Proposal P239 - Listeria - Risk Assessment & Risk Management Strategy

2 October 2002

DRAFT ASSESSMENT REPORT

DEADLINE FOR PUBLIC SUBMISSIONS to the Authority in relation to this matter:
16 October 2002

(See 'Invitation for Public Submissions' for details)

Full Report [ pdf 688 kb ]

EXECUTIVE SUMMARY AND STATEMENT OF REASONS

L. monocytogenes in certain food categories poses a potential public health and safety problem, especially for vulnerable sub-populations such as pregnant women and the elderly.   While the incidence of systemic infection caused by L. monocytogenes in food is low, the consequences can be severe and include death.

The risk assessment for L. monocytogenes in ready-to-eat processed finfish (such as cold smoked salmon) concluded that this pathogen/commodity combination posed a significant risk to health and safety, especially to the susceptible sub-populations.    This conclusion was based on the observations that this food supports the growth of the pathogen, that there is no kill step in the processing of this product and, together with the long shelf-life of the product, growth of L. monocytogenes to hazardous levels can occur.  

An evaluation of alternative regulatory requirement for cold smoked salmon compared the public health outcomes achieved by the existing Standard 1.6.1 (which allows one in five samples from a batch to contain no more than 100 cfu/g of L. monocytogenes) and a hypothetical zero tolerance standard, concluding that there would be no significant difference between the two measures in terms of public health outcomes.   The Draft Assessment concluded that a microbiological standard in Volume 2 of the FSC for L. monocytogenes for ready-to-eat processed finfish, (such as cold-smoked salmon) could be justified and that the current standard is a minimum effective and achievable measure that protects public health and safety.   Changes to the standard for L. monocytogenes in ready-to-eat processed finfish could not be justified on basis of findings in the risk assessment and evaluation of an alternative measure.

The risk assessment concluded that there is a very low likelihood of Listeriosis that would be linked to exposure to L. monocytogenes in cooked crustacea in vulnerable populations (preliminary estimates indicate a mean annual case rate in Australia of one case of Listeriosis for every 1,600 years).   While the residual risk could be managed by mandating a microbiological limit for L. monocytogenes in cooked crustacea , it is unlikely to be an effective risk management measure, because the probability of identifying contaminated product from limited samples and preventing exposure before the food is sold and consumed is low.   This conclusion was based on the observation that the frequency of contamination of cooked crustacea appears to be low (approximately 3%) and that the product has a short shelf life.

Microbiological limits that serve to ensure good hygienic practices associated with food already exist in the Volume 2 of the FSC , thereby encouraging appropriate practices, such as temperature control in the processing and storage of cooked crustacea.    It was concluded that the current microbiological standard for L. monocytogenes in cooked crustacea in Volume 2 of the FSC cannot be justified on basis of public health and safety and effectiveness.   Deletion of the current standard is proposed.

Therefore in this Draft Assessment, it is proposed that:

Statement of Reasons

The proposal to delete the standard in Volume 2 of the Food Standards Code for L. monocytogenes in cooked crustacea will not adversely affect public health and safety.

Retention of the standard for L. monocytogenes in Volume 2 of the Food Standards Code in ready-to-eat processed finfish will provide adequate level of public health and safety protection and will be achievable.

Full Report [ pdf 688 kb ]