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Prepared but not RTE foods – Challenges faced by the industry
IAFP Latin America Symposium on Food SafetyCampinas, SP, Brazil
May 26, 2008
Robert E. Brackett, Ph.D.Senior Vice President and
Chief Science and Regulatory Affairs OfficerGrocery Manufacturer’s Association
Modern Food Industry
• New Generation of Food Products– Ready-to-eat or RTE
• Fully cooked or needs no cooking• Ready to be eaten as-is or after reheating
Modern Food Industry
• New Generation of Food Products– Ready-to-eat or RTE
• Fully cooked• Ready to be eaten as-is or after reheating
– Not-ready-to-eat or NRTE• Prepared with ingredients that are not fully cooked• Require further cooking to assure microbial safety
Food Industry Challenges
Assuring the Safety of NRTE Products
Vehicle for Outbreaks
• Increasingly being recognized as a vehicle for outbreaks by the CDC
Vehicle for Outbreaks• Increasingly being recognized as a vehicle for
outbreaks by the CDC– S. Heidelberg and S. Enteritidis associated with raw
“flash-fried” or “par fried” breaded chicken nuggets and chicken strips in Canada and Australia
– Salmonellosis associated with raw, frozen, microwavable, breaded, pre-browned stuffed chicken products in the United States (Minnesota)
• S. Typhimurium associated with chicken Kiev and other stuffed chicken products
• S. Heidelberg associated with chicken Kiev• S. Enteritidis associated with multiple brands and multiple
varieties of stuffed chicken products
Common Themes
• Frozen, microwavable processed foods
• Consumer confusion over the raw or cooked nature of products
• Consumers did not follow package cooking instructions
Vehicle for Outbreaks
• Outbreaks highlight the need for NRTE foods to be thoroughly cooked before consumption.
The Consumer
• Frozen foods sales in the U.S. are up 5% from 2007– Sales represent 12% of U.S. food and
beverage sales• Third largest category in the marketplace
The Consumer
• Frozen foods sales are up 5% from 2007
• Labeling Confusion– How to determine RTE from NTE
• Products look similar• Subtle differences in labeling
The Consumer
• Frozen foods sales are up 5% from 2007
• Labeling Confusion
• Reliance on consumer for adequate handling
Industry Responsibility
• Assure ingredients are of the highest microbiological quality– Minimize the potential for consumer
preparation errors to result in illness
Industry Responsibility• Assure ingredients are of the highest
microbiological quality
• Validate consumer cooking instructions– Important and effective tool for ensuring safe
consumption of NRTE products by consumersFOR FOOD SAFETY AND QUALITY, FOLLOW THESE COOKING DIRECTIONS:Microwave Oven(Ovens vary; cooking time mayneed to be adjusted)PLACE tray on microwave-safe plate; slit top crustMICROWAVE on HIGH.Med. OR High Wattage Microwave 4 minsLow Wattage Microwave 6 minsLET STAND 3 minutes.CAREFULLY remove as PRODUCT WILL BE HOT
Conventional Oven(fine print: Do not prepare in toaster oven)PREHEAT oven to 400F.Place tray on cookie sheet,slit top crust.BAKE in oven 30 to 32 minutes.CAREFULLY remove asPRODUCT will be hot.Let Stand 5 minutes.
Cooking Instruction Validation
• Types of validation– Product temperature
• Cook following instructions on label• Determine product temperatures
Cooking Instruction Validation
• Product temperature• What temperature is appropriate?
– Is the same temperature appropriate/needed for all products?
– Single temperature or time/temperature combinations?
– What level of lethality is required?
Cooking Instruction Validation
• Product temperature• What temperature is appropriate?
– Is the same temperature appropriate/needed for all products?
– Single temperature or time/temperature combinations?
– What level of lethality is required?» In general, 160°F (165°F for products containing raw
poultry) provides adequate lethality» Target lethality may be different for products
containing cooked meat or poultry components
Cooking Instruction Validation
• Types of validation– Product temperature– Microbiological inactivation
Cooking Instruction Validation
• Microbiological inactivation– Temperature studies
• Products with a higher risk of microbial contamination (e.g., products containing raw meat)
• Cases were validation testing results show inconsistent attainment of product target temperature
– Justification for the log reduction targeted for microbiological inactivation should be provided.
Validation Challenges
• Variability factors – Product and package factors
• Composition• Size• Shape• Components• Package configuration• Initial temperature
Validation Challenges
• Variability factors – Product and package factors– Cooking device
• Stovetops • Fryers• Conventional and toaster ovens• Microwave oven
Microwave Cooking Practices
15
58
59
72
79Follow all of theCooking Instructions
Flip, rotate, or stir duringthe microwave cookingprocess
Increase or decreasecooking time based onmy microwave
Check microwave wattage
Use a food thermometerto be sure food reachesrequired temperature
Validation Challenges
• No single approach to conducting validation studies
• All cooking instruction validation studies have a common goal– Ensure NRTE cooked according the
instructions are safe to consume
Regulatory Focus
• Collecting relevant data in NRTE operations
Regulatory Focus
• Collecting relevant data in NRTE operations– Microbiological profile of environment and
product
Regulatory Focus
• Collecting relevant data in NRTE operations– Microbiological profile of environment and
product– Validation document in support of cooking
instructions• Evidence that consumers understand and will
follow the instructions
Regulatory Focus
• Collecting relevant data in NRTE operations– Microbiological profile of environment and
product– Validation document in support of cooking
instructions– Address labeling and GMPs
Regulatory Focus
• Collecting relevant data in NRTE operations
• Outreach and education
Regulatory Focus
• Collecting relevant data in NRTE operations
• Outreach and education– Reinforce safe cooking guidance
• Use a thermometer• Cook poultry to at least 165°• Cook non-intact meat products to at least 160°
Summary
• Food industry is providing many new and exciting products to consumers.
• Consumers are often mistaking NRTE with RTE products.
• Consumers need clear, obvious information about the product they are purchasing and its cooking requirements.
• Industry needs to validate consumer cooking instructions to ensure pathogenic microorganisms are inactivated during cooking.
• Industry and regulators must work together to find appropriate solutions.