ANSES’s opinion on microbiological safety and hygiene of pork carcasses refrigerated in chilling...

ANSES’s opinion on microbiological safety and hygiene of pork carcasses refrigerated

in chilling roomsand then transported in refrigerated trucks

Laurent GuillierFrench agency for food, environmental

and occupational health and safety (ANSES)

April 15th, 2014U.E.C.B.V. Working group on veterinary issues

Outline

2

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion 2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Outline

3

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion 2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Context: Study conducted by the petitioner

• Just presented by Mariem Ellouze

Context: ToRs from French ministry of agriculture• ToRs

1. Is the petitioner’s approach pertinent (modelling methods and pathogens)

2. Are petitioner’s conclusion valid ?3. What would be the maximal

temperature increase and transport duration acceptable (acceptable for competent authority = “no significant increase of the consumer’s risk”)

Outline

6

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion 2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Outline

7

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion 2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Critical analysis of petitioner approach (2)• Petitioner’s study:

– Time-temperature integration– 4 bacteria : L. monocytogenes, Salmonella, E. coli

(for Enterobacteriaceae) Pseudomonas (for total microflora)

– Growth estimated on surface (but decision rule based on core temperature)

– Fail-safe assumptions : no lag, high aw– Variability integrated (between strains, pH,

slaughterhouses, transports, …)– Comparison between scenarios and a reference

situation– Lot of data:

• 2008: transports kinetics (not representative of practices)• 2011: slaughterhouse kinetics• 2013: Core temperatures when leaving slaughterhouse and at

arrival for thousands of carcasses

Critical analysis of petitioner approach (2)

• Critical analysis regarding pathogens and predictive modelling approach- Right approach chosen: Time-

temperature integration - Ok for both chosen pathogens (the two

others don’t help to give a response to competent authority)

- Assumptions (lag, etc.): really fail safe- Variability taken into account: nothing

to say- …

Critical analysis of petitioner approach (3)

• Petitioner’s studies relies on three complementary arguments

• First argument of petitioner- Reference carcasses at slaughterhouse (24h)- Reference versus : carcasses leave when core

T is > 7C (from 10C to 30C from no representative data of 2008 at loading)

- Results : distribution of differences - Message of petitioner: even for very high

initial temperature, increases are “not so big”- ANSES’s view on theses results : ok but

don’t help to establish a derogation

Critical analysis of petitioner approach (4)

• Second argument of petitioner- Records of temperature in hundreds of

carcasses- Truks can help to decrease temperature- ANSES’s view on theses results :

This gives confidence to results on cooling kinetics of 2008 in trucks → temperature decline in transports is possible

Critical analysis of petitioner approach (4)

• Second argument of petitioner

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Température à cœur des carcasses au chargement Core temperature at loading (C)

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Critical analysis of petitioner approach (5)

• Third argument of petitioner- For evaluation of alternative scenarios,

definition of a reference scenario: but no more cold room (as in argument 1) but conditions corresponding to warm cutting derogation (12◦C-2h)

- Reference versus three scenarios (carcasses leave slaughterhouse when core T is 12, 15 or 18C)

- ANSES’s view on this approach : - Reluctant to this reference (petitioner want to

gain logistic time and to debone warm carcasses)

- Methodology to define scenario: lost of the representativeness (loss of information)

Outline

14

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion 2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Complementary approach proposed by ANSES

• Objective : to complete the petitioner ‘s study in order to help competent authority to appreciate consequences on risk

- Representativeness: objective to model of temperature kinetics

- Decision rules: objective to define adapted situation(s) of reference (corresponding to actual reg. (CE) 853/2004) versus three possible alternative scenarios (carcasses that leave slaughterhouse when core T is 12, 15 or 18C)

• ANSES proposal to model of temperature kinetics- First: core temperature modelling in

slaughterhouse

Complementary approach proposed by ANSES

Core

tem

pera

ture

(C

)

Time (h)

• ANSES proposal to model of temperature kinetics- Second: core temperature modelling in trucks.- Comparison between cooling kinetics rate

Complementary approach proposed by ANSES

Rate of exponential decease (h-1))

• ANSES proposal to model of temperature kinetics- Third: link between core temperature and

surface (the same in trucks and cold rooms)

Complementary approach proposed by ANSES

Core temperature (C)

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• ANSES proposal to model of temperature kinetics- Finally: distribution are available for every

important parameters (exponential rate in cold rooms in trucks and parameters for linking Tc to Ts): Representativeness solve

Complementary approach proposed by ANSES

Time (h)

Su

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(C

)

Outline

20

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Evaluation of different alternative scenarios

• Objective : to complete the petitioner ‘s study in order to help competent authority to appreciate consequences on risk

- Representativeness: objective to model of temperature kinetics

- Decision rules: objective to define adapted situation(s) of reference (corresponding to actual reg. (CE) 853/2004) versus three possible alternative scenarios (carcasses that leave slaughterhouse when core T is 12, 15 or 18C)

Evaluation of different alternative scenarios

• First how to define scenarios (in a stochastic context)- Example for Scenario 12C: what does that

mean? - All carcasses leave when 12C is reached: non

sense because of variability (why the first should leave after 10h, another one after 13h etc.)

- Define a time in cold room where a percentage (95%) of carcasses is below 12C

- 12C (95% below) = 15 h- 15C (95% below) = 10 h- 18C (95% below) = 8 h

Evaluation of different alternative scenarios

• What is(are) the situation(s) of reference ?- Ref A: warm cutting (15h in

slaughterhouse = 95% of carcasses <12 + 2 hours of transport

- Ref B: 24 h in cold rooms (carcasses are below 7) + transport (at a temperature randomly chosen in [2,7] range for [3-20] hours

- Ref C: 24 h in cold rooms (carcasses are below 7) + transport (at a temperature randomly chosen in [2,7] range for [3-20] hours + cold rooms of cutting plants (total time = 72h)

2.3 Third part: Evaluation of different alternative scenarios

• Ref 1A versus scenarios (scenario 15 – Lm 1 example out of 10,000)

- Example

Time(h)

Time(h)

Time(h)

Evaluation of different alternative scenarios

• Ref 1A versus scenarios- Results expressed in Nfinal scenario – Nfinal

reference (in log10)

Evaluation of different alternative scenarios

• Ref 1B versus scenarios (scenario 15 – Salmonella 1 example out of 10,000)

- Example

Time(h)

Time(h)

Time(h)

Evaluation of different alternative scenarios

• Ref 1B versus scenarios- Results expressed in Nfinal scenario – Nfinal

reference (in log10)

Evaluation of different alternative scenarios

• Ref 1C versus scenarios (scenario 18 – Lm 1 example out of 10,000)

- Example

Time(h)

Time(h)

Time(h)

Evaluation of different alternative scenarios

• Ref 1B versus scenarios- Results expressed in Nfinal scenario – Nfinal

reference (in log10)

Outline

30

1. Context: Study conducted by petitioner (with complement of October 2013) and ToR of French Ministry of Agriculture

2. Presentation of ANSES’s opinion2.1 Critical analysis of petitioner approach2.2 Complementary approach proposed by ANSES2.3 Evaluation of different alternative scenarios

3. Conclusion

Conclusion

• ANSES focused on petitioner study (as asked by competent authority)- Petitioner’s conclusions not complete

enough to evaluate safety consequences- ANSES proposed a complementary

approach to solve main limits - Definition of acceptable scenario (what

is the “reference situation”) is of competent authority‘s responsibility

- It’s possible to not comply the “7ºC” while maintaining an acceptable risk level

Conclusion: differences between ANSES and EFSA ?

Similarities• ANSES and EFSA general approaches are similar (TTE,

growth on surface, variability)• ANSES and EFSA used the same reference situation

(24h in slaughterhouse+48h of transport)• ANSES and EFSA’s conclusions are the same: “it’s

possible to define alternative chilling process and transport regimes… without increasing the risk”

• ANSES and EFSA’s conclusions opens the way to possible derogations

Differences• Surface temperature modelling is more “complex” in

ANSES’s opinion• EFSA recommends to establish a process criteria based

on a limit of surface temperature and a transport time /ANSES doesn’t define the nature of process criteria (surface temperature, a core temperature, a percentage of carcasses above a value etc.)