and Food; 1992.
20. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Salmonella in Eggs. Recommendations and
Government's response. Ministry of Agriculture, Fisheries and
Food; 1993.
21. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Interim Report on Campylobacter. Recommendations
and Government's response. Department of Health; 1993.
22. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Report on Verocytotoxin-Producing Escherichia
coli (VTEC). Recommendations and Government's response. Department
of Health; 1995.
23. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Report on Poultry Meat, Recommendations and Government's
response. Ministry of Agriculture, Fisheries and Food; 1995.
24. Ministry of Agriculture, Fisheries
and Food. Department of Health. Advisory Committee on the Microbiological
Safety of Food. Report on foodborne viral infections. Recommendations
and Government's response. Department of Health; 1998.
25. Department of Health. Microbiological
Food Safety Surveillance. Survey of Salmonella contamination
of UK-produced retail eggs. In preparation.
26. de Louvois J. Salmonella
contamination of eggs; a potential source of human salmonellosis.
PHLS Microbiol Dig 1993; 10(3): 158-162.
27. de Louvois J. Salmonella
contamination of eggs. Lancet 1993; 342: 366-367.
ANNEX A
MEMBERSHIP OF THE ADVISORY COMMITTEE ON THE
MICROBIOLOGICAL SAFETY OF FOOD
| |
| Membership | |
| |
| Chairman | |
| Professor D L Georgala | Independent scientific consultant. Retired Director of the Institute of Food Research
|
| |
| Members | |
| Mr D Clarke | Operations Manager, Assured British Meat
|
| Dr T Clayton | Technical Executive, Marks and Spencer plc
|
| Professor R J Gilbert | Head of Food Safety Policy Development, Public Health Laboratory Service. Visiting Professor at the Royal Veterinary College, University of London
|
| Mrs P Jefford | Environmental Health Services Manager, Gravesham Borough Council
|
| Professor A M Johnston | Professor of Veterinary Public Health, Royal Veterinary College, University of London
|
| Mr D Kilsby | Head of Food Microbiology Research, Unilever plc, Colworth Laboratory
|
| Ms E Lewis | Computer consultant. Consumer representative
|
| Dr M J Painter | Consultant in Communicable Disease Control, Infection Control and Surveillance Unit, Public Health Laboratory Service (North West)
|
| Professor S R Palmer | Chairman of Division, Department of Epidemiology and Public Health, University of Wales College of Medicine
|
| Dr T A Roberts | Retired Head of Microbiology, Institute of Food Research
|
| Dr N A Simmons | Emeritus Consultant in Microbiology to the Guy's and St Thomas' Hospital Trust; Honorary Senior Lecturer in Microbiology, St Bartholomew's and the Royal London School of Medicine and Dentistry
|
| Professor W C S Smith | Head, Department of Public Health, University of Aberdeen and Honorary Consultant in Public Health medicine, Grampian Health Board, Aberdeen
|
| Dr J V Stevens | Group Technical Director, Unigate European Food
|
| Mrs B W Thomas | Consumer consultant
|
| Dr T D Wyatt | Consultant Clinical Scientist, Mater Hospital Trust, Belfast
|
| |
| |
| 
