IFT Comments on EFSA safety of substances for the removal of microbial contamination of foods of animal origin

February 22, 2010

Founded in 1939, the Institute of Food Technologists is a not-for-profit scientific society with more than 18,000 individual members working in food science, technology, and related professions around the world. We appreciate the opportunity to comment on the draft guidance document published by the European Food Safety Authority (EFSA), entitled “Revision of the joint AFC/BIOHAZ guidance document on the submission of data for the evaluation of the safety and efficacy of substances for the removal of microbial surface contamination of foods of animal origin intended for human consumption” found at http://www.efsa.europa.eu/en/consultations/call/biohaz100122.htm.  

The following comments are offered:

Line 193 reads “the best way to validate efficacy is to perform large scale in-plant studies”. Upon first read, this could be interpreted as encouragement to intentionally introduce pathogens into a facility. While this is clarified in the appendix, using flocks that have tested positive for Campylobacter, IFT encourages clarification here. The Institute of Food Technologists also suggests that pilot studies outside a production atmosphere be considered as acceptable to in-plant studies.

Line 417 notes post market monitoring for efficacy but does not give a timeframe. Additional guidance on post market monitoring would be helpful.

Lines 474-477 lists the organisms that should be considered. Shiga toxin producing E. colis might also be appropriate for consideration.

Lines 474-477 states that tests should be performed for the “development of resistance to therapeutic antimicrobials”. It was not clear if the antimicrobial producer should assess the potential for resistance in these organisms even if their product is not “therapeutic”, or if this meant organisms demonstrating resistance to the antimicrobial of interest should also be tested for cross resistance to “therapeutic” antimicrobials? Additional clarification is needed.

Lines 481-485- regarding influence on the environment: it’s recommended that environmental bacteria from around wastewater plants be isolated. It is not clear if data from around 1 plant is sufficient. IFT can envision substantial variation in microflora between wastewater treatment plants around Europe.

Line 501- says seasonal changes should be taken into account. It is not clear how many facilities should be tested in geographically different areas.

Appendix A: the size of the meat pieces seems small. Larger pieces are warranted.
General comment:
IFT commends EFSA for considering the environmental impact of discharged antimicrobials. From an overall viewpoint, there seems to be considerably more emphasis put on the environmental aspect as opposed to food safety (e.g., the public health benefits that might be gained by the introduction of new antimicrobials). These requirements will probably discourage the introduction of new compounds.

Please let Jennifer McEntire, Research Scientist and Manager, Science and Technology Projects, know if IFT may provide further assistance. She can be reached at 202-330- 4984 and via email at jcmcentire@ift.org.  

Sincerely,

Marianne Gillette
IFT President

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