The recent high profile investigations into certain food manufacturers have uncovered, not just failures to follow guidance and recommended procedures (which can be remedied) but more serious criminal breaches of the law. The two should not be confused.

In the first of this three part series we will explain the basic principles behind the guidance on use-by dates. Part 2 will give food manufacturers an overview of what they should be doing to stay compliant with current guidelines. And, Part 3 will tackle some of the misunderstanding surrounding how the guidelines should be applied by food buyers and retailers.

The science behind the guidance

Clostridium Botulinum toxin is what causes the potentially fatal form of food poisoning called botulism. It can develop from the species Clostridium botulinum if food is processed or stored in the wrong way. It’s worth noting that, while this bacterium may be present in food, it does not necessarily mean that the hazardous toxin will always develop. 

Evidence in literature indicates that growth and toxin production occurs concurrently. Current methodology is able to detect growth before toxin production in the majority of cases. The cases in which toxin is detected before growth tend to be products that have been held for an extended time at refrigeration temperatures. The FSA guidance therefore gives equal weight to growth and toxin production being monitored.

The so-called ’10-day’ rule has been created to ensure that the c Botulinum toxin isn’t allowed to develop at temperatures of 3C and above.

The role of research in shaping the guidance

Research surrounding vacuum and modified atmosphere packed meat (VP/MAP) and the risk of developing C. Botulinum toxin is being constantly updated. As a result, the technical guidance that food business operators (FBO) rely on to set their use-by dates should also be regularly reviewed to reflect the latest findings.

There have been numerous scientific studies showing that the most reliable way to assess risk is to test for the actual botulinum toxin rather than just measuring the presence and growth of the bacterium

Changes to the official guidance in 2017 (making it extremely precautionary and resulting in an increase in instances of non-compliance) have prompted the need for another review of the guidelines based on new research.

The British Meat Processors Association is currently conducting four research projects drawing on the skills of several experts in the field including Campden BRI and Professor Michael Peck, both internationally recognised authorities on C. botulinum and microbial food safety.

The peer-reviewed findings will help regulators to better understand the risk of botulism from chilled VP/MAP fresh meat and assist in setting more technically appropriate restrictions that will provide confidence to producers, buyers and consumers. Both members and non-members can join the two projects that will be starting very soon.

How is this affecting British businesses?

While effective, scientifically proved methods to prevent C Botulinum toxin developing are essential, the fact remains that the UK is the only country in the world that must work to this restrictive guidance and apply the ’10-day rule’ in the absence of any other controlling factors (more on these in Part 2). This currently stops any exports from the UK of chilled retail packed fresh meat putting UK businesses at a severe disadvantage.

What to do while guidance is being reviewed

The Food Standards Agency (FSA) is working closely with industry groups to review current guidance as new research becomes available. For now, the advice to manufacturers is to follow the current guidance to remain compliant.