Blog

Uncategorized

PECB signs a partnership agreement with Chimera Systems

PECB, a reputable certification body, has pleasingly engaged into a partnership with Chimera Systems to upgrade its presence in South Africa by offering the distribution of PECB training courses on a wide range of international standards.

“We are looking forward to working with Chimera Systems to integrate their expertise and help customers achieve higher levels of satisfaction. We are very excited for this agreement, and we have always welcomed partnership opportunities with such companies that are consistent with and appropriate to our mission,” said Eric Lachapelle, CEO of PECB. “The relationship with Chimera Systems represents a powerful opportunity for PECB to significantly expand our presence in South Africa, a vibrant and very important market, and extend it to other parts of the world over time,” concluded Lachapelle.

David James Scott, and Gillian Katinka de Villiers, Directors, Chimera Systems
Chimera Systems is delighted to be in partnership with PECB, an international company of global repute. In today’s worldwide economy there is increasing concern to ensure the integrity of products and services. Companies are under immense pressure to show due diligence and demonstrate compliance to international standards. Chimera Systems’ core focus in this business venture with PECB will be expanding the reach of Health, Safety, Environment and Quality Management Systems within Southern Africa. To this end we are dedicated to the development of organisations and their personnel in the field of management systems in achieving global recognition through accredited PECB certification. Integral to our vision is the development of PECB brand awareness and their presence in Southern Africa. Chimera Systems and its directors are excited at the opportunity that partnership with PECB affords to provide peace of mind to South African company owners and consumers through international certification.

About PECB
PECB is a certification body for persons, management systems, and products on a wide range of international standards. As a global provider of training, examination, audit, and certification services, PECB offers its expertise on multiple fields, including but not limited to Information Security, IT, Business Continuity, Service Management, Quality Management Systems, Risk & Management, Health, Safety, and Environment.

We help professionals and organizations to show commitment and competence with internationally recognized standards by providing this assurance through the education, evaluation and certification against rigorous, internationally recognized competence requirements. Our mission is to provide our clients comprehensive services that inspire trust, continual improvement, demonstrate recognition, and benefit society as a whole. For further information regarding PECB principal objectives and activities, visit www.pecb.com.

About Chimera Systems
Chimera Systems was founded as an independent consultancy specialising in the areas of quality management systems, and labelling, and is based in Cape Town, South Africa. We provide our clients with the support, training and other dedicated services required to fulfil the unique needs of each project. With a wide background in local and international regulations and standards, we provide assistance to the industry in understanding the quality, legal and safety obligations concerning the products they provide.

Chimera Systems offers support to food manufacturers striving for food safety to implement a reliable Food Safety Management System certifiable to internationally recognised standards. All of our products and services come with the training packages required by these standards to manage and implement an effective Food safety Management System. We provide refresher training where required to ensure continual maintenance and improvement of each management system. Chimera Systems offers gap analysis and pre-certification auditing to verify efficacy of the management system prior to certification.

To ensure compliance of products at market level we offer a wide range of label compliance reviews for local and export markets. These reviews enable our clients to keep abreast of the legal requirements and standards around labelling and advertising of their products.

Claims

Healthy & Wholesome — A regulatory perspective

Health claims were first introduced into legislation with the introduction of R146 in 2010. This legislation has a standard list of specific claims and also a list of words that indicate some form of health claim that may not be used.

The prohibited words are: health, healthy, wholesome, nutritious and any indication that a food can provide balanced or complete nutrition. In the course of consulting I have regularly encountered food marketers who insist that their food is healthy, wholesome or nutritious so why can they not say so?

The simple answer is no food is in itself healthy. Any given food can only be considered healthy if part of a balanced diet. Nobody can argue with the fact that water is necessary for daily life and therefore is healthy. But it is only healthy as part of a balanced diet that includes numerous other foods. Conversely sodium is considered unhealthy by many, but a diet that excludes sodium in its entirety would be harmful. These simple examples hopefully illustrate why no single food can be labelled using any of the above mentioned words.

Industry has attempted to get around this law with numerous methods, two commonly used (or attempted) are the use of endorsements and registering words as a brand.

The regulations published in 2010 closed the gap on endorsements. No product may be endorsed by a health practitioner or related organisation or even individuals that may insinuate a specific health aspect of food. There is exception made for organisations who are registered with the Department of Health for use of specific logos. This has not stopped companies still using this methodology of marketing whether it be by using a reference to a certain diet or having an Olympian training in the background of advertisements. Some of these products have been removed from the market, but walking through the supermarket many of these products are still on the shelf. This is indicative more of a lack of enforcement on the ground than a retraction of this part of the regulation.

The second avenue, registration of words as trademarks, is dealt with in the current draft regulation where this practice is outlawed. There is some indication that a grace period will be given for those brand names registered prior to 1995, although the dates given in the draft are now long come and gone. It will be interesting to see how far this regulation is taken. Will only specific use of words be targeted or any hint of the use? Words such ‘Pure’, ‘Fresh’ and ‘Natural’ appearing in brand names come to mind.

An issue with how nutrient content claims are currently dealt with is that generally only one requirement needs to be fulfilled e.g. for low fat a product simply has to have less than 3 g of fat per 100 g. This allowed manufacturers to push up for example sugar levels and use synthetic substitutes to make up for mouth feel and taste while still being low fat. Ultimately this does not make for a “healthier” product. A nutrient profile calculator has been introduced in the draft regulations requiring a food product to achieve a certain score before a claim can be applied to the product. The score takes into account total energy contribution, sugar, fats, sodium, protein, fibre, fruit and vegetable content. This can almost be seen as an attempt to create a scoring system for the term healthy, although this word may not be used.

A criticism of this system in previous drafts has been that some seemingly “healthy” foods would then not be allowed to carry a claim. This has been largely solved by having different categories of food products namely beverages, naturally high fat foods (e.g. oils and cheeses) and other food products.
Although no system is perfect this has gone some way to close the gaps in the regulation.

The use of any term on a label must be substantiated by sufficient scientific evidence, normally some form of laboratory study. Where no specific test can be associated with a claim e.g. there is no test that can prove “healthy”. So as a food marketer if you can’t substantiate a claim through legal reference the chances are that the specific word may not be used.

Article by: Norah Hayes

CAMS

Complementary & Alternative Medicines

What are Complementary & Alternative Medicines? Complementary and Alternative Medicines (CAMS) are various traditional supplements and treatments that are not considered to be mainstream registered or conventional (allopathic) medicines. Conventional medicines are regulated by the Medicines Control Council (MCC) through Act 101 of 1965. Medicines are regulated under four categories A, B, C and category D. The most crucial requirement of regulating medicines, which now applies to CAMS products (category D) is showing efficacy and safety. Essentially manufacturers must show that the product is safe for consumption and can fulfil its function as claimed, at its intended dosage.

In terms of the guidelines for CAMS, a complementary medicine means “any substance or mixture of substances which a) originates from plants, minerals or animals; b) is used or intended to be used for, or manufactured or sold for use in assisting the innate healing power of a human being or animal to mitigate, modify, alleviate, or prevent illnesses, or the symptoms thereof or abnormal physical or mental state, and c) in accordance with the practice of the professions regulated under the Allied Health Professions Act, 1982 (Act No 63 of 1982).”

What does this mean for manufacturers of food products? The food labelling regulations R. 146 of 2010 (clause 13(g)) prohibit the sale of any foodstuff which bears a medicinal claim, including prophylactic and therapeutic claims. Simply put, a foodstuff bearing any health claim relating to the prevention or treatment of a disease will be regulated as a CAMS product. These include claims relating to diabetes, cancer, blood pressure, osteoporosis, heart disease etc.

What are the requirements for CAMS products? Since 2013, CAMS are now regulated under categories A and D of the Medicines Act (R. 870 of 2013). Category D includes homeopathy, naturopathy, Ayurveda, osteopathy, phytotherapy and aromatherapy. Category A, one of the categories for conventional medicines now includes CAMS medications such as high potency Vitamins.

Labelling for these newly regulated CAMS must comply with the requirements for medicines by February 2014. Registration of various groups of medicines now falling under category D would be called up in batches:

Is your product affected?

March 2014: 20.2.8 Antiviral agents; 21.2 Oral hypoglycaemics (Diabetes); 6 Cardiac medicines; and 26 Cytostatic agents.
November 2015: 32.3 Slimming preparations (weight reduction products); and 7.1, 21.7, 21.8, 21.9 Sexual stimulation products.
May 2016: 32.16 (Other) Immune boosters; 17 Medicines acting on muscular system (body building products); and 22 (Vitamins) Sport supplements containing vitamins and minerals exceeding the upper limit allowed
November 2019: All remaining pharmacological classifications, including products in Category D and other categories.

What is the responsibility of manufacturers of CAMS? All manufacturers and wholesalers of CAMS must now be licenced by the MCC. This registration process is intended to be simplified compared to that of conventional medicines, but must show evidence of safety of the product, as well as appropriate manufacturing standards (Good manufacturing practices) and efficacy. If an applicant cannot provide suitable information to the Council, they must remove the product from the market, until registration with the MCC. Alternatively the product may remain on sale, but no medicinal claim may be made in any published information including advertising, labels and product inserts. By November 2019 the legislation will have come into effect for all complementary medicines affected by R. 870 of 2013.

In addition, the product label, package insert and patient information leaflet of all Category D medications must comply with CAMS labelling requirements. The requirements for CAMS products include that the label must indicate the category and pharmacological classification of the medicine and the discipline (for example homeopathy). In addition if it has not been registered by the MCC it must bear the statement “This medicine has not been evaluated by the Medicines Control Council. This medicine is not intended to diagnose, treat, cure or prevent any disease”.

Then what claims are allowed on “foodstuffs”? Currently only nutrient content claims are permitted on food products. Nutrient content claims are claims regarding the levels of a particular nutrient or energy present in a foodstuff. These include claims relating to fat, carbohydrates, protein, vitamins, minerals etc. These are prescriptive claims and there are strict conditions regarding their use, provided in the regulations.

Phase two of the food labelling regulations which are currently in draft will address nutrient-function claims and disease risk claims, these will be generic statement and include claims such as “Diets low in saturate fat and cholesterol that contain 2 g of plant sterol esters and plant stanol esters daily, may reduce the risk of heart disease by lowering cholesterol” and “vitamin C contributes to normal collagen formation for the normal function of skin”. However, phase two of the regulations has not yet been passed and until such time as they are, such statements will be prohibited on the labelling of foodstuffs.

In summary? Currently any health related claim that is not a nutrient content claim on a food product is prohibited, unless the product complies to the CAMS regulations and is registered with the Medicines control council. CAMS products require that manufacturers produce their product under Good Manufacturing Practice conditions and show safety and efficacy. Additional labelling requirements for CAMS products under Regulation 8 of the Medicines and Related Substances Act, 1965 are also required to be met.

Article by: Gillian de Villiers

CAMS

CAMS and the consumer

“Do you believe that the company that makes the product has to give proof of this claim? … I would like to believe it.”

CAMs, or Complementary and Alternative Medicines are an interesting grey area for the average consumer – somewhere between a medicine and a food. The shelves are full of them, so obviously we are buying them! But what does the man on the street think about the health claims made by these products?

We’ll be examining exactly what is regulated and how a little later in the newsletter – but for now let’s take a look into the mind of the average consumer. Do we believe that solid science and thorough testing back up every health claim that appears on marketed products?

I asked a few people in the medicine aisle of a few local grocery stores three questions:

1. When you see a health claim on a product such as “reduces blood pressure” “assists the immune system”, “aids in weight loss” or “lowers cholesterol” etc – do you believe it?

2. Do you feel that enough information is given on health claims as to how the product does this? Or don’t you feel this information needs to be included?

3. Do you believe that the company that makes the product has to give proof of this claim in order to be allowed to print the claim?

My first telling observation was that for the most part, people seemed surprised by the questions. This would lead me to think that many people hadn’t thought to question these claims – but perhaps I was wrong. Once presented with the questions, they came up with a few surprising answers. While overwhelmingly they seemed to believe that these claims should be strictly governed – many said that you had to employ ‘common sense’ when faced with a health claim on any product. These were often the same people who replied that they didn’t think enough information about how the product accomplished its health claim was given.

So it seems that while we obviously have a lot of consumers who do believe that health claims are strictly governed and can be trusted there is definitely a group which feels you can’t take a claim at face value. One participant mentioned something interesting – that they felt a claim like ‘reduces blood pressure’ should be backed up with proof, while a claim like ‘assists in weight loss’ was “more marketing than a real health claim”.

Some remarked that they rely on brand name when it comes to whether or not they trust a claim. If it is a well-known brand they are more likely to trust the claim, whereas one participant said you need to be more careful with a “dodgy” brand. Most participants said they felt the product should give more information about how it achieves what it claims – but one participant’s honest answer: “It would be too hard for me to understand” might give an indication as to why many products do not. Would a product that stated “Reduces blood pressure through the action of angiotensin- converting enzyme inhibitors” really give the average consumer any more useful information? Unlikely.

What did pleasantly surprise me was that many respondents felt it was important to do their own research before purchasing a complementary medicine, vitamin supplement or herbal remedy. In the Information Age, it seems the customer is starting to become more aware of their own power in making informed purchases – what they do want however is a guarantee that an authority is still looking out for us too. As one respondent replied to the question: ‘Do you believe that the company that makes the product has to give proof of this claim in order to be allowed to print the claim?’ “I would like to believe it.”

For a look into the mind of a more educated consumer, I asked my local pharmacist about these types of products – mainly herbal remedies – and why they stocked them. She confirmed that customer demand is one of the main factors in the pharmacy’s decision to stock them, but that they felt the products definitely benefited their customers too. What she was concerned about was how little information pharmacists have access to with regards to how these medicines could potentially interact with their patient’s prescription medications, but overall she felt the potential benefits of these types of medicines were often overlooked and warranted further study. When questioned about these products not being controlled by the MCC (Medicines Control Council) she made a good point – that she doesn’t need MCC approval to tell pharmacy visitors that increasing their fruit and vegetable consumption is good for them, so why should she discourage them from taking a herbal immune booster? That said, it would be hard to overdose on fruits and vegetables, which do not have written health claims attached to their packaging.

My opinion? My own journey has led me to believe that our lifestyle and dietary choices need to be addressed together with any other therapy – be it an alternative medicine or a prescription drug. And when it comes to health claims, I’m the kind of consumer who emailed a major supplement brand to find out whether their Vitamin B12 supplement contained methylcobalamin or cyanocobalamin – so let me place myself on the pernickety side of the consumer scale!

It’s also very important to mention of course that while there are many manufacturers selling products on the market that have blatantly misleading claims, there are also many manufacturers doing their best to comply to government requirements, ensure the customer’s safety and back up the effectiveness of their product with genuine health claims.

While I can’t quite shake the feeling that society needs to be more aware that every product they see on the shelf is there strictly for the purpose of getting you to buy it – perhaps times are changing. I still feel that we need to become more responsible consumers, that there’s no excuse in today’s world for simply taking a health claim at face value without doing our own research. And I think it’s just as important to Google “why XYZ supplements don’t work” in addition to why they do.

But I was impressed at the level of scepticism I encountered – while it’s very important that health claims are regulated where they can be to protect the consumer, an alert and educated public has the power to protect itself too.

Article by: Catherine Robinson

Food Labels

Food Regulation in South Africa

orange-164985_1280

But I didn’t know: A brief guide to Food Regulation in South Africa

When manufacturers think of “Food regulations”, generally the first things that will pop to mind are the Labelling regulations (R146/2010). Furthermore, if they are asked who governs the food regulations in South Africa, I would imagine the first response you would get is the Department of Health. Although not incorrect, the Department of Health is only one of the bodies tasked with the regulation of food in South Africa. Likewise, the Labelling regulations are only a few of a plethora of regulations directed at the management of food safety and the rights and wellbeing of the consumer. Our aim with this article is to try and provide you with a brief overview of the regulatory landscape of food within South Africa.

There are three main government departments tasked with the management of Food Safety and Quality, namely the Department of Health (DoH), Department of Agriculture, Forestry and Fisheries (DAFF), and the Department of Trade and Industry (DTI) – See hierarchy on lefthand panel. These departments have very specific mandates.

The DoH is tasked with the management of food hygiene (certifying manufacturers – Certificate of Acceptability), developing food safety & quality standards, and managing the country’s food labelling, nutrition and fortification requirements.

Under the DoH, Directorate: Food control is responsible for the administration and enforcement of the DoH food regulation, and to provide consumers with the power to make informed food choices without being misguided.

Similarly, the Chief Directorate: Health Promotion and Nutrition (previously, Directorate of Nutrition) is tasked with the development of a national nutrition programme and the administration of the baby foods and infant formula regulations.

DAFF is responsible for regulating agricultural products including traditional processed products such as jams, vinegars, pickles, honey and canned vegetables, through to dairy products, ice- creams, meat and poultry. It is interesting that the scope of DAFF’s administration does not only cover agronomy, agricultural practices and fresh produce, but extends also to agricultural product standards relating to labelling (grading and marking), import and export. DAFF regulations are promulgated at National level, but enforcement takes place at Provincial level. Thus always ensure that any agricultural products are passed by your local DAFF inspector before being placed on the shelf.

The other regulatory authority, the DTI regulates all canned meats, canned and frozen fish and seafood. Under the DTI, these products are regulated by the National Regulator for Compulsory Specifications (NRCS) through technical regulations known as compulsory specifications. All facilities that produce these products must abide by the strict requirements of these compulsory specifications (VC documents).

As you can see the food regulatory environment within South Africa is understandably quite complex, as different authorities regulate different aspects of labelling, food safety, facility design and product standards. For this reason it is imperative to ensure that all aspects around a product have been addressed before going to market. In many organisations this expertise is available in-house, however in other cases or with highly technical foods it can be well worthwhile to engage the services of a food safety and food labelling consultant.

Article by: David Scott

Food Safety

Aiming for a Food Safety Management System

Aiming for a Food Safety Management System (FSMS)?

Why would one aim for a Food Safety Certification? The basic South African legal requirement for food production is that a food facility must comply with R962/2012. If it complies with this, and a Health inspector passes the facility and awards a Certificate of Acceptability, then food may be manufactured in the facility. This is needed for all organisations, from the smallest mobile coffee operator, to the largest pre-packaged food manufacturer.

A Food Safety Management System is a tool to manage food safety, quality and legal requirements. While R962 covers the essential legal requirements for a facility, a FSMS assists in managing quality and safety. For many manufacturers the greatest reason to apply for a Food Safety Certification is because of customer demand, particularly from retailers.

All full Food Safety Certifications will require a Food Safety Management System to be implemented. This is essentially a documented Quality Management system that describes everything that is being done on the premises and allows production to conform with all aspects of Food Safety and legality. This includes such elements as “GMP/PRP” Good Manufacturing Practice and Pre-requisite programmes, which all facilities will have, such as cleaning, pest control programmes, allergen management, facility and process layout, training needs, etc. In addition a FSMS will include an analysis of the specific needs and risks associated with your own production process, and how to manage this (HACCP – Hazard Analysis and Critical Control Points). Some more widely known certifications in South Africa are FSA (Food Safety Assessment), FSSC 22000 (ISO Food Safety System) and BRC (British Retail Consortium). FSA has recently become a stepping stone towards an FSSC22000 certification, while both FSSC22000 and BRC are internationally recognised GFSI-based Food Safety Certifications.

It typically takes a client between 6 months to a year to put a full food safety management system in place and be ready for an audit, depending on how available the quality manager/ Food technologist is and how much support they have. We would not recommend a client attempt to put a system in place in under 6 months. To be audit- ready it is necessary to have at least 3 months of documentation history, therefore, they have been manufacturing with most production documents in place for a period of 3 months. Likewise, these timelines also apply to clients going for the GMP basic and foundational level FSA audits. In addition, even once a system has been fully implemented, it will require considerable time and human resources to manage it as with most certifications every document in the system needs to be revised annually, all maintenance and calibration managed, monthly microbiological testing performed and process and HACCP documentation updated whenever a change is made to the production process, and this doesn’t even cover the continuous improvement of the system required by the certification body to show due diligence in food safety.

If a potential client requires a certification before they are prepared to purchase the product, it would make sense to try to find other clients who can buy the product in the period that the organisation is manufacturing but not yet certificated, as it may be between 6 months and a year before certification, or even longer.

Because the Food Safety System is a living system, it is also not possible to audit before manufacture, as the audit needs to demonstrate that all the processes and procedures are being followed (including cleaning, pest control, and the appropriate manufacturing methods). The alternative, which some manufacturers have done, is to negotiate with their retailer to accept their product, while giving evidence that they are working towards a Food Safety Management System and certification. Depending on customer requirements, a manufacturer may manufacture for some time with only the Certificate of Acceptability, before choosing to implement a Management System and be certified. In the interim, to booste small business, some retailers have listed products of small manufacturers on the condition that they undergo and pass a GMP basic or foundational level audit.

In summary, gaining a food safety certification is resource intensive both during the initial implementation, and in its upkeep. Applying for a certification may also be a longer term process than manufacturers originally envision, therefore this should be carefully considered as part of the business case.

Article by: Gillian de Villiers

Claims

Food for thought

Food for Thought – How useful are Nutrition labels to the average South African?

With escalating rates of lifestyle-related health issues globally, it has never been more important that consumers are aware of the factors which are under their control when they make food choices. Understanding and correctly interpreting food labels can enable consumers to make informed decisions about the foods they choose to purchase and provide to their families.

In the 2011 study Consumers’ knowledge of food label information: an exploratory investigation in Potchefstroom, South Africa, some valuable insights were gained despite the limited scope.

The study was limited to a group of 299 participants, of which the largest component was Afrikaans-speaking females with a tertiary education and no children. However, 4% and 38% of respondents had below grade 12 or up to grade 12 levels of education respectively.

While information such as best before dates, storage instructions and identifying symbols such as Halaal or Heart Foundation endorsements were easily and accurately identified by the vast majority of respondents, only 53% of respondents were able to calculate how many serving sizes were included in a product. Since many food labels give nutritional information ‘per serving’ – this indicates a clear problem in correct application of the information, even if the values themselves are largely understood, and the participants are well educated. In addition, manufacturers are required to include nutritional values per 100g – however whether this will be of benefit to a consumer making an in-store decision under a time constraint is debatable.

While many consumers may be aware that is it recommended for them to cut back on saturated fat, only 3% of respondents could correctly identify a food as being low in saturated fat.

Under the current labelling regulations (R146/2010) the amount of saturated fat ‘per serving’ and ‘per 100 g’ are mandatory where nutritional information or claims are provided.

Even more importantly, as long as a food manufacturer does not make any nutritional claims about their product – it is not compulsory for them to publish these details at all. And this is not entirely negative – smaller manufacturers without the funds to have their product analysed by an accredited laboratory every 3 years should certainly not be prevented from entering the marketplace in the first place; and they will still be required to provide a list of ingredients, additives, allergens, storage information, etc.

But does reading and understanding food labels actually lead to improved choices?

According to Food and nutrition labelling: the past, present and the way forward (Koen et al., 2016), the short answer is yes. People who make use of food labels were found to be more likely to make informed food choices in practice – with their diets reflecting a reduced fat, cholesterol, sodium, and overall energy intake, and increased consumption of fibre, iron and vitamin C.

In light of this since the publication of the latest regulations relating to the labelling and advertising of foodstuffs, or R146/2010, we have certainly made some progress towards food labelling practices which are easier for the average consumer to understand, however there is still significant room for improvement.

Looking at the largest South African study to date conducted after the implementation of the new regulations, conducted by Bosman et al. with 1997 respondents across four ethnic groups – some general areas of interest were uncovered:

• Most consumers are able to locate the nutritional information on packaging, however some expressed uncertainty in their understanding of the information provided.

• Consumers who did not read labels on a frequent basis indicated lack of interest, habitual purchasing, price concerns and time constraints as the main reasons.

Furthermore, in 2008, 41% of women and 21% of men in South Africa were classified as obese, with 32% of females and 35% of males with high blood pressure, which are considered to be diseases of lifestyle. (WHO, 2014). Between 2010 and 2011, the Department of Health enacted laws governing Trans- Fat and saturated fat in foods and their labelling. Similarly, Sodium reduction laws, currently being revised, were published in 2013, for enforcement between 2016 and 2019.

In essence, many consumers still have difficulty putting their knowledge into action when making purchasing decisions, even with the current labelling systems. While there may be scope to improve the current R146 regulations and make them more accessible to the average consumer – a certain degree of accountability must be taken by individuals as well. Fine tuning the regulations and bringing them in line with global best practices is a goal we certainly need to strive towards, however the education of the public in making food choices is clearly just as vital.

Engagement invitation: What are your thoughts? Do you find nutritional labels hard to decipher? Let us know in the comments section below.

Article by: Catherine Robinson

References

1. van der Merwe D, Bosman M, Ellis S, de Beer H, Mielmann A. Consumers’ knowledge of food label information: an exploratory investigation in Potchefstroom, South Africa. Public Health Nutr 2012: 16(3) 403-408.
2. Koen N, Blaauw R, Wentzel-Viljoen E. Food and nutrition labelling: the past, present and the way forward. S Afr J Clin Nutr 2016: 29(1) 13-21.
3. World Health Organization. Noncommunicable Diseases (NCD). Country Profiles, 2014.

Hygiene

Hygiene in the Kitchen

How can a kitchen or food factory ensure they are reducing the opportunity for microbial growth?

Cleaning is the process of removing dirt, grease and grime from a surface. Cleaning must be performed on hands, fruits and vegetables, food contact surfaces and non-food contact surfaces.

One of the best ways to prevent food contamination is hand-washing. The WHO recommends hand-washing to prevent disease. To wash your hands properly rub with soap for 20 seconds, rinse, dry with a clean paper towel and then rub with sanitiser and allow the sanitiser to dry (see http://www.who.int /gpsc/5may/How_To_HandWash_Poster.pdf). Hand washing should be performed whenever changing tasks, such as after going to the toilet, after handling rubbish or dirty utensils, after coughing, sneezing, nose-blowing, smoking, eating or drinking, after handling money, when switching between raw and ready-to-eat food and before putting on gloves.

Fruit and vegetables should be cleaned before use with a vegetable wash, or disinfectant such as chlorinated or ozonated water.

A detergent is a chemical that removes residue and grease from a surface, but it does not usually disinfect (kill microbes). A disinfectant chemical is a chemical that can kill most micro-organisms on surfaces, including pathogens (although it may not be able to kill viruses or bacterial and fungal spores). A detergent-disinfectant has the ability to both clean and disinfect. For the food industry, cleaning chemicals must comply with the SANS 1828 requirements, and detergents or detergent- disinfectants with the SANS 1853 requirements.

Food contact surfaces (such as utensils, mixers, containers, chopping boards, work surfaces and production belts) and hand contact surfaces (such as handles of cupboards, freezers, refrigerators, utensils as well as taps and switches) need both cleaning and disinfection. Cleaning materials and equipment also need to be carefully cleaned and disinfected to avoid becoming a source of cross-contamination, use of disposable cloths and paper towels are recommended. It is always necessary to clean before disinfecting, as particles and grease provide areas where microbes can be protected from the disinfectant which is meant to kill them. In order to disinfect, chemicals, steam and hot water (above 82°C) can be used.

After preparing a food, and before preparing the next product, equipment such as cutting boards, utensils, dishes and countertops must be cleaned. To clean, first pre-clean by scraping off large amounts of food and grease particles. Then use detergent to take all the rest of the dirt and grease into the water. Rinse with clean water, disinfect with a chemical disinfectant, then rinse so no disinfectant remains. Or disinfect by submerging a rack of items into hot water (at least 82°C) for 30 seconds. Then air dry and cover the item so it is safe from being contaminated before the next use.

Segregation. The principle of segregation, or separating things from one another, is used to manage a number of risks, including that of physical, chemical and allergen contamination. Segregation is also used to reduce microbiological risks to a product. Separating foods to reduce microbial risk will also apply to storage: raw vegetables should be stored apart from raw meat. It is best to store raw and cooked foods separately in a refrigerator, storing cooked foods above raw foods, so that raw food cannot accidentally fall into and contaminate cooked food. In addition cooked food should not be returned to containers which housed raw food, unless the container was thoroughly cleaned. This is meant to prevent microbial contamination of, for example, cooked chicken by raw chicken. Similarly, a food production environment should be set up in such a way that there is minimal chance for raw materials, work in progress, final product and waste to cross paths, thereby again reducing the opportunity for transfer of microbes between items. One example of this is to use different, colour coded, cutting boards for different foods such as fish, poultry, raw meat, raw vegetables and cooked foods. Therefore separating food prevents transfer of microbes from one food to another, keeping cleaned and/or cooked foods from being exposed to microbes again. Thus, reducing risk of spoilage, and harm to consumers.

Time & Temperature control. Temperature can control microbes in two ways: chilling can slow their growth, and cooking can kill them outright. It is important to keep food cooler or warmer than the temperatures that pathogens (dangerous microbes) grow the fastest, which is from 4°C to 65°C. Therefore, ensure that as soon as foods are received that frozen foods are put in the freezer (below -12°C) and chilled foods are refrigerated (below 4°C). Food must only be defrosted in the refrigerator or under cold running water, and food defrosted with water must be cooked immediately. Similarly always marinate food in a refrigerator. It is important to remember that once a food that was frozen or chilled warms up again, the microbes will grow as fast as ever.

Microbes can be killed by cooking, when food is cooked to the correct internal temperature (the temperature in the very middle of the food, e.g. middle of a chicken breast), or higher. This is because lower temperatures will not be enough to kill microbes. An internal temperature of more than 80°C for more than 10 minutes is generally sufficient, as it will kill Salmonella species, Listeria monocytogenes, Staphylococcus aureus, Enterobacteriaceae, Escherichia coli and Clostridium perfringens (excluding C. perfringens spores). The guidelines above are, however, not appropriate for hermetically sealed foods (e.g. canned products) as they do not reduce the risk of spore-forming bacteria such as Clostridium. For microwave cooking it is important to ensure that cooking is done evenly with no cool areas where microbes could survive.

Cooked foods must be stored in such a way that new microbes will not contaminate it, and that those that were not killed do not have the chance to grow further. The South African regulation R962 of 2012 require hot foods to be held at 65°C or higher temperatures. If a cooked food is to be chilled, it must be cooled to 70°C, but not below 65°C, before storing in a holding fridge.

When kitchens and factories apply cleaning, segregation and temperature control appropriately, it will substantially reduce the risk of microbial problems in the final product.

Article by: Gillian de Villiers

Microbiological limits

Just give me the limit already!

An International perspective:

When it comes to conducting a hazard analysis, microbiological risks and their associated limits are often difficult to define. Although everybody in industry recognises the need for microbial limits, newcomers often do not have the technical knowledge in the field to accurately write up specifications for their products. This inevitably results in a search for regulations, as one would for contaminants such as pesticides and heavy metals. However, consistent and specific micro limits are often hard to find. Unfortunately microbiological guidelines are predominantly set up for a limited list of products, in general for single agricultural products. Therefore it is difficult to find a specification for more complex foods such as baked pasta dishes or cooked stews.

One of the major reasons why microbiological specifications are generally conservative, is because microbiological testing is seen as a tool that contributes to food safety, but is fundamentally supported by other facets such as product and process design (European Commission, 2016). Microbiological testing needs to take into account various factors, one of which is the ability of the product to support the growth of the bacteria being tested for.

Internationally, Codex Alimentarius is advised by the Joint FAO/WHO Expert Meetings on Microbiological Risk Assessment (JEMRA). JEMRA uses a risk based model to advise Codex on new and emerging microbiological risks, which in turn advises signatories to Codex.

The European Union issued regulations on the microbiological criteria for foodstuffs in 2005. The regulations cover mainly pathogens and not indicator organisms and stipulate methodology for testing. The European regulation gives details regarding the number of samples to be tested and how many of these samples can exceed the limit, if any. For example, for sprouts, within 5 samples, no sample may contain Salmonella in 25 g when tested according to EN/ISO 6579 (Official Journal of the European Union, 2005).

The Food and Drug administration (FDA) of the United States of America has a variety of regulations and guidance documents published that cover aspects of microbiological testing, but not a single standard. These cover items such as seafood [1], fruit juice [2] and low acid canned foods [3]. It is therefore recommended that manufacturers exporting, or looking for reference documentation, do a product specific search on the FDA website. The FDA also publishes the “Bad Bug Book” that covers various pathogens and their growth conditions [4]. It is a useful guide for professionals in the food industry having to write specifications.

The Australia New Zealand food standards authority has a microbiological standard (1.6.1), published as part of their food standards. The document includes similar information as with the European regulation, but covers fewer products. It is also interesting to note that the standard not only covers pathogens, but also indicators of poor hygiene such as coliforms (FSANZ, 2000).

It is important that microbiological specifications be applied to the entire shelf life of the product and not just at the time of production. Product developers need to take into account the physical and chemical parameters of the product during storage that could support growth. In addition, abuse of the product by the consumer, such as incorrect storage temperature should also be considered when setting up micro limits. Thus, although the legal requirements must be consulted, the risk of the product and its storage must also be carefully considered. It always remains the responsibility of the producer to supply safe food even in the absence of legislation.

Article by: Norah Hayes

References:
1. FDA. 2010. Compliance Program Guidance Manual: Import Seafood Products Compliance Program – 7303.844. Available from: <http://www.fda.gov/downloads/Food/ ComplianceEnforcement/UCM219993.pdf>. [25 April 2016].
2. FDA. 2015. Compliance Program Guidance Manual: Juice HACCP Inspection Program – 7303.847. Available from: <http://www.fda.gov/Food/ComplianceEnforcement/ FoodCompliancePrograms/ucm236946.htm>. [25 April 2016].
3. FDA. 2010. Compliance Program Guidance Manual: Domestic Acidified and Low-Acid Canned Foods – 7303.803A. Available from: <http://www.fda.gov/ downloads/Food/ComplianceEnforcement/ UCM406274.pdf>. [25 April 2016].
4. FDA. 2012. Bad Bug Book, Foodborne Pathogenic Microorganisms and Natural Toxins. Second Edition. Available from: <http://www.fda.gov/downloads/Food/ FoodborneIllnessContaminants/UCM297627.pdf>. [25 April 2016].

Microbiology

They are everywhere!?

bacteria-359956_1280
Bacteria on culture medium

Microbes are ubiquitous in our surroundings, but from a food production aspect our main concern are pathogens and indicator organisms. Pathogens are bacteria that cause people to become ill, while indicator organisms present at unsatisfactory levels indicate that hygiene is a concern and that there may be other harmful bacteria. E.coli for example is an indicator of faecal contamination. E.coli could indicate bad hygiene practices in the production area (for example not washing hands), but could also indicate transfer of faecal contaminants from the field in the case of fresh vegetables. Indicator organisms help us to identify problem areas and put steps in place to prevent reoccurrence.

%d bloggers like this: