be predefined. This is of course helpful, but these types of phrases will surely lead to
much debate about what is and what is not “critical” between in-plant personnel of
FSIS and food company personnel attempting to explain their scientific support and
validation for cooling.
Future Revisions Likely
FSIS has provided much more detail than in previous versions of compliance
guidelines for appendices A and B. The agency has taken an approach toward these
guidelines of trying to refine and improve upon their technical accuracy and utility
for industry and in-plant personnel. FSIS has been open to industry and academic
input on ways the guidelines can offer flexibility and still ensure pathogen control. For instance, an industry expert on cooking has proposed the use of wet-bulb
temperature as a suitable means to ensure adequate moist heating of meat product
surfaces in lieu of the humidity measurements or minimum steam injection requirements (B Hanson, personal communication). What is most clear is that FSIS
is willing to accept suitable scientific support for the safety of meat cooking and
cooling processes in the form of challenge studies, predictive modeling, in-plant
data, and other reliable sources. Therefore, the need to rely on safe harbors in appendices A and B, and the now more prescriptive qualifying criteria for using such
safe harbors, should nudge industry to seek its own scientific validation of customized processes. For cooking, newer, more accurate thermal inactivation data for
Salmonella, Shiga toxin-producing E. coli, and L. monocytogenes have been collected
in roast beef, turkey, and ham.
18 Such data could form the scientific basis for a cook
process instead of Appendix A, especially when used in conjunction with the process
19 Similarly, a number of scientific studies demonstrate control
of growth of C. perfringens as a result of product formulations. Matching the critical
operating parameters of such scientific data to those of an industrial process is necessary to consider the process or product validated, but in many instances, that may
be easier than meeting the current stipulations of the safe harbors in the compliance
guidelines for appendices A and B. n
Peter J. Taormina, Ph.D., is president of Etna Consulting Group. Dr. Taormina earned his B.Sc. in biology from
Valdosta State University and M.Sc. and Ph.D. from the Department of Food Science and Technology and Center
for Food Safety at the University of Georgia.
1. Goodfellow, SJ and WL Brown. 1978. “Fate of Salmonella Inoculated into Beef for Cooking.” J
Food Prot 41:598–605.
2. Bengtsson, NE, et al. 1976. “Cooking of Beef by Oven Roasting: A Study of Heat and Mass Transfer.” J Food Sci
3. Doyle, ME and AS Mazzota. 2000. “Review of Studies on the Thermal Resistance of Salmonellae.”
J Food Prot 63( 6):779–795.
4. Taormina, PJ and JN Sofos. “Low-Water Activity Meat Products” in The Microbiological Safety of
Low Water Activity Foods and Spices, edited by JB Gurtler, JL Kornacki, and MP Doyle (New York:
Springer, 2014), 127–164.
5. U.S. Centers for Disease Control and Prevention. 1995. “Outbreak of Salmonellosis Associated
with Beef Jerky—New Mexico, 1995.” MMWR 44( 42):785.
6. Eidson, M, et al. 2000. “Beef Jerky Gastroenteritis Outbreaks.” J Environ Health 62( 6): 9–13.
7. Kalinowski, RM, et al. 2003. “Impact of Cooking, Cooling, and Subsequent Refrigeration on
the Growth or Survival of Clostridium perfringens in Cooked Meat and Poultry Products.” J
8. Taormina, PJ, et al. 2003. “Incidence of
Clostridium perfringens in Commercially Produced
Cured Raw Meat Product Mixtures and Behavior
in Cooked Products during Chilling and Refrigerated Storage.” J Food Prot
9. Taormina, PJ and GW Bartholomew. 2005.
“Validation of Bacon Processing Conditions
to Verify Control of Clostridium perfringens
and Staphylococcus aureus.” J Food Prot
10. Golden, NJ, et al. 2009. “Risk Assessment
for Clostridium perfringens in Ready-to-Eat and
Partially Cooked Meat and Poultry Products.” J
Food Prot 72( 7):1376–1384.
15. Mohr, TB, et al. 2015. “Assessing the Performance of Clostridium perfringens Cooling
Models for Cooked, Uncured Meat and Poultry
Products.” 78( 8):1512–1526.
17. Zaika, LL. 2003. “Influence of NaCl Content
and Cooling Rate on Outgrowth of Clostridium
perfringens Spores in Cooked Ham and Beef.” J
18. McMinn, RP, et al. 2018. “Processed Meat
Thermal Processing Food Safety — Generating
D-Values for Salmonella, Listeria monocytogenes, and Escherichia coli.” Meat Muscle Biol
“The revised document includes a definition
of pasteurization and guidance on how to label
products as pasteurized.”