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November / December, 2003
The following is excerpted from a recent article in:
Meat Marketing and Technology (Oct. 2003). Vol. 10. Issue 10. pp.65-72.
FOOD SAFETY BEYOND GUIDELINES AND REGULATIONS
By: Bradley P. Marks, Ph.D., P.E.
Associate Professor of Biosystems Engineering
Michigan State University
marksbp@msu.edu
Introduction
Americans increasingly are demanding food that is more convenient,
but with a higher level of safety assurance. These changes in the market
and evolving federal regulations are creating a need for better information
related to inactivation and growth of pathogens in meat and poultry products.
Regulatory changes are shifting the burden to processors to ensure, through
scientific rationale, that a new or modified process meets performance
standards for pathogen reduction and control. Although product and process
variables are known to affect thermal resistance of bacteria, most reported
information is from laboratory studies that encompass a limited range
of conditions. In most cases, the validity of this information for commercial
processes is uncertain. Therefore, the purpose of this article is to address
three questions: (1) How do food safety regulations relate to the current
state-of-knowledge? (2) What is currently known about various factors
that might affect thermal inactivation of pathogens in meat and poultry
products? and (3) What should be done to account for these complicating
factors, now and in the future?
Relating Regulations and Guidelines to the State-of-the-Art
Heat is the primary means for both adding value and ensuring
microbial safety of meat and poultry products. Although numerous technologies
(e.g., irradiation, ultra high pressure, pulsed electric fields) loom
on the horizon for the broader food industry, the application of heat
will certainly continue as the dominant means to impart desirable characteristics,
add economic value, and ensure product safety. Additionally, major shifts
in consumer demand and regulatory burden are increasing the importance
of thermal processing. Therefore, this article focuses on thermal processing
as the key step in ensuring the safety of ready-to-eat (RTE) products.
Regulatory evolution
In terms of regulatory pressures in this domain, there is
an evolving shift from a command-and-control paradigm (i.e., meeting specific
endpoint temperatures) to lethality performance standards (USDA 1999,
2001). A central theme to these regulatory changes is the emphasis on
developing science-based regulations. For example, processors are no longer
held to specific endpoint temperatures; however, they “must validate
new or altered process schedules by scientifically supportable means”
(USDA 1999). These are suggested to include “…using information
obtained from the literature” or conducting an inoculated challenge
study (adding pathogens to a real food product prior to processing). The
proposed rule changes (USDA 2001) extend the same general approach to
all RTE products containing meat or poultry. Although the new regulatory
paradigm creates greater opportunities for customized processes, it clearly
puts significant pressure on the industry to document process lethality
for any new product or process.
State-of-the-Art
If the state-of-the-art encompasses two domains, knowledge
and tools, then it is important to assess the intersection of these domains
with the evolving regulatory domain described above (Fig. 1). In this
case, the knowledge base is comprised of the latest research related to
pathogen response to processing, product effects, etc., which will be
discussed in the next section. A fair amount of previous research has
been aimed at developing this type of knowledge. However, mere knowledge
that these effects exist is insufficient to aid a processor in designing,
operating, or evaluating the efficacy of a thermal process, in terms of
the relevant lethality performance standards. Quantitative analysis requires
tools. Operating in the area where the regulatory and knowledge domains
overlap may result in food safety decisions that are essentially “educated
guesses”. However, if that knowledge has been used to develop validated
tools, then operating in the area where the regulatory and tool domains
overlap should result in reliable assessments of process lethality and
product safety.
Unfortunately, the current state-of-the-art, regarding validated
tools, is insufficient for reliable lethality predictions in commercial
processes. The strengths and weaknesses of the two general methods (challenge
studies and predictive models) are listed in Table 1. In general, challenge
studies (i.e., inoculation of real products with target organisms) are
impossible in commercial facilities, where pathogens cannot be brought
on site. If the capacity does exist to conduct such tests, they have the
advantage of directly accounting for any product effects by virtue of
using the actual product in the tests. However, it is important to understand
that direct matching of the conditions in a pilot-scale test with those
in an actual commercial process can be extremely difficult, due to process
scale-up issues.
Additionally, existing pathogen inactivation data and models
(as described in the next two sections) have been developed primarily
with pathogen cultures grown under ideal laboratory conditions, inoculated
into model products, and subjected to isothermal laboratory conditions;
therefore, the resulting models are not necessarily valid for conditions
occurring in many commercial processes. In fact, one of the greatest dangers
in using predictive models from the literature is extrapolation to conditions
for which the model has not been validated. When this is done, the reliability
of the prediction is impossible to quantify.
Factors Affecting Thermal Inactivation
Obviously, heat inactivates bacteria. However, when evaluating thermal
process lethality, it is essential to understand the wide range of factors,
beyond just temperature, that affect the process outcome. These factors
can be classified as pathogen, product, or process parameters. This section
briefly summarizes the state-of-knowledge in this area.
Pathogen Factors
Thermal resistance of pathogens can vary widely, depending
on the organism being considered. Salmonella was selected as the reference
organism for the lethality performance standards in part because it tends
to be more thermally stable than other bacterial pathogens of concern
(USDA 2001). Once the pathogens are in a food matrix, the previous conditions
to which they have been subjected can also significantly affect their
future response (Wesche 2003). For example, in a commercial operation,
a pathogen cell on a carcass, which is held chilled before further processing,
might thereby develop increased thermal resistance due to the cold stress.
Likewise, pathogen cells that are exposed to, but not inactivated by,
sanitizing agents, could thereafter also exhibit greater thermal resistance.
Although stressed cells respond differently than cells grown under optimal
conditions, it is the latter cells that are routinely used in food safety
studies. Therefore, process validations based on solely laboratory studies
may not be adequate to ensure the safety of RTE products.
Product Factors
In terms of product attributes, the heat resistance of pathogens
can be affected by meat species, muscle type, pH, carbohydrates, fat content,
water content, and salts (e.g., Juneja et al. 1997, Maurer 2000, Veeramuthu
et al. 1998, Carlson 2002). In general, thermal resistance of bacteria
is higher in meat products than in laboratory media. Not only do food
components appear to enhance heat resistance, but cell location (surface
attachment vs. interior dispersion) may also affect the resistance of
Salmonella (Doyle and Mazzotta 2000). For example, Salmonella that has
migrated into the interior of vacuum-tumbled, whole-muscle product appears
to be more heat resistant than Salmonella in ground and formed product
(Orta-Ramirez et al. 2003). Therefore, the validity of applying previous
inactivation data from liquid media or meat slurries to thermal process
calculations for real meat and poultry products is not well known.
Process Factors
Although product factors, such as pH, fat content, and water
activity, all have an effect on thermal resistance of pathogens, the environmental
conditions during thermal processing can affect the inactivation of pathogen
both directly and indirectly, by changing the product properties during
processing. In this context, consider process factors to be those parameters
that can be controlled either by the process design or operation, such
as heating (e.g., air) temperature, cooking time, humidity, and heating
(or cooling) rates. With the exception of heating temperature and time,
far less is known about the effects of environmental conditions on thermal
inactivation, as relevant to commercial processes. As previously mentioned,
these effects can be either immediate or delayed, as occurs when bacteria
exhibit stress-induced tolerances to heat. For example, when a meat product
is heated at a very slow heating rate (<1degree C /min), pathogens
present in that product can become more heat resistant.
What to Do (Now and in the Future)
Clearly, pathogen, product, and process parameters can have
significant effects on the thermal resistance of pathogens in meat and
poultry products. Because commercial cooking systems create complex conditions
around the product, with varying temperature, humidity, airflow, etc.,
scale-up of laboratory-based inactivation data to commercial-scale processes,
without evidence that the data account for all of the relevant process
parameters, can be a dangerous leap. However, given the impracticality
of challenge studies, the processor is left with predictive models as
the primary means for evaluating and documenting process lethality. It
is critically important, therefore, to determine the implications the
aforementioned difficulties have for the present and for the future, in
terms of process design, validation, and operation.
For Now
For the present, caution is the key recommendation regarding
selection and use of published inactivation data and models. The most
important caution about predictive models is that they must be validated,
against data independent of those used to create the model, before they
can be used for prediction of future results. Unfortunately, the vast
majority of published data and models for thermal inactivation of pathogens
are never validated as part of the original studies.
Wide variability of lethality predictions can result from the use of different
data and models; therefore, it is incumbent upon the processor to be extremely
cautious in using published inactivation data. In particular, the user
of any microbial inactivation model should be sure to use parameters that
most closely match their own situation, in terms of product type, fat
and water content, process conditions, etc. Given that no universally
applicable modeling tool yet exists, the best that the user can do is
to consider comparing results from several different models and/or parameters
that are most relevant to the specific case. This can help define a range
of possible lethality outcomes. Most importantly, the user should particularly
avoid extrapolating a given model to conditions beyond which the model
has been validated, because there is no way to know the accuracy of the
resulting predictions in this case.
For the Future
Clearly there is a need for validated lethality models that
have broad applicability across a range of products and processes, and
which account for all of the factors known to affect lethality. Existing
modeling tools, such as the USDA-ARS Pathogen Modeling Program (PMP, v.
6.1, http://www.arserrc.gov) and the AMI Process Lethality Spreadsheet
(American Meat Institute, http://www.amif.org/processlethalityinstr.htm),
have a number of limitations relevant to the real thermal processes. First,
the current version of PMP does not include primary models for thermal
inactivation of Salmonella, nor does either model account for the effects
of important product and process conditions (e.g., fat content, humidity)
on inactivation. Both assume first-order (log-linear) inactivation kinetics,
which ignore any lag or tailing phenomena that can be important, in terms
of resistant sub-populations. Additionally, neither model accounts for
temperature and moisture gradients that occur in real food products and
therefore cause “lethality profiles” within a meat product.
Consequently, there is still a need to further extend the methods of quantitative
microbiology by coupling pathogen inactivation models with process (heat
and mass transfer) models to evaluate the lethality of actual commercial
cooking systems.
Summary
The general observation that current microbial inactivation
models fail to account for all of the factors relevant to commercial thermal
processes is certainly of no comfort to an industry that is increasingly
being compelled to verify and prove that cooking systems are meeting lethality
performance standards. There is a significant need for user-friendly,
publicly available, validated models that would allow a user to enter
product conditions (size, shape, composition, initial temperature) and
process parameters (equipment specifications, such as temperature, time,
air velocity, humidity, etc., for each stage of a multi-stage process)
and get back a prediction of product temperature profiles, cooking yield,
and pathogen inactivation. Such a tool could ultimately be used to design
and control multi-stage processes to ensure that the lethality performance
standard is met while simultaneously optimizing cooking yield and product
quality.
In the meantime, processors should be cautious in applying laboratory-based
microbial inactivation models to their own process data. Minimally, they
should be aware of the medium and heating conditions used to generate
the inactivation parameters, and recognize whether their processes differ
from those conditions in significant ways, such as product composition
or process humidity. Even though under-cooking in food manufacturing facilities
is not currently causing widespread food safety problems, continued development
of new products and processes (and the ongoing regulatory changes) necessitate
a proactive stance in ensuring proper evaluation of thermal process lethality.
References
Carlson, TR. 2002. Effect of water activity and humidity
on the thermal inactivation of Salmonella during heating of meat. M.S.
Thesis. Michigan State University. East Lansing, MI.
Doyle ME, Mazzotta AS. 2000. Review of studies on the thermal resistance
of Salmonellae. J. Food Prot. 63: 779-795.
Juneja VK, Snyder Jr. OP, Williams AC, Marmer BS. 1997. Thermal destruction
of Escherichia coli O157:H7 in hamburger. J. Food Prot. 60: 1163-1166.
Maurer JL. 2001. Environmental effects on the thermal resistance of Salmonella,
Escherichia coli O157:H7, and Triose Phosphate Isomerase in ground turkey
and beef. M.S. thesis. Michigan State University, East Lansing, MI.
Orta-Ramirez A, Warsow CR, Ryser ET, Marks BP, Booren, AM. 2003. Enhanced
thermal resistance of Salmonella in whole-muscle vs. ground beef. IFT
Abstract 60C-7. Presented at the Annual Meeting of the Institute of Food
Technologists. Chicago, IL. July 12-16, 2003.
USDA. 1999. Performance standards for production of certain meat and
poultry products. United States Department of Agriculture. Food Safety
Inspection Service. 9 CFR Parts 301, 317, 318, 320, and 381. Federal Register.
64:732-749.
USDA. 2001. Performance standards for the production of processed meat
and poultry products; proposed rule. United States Department of Agriculture.
Food Safety Inspection Service. 9 CFR Parts 301, 303, et al. Federal Register.
66(39):12590-126363.
USDA. 2002. Use of Microbial Pathogen Computer Modeling in HACCP Plans.
FSIS Notice 55-02. United States Department of Agriculture. Food Safety
Inspection Service. December 2, 2002.
Veeramuthu GJ, Price JF, Davis CE, Booren AM, Smith DM. 1998. Thermal
inactivation of Escherichia coli O157:H7, Salmonella senftenberg, and
enzymes with potential as time-temperature indicators in ground turkey
thigh meat. Journal of Food Protection. 61: 171-175.
Wesche AM. 2003. Thermal resistance of sublethally injured Salmonella.
M.S. Thesis. Michigan State University. East Lansing, MI.
Table 1. Strengths and weaknesses of tools for validating thermal process
lethality.
| |
Challenge Studies |
Predictive Models |
| Strengths |
• Product-specific results.
• Results are lumped for an entire piece of product (i.e., the
real case).
|
• No requirement of special biohazard facilities or testing.
• Can compare effects of using different literature data.
|
Strengths
Weaknesses
|
• Not practical (due to typical lack of biohazard
pilot-processing facilities).
• Results are strain-dependent.
• It is difficult for off-line tests to exactly mimic actual
process.
• Pathogen recovery methods affect results (e.g., sub-lethally
injured cells).
|
• Typically based on only Tcenter, which neglects the “lethality
profile” in a product.
• Few account for factors other than time and temperature.
• Usefulness limited to domain used for model validation.
• Unlikely to find inactivation data exactly matching specific
product/process scenario.
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