New 2014 E. coli Guidance from the FSA

Just published by the FSA…

The Food Standards Agency has finally published (with little fanfare that we can see) its long-awaited update to E. coli cross-contamination guidance. This updates the ‘2011 Guidance’ that came in after the Pennington Report. Interestingly the guidance on thermal disinfection in commercial dish wash machines bit disappeared between drafts 3 and 4 of this version(IIRC) to be replaced by ‘follow the manufacturer’s instructions’. While new guidance is always welcome we suspect this document may cause confusion; there are some slight changes – more focus on touch points, vac packers and sinks –  and one great big one that may be problematic.

Confused?

Between drafts three and four of this document all references to thermal disinfection in dish washers was replaced by the phrase ‘follow manufacturers’ instructions’. Here’s why that will be problematic for food businesses. Under EU law the 82ºC / 15secs rule still applies for any utensils used in raw food prep. So is the rule now 82ºC / 15secs for chopping boards and ‘follow manufacturer’s instructions’ for crockery? Will EHOs conflate the different standards and insist on the higher standard for everything? They might revert to 65ºC for 8.4 seconds for crockery – but only if they read the 125-page Campden BRI report published at the same time.  They also refer to ‘steam heat’ – but the problem  you get a 4 log reduction in E. coli in 8.4 seconds at 65ºC under wet steam. If it’s dry it’s 547 minutes at the same temperature. (These are the kinds of anomalies you get in microbiology that drive chemists nuts…)

It will be interesting to see how the enforcement community reacts in terms of how inspections happen. We will report back…