Proposed new guidance on permitted limits on Listeria monocytogenes in Ready to Eat Food: Request for Information on Associated Costs
Industry Questionnaire
Objective
As part of the Listeria Risk Management Programme, the FSA is looking to implement more stringent advice on permitted levels of Listeria monocytogenes present in ready-to-eat (RTE) food that is supplied to hospitals, nursing homes and similar health care settings. In this context, RTE foods refer to foods that do not require further processing before consumption and need to be kept at chill temperatures e.g. cooked sliced meats, smoked fish, sandwiches, prepared fruit, prepared vegetables, prepared salads, etc.
In very general terms the current L.monocytogenes level is no more than 100cfu/g in RTE foods at the end of shelf-life and a requirement for absence in certain food categories (e.g. foods intended for infants or for special medical purposes). Foods supplied in general to hospitals and similar healthcare settings are not considered as foods for special medical purposes. Two main options are being considered: (i) advice that RTE should not be supplied to health care settings unless the level of L.monocytogenes contamination is a very low level (e.g. reduce current level of <100cfu/g to <20cfu/g or <10cfu/g); and (ii) advice that RTE food supplied to hospitals and similar healthcare settings should be absent from L.monocytogenes. The new guidance for stricter levels of L.monocytogenes RTE food supplied to hospitals and similar healthcare settings would apply at the level of consumption of the food.
The FSA is now seeking information on the costs and benefits that may arise as a result of this new guidance.
All information provided in response to this questionnaire will be held securely, treated anonymously, and commercial information will not be disclosed to third parties. If you have any queries on this or any other aspect of the questionnaire, please contact Kathryn Callaghan of the Food Standards Agency, telephone 020 7276 8943.
Please return your completed questionnaire by 5pm on Friday 24 August 2013 to: .
Structure of Questionnaire
The questionnaire is comprised of 2 sections which. Section A: Business Profile - looks to gather information on the type and scale of business currently in operation. Section B: Potential Costs to Business – seeks to gather data that is as up to date as possible on the extent to which the legislative changes could impact on the cost to individual businesses and industry.
Section A: Business Profile
A) Manufacturer of Ready to Eat (RTE) foods
B) Retailer of Ready to Eat foods
C) Supplier of RTE food to hospitals/health care settings
D) Other (specify)
2. What is the average annual turnover of your business? [Choose only one]
A) Less than £2m
B) £2m - <£10m
C) £10m - <£50m
D) £50m +
H) Other (please give an approximation) /
3. What proportion of your annual turnover is related to the production of Ready to Eat (RTE) food that is supplied to hospital or health care settings?
A) Less than 10%
B) 10% - <50%
C) 50% - < 75%
D) 75% +
H) Other (specify) /
4. How many Full Time Equivalent foodhandlers are there in your business? [Choose only one]
A) Micro (<10)
B) 10- 19 employees
C) Small (20-49 employees)
D) Medium (50-249 employees)
E) Large (250+ employees)
5. In which UK country is your business located?
England / Wales / Scotland / Northern Ireland
Section B: Potential Costs to Business
6. One-Off Costs of Familiarisation and Dissemination
6 (a). Would your business need to familiarise itself with the changes in guidance on permitted levels of Listeria monocytogenes in RTE foods supplied to hospital or health care settings?Familiarisation involves key staff reading and understanding the new guidance, as well as disseminating this information to other staff within the organisation
Yes
No
If you have chosen NO to question 7(a) please continue to question 8
6 (b). If yes, please indicate in the table below the familiarisation time required. Please complete for as many staff that are required for familiarisation.Please use the format provided in the example immediately below in italics
Grade of staff / Number of staff at this grade required for familiarisation / Time required for familiarisation per staff at this grade
e.g. Senior manager / 1 / 1 hour
e.g. Production manager / 2 / 15 mins
Insert your approximations below:
Grade of staff / Number of staff of this grade required for familiarisation / Time required for familiarisation per staff at this grade
7. Testing and Sampling of Listeria
7 (a). Are your RTE products currently tested for the presence of Listeria monocytogenes? [Cross where applicable]Current Regulation requires that a certain number of samples should be tested for the presence of Listeria monocytogenes from each production batch
Yes – we carry out tests within our organisation and do the testing in-house
Yes – we carry out tests within our organisation and we send the samples to a lab for testing
Yes – the Local Authority carries out testing
No – No tests are carried out
7 (b). If yes, at what point(s) are your RTE products tested for Listeria monocytogenes?
Testing point(s) for Listeria monocytogenes /
7 (c). If yes, approximately how many production batches, per annum, are tested for Listeria monocytogenes?
Current number of batches tested, per annum /
Proportion of those batches destined for hospitals/health care settings /
7 (d). If yes, approximately how many production batches, per annum, would test positive or absent for Listeria monocytogenes, at the below specified levels?
Please insert approximate number of positive batches per annum
<100cfu/g /
<20cfu/g /
<10cfu/g /
Absence of Listeria monocytogenes /
7 (e). In relation to supplying RTE foods to hospitals and similar healthcare settings, what currently happens to products when low level contamination with Listeria monocytogenes has been detected (i.e. lower than the permitted level of no more than 100 cfu/g at the end of shelf-life)
We remove them from market
New buyers are found
We investigate
We continue to supply, it is below the legal limit
Other /
7 (f).If products are removed as a result of changes in guidance, what is the associated impact and cost?
Please insert approximate numbers / Number of batches withdrawn, per annum
<100cfu/g /
<20cfu/g /
<10cfu/g /
Absence of Listeria monocytogenes /
What is the cost of withdrawing a product from market, per batch? / Cost per batch
7 (g).If new buyers need to be found as a result of changes in guidance, what are the associated costs?
Please insert approximate numbers / Number of batches sold elsewhere, per annum
<100cfu/g /
<20cfu/g /
<10cfu/g /
Absence of Listeria monocytogenes /
What is the cost of finding new buyers for a product, per batch? / Cost per batch
7 (h). As a result of the changes to guidance, would your organisation need to increase any internal (within organisation) testing for Listeria monocytogenes in RTE products supplied to health care settings?
Yes
No
7 (i). If yes, please state the change in number of batches tested and the associated costs, at the below specified levels?
Number of additional batches tested, per annum
After a move to <20cfu/g /
After a move to <10cfu/g /
After a move to an Absence limit /
What is the cost of testing your product for Listeria monocytogenes, per batch? / Cost per batch
8. Changes to premises
8 (a). As a result of the changes to guidance, would your organisation need to make changes to raise standards to meet the requirements of a High Care area regime?Yes
No
I am not sure what a High Care area is
8 (b). If yes, please state the estimated cost to raise standards and if these would differ depending on the guidance of a particular level of Listeria monocytogenes in RTE foods:
<100cfu/g /
<20cfu/g /
<10cfu/g /
Absence of Listeria monocytogenes /
9. Changes to product
9 (a). As a result of the changes to guidance, would your organisation need to make changes to your product formulation (e.g. add a final in-pack pasteurisation step)?Yes
No
9 (b). If yes, please state the estimated cost to change your product formulation and if these would differ depending on the guidance of a particular level of Listeria monocytogenes in RTE foods:
<100cfu/g /
<20cfu/g /
<10cfu/g /
Absence of Listeria monocytogenes /
10. Likely Impact of Policy
10. The proposals for stricter criteria for Listeria monocytogenes in RTE food destined for hospitals and similar healthcare settings will be FSA guidance rather than European Union law. What is your assumption about market response to the guidance?If new level is <20cfu/g / If new level is <10cfu/g / If new level is absence
I will follow the new advice
I believe this proportion of the whole market will follow the new advice / / /
I will not follow the new guidance
[please insert any comments]
11. Any additional costs to industry
11. If you envisage any additional costs to industry from the changes to guidance that have not been identified in this questionnaire, please indicate below?[please insert any comments]
12. Potential benefits to industry
12. If there are any potential benefits to industry from the changes to guidance, please indicate below?[please insert any comments]
13. Additional Comments
13. Do you have any additional comments on the proposed change in policy?[please insert any comments]
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