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1 Introduction SOURCES OF MICROORGANISMS IN FOODS Man's food supply consists primarily of plants and animals and products derived from them. Microorganisms are naturally present in the soil, water, and air, and therefore exterior surfaces of plants and animals are contam- inated with a variety of microorganisms. There is little specificity to this microflora since it reflects that of the environment in which the plants were grown and the animals were raised. Interior tissues of plants and animals usually contain few, if any, microorganisms. The gastrointestinal tracts of animals, however, contain large numbers of organisms. But if proper slaughtering-dressing procedures are used, contamination of inte- rior muscle tissue can be avoided. From the time of slaughter, catch, or harvest, the surface and interior tissues of animals and plants are subject to contamination. This is due in part to the breakdown of normal defense mechanisms, particularly in animals. Each processing step subjects the raw material to additional opportunities for contamination. Sources of contamination include surfaces of the harvested plant or slaughtered animal, water, equipment, utensils, workers, and the processing environment. MICROBIAL ACTIVITIES IN FOODS Historical Aspects During their existence, human beings have been confronted with the problem of limited shelf-life of animal and plant foods in part due to 41

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42 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA microbial activities. During the last 5,000 to 10,000 years a variety of techniques (such as drying, salting, heating, fermentation, refrigeration, or freezing) evolved empirically and contributed to the increased shelf- life of plant and animal foods. These techniques, which controlled mi- crobial activity to a greater or lesser extent, were applied before the mechanism of their effect was understood. In the early 1800s Francois Nicholas Appert was awarded a patent for a practical method of food preservation, namely, "canning." Since that time, and particularly during the last 40 years, new processes have been developed to extend shelf-life of foods. Although some others may have suggested microbial involve- ment in food spoilage at earlier dates, it was Louis Pasteur who in the mid-1800s first established a scientific basis for the direct relationship between food spoilage and microbial activity. Microorganisms responsible for foodborne diseases were first recognized around 1880. Since that time, the number of microbial agents recognized as involved in foodborne illness has increased steadily. Spoilage, Pathogenic, and Useful Microorganisms Microorganisms associated with foods can be categorized as "spoil- age," "pathogenic," or "useful." Spoilage microorganisms are those that can grow in a food and cause undesirable changes in flavor, consis- tency (body and texture), color, or appearance. Also bacterial enzymes may effect slow deterioration of frozen or dried foods during long-time storage. These changes diminish the quality characteristics of foods and may render them ultimately unfit for human consumption. For example, refrigerated perishable foods such as milk, fresh meat, poultry, fish, fruits, tat ~~ r and vegetables lose some quality characteristics during normal storage and ultimately spoil, due in part to the activity of microorganisms capable of growth at refrigeration temperatures. Usually, extensive microbial growth (millions of organisms per g or cm2) occurs before quality losses are perceptible. These changes, when perceived by the consumer, serve as an alert that extensive microbial activity has taken place. Pathogenic microorganisms can render foods harmful to humans in a variety of ways. Foods may serve as the vehicle for the introduction of infectious microorganisms into the gastrointestinal tract, e.g., Salmonella and Shigella. Multiplication of certain microorganisms in foods prior to consumption may result in production of toxins, e.g., Clostridium botu- linum, Staphylococcus aureus, and Bacillus cereus. Foods may also be the vehicle for microorganisms that form toxins in viva, e.g., Clostridium perfringens and certain pathogenic Escherichia colt. With some foods, conditions are chosen to favor the development of

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INTRODUCTION 43 useful microorganisms such as lactic acid bacteria and yeasts, which are either naturally present or added intentionally. Such foods as cheeses, yogurt, breads, pickles, and fermented sausages offer desirable organo- leptic properties and shelf-life. Food as a Selective Environment Microbial activities in foods can be viewed from the perspective of the food as a "selective environment," despite the diversity of microorgan- isms that contaminate the surfaces of the raw materials. The selectivity is imposed by the physical-chemical characteristics of the food, the ad- ditives it contains, the processing techniques, the packaging material, and the storage conditions. It is necessary to distinguish between the shelf- life of two broad categories of foods, namely those that are shelf-stable and those that are perishable. For this discussion, shelf-life will be treated as it relates to microbial activity only. Microbiological shelf-stability of many foods is related to storage con- ditions. For example, dried and frozen foods are microbiologically shelf- stable as long as they remain dry or frozen. Shelf-stable foods are not necessarily sterile; indeed, many do contain microorganisms. Some shelf- stable canned foods may undergo microbiological spoilage if they are exposed to elevated temperatures permitting the growth of surviving ther- mophilic sporeforming bacteria, whereas these organisms are inactive at ambient temperatures and indeed tend to die during normal storage. Shelf- stable food is distinguished from perishable food in that an attribute or attributes of the shelf-stable food prevented the growth of contaminating microorganisms. For example, certain canned products are heat processed to the degree that they are sterile; the attribute assuring stability of such products is elimination of all living forms. With many shelf-stable foods, other attributes prevent microbial growth. Dried beans are shelf-stable because they contain insufficient moisture to permit microbial growth. Mayonnaise is shelf-stable because it contains sufficient quantities of acetic acid in the moisture phase of the product to prevent growth of contami- nating organisms. Certain canned cured meats are shelf-stable, not because they are sterile, but because sublethal heat treatment so injures surviving spores that they are incapable of outgrowth in the presence of salt and nitrite. The distinguishing characteristic of shelf-stable foods, then, is their resistance to microbiological spoilage. Microbial growth in such products is an abnormal and unexpected event. Perishable foods, on the other hand, have a finite shelf-life and if not consumed, will spoil at some time during storage. The exact time of spoilage depends upon a great number of variables. Though various pro

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44 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA cessing procedures, additives, packaging methods, and storage conditions may be applied to increase shelf-life, microorganisms capable of growth survive and ultimately grow. When such growth proceeds to the extent that undesirable changes are perceptible to the processor, preparer, or consumer, the food is deemed of inferior quality or spoiled and is rejected. The distinguishing feature of perishable foods, in contrast to shelf-stable foods, is that microbiological spoilage is an expected event. It will ulti- mately occur even if the food has been prepared from wholesome raw materials and has been properly processed, packaged, and stored. Microflora of Processed Foods Although the microflora of raw materials is usually heterogeneous, processing of foods (except those that are sterile) often imposes a char- acteristic and highly specific microbiological flora. The normal flora of severely heat processed, but not sterilized, low-acid canned foods is com- prised of thermophilic sporeforming bacteria, the most heat-resistant mi- crobial components of the raw materials. The predominating flora of shelf- stable canned cured meats consists of mesophilic aerobic and anaerobic sporeforming bacteria, the predominant organisms resistant to the heat process applied to these products. The normal flora of mayonnaise and salad dressing is comprised of small numbers of sporeforming bacteria, yeasts, and lactic acid bacteria. Aerobic sporeforming bacteria predomi- nate in dry spices and in a number of dry vegetable products. Molds and yeasts predominate in dried fruits. The normal flora in carbonated bev- erages is comprised of yeasts. In each of the foregoing, the surviving and predominating microflora reflects the nature of the raw materials, pro- cessing conditions, packaging, and storage of the shelf-stable product. However, spoilage is still possible. If the severely heat-processed canned foods were exposed to high temperatures during storage, spoilage due to the germination and outgrowth of thermophilic sporeforming bacteria might occur. If shelf-stable canned cured meat were to contain excessive numbers of aerobic sporeforming bacteria, growth of these organisms might result in spoilage, despite an adequate heat process and normal levels of salt and nitrite. Excessive levels of yeasts or lactic acid bacteria might result in their growth and subsequent spoilage of the mayonnaise, despite levels of acetic acid that would assure the stability of a product containing "normal" levels of the same organisms. Time/temperature abuse of an ingredient of a carbonated beverage (for example, a flavor) may lead to the development of large numbers of yeasts that could overcome the effect of carbonic acid, which would normally render the same beverage stable. The normal flora in microbiologically shelf-stable products is, therefore,

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INTRODUCTION 45 rather specific. If the stabilizing nature of the system should be overcome, this microflora may multiply and cause spoilage-an unexpected event. With perishable products, the microflora that survives processing may be heterogeneous, but that portion of it developing during storage and causing spoilage is usually quite specific. For example, a heterogeneous flora exists on raw red meats, poultry, and fish as a result of contamination from the animal and/or the processing environment. Yet, during refrig- erated storage of such products, spoilage is caused predominantly by a highly specific group of microorganisms, namely Pseudomonas and closely related aerobic, psychrotrophic gram-negative bacteria. If the same prod- ucts are vacuum-packed in oxygen-impermeable films, a different micro- flora becomes predominant, namely, lactic acid bacteria that grow under both aerobic and anaerobic conditions. In both examples, despite the heterogeneous flora of the finished product, a rather restricted group of microorganisms may develop and ultimately cause sensory changes in the product. Similar relationships exist for many other perishable foods. It follows that since most classes of perishable foods constitute selective environments for rather restricted groups of microorganisms, the spoilage caused by the growth of these microorganisms manifests itself in a char- acteristic manner, i.e., normal spoilage pattern. For example, when pseu- domonads and other closely related gram-negative psychrotrophic aerobic bacteria grow to large numbers on the surface of refrigerated fresh meat, poultry, and fish, sensory changes occur. The first manifestation of spoil- age is development of off-odor. As growth proceeds, slime may develop and the off-odor may intensify. The normal spoilage pattern of a perishable food can be a safeguard, since under certain situations it warns the pro- cessor, preparer, or consumer that the food is no longer edible. Changes in processing of perishable foods must take into account the effect these changes may have on the spoilage flora, and thus on the normal spoilage pattern of the food involved. If such changes tend to alter the normal patterns of spoilage the public health aspects must be taken into account. A classic example of this relates to the merchandising of smoked whitefish. For generations this product was merchandised under conditions where the fish was exposed to air. Spoilage was evidenced by the development of bacteria which produced off-odors and slime that were readily recognized by the consumer and caused rejection of the product. Then it was discovered that the shelf-life of smoked fish could be signif- icantly increased if the product was packed in an oxygen-impermeable film. With extended storage of the product under these conditions, C. botulinum type E was able to grow and produce toxin, just as it would have been able to do in the conventionally packaged product. However, under these storage conditions the aerobic bacteria producing off-odor and

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46 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA slime could not develop and the normal spoilage flora was now comprised of lactic acid bacteria that did not produce off-odors. This change in the normal spoilage pattern of the product reduced the probability that the consumer would reject a product that had been held in storage out of refrigeration for an extended period of time. This led to a multistate outbreak of type E botulism (Kautter, 19641. Thus, it is essential that if changes are made in the processing or merchandising of a perishable product, the influence of these changes on the normal spoilage patterns of the product be taken into account. CONTROL OF MICROORGANISMS IN FOODS Control must be exercised over three different categories of microor- ganisms that may be present in foods: (1) those that have the potential for producing foodborne disease, (2) those that cause food spoilage, and (3) those that grow in food and produce desirable changes. Effective food control programs eliminate the potential for foodborne illness in a variety of ways. Processing techniques that cause destruction of pathogens may be employed, e.g., the pasteurization of milk to destroy Coxiella burnetii and Mycobacterium tuberculosis and less heat resistant pathogens such as the diphtheria bacillus, salmonellae, and pyogenic strep- tococci, and the 12-D process for the destruction of C. botulinum in low- acid canned foods. In other cases, toxigenic and infectious microorganisms are controlled by product formulation (acetic acid in mayonnaise) or stor- age conditions (the refrigeration of perishable pasteurized canned cured meats to control the growth of C. botulinum). In yet other situations, the ultimate control is exercised by the person who prepares the food (adequate cooking of poultry to eliminate salmonellae and of pork to eliminate trichinellae). Despite such efforts, food control programs have fallen short of their goals for controlling foodborne pathogens (see in particular Chapter 4 where foodborne illness of microbiological origin is treated in detail). Control measures directed toward prevention of spoilage have also fallen short of the ideal. Although precise figures are difficult to obtain, it is estimated that one-fourth of the world's food supply is lost through mi- crobial activity alone. The control of food spoilage is a prime economic objective of control programs. For products designed to be shelf-stable, The 12-D process is the minimum heat treatment applied to low-acid canned foods; it provides for the reduction of 10~2 heat-resistant spores of C. botulinum to one. This requires approximately 2.5 minutes exposure at 121.1C (250F) or its equivalent.

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INTRODUCTION 47 control is accomplished through processing and/or formulation procedures that result in the inhibition of spoilage organisms. With perishable foods, the object is to achieve the longest possible shelf-life consistent with product safety. In general, this is attempted by instituting measures that will result in products with low microbial loads, since shelf-life and initial level of contamination are usually directly related in perishable foods. Control of remaining microorganisms is most often achieved by proper refrigerated storage. The desirable organoleptic properties (taste, odor, body, and texture) of such foods as cheeses, yogurts cultured buttermilk, sour cream, pickles, and fermented sausages result in part from the activities of a specific microbial flora. Extensive microbiological control procedures are needed to produce "cultured products" of high quality and to ensure that the microbial activities are guided in such a manner that the end products have the desirable sensory properties. For example, in cultured dairy products this is achieved by (1) proper selection and handling of starter cultures, (2) control of the presence of antibiotics and bacteriophages, and (3) checking by chemical and organoleptic means the progress of microbial activity in raw and finished products. These measures can influence both the quality and the safety of the food. For example, the lack of acidity caused by culture failure can allow the development of S. aureus, which could result in cheese containing staphylococcal enterotoxin. Another objective of food control programs is to keep filth and other foreign substances out of food. In some cases, extraneous matter is of public health concern, e.g., rodent pellets and hairs; in other instances, the foreign material is of aesthetic rather than health significance, e.g., certain cereal insects. Finally, another objective of food control programs is to ensure that packaging, storage, handling, transportation, display, and sale of foods are all properly carried out. Processors and regulatory officials can exert control over a product while it is packaged, stored, and readied for dis- tribution from the plant of origin. But beyond that point, the intensity of control rapidly diminishes. The bulk of the problems with foodborne disease and food spoilage results from events that occur after food has left the processing plant- during transport, during retail sales, and ultimately in the food service establishment or home (CDC, 19811. In these locations, control on oc- casion either does not exist or is executed ineffectively, thus producing the weakest link in the food chain. Many improvements in food control that are made at the processing level will be nullified if handling procedures beyond the plant are not effectively controlled.

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48 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA APPROACHES TO MICROBIOLOGICAL CONTROL IN FOODS Traditionally, three principal means have been used by regulatory agen- cies and food processors to control microorganisms in foods. These are (1) education and training, (2) inspection of facilities and operations, and (3) microbiological testing. Although food handlers have the potential for contaminating foods with disease-producing microorganisms, i.e., staphylococci, salmonellae, and hepatitus virus, health examination of food handlers is a nonproductive approach to the control of foodborne illness. Specimens from food handlers have traditionally been examined only for a few microorganisms, and such tests do not always detect carriers. Screening tests cannot be made with sufficient frequency to be effective in detecting the carrier status in persons who are continually exposed to the risk of acquiring foodborne pathogens. Negative tests convey to food handlers, managers, and public health per- sonnel the erroneous concept that the workers are free of infections and therefore incapable of transmitting foodborne pathogens to the foods they handle. Although direct transfer of pathogens from food handlers to food is a hazard, far more frequently improper food-handling practices create a hazard that is not circumvented by health examinations. Education and Training Programs These programs are directed primarily toward developing an under- standing of the causes and consequences of microbial contamination and of measures to prevent contamination and subsequent growth. The extent of training required of personnel within processing plants and food service establishments depends upon the technical complexity of the food oper- ation and the level of responsibility of the individuals being trained. In- depth training may be necessary for supervisory personnel, while for others training may relate only to specific aspects of a food operation. Although education and training are necessary parts of any food control program, standing alone they have certain limitations and shortcomings. Personnel turnover in the food industry is both constant and rapid, and thus education of workers must be a continuing rather than a sporadic exercise. It is essential that supervisory personnel be properly trained with respect to the hazards associated with the operations for which they have responsibility. Inspection of Facilities and Operations Inspections of facilities and operations are commonly used to evaluate adherence to good handling practices. The U.S. Department of Agriculture

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INTRODUCTION 49 (USDA) relies almost entirely upon this approach in the regulation of meat and poultry operations. Resident inspectors observe all phases of pro- cessing from the live animal to the finished product. Little reliance is placed upon microbiological testing in the meat and poultry control pro- grams. In its activities with respect to dried milk and egg processing, the USDA relies not only on inspections but also on microbiological testing of the finished products. The Food and Drug Administration (FDA) also relies heavily on in- spection of facilities and operations. In addition, both in-process and finished product samples are collected and analyzed. Results of such analyses are used to corroborate observations made during inspections; they are not intended to perform the processors' responsibility of micro- biological control on a day-to-day basis. The FDA inspection program is designed to determine whether or not processors are operating in com- pliance with the Federal Food, Drug and Cosmetic Act. Thus, this activity is in sharp contrast to that of the USDA meat and poultry inspection, wherein resident inspectors are charged to assure that plants are in com- pliance with the Federal Meat Inspection Act and Poultry Products In- spection Act on a day-to-day basis. Procedures vary widely at the state, county, and municipal levels, but the approach to regulatory control is primarily through periodic inspection of facilities and operations. Just as with the education and training approach to food control, in- spection of facilities and operations alone is not sufficient. Generally, the inspector relies upon advisory or mandatory documents such as Good Manufacturing Practice (GMP) guidelines and Codes of Hygienic Practice or local food control laws, ordinances, or regulations. Unfortunately, such documents often refer to stated requirements without specifying what is considered to be in compliance with the requirements.2 This lack of spec- ificity, or failure to indicate the relative importance of the requirements, leaves interpretation of compliance solely at the discretion of the inspector. Lack of discrimination between important and relatively unimportant re- quirements may result in overemphasis upon unnecessary or relatively minor requirements, and thus increase costs without significantly reducing hazards. Requirements that are critical to the safety of the product may be overlooked or underestimated. 2A notable exception is the USPHS/FDA Grade A Pasteurized Milk Ordinance wherein for each requirement a statement is given that specifies what constitutes compliance with the re- quirement.

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50 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA Microbiological Testing Samples of ingredients, materials obtained from selected points during the course of processing or handling, and finished products may be ex- amined microbiologically to determine adherence to Good Manufacturing Practices. In some instances, foods are examined for a specific pathogen or its toxins, but more often examinations are made to detect organisms that are indicative of the possible presence of pathogens or spoilage or to detect presence of the specific spoilage organisms or their products. Mi- crobiological testing is absolutely essential to the control of certain prod- ucts, e.g., to assure that dried milk and eggs and confectionery products are free of a Salmonella hazard. Testing is essential to assure that critical raw materials are satisfactory for their intended use, e.g., to assure that the sugar used in canning meets established standards and to assure that critical products used in dried blends are free of Salmonella. Microbiological testing has severe limitations as a control option. The most serious shortcoming is the constraint of time. Most microbiological test results are not available until several days after testing. Therefore, if finished product acceptability must be measured by microbiological test- ing, the product is held pending results. With perishable foods, this is generally not possible; with shelf-stable foods, the warehousing of finished product increases costs. If in-line samples are collected and analyzed, the results are of retrospective value since the finished product has already been produced. Other difficulties are related to sampling (see Chapter 6), analytical methods (see Chapters 4 and 5), and the use of indicator or- ganisms for pathogens (see Chapter 51. Composite Programs Sophisticated microbiological control programs encompass the three approaches, namely education and training, inspection of facilities and operations, and microbiological testing. The emphasis varies from plant to plant, product to product, and establishment to establishment, as does the success of the various microbiological control programs. The Hazard Analysis Critical Control Point (HACCP) System The HACCP system, first presented at the 1971 National Conference on Food Protection (APHA, 1971), provides a more specific and critical approach to the control of microbiological hazards than that achievable by traditional inspection and quality control procedures. The system con- sists of: ( 1 ) identification and assessment of hazards associated with grow

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INTRODUCTION 51 ing, harvesting, processing-manufacturing, marketing, preparation, and/ or use of a given raw material or food product; (2) determination of critical control points to control any identifiable hazarded; and (3) establishment of procedures to monitor critical control points. Analysis of factors to be considered in hazard analyses, detailed in Chapter 3, leads to establish- ment of the control points to be monitored. Depending upon the situation, the monitoring may involve inspections, physical or chemical measure- ments, and/or microbiological testing. The HACCP system is a structured approach to microbiological quality control. The key lies in the meaning of "critical control point," which is a location or a process that, if not correctly controlled, could lead to contamination of the product with foodborne pathogens or spoilage mi- croorganisms or their survival or unacceptable growth. A careful hazard analysis leads to the identification of critical control points. Once the critical control points have been identified, the final problem involves finding the most effective and practical means for monitoring these points. Properly applied, the HACCP system separates the essential from the superfluous aspects of microbiological control. As discussed in Chapter 10, use of the HACCP system by industry not only offers the food processor a rational approach to microbiological control, but also leads to more effective and economical utilization of regulatory manpower. The in- spector focuses initial attention on monitoring records and, if the results indicate satisfactory control over critical control points, logically con- cludes that efforts could be more effectively expended on other food- processing operations either with the same or with other food-processing plants. The HACCP system has been successfully applied to the microbiological control of low-acid canned foods. Indeed, in the United States monitoring of critical control points in the production of these products is subject to federal regulations. Many industrial organizations have adopted the HACCP system as a means of microbiological control over products other than low-acid canned foods. The system has also been applied to microbio- logical control over food service establishments and has even been used in the home. Unfortunately, only limited use has been made of the HACCP system by regulatory authorities. Impediments to its more widespread use are discussed in detail in Chapter 10. THE CURRENT ROLE OF CRITERIA IN MICROBIOLOGICAL CONTROL IN FOODS Microbiological criteria in one form or another have been in existence in the United States since the early part of this century. The more prominent

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52 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA microbiological standards formulated and enforced by federal regulatory agencies are those for milk, water, shellfish, and egg products. Other standards exist for aflatoxins, scombroid toxin, paralytic shellfish toxin in specific foods, and defect action levels for specific foods. The enforce- ment of these standards has contributed to significant improvements in the microbiological safety and quality of these products. At the federal level no formal microbiological standards exist for other foods. Despite this lack, existing laws provide sufficient authority for the removal from the marketplace of products with microbiological conditions that pose a threat to health. Therefore, "implied" microbiological standards do exist.3 Even in the absence of a threat to health, existing federal laws provide sufficient authority for seizure of products if there is direct or indirect evidence that a product is contaminated with filth, e.g., seizure of tree nuts contaminated with E. cold and seizure of raw shrimp contaminated with salmonellae. In the latter case, seizure is based not on a health hazard, but on the premise that the presence of salmonellae is indicative of in- sanitation in the processing of the shrimp. Federal laws also give sufficient authority for seizure of products for aesthetic reasons. If GMPs were held to have the force of law, they could provide authority to the FDA to use microbiological criteria therein in the assessment of good manufacturing practices. However, with few exceptions, umbrella GMPs are inadequate for such purposes as they lack precise, achievable standards (U.S. v. An Article of Food, 19721. Thus, at the federal level, though limited use has been made of formal standards, the law has nevertheless provided adequate authority for seizure of foods known to present health hazards. A detailed discussion of the current status of microbiological criteria and their legislative bases is 3Section 402(a)(1) of the Food, Drug and Cosmetic Act (U.S. Congress, 1980) specifies that a food that bears or contains any poisonous or deleterious substance that may render it injurious to health is deemed to be adulterated. Pathogens or their toxins may be considered as deleterious or poisonous substances, respectively. However, the presence of certain pathogens in any number in a food available to consumers must not be tolerated (e.g., Shigella dysenteriae, Vibrio cholerae O-1); the mere presence of certain others is not hazardous although high populations of them would be (e.g., C. perfringens, B. cereus). Section 402 (a)(1) does not make this distinction. Accordingly, microbiological criteria become useful in interpreting this section of the act as they specify the pathogen or toxin of concern, the analytical method by which they may be detected, the sampling plan for obtaining the food to be analyzed, and the level of population of a pathogen or concentration of toxin that must not be exceeded. Nevertheless, in the absence of such criteria "implied" standards for pathogens do exist by the very nature of the wording of Section 402(a)(1), and have been enforced by the FDA when in its judgment a direct health hazard exists, i.e., a food contains a deleterious agent that may render it injurious to health. Thus, microbiological criteria provide a means for interpreting the provisions of 402(a)(1) as it pertains to pathogens.

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INTRODUCTION 53 presented in Chapter 8. Microbiological criteria adopted by state, county, and local health agencies are also included in this review. Twenty-five states have microbiological criteria, usually guidelines, for one or more foods (Wehr, 19821. Microbiological quality standards have recently been proposed by the FDA. These standards do not purport to have any relationship to safety. As yet, none has been adopted. For further discussion of microbiological quality standards, see Chapter 2. Microbiological criteria have long been used by industry to assess the microbiological safety and quality of its products, for in-process moni- toring, and for microbiological inspection of raw ingredients. Generally, these criteria are internally generated and proprietary, though some com- panies publish the microbiological criteria relating to their finished prod- ucts for sales promotion purposes. Microbiological criteria are also used by industry in connection with purchase specifications. These criteria are included in purchase contracts between vendors and purchasers of prod- ucts. Industry "standards" exist for certain raw materials, the best ex- amples being the National Food Processors Association standards for sporeforming bacteria in sugar and starches and the National Soft Drink Association standard for the presence of yeasts, molds, and bacteria in sugar. CONSIDERATIONS IN ESTABLISHING CRITERIA The establishment of a meaningful microbiological criterion is not a simple process. In 1964, the Food Protection Committee of the National Research Council proposed three basic principles for setting a microbio- logical criterion (NRC, 19641. These principles were that microbiological criteria for foods should: (1) accomplish what they purport to do, i.e., reduce public health hazards; (2) be technically feasible, i.e., attainable under conditions of good commercial practice; and (3) be adminstratively feasible. Difficult questions must be answered before a useful microbiological criterion can be established. For example, what foods should be subject to microbiological criteria and on what basis? What contaminants should be specified (pathogens, indicator organisms, toxins, etch? What limits should be placed on the presence of each contaminant? How large a sample of each food should be examined and by what method? The most com- prehensive discussion of these questions on the international level is pro- vided by the International Commission on Microbiological Specifications for Foods (ICMSF, 1985) and the Codex General Principles for the Es- tablishment and Application of Microbiological Criteria for Foods (see Appendix B).

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54 EVALUATION OF THE ROLE OF MICROBIOLOGICAL CRITERIA THE CURRENT REPORT This book is the result of the Subcommittee on Microbiological Cr~- ter~a's examination of the value of microbiological criteria in the control of food quality and safety. The subcommittee tried to bring the uses of microbiological criteria into perspective with respect to their place in a total program for microbiological control of foods in the United States. The book contains chapters on the purpose of microbiological criteria and definitions of terms used in relation to them, on factors that influence the selection of foods to be considered for criteria, on the selection of mi- croorganisms as components for criteria, on the selection of sampling plans, and on the action to be taken when a criterion is exceeded. Foods of several major commodity groups are identified as appropriate candidates for microbiological criteria on the basis of recognized problems related to safety and quality. Finally, plans of action are presented for imple- mentation of the HACCP system and development of meaningful micro- biological criteria. The subcommittee's responses to specific questions raised by the sponsoring agencies and the general recommendations of the subcommittee are presented in sections devoted to those purposes. REFERENCES APHA (American Public Health Association) 1971 Proceedings of the 1971 National Conference on Food Protection. Washington, D.C.: U.S. Department of Health, Education and Welfare, Public Health Service, Food and Drug Administration. CDC (Centers for Disease Control) 1981 Foodborne Disease Outbreaks. Annual Summary 1979. Issued April 1981. Atlanta: U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control. ICMSF (International Commission on Microbiological Specifications for Foods) 1985 Microorganisms in Foods. 2. Sampling for microbiological analysis: Principles and specific applications. 2nd Ed. In preparation. Kautter, D. A. 1964 Clostridium botulinum type E in smoked fish. J. Food Sci. 29:843-849. NRC (National Research Council) 1964 An Evaluation of Public Health Hazards from Microbiological Contamination of Foods. Food Protection Committee. Washington D. C.: National Academy of Sciences- National Research Council. U.S. Congress 1980 Federal Food, Drug and Cosmetic Act, as amended. Washington, D.C.: U.S. Gov- ernment Printing Office. U.S. v. An Article of Food 1972 Pasteurized whole eggs, 339 F. Supp. 131 (N.D. Gal, 1972). Wehr, H. M. 1982 Attitudes and policies of governmental agencies on microbial criteria for foods-an update. Food Technol. 36(9):45-54, 92.