US FDA Posts US Food Code Revision - Addendum

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Thu Sep 29 2005 - 19:02:06 PDT

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    To: Seafood Community

    I'm providing additional information about the changes to the 2005 US Food
    Code. (See earlier message which is archived at:
    http://listproc.ucdavis.edu/archives/seafood/log0509/0019.html)

    The SUMMARY OF CHANGES from the 2001 FDA Food Code and the Supplement to
    the 2001 Food Code chapters and Annexes (issued in 2003) to the 2005
    edition are on the FDA web site at:
    http://www.cfsan.fda.gov/~dms/fc05-sum.html

    Some of the changes made in the 2005 Food Code are minor and include
    editorial changes made for consistency and clarity. More SIGNIFICANT
    CHANGES include:

    - added and changed definitions of terms,
    - information about major food allergens consistent with the Food Allergen
    Labeling and Consumer Protection Act of 2004 (FALCPA)
    (http://www.cfsan.fda.gov/~dms/alrgact.html), and
    - amended date marking practices for consistency with recommendations in
    the Listeria monocytogenes Risk Assessment.

    Potentially hazardous food: two pH and water activity INTERACTION TABLES
    were added to the definition of food that requires time/temperature
    control for safety (TCS) to limit pathogenic microorganism growth or toxin
    formation.
    See Chapter 1-201.10 (http://www.cfsan.fda.gov/~acrobat/fc05-1.pdf)

    MAJOR FOOD ALLERGENS: means milk, egg, fish (such as bass, flounder, cod),
    crustacean shellfish (such as crab, lobster, or shrimp), tree nuts (such
    as almonds, pecans, or walnuts), wheat, peanuts, and soybeans; or a food
    ingredient that contains protein derived from one of these foods
    (consistent with the FALCPA). See Chapter 2-102.11 on how this definition
    is applied through the Code.
    (http://www.cfsan.fda.gov/~acrobat/fc05-2.pdf)

    EMPLOYEE HEALTH of Chapter 2 of the Food Code is revamped to better
    address ways to protect public health, based on new science regarding the
    agents that are most likely to be transmitted from an infected food worker
    through food. More targeted criteria for reporting, restriction,
    exclusion, and returning to work are included. Handwashing procedures are
    amended to update the proper sequence for handwashing procedure and
    avoiding recontamination of the hands after handwashing and to be more
    consistent with the recommended handwashing procedure in CDC's Hygienic
    Practice Guidelines for Health Care Workers.

    Chapter 2 better describes the fact that a CONDITIONAL EMPLOYEE may not
    become a Food Employee unless the applicant is in compliance with the
    employee health provisions of the Code. Annex 2
    (http://www.cfsan.fda.gov/~acrobat/fc05-a2.pdf) now includes a description
    and link to a U.S. Equal Employment Opportunity Commission (EEOC) Guide,
    "How to Comply with the Americans with Disabilities Act: A Guide for
    Restaurants and Other Food Service Employers." This Guide clarifies many
    situations in food establishments related to the Americans with
    Disabilities Act (ADA) that may occur during the hiring process. See
    Chapter 2-201.11, 2-201.12 2-201.13, and 2-301.14
    (http://www.cfsan.fda.gov/~acrobat/fc05-2.pdf)

    The 2005 Food Code not only AMENDS PROCEDURES FOR REDUCED OXYGEN PACKAGING
    (ROP), but adds LISTERIA MONOCYTOGENES as a pathogen of concern that needs
    to be controlled in addition to Clostridium botulinum. The 2005 Food Code
    amends the procedures to require specific temperature controls for
    cook-chill and sous vide packages. These procedures require that bagged
    products must be cooled to 34 degrees F within 48 hours and held for no
    more than 30 days.

    Further, if foods are packaged using a cook-chill or sous vide process,
    other food safety measures must be taken including: a HACCP plan; records
    retention for 6 months, and no sale of the ROP bagged product to another
    business or consumer who may not have adequate temperature control.
    (http://www.cfsan.fda.gov/~acrobat/fc05-3.pdf)

    Based on the results of FDA's Listeria risk assessment
    (http://www.foodsafety.gov/~dms/lmr2-toc.html) and the
    recommendations from the 2004 Conference for Food Protection, FDA
    reevaluated DATE MARKING provisions in the Food Code and focused its
    recommendations for date marking on high-risk foods rather than foods that
    present a low risk of Listeria contamination. The 2005 Food Code now
    exempts deli salads (e.g., ham, chicken, egg, seafood, pasta, potato, and
    macaroni) prepared and packaged in a food processing plant. Scientific
    data support the exemption of these products because deli salads prepared
    and packaged by a food processing plant contain sufficient acidity and
    preservatives to prevent the growth of Listeria monocytogenes.
    (http://www.cfsan.fda.gov/~acrobat/fc05-3.pdf)

    Annex 2 of the 2005 Food Code, "Food Defense Guidance from Farm to Table,"
    provides a summary of available resources on food defense and links to
    useful publications from FDA, CDC, and USDA as well as industry groups.
    Food security measures continue to be only recommendations in the Food
    Code. (http://www.cfsan.fda.gov/~acrobat/fc05-a2.pdf)

    Source: The 2005 FDA Food Code Questions and Answers
    (http://www.cfsan.fda.gov/~dms/fc05-qa.html)

    Pamela Tom
    University of California
    Sea Grant Extension Program



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