Meeting on January 28, the FSA Board agreed the Agency needed to offer definitive advice on this issue as a matter of urgency, since there was widespread confusion among local authority (LA) food hygiene inspection teams and foodservice outlets about the rules governing the sale of rare burgers.
“I see the consumption of rare burgers as a kind of Russian roulette,” said Board member Dr Roland Salmon. “If it ceased to be niche it would represent a considerable amount of illness.” Other Board members also expressed their concern.
The Board said that until further risk assessment modelling was completed in March 2015 to identify the extent of the danger to consumers, the FSA should continue to communicate the advice of its Advisory Committee on the Microbiological Safety of Food (ACMSF) that burgers should be thoroughly cooked for the equivalent of 70°C for two minutes, sufficient to achieve a 6-log10 reduction in dangerous pathogens such as E. coli O157.
Safely serving rare burgers
However, while the Board stressed that communication of proper cooking advice was essential to ensure the many small foodservice outlets across the country didn’t start to cause avoidable food poisoning incidents, it recognised there was increasing pressure from a number of larger chains, which argued they had control measures in place to safely serve rare burgers.
“I see the consumption of rare burgers as a kind of Russian roulette. If it ceased to be niche it would represent a considerable amount of illness.”
FSA Board member Dr Roland Salmon
The reaffirmation of proper cooking advice was also necessary to ensure that as sales of raw burgers in the UK increased, consumers – especially vulnerable individuals – were not mistakenly led to believe they could also cook products safely rare at home.
In a paper presented by FSA director of policy Steve Wearne and John Barnes of the FSA’s local delivery division, it was brought to the Board’s attention that some of larger catering chains had procedures in place to produce a 4-log10 reduction in pathogens and that these had been validated by challenge testing.
The problem for the UK is that the law does not prohibit the sale of raw burgers or specify a level of reduction in bacterial load within products – the requirement is for food to be safe. At the same time, rare burger raw mince products are widely available in some Member States. These often come from sources which comply with EU regulations controlling mince that is intended to be eaten raw and must demonstrate, for example, a complete absence of salmonella bacteria.
As a consequence, foodservice outlets with validated hazard analysis critical control point (HACCP) systems, developed with independent advice and challenge testing, were presenting problems for the FSA, LAs and the courts in terms of proportionate and appropriate advice and enforcement, the Board heard.
These larger catering chains serving rare burgers included within their controls a requirement to source their meats from establishments approved for the sale of mince intended to be served rare. They also specify that sampling is carried out in accordance with these criteria as part of their HACCP systems.
FSA ceo Catherine Brown said that while its advice about the need for proper cooking of burgers would remain, there was probably a need for better public health information about the risks of eating rare burgers and better warning labelling on products and at sales outlets. However, she recognised that “differential advice” was necessary to take account of catering chains with accredited controls, so that any action LA’s took could be targeted at the riskier outlets.
In the longer term, antimicrobial treatments with lactic and peracetic acid and irradiation might become available for use in the EU to ensure that raw mince preparations are safer to eat. While they can, and in some cases are, used in the US, they are currently not legal in the EU – apart from in very restricted examples, such as for the irradiation of herbs.
However, Wearne remarked that studies had shown the UK public reluctant to accept greater use of irradiation in the food they consume.