A Microbial Assessment Scheme To Measure

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International Journal of Food Microbiology 134 (2009) 113–125

Contents lists available at ScienceDirect

International Journal of Food Microbiology


j o u r n a l h o m e p a g e : w w w. e l s ev i e r. c o m / l o c a t e / i j f o o d m i c r o

A Microbial Assessment Scheme to measure microbial performance of Food Safety


Management Systems
L. Jacxsens a,⁎, J. Kussaga a,b, P.A. Luning b, M. Van der Spiegel b, F. Devlieghere a, M. Uyttendaele a
a
Department of Food Safety and Food Quality, Laboratory of Food Preservation and Food Microbiology, Faculty of Bioscience Engineering, Ghent University,
Coupure Links, 653, 9000 Ghent, Belgium
b
Product Design and Quality Management Group, Department of Agrotechnology and Food Sciences, Wageningen University, P.O. Box 8129, NL-6700 EV Wageningen, the Netherlands

a r t i c l e i n f o a b s t r a c t

Keywords: A Food Safety Management System (FSMS) implemented in a food processing industry is based on Good
Food Safety Management System Hygienic Practices (GHP), Hazard Analysis Critical Control Point (HACCP) principles and should address both
Microbiological food safety food safety control and assurance activities in order to guarantee food safety. One of the most emerging
Performance tool challenges is to assess the performance of a present FSMS. The objective of this work is to explain the
development of a Microbial Assessment Scheme (MAS) as a tool for a systematic analysis of microbial counts
in order to assess the current microbial performance of an implemented FSMS. It is assumed that low
numbers of microorganisms and small variations in microbial counts indicate an effective FSMS. The MAS is a
procedure that defines the identification of critical sampling locations, the selection of microbiological
parameters, the assessment of sampling frequency, the selection of sampling method and method of analysis,
and finally data processing and interpretation. Based on the MAS assessment, microbial safety level profiles
can be derived, indicating which microorganisms and to what extent they contribute to food safety for a
specific food processing company. The MAS concept is illustrated with a case study in the pork processing
industry, where ready-to-eat meat products are produced (cured, cooked ham and cured, dried bacon).
© 2009 Elsevier B.V. All rights reserved.

1. Introduction 22000 (ISO, 2005b), International Food Standard (IFS, 2007), and
Global Standard for food safety (BRC, 2008), which are specifically
Microbial food safety has emerged to be a global concern (NØrrung developed for food (processing) industries and against which
and Buncic, 2008; Sofos, 2008). In response to the increasing number certification is possible (often demanded by retailers). A big challenge
of foodborne illnesses, governments all over the world are intensifying for food business operators is to translate and to implement these
their efforts to improve food safety (Anonymous, 2002; Codex requirements in a company specific FSMS, in order to assure food
Alimentarius Commission, 2003; Orriss and Whitehead, 2000; safety and in many cases also food quality. A company specific FSMS
Schlundt, 2002; Wallace et al., 2005). Regulations forced food business should be a translation of Good Hygienic Practices (GHP), Hazard
operators in the agri-food chain to design and implement a Food Analysis Critical Control Point system (HACCP), management policies,
Safety Management System (FSMS) in order to control the outbreaks traceability and recall systems into company specific setting (CIES,
of foodborne illnesses (Baird-Parker, 1995; Jacxsens et al., 2009; 2007; FAO/WHO, 2007; Luning and Marcelis, in press; Jacxsens et al.,
Luning et al., 2006; Schlundt, 2002; Tsalo et al., 2007). An FSMS can be 2009).
defined as a company specific system of control and assurance The performance of FSMS in practice is, however, still variable
activities in order to realise and guarantee food safety. Control (Cormier et al., 2007; Manning et al., 2006; Tsalo et al., 2007), and
activities aim at keeping product and process conditions within attention is shifting from implementing QA standards to the better
acceptable limits in order to realise food safety, while assurance understanding of the performance of an FSMS (Doménech et al., 2008;
activities concern the evaluation of system performance and organiz- Luning et al., 2008; Stringer and Hall, 2007). As a consequence, various
ing necessary changes (Luning and Marcelis, 2007). Nowadays, audit tools have been developed to determine the performance towards
several Quality Assurance (QA) standards are available, like ISO QA standards (e.g. CIES, 2007; Cormier et al., 2007; Doménech et al.,
2008; Wallace et al., 2005), but they basically check on compliance to the
set requirements, for instance, during internal or external auditing (Van
der Spiegel et al., 2005). Recently, an instrument has been developed to
⁎ Corresponding author. Mailing address: Department of Food Safety and Food
Quality, Laboratory of Food Microbiology and Food Preservation, Coupure links 653,
diagnose in a comprehensive and differentiated way a company specific
9000 Ghent, Belgium. Tel.: +32 9 264 60 85; fax: +32 9 225 55 10. FSMS, independent of the QA standard that is implemented (Luning
E-mail address: liesbeth.jacxsens@ugent.be (L. Jacxsens). et al., 2008, in press).

0168-1605/$ – see front matter © 2009 Elsevier B.V. All rights reserved.
doi:10.1016/j.ijfoodmicro.2009.02.018
114 L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125

According to Luning et al. (in press), a more sophisticated FSMS Table 1


would be better able to realise products with lower contamination levels Distinct control strategies with core control activities as addressed by the FSMS
diagnostic instrument (based on Luning et al., in press) and linked to the identified
and less variation in contamination loads. The FSMS diagnose on system critical sampling locations (CSL) in the proposed case study (see Table 2).
level gives, however, no indication of the actual microbial performance
of companies' FSMS. Food processing companies commonly use Preventive measures CSL

microbial testing of final products to assess if their products meet food These strategies are aimed at creating circumstances to prevent entry and or growth of
pathogens in food production systems by reducing the chance on (cross)
safety criteria (e.g. ICMSF, 2002; Legan, 2001). These criteria are set by
contamination or growth
different stakeholders or regulatory bodies, like EU and/or country Indicators to assess design of preventive measures
regulations and/or customers' requirements but are also used to guide • Adequacy of product specific preventive measures (e.g. control of raw 1
the manufacturing process enabling a proper evaluation and define materials)
preventive actions (Anonymous, 2005; Kvenberg and Schwalm, 2000; • Sophistication of hygienic design of equipment and facilities 2, 7/8/9
• Adequacy of cooling facilities 3
Martins and Germano, 2008). Different authors recommended the use • Specificity of sanitation program 2, 7/8/9
of microbial testing to evaluate Critical Control Points (e.g. Cormier et al., • Extent of personal hygiene requirements 2, 10/11/12
2007; González-Miret et al., 2001; Kvenberg and Schwalm, 2000;
Martins and Germano, 2008; Swanson and Anderson, 2000) and to Intervention processes
These are distinguished from physical (like heat treatment, irradiation, high hydrostatic
evaluate procedures for Good Hygienic Practices (GHPs) and Standard
pressure, drying), chemical (like the use of preservatives, salts, organic acids, smoke),
Operating Procedures (SOPs) (e.g. Brown et al., 2000; Eisel et al., 1997; and biological interventions (like the use of probiotics, lactic acid bacteria,
Leaper and Richardson, 1999). However, to our knowledge, no fermentation, and natural antimicrobials like lysozyme)
systematic microbiological evaluation of an FSMS performance has Indicators to assess the design of intervention processes
been described previously. • Adequacy of intervention equipment 4
• Specificity of maintenance program for intervention equipment
This paper presents a Microbial Assessment Scheme (MAS) that can
• Effectiveness intervention methods 4
be used for systematic analysis of microbial counts to assess the microbial
performance of core control activities in an implemented FSMS. Microbial Monitoring system
analyses to assess the FSMS performance are aimed at obtaining insight They affect food safety by providing information about the actual status of product or
process conditions, which enables process corrections, removal of non conformance
in contamination profiles, which means insight into the maximum level
products, and system improvements in case of structural problems
of microbial counts and the distribution in microbial contamination. This Indicators to assess design of monitoring system
information gives insight into the dynamics of microbial contamination • Appropriateness of CCP analysis
as a result of the designed and applied control strategies in an FSMS. The • Appropriateness of standards and tolerances
concept of MAS is illustrated with a case study in a pork processing • Adequacy of measuring equipment to monitor process/product
• Specificity of calibration program for measuring and analytical equipment
company, where ready-to-eat meat products are made.
• Specificity of sampling design/measuring plan
• Extent of corrective actions
2. Materials and methods
Operation of core control activities2
Indicators to assess actual operation of control activities
2.1. FSMS diagnostic instrument principle
• Actual availability of procedures1
• Actual compliance to procedures
The structure of the FSMS diagnostic instrument is applied as the • Actual performance product specific measures
start point for the development of MAS. It comprises a comprehensive • Actual hygienic performance of equipment and facilities
list of core control and grids to assess at which levels these activities are • Actual cooling capacity
• Actual process capability of intervention processes
executed. The systematic diagnosis reveals which core control activities
• Actual measuring equipment performance
are addressed in companies' FSMS and at which level. The basic • Actual analytical equipment performance
assumption behind this assessment tool is that systems performing on a 1
Procedures for cleaning, personal hygiene, maintenance and calibration intervention
higher level are more predictable and better able to achieve a desired equipment, calibration and verification measuring and analytical equipment, CCP
safety outcome, because of less ambiguity (due to more insight in the procedures.
2
underlying mechanisms) and less uncertainty (due to more accurate CSLs 5 and 6 indicate the performance of the overall food safety control activities.
information) (Luning and Marcelis, 2006; Luning et al., in press). Table 1
provides more detailed information about the core control activities in
the FSMS, diagnosed by the diagnostic instrument. A distinction is made core control strategies as addressed in the FSMS diagnostic instrument
between preventive measures, intervention processes and monitoring (Table 1). In other words, loss of control at these locations will lead to
systems, each strategy contributes differently to the control of microbial unacceptable food safety problems due to contamination, growth
food safety (Luning et al., 2008). and/or survival of microorganisms. The locations, where samples are
taken, will differ depending on the control activities that are
2.2. Elaboration of Microbial Assessment Scheme (MAS) addressed in the companies specific FSMS (Table 2 is exemplified for
the illustrating case study).
The proposed concept of MAS is based on a comprehensive A first CSL is the point of receipt of raw materials because initial
literature study in this field, discussions with experts on the concept of concentrations of microorganisms give insight into the potential safety
FSMS diagnosis (Luning and Marcelis, 2006, 2007; Luning et al., 2006, risks of the raw materials, which puts demands on the FSMS. Eisel et al.
in press) and practical experience in food processing companies in (1997) and Codex Alimentarius Commission (2003) recommended the
implementing their FSMS and fulfilling the legal/retail/QA standards inspection of raw materials before processing and where necessary
requirements by the Laboratory of Food Microbiology and Food laboratory tests should be made to establish fitness for use. According to
Preservation of Ghent University, Belgium (LFMFP-UGent) (Jacxsens Luning et al. (in press) higher initial levels of pathogens require more
et al., 2006, 2007). The MAS procedure includes different elements sophisticated and reliable FSMS. The microbial performance at this CSL
which are discussed below. gives insight in the adequacy of the raw material control in the FSMS (e.g.
proper selection procedures of suppliers and specifications of raw
2.2.1. Identification of critical sampling locations materials (Jacxsens et al., 2009; Luning et al., 2008)).
Critical sampling locations (CSL) are defined as locations where Another CSL, that is assigned in the MAS, is during processing of
microbial sampling provides information about the performance of raw materials such as portioning, deboning, cutting and mincing,
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125 115

Table 2
MAS procedure elaborated as a case study for the pork processing industry.

No CSL Microbiological Frequencya Sampling method Interpretation of results


parameters
1 At point of receipt of — Aerobic mesophilic 3 times 1 sample Non-destructive method a) According to EU Regulation
raw materials plate count (APC) on 100 cm2 of raw pork 2073/2005 Category 2.1.2b
(raw pork meat parts) — Salmonella meat parts APC: mc = 3.5 log CFU/cm2
— E. coli Md = 4.5 log CFU/cm2
— Enterobacteriaceae Enterobacteriaceae:
— L. monocytogenes m = 1.5 log CFU/cm2
2 After deboning and — APC 3 times 1 sample Non-destructive method M = 2.5 log CFU/cm2
cutting or portioning — Salmonella on 100 cm2 of raw pork b) According to EU Regulation
(fresh pork meat cuts) meat cuts 2073/2005 Category 2.1.4 Salmonella
absent in the area tested
— E. coli c) According to microbiological guide
values of LFMFP-UGente
— Enterobacteriaceae E. coli absent in the area tested
— L. monocytogenes L. monocytogenes: absent in the area tested
3 After intervention — APC 3 times 1 sample Destructive method on According to microbiological guide values
strategy; curing 30 g of raw cured bacon of LFMFP-UGent for meat preparations
(raw cured bacon). — Salmonella before packaging a) APC
m = 5.7 log CFU/g
— E. coli M = 6.7 log CFU/g
— Enterobacteriaceae b) Enterobacteriaceae
— L. monocytogenes m = 3.7 log CFU/g
M = 4.7 log CFU/g
c) E. coli
m = 2.7 log CFU/cm2
M = 3.7 log CFU/g
d) Salmonella: absent in 25 g
e) L. monocytogenes: absent in 25 g
4 After chilling or cooling — APC 3 times 1 sample Destructive method on According to microbiological guide values
processes i.e. fast 30 g of cooked ham before of LFMFP-UGente for cooked products
cooling (cooked ham) packaging without post contamination
— Salmonella a) APC
m = 3.0 log CFU/g
— E. coli M = 4.0 log CFU/g
— Enterobacteriaceae b) Enterobacteriaceae
— L. monocytogenes Below detection limit
c) E. coli: Below detection limit
d) Salmonella: absent in 25 g
e) L. monocytogenes: absent in 25 g
5 After packaging of the — APC 3 times 1 sample Destructive method on According to microbiological guide
final product 30 g of packaged cooked values of LFMFP-UGente for cooked
(cooked ham) ham products with post contamination
— Salmonella a)APC
m = 3.0 log CFU/g
— E. coli M = 4.0 log CFU/g
— Enterobacteriaceae b) Enterobacteriaceae
— L. monocytogenes m = 1.0 log CFU/g
M = 2.0 log CFU/g
c) E. coli
m = b 10 CFU/g
M = 1.0 log CFU/g
d) Salmonella: absent in 25 g
e) L. monocytogenes: absent in 25 g
6 After packaging of the — APC 3 times 1 sample Destructive method on According to microbiological guide
final product 30 g of packaged raw values of LFMFP-UGente for raw
(raw cured bacon) cured bacon mildly salted meat products
— Salmonella a) APC
m = 4.0 log CFU/g
— E. coli M = 5.0 log CFU/g
— Enterobacteriaceae b) Enterobacteriaceae
— L. monocytogenes m = 2.0 log CFU/g
M = 3.0 log CFU/g
c) E. coli
m = 2.7 log CFU/cm2
M = 3.7 log CFU/g
d) Salmonella: absent in 25 g
e) L. monocytogenes: absent in 25 g
7 Working tables at deboning — APC 3 times 3 samples at start–middle Surface swabbing of According to microbiological guide values
section (initial stage of the and end of the production day 25 cm2 of the table of LFMFP-UGente
process — production area) — E. coli Salmonella and L. monocytogenes: absent
in the tested area
— Enterobacteriaceae
— Salmonella
— L. monocytogenes

(continued on next page)


116 L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125

Table 2 (continued)
No CSL Microbiological Frequencya Sampling method Interpretation of results
parameters
8 Working tables at cured meat loins — APC 3 times 3 samples at start–middle Surface swabbing of
preparation (middle of the — E. coli and end of the production day 25 cm2 of the table
process — production area) — Enterobacteriaceae
— Salmonella
— L. monocytogenes
9 Working tables at packaging — APC 3 times 3 samples at start–middle Surface swabbing of
section (final stage of the — E. coli and end of the production day 25 cm2 of the table
process — packaging area) — Enterobacteriaceae
— Salmonella
— L. monocytogenes
10 Hands or gloves of food operators — E. coli 3 times 3 samples at start–middle Surface swabbing of According to microbiological guide values
at deboning section — production and end of the production day 25 cm2 of the hands of LFMFP-UGente
area — Enterobacteriaceae St. aureus: below detection limit
— S. aureus
11 Hands of food operators at cured — E. coli 3 times 3 samples at start–middle Surface swabbing of
meat loins preparation section (middle — Enterobacteriaceae and end of the production day 25 cm2 of the hands
of the process — production area) — S. aureus
12 Hands of food operators at the — E. coli 3 times 3 samples at start–middle Surface swabbing of
packaging area — Enterobacteriaceae and end of the production day 25 cm2 of the hands
— S. aureus
a
Frequency of MAS as explained in Section 2.2.3.: CSLs 1–6: 3 times are 3 days in 3 consecutive months (i.e. March, April and May); CSLs 7–12: 3 times are 3 days in 3 consecutive
months (i.e. March, April and May) and 3 samples per time (day).
b
Abrasive sponges are applied for the carcass/meat part swabbing, therefore, the process hygiene criteria, according to EU Regulation 2073/2005 need to be adapted (Anonymous,
2005). Via the non-destructive method, it must be considered that only a fraction of the cells are captured. In Anonymous (2001) it is stated that with swabbing only 20% of the total
flora is captured. In a reviewing article of Capita et al. (2004) an average of 50% is mentioned. The Scientific Committee of the Food Safety Agency of Belgium (FAVV, 2006) has
concluded that for both Enterobacteriaceae and total count with non-destructive method, the faction of captured cells is 0.5 log lower compared to the destructive method.
Consequently, the process hygiene criteria need to be adapted by this 0.5 log unit.
c
m = under limit.
d
M = upper limit.
e
LFMFP-UGent = Laboratory of Food Microbiology and Food Preservation, Ghent University.

which are potential sources of (cross)contamination if not properly when they have not been effectively cleaned or have been allowed to
handled. The main sources of (cross)contamination during processing remain moist between cleaning and use (e.g. Evans et al., 2004).
come from food contact surfaces, equipment and the food operators If during processing direct hand contact with the food product is
(Gill et al., 2001; McEvoy et al., 2004; Tsalo et al., 2007). Consequently, possible, also the hygiene of the hands/gloves of the food operators is
this CSL provides insight into the microbial performance as a result of considered as a CSL, indicating the performance of personal hygiene as
various preventive measures addressed in companies' FSMS, such as a preventive measure in the FSMS (Table 1). Hands can contaminate
the extent of personal hygiene, specificity of sanitation program, food through residential flora of the skin e.g. micrococci, staphylo-
adequacy of product specific preventive measures, and hygienic cocci, propionic bacteria and corynebacteria; and contact between
design equipment and facilities (Table 1). hands and the environment, which contaminates hands with
A third distinct CSL is at the cooling facilities. Adequate cooling transient flora such as fecal indicators E. coli and Salmonella (Aarnisalo
capacity prevents the growth of mesophiles and mesophilic patho- et al., 2006; Dijk et al., 2007).
gens and the development of spores and limits the growth of
psychrotrophic microorganisms (ICMSF, 2005; Mossel et al., 1995). 2.2.2. Selection of the microbiological parameters
Inadequate food temperature control is reported to be amongst one of For each CSL, microbiological parameters must be defined. The
the most common causes of foodborne illness or food spoilage (Codex selected microbiological parameters will differ depending on the
Alimentarius Commission, 2003; Todd et al., 2007). Therefore, a CSL is production processes and food type that are addressed in the specific
defined after critical cooling activities in order to assess the adequacy company. Table 2 exemplifies this selection for the presented case study.
of cooling facilities present in the food processing company. An FSMS is in the first place aiming at the production of safe food
Intermediate products directly after core intervention strategies, are according to the regulation and international guidelines (Anonymous,
also considered as CSL. It provides information on the actual effectiveness 2002; Codex Alimentarius Commission, 2003). Therefore, common
of the applied intervention processes in the FSMS. Different intervention pathogenic microorganisms, relevant for the type of food product
strategies are presented in Table 1. The level of microbial counts in final processed in the company must be taken into consideration. Typically,
products is another CSL, because it gives an indication of the overall though not exclusively, Listeria monocytogenes and Salmonella spp. are
performance of an FSMS as a result of technology and managerial analysed for meat, fish, egg, vegetable, fruit and dairy processing
dependent control activities that are executed to keep bacterial counts (Anonymous, 2005; ICMSF, 2005). Campylobacter and Salmonella spp.
below required limits (Luning and Marcelis, 2006, 2007). should be included in the case of poultry processing (Habib et al., 2008;
The MAS also addresses food contact surfaces as critical sampling ICMSF, 2005). As indicators of (fecal) hygiene, E. coli and Enterobacter-
locations, because it will give insight into the actual status of the iaceae can be monitored (Anonymous, 2005). The enumeration of total
sophistication of hygienic design equipment and facilities, and specifi- counts gives insight into the overall performance of the critical sample
city of sanitation program present as a preventive measure in the FSMS location (ICMSF, 2002; Mossel et al., 1995). As an indicator of good
(Table 1). According to the different studies (e.g. Aarnisalo et al., 2006; personnel hygiene and correct hand practices, Staphyloccocus aureus can
Bagge-Ravn et al., 2003; Cools et al., 2005; EHEDG, 2007; Fuster-Valls be selected (Aarnisalo et al., 2006; Dijk et al., 2007).
et al., 2008; Jessen and Lammert, 2003) diverse food pathogenic bacteria
are able to attach to food contact surfaces, which can subsequently be 2.2.3. Assessment of sampling frequency
detached during production and contaminate food as it passes the The first aim of MAS is to obtain a picture of the current
surface. Equipment and surfaces can be a source of direct contamination microbiological status of the core food safety control activities in an
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125 117

FSMS and their actual efficacy. Consequently, it is not the objective 2.2.5. Data processing and interpretation of the obtained results:
to have a statistically underpinned sampling plan as described by microbial safety level profiles
e.g. Augustin and Minvielle (2008), Baird-Parker (1995), Green The last part of the MAS protocol is the data processing and
(1991) and Legan et al. (2001). It is as well not the aim to establish interpretation of obtained results. The data processing can easily be
attribute plans for food lot acceptance, as described by ICMSF 2 and done with Microsoft Office Excel in order to make graphs or tables to
7 (Dahms, 2004; ICMSF, 1986, 2002; Legan et al., 2001). Therefore, illustrate visually the levels and distribution of microbial contamina-
we propose to perform a MAS over three periods (e.g. three tion over the three different sampling periods. No averages, standard
consecutive months) in order to have insight in the distribution of deviations or statistics need to be applied in order to evaluate the
the microbial load at each CSL. For the environmental CSLs (food variability over the three sampling periods on single company level.
contact surfaces and hands/gloves of food operators), also the Because, the microbial analyses for FSMS performance are aimed at
microbial contamination during the production day should be obtaining insight in contamination profiles, which means insight into
followed by taking samples at the start of the production, at an the maximum level of microbial counts and the distribution in
intermediate time, and at the end of the production. This gives microbial contamination. This information gives insight into the
insight into the daily fluctuations. dynamics of microbial contamination as a result of the designed and
applied control strategies in an FSMS system.
2.2.4. Selection of sampling method and method of analysis The obtained results are evaluated in two ways. First, the obtained
The selection of sampling method and method of analysis must be results of each analysed microbiological parameter in a specific CSL are
performed in a reliable and systematic way. It is recommended to interpreted. Therefore, the European Regulation on microbiological
follow-up the appropriate procedures as described in the ISO criteria for foodstuffs should be applied if appropriate (Anonymous,
standards issued by the ISO TC 34 SC9 on Microbiology of food and 2005). If no legal requirements are set microbiological guidelines can
animal feeding stuffs or the EU Regulation (Anonymous, 2005) where be applied. But it is recognized that although microbiological guide-
appropriate. lines are widely used in the food industry, they have been published
rarely. They are mainly internal criteria applied by food business
2.2.4.1. Raw materials, intermediate products and final food products. operators (Stannard, 1997). These guidelines are aids to evaluate
In the case of raw materials being meat carcasses (or parts) one is whether the production process took place under controlled condi-
referred to ISO 17604: 2003 which includes the use of destructive and tions. If the legal requirements or the guide values are exceeded for a
non-destructive techniques for the detection and enumeration of specific microorganism in a CSL, it indicates that the specific control
microorganisms on the carcass surface of freshly slaughtered (red) activity in the FSMS, dedicated towards the defined CSLs according to
meat animals and to EU legislation (Anonymous, 2005; ISO, 2003e). Table 1, is not working properly. Consequently, a corrective action (or
Some literature reports state excision as the most appropriate carcass several) needs to be taken in order to change this non-conforming
sampling technique because the excision procedure achieves a higher situation and to improve the current FSMS performance.
recovery of bacteria from meat carcasses as compared to swabbing Secondly, the concept of microbial safety level profiles is
(Bolton, 2003; Capita et al., 2004). This is because swab sampling introduced. For each microbiological parameter over the different
removes only a proportion (often 20% or more) of the total flora analysed CSLs a level is concluded. A microbial safety level can be
present on the meat surface (Anonymous, 2001; Capita et al., 2004). classified from 1 to 3, where level 3 is a good result (legal criteria or
Other studies, e.g. Byrne et al. (2005); Lindbald (2007), favor guidelines are respected, no improvements are needed — current level
swabbing to be efficient over excision because, the excision technique of FSMS is high enough to cover this hazard), level 2 is a medium
samples a smaller area (typically 5 cm2) than swabbing (typically result (legal criteria or guidelines are exceeded, improvements need
100 cm2) and excision may not be the most suitable carcass sampling to be made on a single control activity of the FSMS) and level 1 is a low
technique for recovering enteric bacteria, which have a low incidence result (legal criteria or guidelines are exceeded, improvements need
and/or uneven distribution on meat carcasses. Moreover, meat from to be made on multiple control activities of the FSMS). The sum of the
healthy animals is internal sterile, hence excision sampling will not levels is resulting in the microbial food safety level profile.
produce a representative result for the surface contamination of the
fresh meat cuts. 2.3. Case study — pork processing company
For other food products, a representative sample is taken (10–30 g)
and analysed according to ISO 6887-2: 2003 (ISO, 2003b). For illustration purposes, MAS was performed in a pork processing
plant in Belgium. In this SME (approximately 50 people working in the
2.2.4.2. Environmental sampling and sampling from hands and gloves of production area), an FSMS (certified for 4 years against the QA
food operators. ISO 18593: 2004 specifies horizontal methods for standard BRC) has been implemented. The company specializes in
sampling techniques using contact plates or swabs on surfaces in the processing different ready-to-eat pork meat products. To evaluate the
food industry environment (and food processing plants), with a view microbiological performance of the FSMS by MAS, we selected in this
of detecting or enumerating viable microorganisms (ISO, 2004a). The study the production of cooked ham and cured bacon. Cooked ham is
same methodology is used to sample the hands or gloves of food cured, cooked, cooled and packaged under vacuum conditions. The
operators where a fixed surface (cm2) needs to be taken. raw cured bacon is dry cured, cured with brine, ripened in low
temperature conditions and is packaged under vacuum (final water
2.2.4.3. Analytical methods. Standardized methods (e.g. ISO activity is approximately 0.96).
methods) are generally acknowledged as the reference method Along with MAS, we also conducted an FSMS diagnosis using the
and are recommended to be applied as the analytical methods for instrument of Luning et al. (in press) via an in depth-interview in the
MAS. However, also alternative (rapid) methods such as those company (explained in Section 2.1). The levels of core control
based on metabolic activity, immunoassays and nucleic acid based activities were judged based on assessment grids. Level 1 indicates a
tests, overviewed by Baylis (2005), can be applied, if they have low level of the specific control activity in the FSMS and typically
established performance characteristics or by preference are related to the lack of scientific evidence, the use of company
validated according to ISO 16140: 2003 (ISO, 2003d). Analytical experience/history, variable, unknown, unpredictable, based on
methods are preferably executed in laboratories which operate common materials/equipment, and not specific nor adapted for own
under quality assurance according to the principles of ISO 17025: production system. Level 2 is an intermediate level of the specific
2005 (ISO, 2005a). control activity in the FSMS that corresponds with best practice
118 L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125

knowledge/equipment, sometimes variable, not always predictable, for the detection of Salmonella spp. and in 5 ml demi-Fraser solution
and based on generic information for the product sector. Level 3 is a for the detection of L. monocytogenes were used to swab the working
high level of the specific control activity in the FSMS typically tables. For enumeration of Enterobacteriaceae, E. coli and S. aureus on
associated with proper scientific underpinning (accurate, complete), hands or gloves of food operators, pre-moistened swabs in 5 ml
stable, predictable, and tailored and tested for the specific food peptone water were used. A new sterile swab for each food contact
production situation (Luning et al., in press). Where specific control surface and analytical parameter was taken. Next, sampling swabs
activities are not applicable or not relevant, level 0 is applied. The were aseptically inserted back into their respective tubes containing
interviewer with responsibility of quality and the manager of the 5 ml of the dilution media; the tubes were tightly closed, stored and
company assessed at which levels the various control activities in their transported in cool box at ≤4 °C to the laboratory; and the samples
FSMS were executed. These data are presented in spider web diagrams were analysed within 6 h of sampling.
(Fig. 1).
2.3.4.4. Analytical methods. In the lab, 30 g subsamples were taken for
2.3.1. Identification of critical sampling locations (CSL) each food stuff per analytical parameter or group of analytical
According to the MAS protocol (see Section 2.2.1), 12 CSLs were parameters. Then, the samples were stomached for 30 s in the stomacher
defined for this type of production processes (Table 2). The CSLs are with 270 ml of peptone water for enumeration of aerobic mesophilic
selected vertically through the production process and areas from raw plate counts, Enterobacteriaceae, E. coli, and L. monocytogenes. Similarly,
materials to the final products, including environmental samples. The 25 g subsamples for each food stuff were taken and mixed with 225 ml of
link between the identified CSLs for this case study and the FSMS either buffered peptone water for the detection of Salmonella spp. or
structure is illustrated in Table 1. demi-Fraser solution for the detection of L. monocytogenes. For the
abrasive sponges, the samples were also stomached for 30 s; while for
2.3.2. Selection of the microbiological parameters the cotton swabs the tubes were vortex mixed for 10 s.
The selected food safety parameters are, according to the MAS protocol The samples to be subjected to an enumeration procedure initially
in Section 2.2.2, the pathogens Salmonella spp. and L. monocytogenes. As were serially diluted (1:9), then the resultant bacterial suspensions
hygiene indicators E. coli and Enterobacteriaceae are defined and as were plated and incubated according to the appropriate ISO methods
indicator of personal hygiene Staphylococcus aureus. As indicator of overall (ISO 1996, 1998, 2001, 2002, 2003a, 2003c, 2004b).
microbial quality, aerobic mesophilic plate counts are determined (utility
parameter) (Table 2). 2.3.5. Data processing and interpretation of the obtained results
The data processing is performed applying Microsoft Office Excel
2.3.3. Assessment of sampling frequency 2003. In Table 2 an overview is given for each CSL, which legal criteria
MAS was performed during three visits in three consecutive or microbiological guidelines were applied for the interpretation of
months, during each visit the 12 CSLs were sampled, as is motivated in the results. If possible, the criteria from the European legislation are
the MAS protocol in Section 2.2.3. The food stuffs (CSLs 1 until 6) were applied (Anonymous, 2005). If legal criteria were not present for all
each time single sampled, while the environmental samples (CSLs 7 CSLs, then microbial guidelines, recommended by the Laboratory of
until 12) were taken at three different times (beginning, middle and Food Microbiology and Food Preservation (LFMFP-UGent), Ghent
end of the production day) during each visit (Table 2). Overall, a total University (Debevere et al., 2006) were used.
of 156 samples were taken.
3. Results
2.3.4. Selection of sampling method and method of analysis
3.1. Results of FSMS diagnosis
2.3.4.1. Carcasses and fresh meat cuts (non-destructive sampling) (CSLs
1 and 2). One site covering 100 cm2 for both raw pork meat parts The results of the diagnostic instrument of the assessment of core
and fresh pork meat cuts, was sampled using abrasive sponges control activities, as addressed in the companies' FSMS and explained
(Envirosponge™, Biotrace International). Areas of sampling were in Sections 2.1 and 2.3, are demonstrated in spider web diagrams.
delimited by a sterile template. Sterile pre-moistened abrasive These show the profiles of preventive measures design, intervention
sponges were used to swab vertically, horizontally and diagonally on process design, monitoring system design, and the actual operation of
the delineated area. After swabbing, the abrasive sponges were the core control activities (Fig. 1A, B, C and D). These diagrams clearly
individually put in a sterile stomacher bag containing: 100 ml peptone illustrate that a more coloured spiderweb is associated with control
water for the enumeration of total mesophilic counts, Enterobacter- activities that are elaborated at a higher level (level 3). The overall
iaceae, E. coli and L. monocytogenes; 100 ml buffered peptone water level of the preventive measure design (Fig. 1A) is at level 3, only the
for the detection of Salmonella spp; and 100 ml demi-Fraser solution performance of the sanitation program scored level 2. The cleaning
for the detection of L. monocytogenes. The samples were kept and and disinfection agents are based on knowledge from suppliers, but
transported in a cool box maintained at ≤4 °C to the laboratory for are not adapted and tested for the specific food production
microbial analysis; and the samples were analysed within 6 h of circumstances. Fig. 1B illustrates the intervention process design for
sampling. cooked ham and raw cured bacon separately because raw cured bacon
has no intervention equipment, whereas cooked ham does (i.e.
2.3.4.2. Intermediate products and final meat products (CSLs 3 until 6). cooking and cooling). The used intervention steps are on level 3 (so
Three hundred gram samples of raw cured bacon and cooked ham well tested for the specific production circumstances, and process
were cut by using a sterile knife. The samples were aseptically stored in capability and effectiveness of intervention method are known),
stomacher bags and transported in a cool box maintained at ≤4 °C to which results in the reduction of the microbiological load. The results
the laboratory; then the samples were analysed within 6 h of sampling. of the monitoring system design are shown in Fig. 1C, where mainly
level 3 is obtained (i.e. scientific underpinned, systematic assessment,
2.3.4.3. Cotton swabs (hands or gloves and food contact surfaces) (CSLs 7 sophisticated equipment for monitoring). However, the sampling
until 12). A sterile template was applied to delineate a 25 cm2 area design and CCP analysis, for raw cured bacon, is on an intermediate
for sampling. Sterile pre-moistened cotton swabs (Cultiplast®) in 5 ml level (level 2) because both were designed based on, respectively,
peptone water for enumeration of total mesophilic count, Enterobac- empirical sampling plan and hygiene codes for the sector in
teriaceae, E. coli and L. monocytogenes; in 5 ml buffered peptone water combination with expert support (which is typically level 2). Fig. 1D
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125
Fig. 1. Results of the diagnosis of core control activities in an FSMS of a pork processing SME, according to Luning et al. (in press): preventive measures design (A), intervention process design (B), monitoring system design (C), and operation of
food safety control system (FSCS) (D). (level 3 sophisticated situation, level 2 intermediated situation, level 1 low sophisticated situation, level 0 not appropriate).

119
120 L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125

shows the assessment of the actual operation of core control activities, mesophilic plate counts) and B (Enterobacteriaceae and E. coli) for the
showing level 2 for compliance to procedures because the majority of CSLs 7, 8 and 9. The highest APC (1,10 × 105 CFU/25 cm2) was detected
operators are familiar with existence of procedures (but not always at CSL 7; the working tables at the deboning area; the first part of the
exact content); tasks are executed based on habits. Operators are processing line, but CSL 8 obtained similar results ranging from 103–
controlled on compliance to procedures on a regular basis. Fig. 1D also 105 CFU/25 cm2. The APC on CSL 9 (working tables in the packaging
indicates a level 2 for the appropriateness of procedures, meaning that area) was lower (ranging from 102–104 CFU/25 cm2) as compared to
the procedures are available at location (often paper-based) and CSLs 7 and 8 (production area). Variation in numbers of APC is noticed
understandable for most users but are kept up-to-date on ad-hoc between the visits and times of sampling during production but no
basis. The activity ‘actual analytical equipment performance’ scored 0 systematic build up of the total counts can be detected. Enterobacter-
because no in-company laboratory activities are present. Overall, the iaceae were often (17/27 samples) recovered from the food contact
core control activities as addressed in their FSMS are at level 3, with surfaces with numbers ranging from 10 to 470 CFU/25 cm2, CSL 8
some at level 2 (which corresponds with aspects such as available being the most contaminated, CSL 9 to a lesser extent. E. coli was only
practice/equipment, experts knowledge and guidelines), indicating a rarely detected (4/27 samples) with a maximum of 10 CFU/25 cm2
well elaborated FSMS, according to Luning et al. (in press). (Fig. 3B).

3.2. Results for pathogens Salmonella spp. and L. monocytogenes 3.5. Results for CSLs 10 until 12 (hands/gloves of food operator)

For each of the pathogens, 45 samples were analysed including The results obtained from swabbing the hands or gloves of food
both food stuffs and environmental samples of food contact surfaces operators over the three visits and three sampling times during
as well as hands/gloves of food operators (Table 2). For none of the production are shown in Fig. 4A (S. aureus) and B (Enterobacteriaceae
samples, neither Salmonella spp. nor L. monocytogenes were detected and E. coli) for the CSLs 10, 11 and 12.
in 25 g product or 25 cm2 of food contact surface/hand or 100 cm2 E. coli was detected only twice, with the highest number (45 CFU/
carcass area. 25 cm2) counted on the hands of food operators working at the
packaging area (CSL 12). The hands/gloves at CSL 11 were shown to be
3.3. Results for CSLs 1 until 6 (food stuffs) the most vulnerable CSL for the occurrence of Enterobacteriaceae. CSL
11 was the hands of a person preparing the cured meat. Numbers
Aerobic mesophilic plate counts (APC) at the different CSLs (1 until ranged from 10–100 CFU/25 cm2. As is shown in Fig. 4A, S. aureus was
6) are shown in Fig. 2. APC increased over CSLs 1, 2 and 3 during visits found on the hands from the food operators, not wearing gloves,
1 and 2 but remained at the same level during visit 3. Over all visits, during the three visits and incidentally over the whole production/
the Enterobacteriaceae and E. coli count were very low or below the packaging area. The counts ranged from 10–1000 CFU/25 cm2
detection limit on the CSLs 1 until 3: on the raw materials (CSL 1) both (Fig. 4A). The highest contamination of 1000 CFU/25 cm2 was
Enterobacteriaceae and E. coli were found below the detection limit quantified on the hands of a food operator packaging grilled cooked
(b1 CFU/cm2). Enterobacteriaceae were quantified on the fresh meat ham on CSL 12.
cuts (CSL 2) but in low numbers (highest count of 30 CFU/100 cm2).
Also on the intermediate cured meat (CSL 3) Enterobacteriaceae and 3.6. Microbial safety level profile
E. coli were found below the detection limit (b10 CFU/g).
In two visits, APC were below the detection limit (b10 CFU/g) at CSL Based on the results obtained of the 156 samples taken over the 12
4 (the chilled cooked ham which was sampled just after cooking and fast CSLs in the 3 month period, a microbial safety level profile can be
cooling) (Fig. 2). Enterobacteriaceae and E. coli were below the detection derived for this case study for each microorganism over the different
limit (b10 CFU/g) in CSL 4. After packaging the cooked ham (CSL 5), an CSL's to evaluate the current microbiological status of the FSMS
average increase of 1 log occurred (compared to CSL 4) in APC. However, (Fig. 5). For the pathogens Salmonella spp. and L. monocytogenes, level
for cured bacon, an average decrease of 1 log occurred (APC comparing 3 can be attributed because no pathogens are detected. These results
CSL 6 with CSL 3) (Fig. 2). But Enterobacteriaceae and E. coli were below are acceptable according with the legal requirements and/or guide-
the detection limit (b10 CFU/g) on the final products. lines (Table 2). Also for E. coli a level of 3 is obtained as this fecal
hygiene indicator is only found sporadic, in low amounts and not on
3.4. Results for CSLs 7 until 9 (food contact surfaces) food stuffs. The obtained results are in accordance with the legal
requirements and/or guidelines (Table 2). S. aureus was detected on
The results obtained from the environmental swabbing over the the hands of food operators, both in the production and the packaging
three visits and three sampling times are shown in Fig. 3A (aerobic areas (Fig. 4A). These results are not in line with the guidelines
(Table 2). This indicates that a specific improvement regarding
personal (hand) hygiene in the current FSMS is needed to solve this
problem and therefore level 2 is attributed (one specific control
activity in the FSMS needs to be improved). High counts are found on
the food contact surfaces for Enterobacteriaceae and APC. On the food
stuffs itself, these parameters were in accordance with the legal
criteria/guidelines. Therefore, a level 2 is attributed resulting in a
necessary improvement of sanitation processes in the current FSMS. A
total microbiological safety level profile of 15 is obtained in the case
study (Fig. 5).

4. Discussion

The two outputs of MAS (i.e. evaluation of each microbiological


Fig. 2. Distribution of aerobic mesophilic plate counts for CSLs 1–6: first visit sampling
parameter in a specific CSL and the microbial safety level profiles) give
(x); second visit sampling (■); third visit sampling (◯) CSLs 1 and 2 (log CFU/100 cm2 — insight in the actual microbiological status/performance of the
detection limit: b0 log CFU/cm2); CSLs 3–6 (log CFU/g — detection limit: b1 log CFU/g). current FSMS present in a company. First, the MAS results give
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125
Fig. 3. A. Mesophilic aerobic plate counts (log CFU/25 cm2 — detection limit b1 log CFU/25 cm2) on food contact surfaces CSLs 7–8–9: time 1 beginning of the production day–time 2 middle of the production day–time 3 end of the production
day for visit 1 –visit 2 –visit 3 □. B. Enterobacteriaceae (log CFU/25 cm2 — detection limit b 1 log CFU/25 cm2) on food contact surfaces CSLs 7–8–9: time 1 beginning of the production day–time 2 middle of the production day–time 3 end
of the production day for visit 1 –visit 2 –visit 3 □, ⁎ indicates E. coli counted on the detection limit (b 1 log CFU/25 cm2).

121
122
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125
Fig. 4. A. S. aureus (log CFU/25 cm2 — detection limit b1 log CFU/25 cm2) on hands/gloves of food operators CSLs 10–11–12: time 1 beginning of the production day–time 2 middle of the production day–time 3 end of the production day for visit
1 –visit 2 –visit 3 □. B. Enterobacteriaceae (log CFU/25 cm2 — detection limit b 1 log CFU/25 cm2) on hands/gloves of food operators CSLs 10–11–12: time 1 beginning of the production day–time 2 middle of the production day–time 3 end
of the production day for visit 1 –visit 2 –visit 3 □, ⁎ indicates E. coli counted on the detection limit (b1 log CFU/25 cm2).
L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125 123

A very low contamination was detected on the cooked ham after


the fast cooling process (CSL 4). This is indicating that their cooling
capacity and process is adequate. This result was further confirmed by
the FSMS diagnosis of the ‘adequacy of the cooling facilities’ and the
‘intervention process design of cooked meat products’ at level 3
(Fig. 1A and B).
In the production area where raw meat parts and cuts are
processed, high APC and Enterobacteriaceae counts were found on
food contact surfaces. However, it did not led to an increase in
microbiological contamination of the fresh cut cuts. But when the
cooked ham was further processed in the packaging area, recontami-
Fig. 5. Microbial safety level profile for the pork processing company: profile is
constructed by levels: total mesophilic counts, S. aureus, Enterobacteriaceae, nation occurred (Fig. 2). It is clear that a recontamination from the
E. coli, L. monocytogenes, Salmonella. □ indicates the remaining microbial safety product originates from the environment in the packaging area.
level according to the maximum of 18, where improvement in the FSMS can be made. Different studies have reported working tables, equipment and hands
of food operators as the potential sources of cross contamination in
food processing industry (Gill et al., 2001; McEvoy et al., 2004; Tsalo
information concerning the performance of a specific control activity et al., 2007). The FSMS diagnosis revealed also that the ‘specificity of
in an FSMS (in the case study demonstrated by results in Sections 3.2 their sanitation program’ is at level 2 (Fig. 1A) and can be improved. By
until 3.5 linked to control activities of an FSMS shown in Table 1). applying a more sophisticated sanitation program (i.e. typified by
Secondly, the microbial safety profiles provide additional information cleaning agents adapted for the specific product and process
concerning the nature of the microbiological problem (in the case situations and involving a complete full-step cleaning procedure),
study illustrated by Fig. 5). the microbiological load of food contact surfaces should be reduced.
In this case study, pathogenic microorganisms were not detected The actual microbial performance of hand hygiene, resulting in the
in any of the CSLs for the whole period of the study. Therefore, it can be presence of S. aureus in the hands in both the production and
suggested that the current FSMS in the company, with respect to packaging area, demonstrates that the hand hygiene was insufficiently
pathogens, is effective. This output from MAS can be combined with respected. Although the ‘extent of personal hygiene requirements’ was
the overall FSMS diagnosis (Fig. 1): although the FSMS diagnosis assessed at level 3 (i.e. high requirements, for all food operators, on
shows a level 2 (intermediate level) on some control activities, the clothing, personal care and health, with tailored facilities to support
MAS results demonstrate that they appear to be effective at this personal hygiene, and specific training and hygiene instructions)
moment. Thus, the current FSMS does not require improvements (Fig. 1A), the MAS results showed unsatisfactory performance, which
regarding the control of the pathogens. might be due to ‘inadequate compliance to procedures’, indicated by
The incoming raw materials had low initial levels of contamination the diagnostic instrument (level 2 in Fig. 1D). Nel et al. (2004)
with respect to the APC and Enterobacteriaceae compared to the legal emphasised that although basic personal and hygiene practices are
requirements (Table 2). Also the variation of the APC was small, available they need to be optimised and regularly checked in practice
ranging from 60–380 CFU/100 cm2 which indicates an efficient to be effective. Although the design is good, inadequate compliance to
control of raw material. It is reported that the higher number of APC procedures and instructions and/or their misinterpretation may
usually relates to poor quality and a reduced shelf life of meat and contribute to safety problems (Azanza and Zamora-Luna, 2005;
meat products (Eglezos et al., 2008; Eisel et al., 1997; Stopforth et al., Gilling et al., 2001). Improvement can be obtained by the requirement
2006). These MAS results suggest a good relationship with the that all food operators are wearing gloves and training them in good
suppliers and robust procedures for the selection of suppliers in the personnel hygiene and practices (Dijk et al., 2007).
companies' FSMS. This was confirmed in the diagnosis of the FSMS A total microbiological safety level profile of 15 is obtained in the case
with the evaluation of the ‘product specific preventive measures’ on study, while the maximum level is 18 (i.e. 6 microbiological parameters
level 3 (Fig. 1A). with a microbial safety level of 3) (Fig. 5). Consequently, this companies'
A limited (and variable) increase in the microbial contamination of FSMS still has opportunities for improvement, specifically on the
the fresh meat cuts was noticed in the first stage of the production microbial safety levels of S. aureus, Enterobacteriaceae and total counts.
process; deboning and trimming. The results correspond to the ones In conclusion, the MAS gives an indication of the current microbial
obtained by Augustin and Minvielle (2008) who did a study on performance of the different control activities in an FSMS, while the
microbiological contamination of pork meat cuts of 9 French cutting FSMS diagnose indicates the level on which control activities are
plants from 1999 to 2003; finding that Enterobacteriaceae mean log conducted. The combination of these two tools can help food
counts ranged from 0.6 to 2.2 log CFU/cm2. However, the surface processing industries to analyse their current FSMS in a systematic
contamination on the meat cuts stayed below the legal criteria/ way and can lead to define possibilities for improvements of an
guidelines (Table 2). These results are suggesting that no improve- effective FSMS.
ments need to be made on ‘preventive measures’ in the control Further, MAS can be applied as a tool for the (yearly) verification of
activities of the FSMS (Table 1) in the production area. If we compare an FSMS on company level, as demanded by Codex Alimentarius (CAC,
the intermediate product to the final product raw cured bacon, a 2003; Hong et al., 2008; Jacxsens et al., 2009; Scott, 2003; Wallace
reduction in aerobic mesophilic counts is seen due to the short et al., 2005). The presented MAS protocol can easily be transferred
ripening process at low temperatures before packaging as well as a towards other sectors as meat product processes. The microbial safety
reduction in water activity (final water activity is approximately 0.96). profiles can also be used to compare the current microbiological
The raw cured bacon did not undergo an intervention strategy (dry performance of different companies with the same type of production
curing followed by brine curing at low temperatures) to eliminate the processes and food products. As such, microbiological problems in a
microorganisms but to reduce them to an adequate level. Therefore, sector can be identified, independent from company level.
this product should be regarded as a high risk product. These findings
are in line with the intermediate level of the diagnosis of the ‘CCP Acknowledgments
analysis of raw cured bacon’ (level 2 in Fig. 1C). Consequently, the
companies' CCP analysis of raw cured bacon needs to be further The research performed has been part of the project FOOD-CT-
elaborated. 2005-007081 (PathogenCombat) supported by the European
124 L. Jacxsens et al. / International Journal of Food Microbiology 134 (2009) 113–125

Commission through the Sixth Framework Programme for Research FAO/WHO, 2007. FAO/WHO guidance to governments on the application of HACCP in
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