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Microbiological standards for raw pet food, milk and milk products and other ABPs - SE4403

In response to a number of diseases affecting public and animal safety including, for example, the emergence of Bovine Spongiform Encephalopathy (BSE), the European Parliament implemented Regulation (EC) 1774/2002 to regulate the use and disposal of animal by-products (ABPs). Recently, the Regulations have been reviewed given feedback from Member States, via the EU Commission, and in light of more recent information regarding the risks posed by certain ABP material and treatment standards in producing a “safe” product. Given the feedback from the EU Commission consultation process, the Regulations were revised whilst ensuring, importantly, protection of public and animal health and food safety remained. The resulting Regulation (EC) No 1069/2009 and its corresponding Implementing Regulation (EC) 7066/2010 came into effect on 4th March 2011, revoking and replacing Regulation (EC) 1774/2002.

Whilst the revised Regulations have addressed concerns regarding, for example, the categorisation of ABPs being proportionate to the risks they pose, the Regulations have not addressed concerns in meeting specific microbiological standards of final ABP derived products (e.g. pet food). Within this new Regulation, Annex X and Annex XIII define microbiological standards for ABP derived products including raw and processed pet food and milk and milk derived products. Any sample for either product which exceeds the specified microbiological limits is considered unsatisfactory and the plant operator is informed of the failure to comply with the legislative requirements which may result in the suspension of premises approval (if it is a new premises).

In the United Kingdom (UK), the adherence to the Enterobacteriaceae stipulations, particularly for raw pet food, has been challenging for certain plants. This may be due to the use of tripe (a Category 3 material) which is a popular raw pet food ingredient in the UK and likely to have very high Enterobacteriaceae counts. This issue has been considered in relation to the production of animal feed within an EFSA Microbiological Risk Assessment (EFSA, 2008). That risk assessment concluded it was not desirable to use microbiological criteria for indicator organisms such as Enterobacteriaceae although such criteria could be used voluntarily by the industry as an indicator on whether action should be taken.

The UK has approached the EU Commission with the stakeholder concerns of having an absolute maximum value for Enterobacteriaceae numbers for feed materials and raw pet food in particular. However, further scientific information is required to provide a robust evidence base for the UK to negotiate with the Commission on this point. The aim of this project is to provide that robust evidence base by using a combination of primary social research and analytical methods to determine the scientific validity and practical feasibility of the current microbiological standards for raw petfood, milk and milk derived products and other ABPs and to recommend alternative standards, if applicable. To meet this aim, firstly, the current evidence base for Regulation (EC) 7066/2010 will be reviewed to understand the scientific evidence underpinning the current microbiological standards. This will be supplemented with current scientific evidence that may agree or challenge the current standards and/or their thresholds.

Once this information has been gathered, in conjunction, with a stakeholder map of those ABP industries which may be affected by the microbiological monitoring requirements of the EU ABP legislation, the scope for the remaining research would be defined. This would include the use of focus groups with the ABP industry to ascertain the current problems stakeholders in the UK experience with complying with the Regulation (EC) 7066/2010 and what possible solutions could be implemented with regards to revised microbiological standards for pet food, milk and milk products and other ABPs. Using the information gained from these focus groups and the literature review, expert opinion would be elicited using established methods from a range of scientists and industry representatives on possible alternative microbiological standards. The key output from this elicitation process would be a scientific evidence base in conjunction with the information from the focus groups and the literature research, for presenting recommendations for an alternative, if appropriate, microbiological standards for ABP products to be implemented at the EU level. This would also include consideration of how, if such revised microbiological standards were adopted by the EU parliament, they would be applied equally to imported ABP products.
Objective 1: Review the microbiological standards for raw pet food, milk and milk derived products and other ABPs required by Regulation (EC) 7066/2010.

Objective 2: Provide a detailed research plan for the remaining research.

Objective 3: Recommendations of scientifically sound approaches for applying microbiological standards to final products derived from ABPs.
Project Documents
• FRP - Final Report : evid4 SE4403   (309k)
• ANX - Annex : SE4403Report Milestone4   (487k)
Time-Scale and Cost
From: 2011

To: 2012

Cost: £87,177
Contractor / Funded Organisations
Veterinary Laboratories Agency
Science Policy