Enforcement mincing of chilled meat

This applies only to Approved Premises under MHS

1. EU legislation (paragraph 2(b), Chapter III, Section V, Annex III of Regulation (EC) 853/2004) prescribes the maximum number of days between the slaughter of animals and the mincing of chilled meat. These limits are that meat must be minced within no more than:
– 6 days of slaughter for red meat.
– 3 days of slaughter for poultry meat. and
– 15 days of slaughter for boned vacuum packed beef and veal.

2. These time limits prevent approved meat plants from using any part of a carcase that has been stored for more than the prescribed number of days for the production of minced meat. The FSA believes these time limits do not provide additional protection of public health and do not fit with the risk based approach to food hygiene advocated in Article 5 of Regulation (EC) 852/2004.

3. The scientific evidence suggests there is no increased risk to human health from meat that has been stored hygienically and at appropriate temperatures for longer than the time limits specified in the legislation. The evidence also indicates that no specific additional controls are required where meat is stored for longer periods before mincing, other than those specifically associated with ageing rooms. The storage temperature will however influence the time meat can be stored, with lower temperatures allowing storage for longer periods.

4. The FSA has written to the European Commission to seek amendments to Regulation (EC) 853/2004 regarding the time limits between slaughter and the mincing of chilled meat.

5. In the meantime, we are aware that many approved meat plants, while complying in all other respects with the requirements of the Food Hygiene Regulations are continuing the traditional practice of producing minced meat from chilled meat stored for longer than the prescribed time limits. The Agency's view is that enforcement action against food business operators (FBO) is unlikely to be appropriate solely on the basis that the time limits have been exceeded. Instead, our advice to official controllers and enforcement officers is that they should, using their professional judgement, assess the full range of food safety controls that the FBO has put in place to determine whether they are appropriate and proportionate to the product manufactured and the risk to human health. Therefore, official controllers and enforcement authorities should, when performing normal auditing and inspection tasks, review FBOs' HACCP plans and their implementation bearing in mind that they will be different in individual cases. In particular they should:
a) check that the FBOs individual HACCP plans reflect the processes/products they are producing and how they are mitigating any risks to human health. Where meat is kept for longer than the prescribed time limits FBOs should store their meat at a lower temperature to that prescribed in legislation. The storage temperature will influence the length of time meat can be stored and the maximum length of time meat is planned to be stored should be considered when determining the maximum temperature at which the meat should be stored. (Experience and knowledge of industry practices suggests that most are storing meat during maturation at less than 2°C, which would seem to be an acceptable good practice.) Enforcement officials may wish to note Table 3 (attached) of the Summary of Relevant Science and Evidence sent to the Commission in July 2010, seeking an EFSA opinion on the number of days between the slaughter and the mincing of chilled meat. This Report is based on the results of the early stages of the Agency's Research project. and

b) consider how food business operators are monitoring and controlling the processes set out in their HACCP plans. and

c) look at any other measures the FBO is taking to ensure the safe production of minced meat, including, for example, the general standards of hygiene, hygienic practices both at the product/carcass intake and within the premises, and the general operating procedures in the establishment. and

d) consider what evidence (either microbiological or other) is available to support the FBO's production of safe food. This would include the existing levels of microbiological testing and the 'safe margins' this allows and, where known, what the meat is to be used for after it has left the premises of production.

6. The above guidance will be reviewed when the European Commission respond to our request to amend the relevant time limits in Regulation (EC) 853/2004, or sooner if scientific opinion or the experience of enforcement officers or the meat industry indicate that such a review is required.

7. If you have any comments on the above please contact Steve Hardie at [email protected] or telephone him on 01224 285145.

Food Standards Agency
29 November 2010