BHA responds to FSA draft guidance on advisory notices for safe production of beef burgers

Recent draft guidance issued by the Food Standards Agency (FSA) sets out a number of options for serving burgers:

1. Cook in accordance with the ACMSF guidance to achieve a 6-log reduction
2. Carry out processes such as surface treatments (e.g. sear and shave) which give an equivalent of 6-log reduction
3. Control through the surface treatment at supplier level (e.g. lactic acid) and at least a 4-log cook, ideally 6-log
4. Controls at supplier level with a validated 4-log reduction at cooking stage

After BHA lobbying, the FSA now recognises in the Guidance the importance of the time-temperature relationship for safe cooking, and also the need to check the temperature of food. This is a far more scientific approach than judging the safety of meat products purely based on colour.

For businesses that want to use methods other than cooking (Options 2, 3 and 4) to achieve a visibly less well-cooked burger, scientific validation will be required which is often expensive. This, however, is where the value of Assured Advice will come into play, and the availability of free Primary Authority assistance through the British Hospitality Association.

The biggest unresolved issue for many members, however, will be that the draft guidance refers to Consumer Advisory Notices being required or as “best practice”.

The FSA is proposing that for foods that are considered more risky, such as burgers which appear less well cooked, advisory notices may be required as “best practice” in some circumstances, and must be provided where businesses control safety through the meat supply chain rather than by achieving a validated 6-log reduction of bacteria through cooking or control processes.

The FSA have stated that they are doing this to help consumers understand that whilst businesses can achieve serving safe less visually well-cooked burgers, they should not try it at home.
The BHA is of the opinion that if the food is safe for consumption, then a notice is not needed and it is not the position of business to educate the consumer on what or how they cook at home.

The BHA is also concerned that even if provision of a notice is “best practice” in the guidance, then this may lead to a detrimental scoring for a Food Hygiene Rating if a business decides not to use the notice.

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