Why can you have a safe rare steak and not a rare burger?
Bacteria, for example E. coli, tend to be found on the outside surfaces of meat, rather than the inside, of a steak or joint of meat. If you mince meat, the outside surfaces are then mixed up with bacteria inside and this means that any E. coli from the outside will be mixed all the way through the burger.
But if you sear the outside of a steak, you will have killed off the bacteria on the outside surfaces and the inside surfaces will be safe even if served rare. The only exception to this is if the meat has been mechanically tenderised or you have spiked it with a fork or probe when raw – in these cases, bacteria from the outside may have transferred to the inside. If in doubt about mechanical tenderising check with your supplier.
In summary, if you sear just the outside of a minced meat burger, the inner surfaces could still be contaminated and harmful bacteria could survive.
Yes, it is a problem. Illness from some strains of E. coli, for example O157 can be very serious. It can cause food poisoning symptoms such as diarrhoea and vomiting, as well as more serious complications such as kidney failure, paralysis, or even death.
Every year there are around 800-1000 cases of E.coli poisoning. Not all are from burgers though – this illness can be caused by unpasteurised milk and contamination from root vegetables and from raw meat in the kitchen. That is why there are comprehensive guidance notes about controlling cross-contamination from E. coli.
Find out more on E. Coli contamination here: https://www.food.gov.uk/sites/default/files/ecoli-cross-contamination-factsheet.pdf
What’s the new advice from the Food Standards Agency on cooking burgers?
The longstanding Food Standard Agency (FSA) advice is that the safest approach to cooking burgers is to ensure that they are cooked thoroughly all the way through – in catering settings time and temperature combinations are advised in a report by a committee called the Advisory Committee on Mircrobiological Safety of Food (ACMSF).
Click here to read the ACMSF's report on the safe cooking of burgers: http://www.food.gov.uk/sites/default/files/multimedia/pdfs/acmsfburgers0807.pdf
This report suggests that cooking at 70 °C for 2 minutes at the centre of the meat or 75 °C for 30 seconds) would be sufficient to achieve a 6-log10 reduction of pathogens. This means that if you had 10 million bacteria to start with, you would have 10 left after cooking.
However, in September 2015, the FSA Board agreed a new position, whereby caterers can serve burgers which are less than thoroughly cooked provided there are robust, validated HACCP-based procedures in place throughout the supply chain and the caterers cook burgers to a time/temperature capable of achieving at least a 4-log10 reduction in pathogens and a message given to customers at the point of ordering making them aware that they would be eating a more risky food. This would mean if you had 100,000 bacteria, you would end up with 10 bacteria at the end of cooking.
It is important to note though that different ways of cooking can achieve a 6-log10 reduction and still produce a succulent tasty burger that is not incinerated! Lower final temperatures however need a longer time, for example The ACMSF recommend final if the final temperature is 65°C then this needs to be held for 13.6 minutes, at 60°C, 93 minutes. These times would be unlikely to be acceptable in a busy kitchen. The BHA is working with EHO groups and our members to identify good, practical but safe solutions.
Is colour an adequate means of testing whether a burger is safe?
Not really – it is very difficult to judge, and you have to prise open the burger to have a look. Using a probe is the simplest and most accurate way to test you have cooked it adequately. Using a fine needle probe gives you an answer quickly. You also don’t have to worry about different perceptions of colour, colour blindness etc – it is either the correct temperature or not. Make sure you disinfect the probe before and after use and that you put the tip in the centre of the burger.
What hoops does a caterer need to jump through to be able to serve a rare burger?
At the BHA our advice is first think very carefully about whether there is a demand for rare burgers in your business – the route to a rare burger could be costly, and whilst at the BHA we working on making an approved system for members, this may take some time. If you want to serve rare burgers, the FSA says it is unacceptable unless a “validated and verified food safety management plan is applied that combines the following steps”:
- Sourcing the meat
According to the FSA you need to source your meat from premises that are approved under EU law to supply minced meat intended to be eaten raw or lightly cooked. In addition, the supplier needs to have sampling and testing regimes that would identify pathogens including Salmonella and E. coli O157.
- Managing the preparation and cooking process
In addition to the above, the FSA says you would have to identify how you would prepare and cook the burgers to get a reduction of at least 4-log10 which means that if you had 100,000 E. coli you would only have 10 left after cooking. This would probably need to be assessed in a laboratory as well as in practice, and could be expensive.
Methods such as sear and shave have been used by some caterers where the outside of a large piece of meat is heat-treated and then that part shaved off, and the rest is then treated as virtually “ready-to-eat” and kept free of contamination. However, in many small kitchens this may not be possible, it would be very expensive, and it may even introduce more cross-contamination hazards.
Other considerations businesses have to consider is the difficulty of monitoring cooking times and temperatures accurately, which can be difficult enough anyway, but under stress at busy times may be challenging. The consistency, composition and shape of burgers will also be critical in relation to determination of safe cooking times and temperatures. These are all areas which the BHA will be investigating.
- Consumer advice
In accordance with the decision by the FSA, if you want to go down the route of serving a less well-done burger, you would need to have a consumer advisory statement at the point of ordering, for example on the menu, stating the risk of rare burgers and stating that vulnerable groups should not eat them and that children are only served well done burgers.
However, if you can show that you can achieve a 6-log10 reduction then you would not need to give such advice. Again you may have to validate this in a laboratory if you are not following standard cooking times and temperatures agreed by the ACMSF.
The cheapest and simplest route is to follow the temperatures set out by the ACMSF which in practice would be achieving 70 °C for 2 minutes or 75 °C for 30 seconds and to experiment with cooking techniques to get the best quality out of your burger at these temperatures – flipping, slower cooking, covering whilst cooking etc.
What should the consumer advice say?
If you have carried out all the steps above needed to get a robust and validated system for serving a less well-cooked burger, which the local authority is happy with, then the FSA say you will need an advisory notice at the point of order, for example on the menu.
The Agency has come up with some examples of advisory notices but we think it’s best to have an advisory note that explains the difference between a rare steak and a rare burger. This is an example that could be adapted as you see fit:
“We want our customers to enjoy foods cooked to their preference. However some foods served rare or lightly cooked may have a risk of causing illness. Rare steak is different as cooking destroys contamination on the outside but burgers could be contaminated all the way through. Whilst we have put in place robust systems to protect our customers, the Food Standards Agency advises that the very young, elderly, pregnant or those suffering other illnesses are more at risk of illness and should avoid under-cooked burgers”.
If I put an Advisory Notice up, am I safe from prosecution if a customer becomes ill?
Unfortunately, the short answer to this is “No”! You have a duty under the law to sell safe food, and if you poison someone then you could be prosecuted and of course civil action could be taken against you as well. Even if you have taken all the steps listed as necessary by the FSA, you may still have a higher risk of causing illness than if you cooked your burgers to the 75°C for 30 seconds or equivalent.
Would I have a due diligence defence if I did everything listed above and the EHOs said my methods were safe?
Only the courts can decide on that.
Do I have to tell the EHO about serving rare burgers?
Under the legislation relating to Registration of your business, you must keep the local authority up to date and notify them of any “significant change in activities” – the FSA says that serving rare burgers would be a significant change so that means you should tell your EHO if you are proposing to serve rare burgers. They will want to check that you have a robust and validated system of control for your burgers.
What if I just go ahead and serve rare burgers without doing anything?
Local authorities have been advised that if there is poor understanding of the potential hazards at the food business, and or there are no appropriate, validated food safety management procedures in place, then enforcement action should be considered. This means that they may take action such as serving Notices or they could prosecute. It would also affect your Food Hygiene Rating if the EHO feels they have little confidence in management at the premises. It may also mean that the frequency of inspection of your premises is increased because of the additional perceived risk. Some local authorities have already started legal proceedings where standards are not satisfactory.
So what should I do about rare burgers?
The choice is yours.
- Our advice is to think very carefully about whether there is a business case – how many customers are likely to want a rare burger. Is it worth the trouble?
- How rare do customers want their burgers? If you cook the burger carefully it may still appear slightly pink and yet reach 75°C for 30 seconds? Colour may be deceptive – temperature is accurate.
- Next, double-check how you are currently cooking your burgers. Are there any ways you can improve the texture and flavour of the burger by different cooking techniques. Fast cooking is not always the best for getting a moist burger.
- Do some experiments yourself. Using a probe thermometer, note the time and technique it takes to obtain 75°C for 30 seconds in the middle of the patty. We have heard reports from one member who did some tests and found that chefs were actually over-cooking burgers, but others have found that they were under-cooking them. Remember also that the burger may continue cooking when taken off the griddle.
- If you already routinely reach 75° for 30 seconds then you have cooked your burger well enough, and you can carry on as usual. Document what you are achieving and record temperatures.
- Check carefully when taking the temperature of burgers that you are in fact positioning the probe in the centre of the burger (put it too far in and you may be checking the griddle temperature)! You will need to think about how to train your team to take accurate temperature measurements.
- Document any work that you go through, and if in doubt, contact your EHO and ask for their opinion.
- Make sure your chefs are very well trained on your cooking process. EHOs will ask them questions to test their understanding.
What is the BHA doing?
The FSA is currently consulting on detailed Guidance on "less well cooked burgers" and the BHA’s Dr Lisa Ackerley is participating in this process.
The BHA is currently looking into ways to help members with ways to cook medium/rare burgers and we are liaising with the Food Standards Agency, EHOs, our Primary Authority, Partners and other Trade Bodies. We are hoping to develop an assured HACCP based methodology and provide advice on best cooking practice and sourcing reputable suppliers. Further guidance will be issued in the near future, please watch this space.
For further information, please contact our Policy Manager, Lucy Aldrich-Smith firstname.lastname@example.org