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

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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.