Food Protection Trends - February 2009 - 73

INTRODUCTION Consumers today enjoy a vast selection of convenient and nutritious foods that can be quickly prepared in the home by consumers. While some ready-to-eat (RTE) meals, entrées and snacks can be safely eaten in the form in which they are purchased, other foods, classified as not-ready-to-eat (NRTE) products, must be cooked by consumers before they are consumed. It is the obligation of the food processor to ensure that the consumer knows that cooking, rather than just heating or warming for palatability, is necessary for these products and that the cooking instructions provided to the consumer are adequate for their intended purpose. In recent years a number of cases of foodborne illness associated with NRTE products have brought increased recognition by industry of the importance of the cooking instructions for these products and a growing concern by the regulatory agencies about their adequacy (2, 6, 7, 8, 9, 14). A proactive industry initiative by the Grocery Manufacturers Association (GMA) has led to substantive guidelines that will aid processors in validating that the cooking instructions on the label, when properly followed by consumers, will result in safe products. This article highlights GMA’s “Guidelines for Validation of Consumer Cooking Instructions for Not-Ready-to-Eat (NRTE) Products” (“the guidelines” or “the guidance document,” hereafter) that were finalized in July 2008 (5). The guidance document discusses the wide range of factors, especially for microwave ovens, that should be taken into account when validation testing is performed. Topics addressed in the guidelines include Purpose and Scope; Determining Appropriate Lethality Requirements; Type of Validation Required; Number of Samples to Test; Factors Affecting the Validation Test, including Product and Package Factors and Type of Cooking Device (Microwave Ovens, Conventional and Toaster Ovens, Fryers, Stovetops). For microwave ovens, information is provided on the following subjects: Microwave Oven Wattage, Rotation of Product, Magnetron Power Output, Number of Units Being Cooked at One Time, Cold Spot Determination and Heating Uniformity in Product, Temperature Determination, and Labeling Products for Microwave Cooking. The guidelines also cover Evaluating the Results of the valida- tion tests. Broad industry adoption and adherence to the guideline recommendations should help assure the continued safety of this category of convenient food products. Cooking for safety is required for NRTE foods because these products typically contain at least one ingredient for which the processor cannot ensure the elimination of vegetative pathogens, such as Listeria monocytogenes and Salmonella, during their manufacture. Many NRTE products contain an RTE (or fully cooked) meat or poultry component combined with one or more other ingredients that are uncooked or only partially cooked and that therefore have not received heat treatment adequate to eliminate vegetative pathogens. Although these NRTE products are not subject to specific lethality requirements as are many RTE products, USDA’s Food Safety and Inspection Service (FSIS) has certain explicit expectations for these products, including validation of the cooking instructions provided on product labels (12, 13). The Food and Drug Administration (FDA) currently has no regulations or written policies that specifically address the NRTE products that fall under its jurisdiction. However, FDA fully expects NRTE products to be safe. Manufacturer validation of cooking instructions is a key step in ensuring that products prepared by the consumer according to the manufacturer’s preparation instructions are safe to eat. After several foodborne illness outbreaks linked to undercooked frozen, raw breaded poultry products, FSIS in late 2006 issued a notice (12) instructing NRTE food processors to validate the cooking instructions they provide to consumers. Regulatory interest in these and similar frozen products intensified during the summer of 2007 when frozen NRTE products, such as pot pies and pizzas made with RTE meat or poultry components, were implicated in foodborne illness outbreaks. Even before the illness outbreaks of 2006 and 2007, GMA had recognized that a protocol for the validation of consumer cooking instructions for NRTE foods would facilitate industry efforts to ensure the adequacy of those instructions and could lessen the potential for new and possibly restrictive regulations for these products. As a result, GMA staff, with valuable assistance from the GMA Consumer Cooking Instruction Valida- tion Task Force, developed guidance on this issue. For the guidance document to reflect input from, and be relevant to, the broadest audience possible, drafts were circulated to allied trade associations, as well as to FSIS and FDA, for review and comment. OVERVIEW OF THE GUIDELINES These guidelines are intended for manufacturers of FSIS- and FDA-regulated retail NRTE products that, by definition, require a pathogen lethality treatment (cooking) by consumers before being consumed. They are not intended for RTE products that are simply heated or warmed for palatability. The guidelines recommend that all labeled cooking instructions should be validated to confirm and document that they will provide adequate lethality to destroy any pathogenic organisms of concern that might be present. Cooking instructions should be reassessed and revised if necessary when product or packaging design changes are made that may adversely impact any of the conditions originally validated. Rather than exhaustively detailing how validation testing should be performed for all methods of preparation and all types of NRTE products, these guidelines highlight the many issues that manufacturers should consider when conducting validation studies. The guidelines emphasize that cooking instruction validation can be performed in many different ways. Thus, it is very important to note that the guidelines are not intended to set a standard that limits or restricts industry’s ability to employ other science-based validation methodologies. These guidelines apply to both frozen and refrigerated NRTE products; however, it is appropriate to note that to date food safety problems for this category of foods have consistently involved frozen products. Consequently, frozen NRTE products, especially those bearing microwave cooking instructions, can be expected to be a focal point for attention by the regulatory agencies. It is recognized that validation testing based on worst case scenarios for every conceivable variable that could be encountered in cooking NRTE products represents a situation that is highly unlikely to occur in the home. Furthermore, it would almost certainly result in overcooked and FEBRUARY 2009 | FOOD PROTECTION TRENDS 73
Food Protection Trends - February 2009

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