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Vacuum packing ready-to-eat meat food safety requirements

The Australia New Zealand Food Standards Code (the Code) contains standards to regulate food sold in Australia and New Zealand, including Chapter 4: Primary Production and Processing Standards (PPPS).

Standard 4.2.2 Poultry Meatand Standard 4.2.3 Meat set out food safety requirements for the production and handling of ready-to-eat poultry meat and ready-to-eat meat (RTE meats).

Why the need for the Standard

RTE meats have been associated with food poisoning outbreaks from harmful bacteria both in Australia and internationally. Listeria monocytogenes is the main pathogen of concern with RTE meats, as it kills 20 to 30% of people who become ill from it.

To improve food safety for the consumer, these Standards require RTE meat producers and/or handlers to implement a documented Food Safety Management System.

Businesses required to comply

RTE meat producers food businesses that take raw ingredients and turn them into a RTE meat product. For example, RTE meat manufacturers, butchers who produce RTE meats (smallgoods).

Does not include food businesses that sell or use RTE meat for direct consumption. For example:

  • restaurants
  • cafés
  • canteens
  • takeaways
  • caterers
  • any commercial kitchen.

RTE meat handling food businesses that repackage RTE meats in modified atmosphere packaging, such as vacuum packing for extended shelf life. RTE meat manufacturers who vacuum pack, or any other food business that vacuum pack. For example,  RTE meats to extend the shelf life.

Does not include food businesses that slice RTE meat and only wrap for direct consumption or sell RTE meat in original packaging. For example:

  • supermarkets
  • butchers
  • delis
  • other retailers.

Examples

Examples of food businesses that are covered by these Standards:

  • Supermarkets and continental delicatessens which purchase RTE meat or RTE poultry, and then slice it up into smaller portions and then vacuum package it for sale direct to the consumer.
  • Snack bars, cafes or restaurants which may produce or purchase RTE meat or poultry and then vacuum-pack portions in an attempt to prolong the shelf life which is then used in the production of food sold at the premises at a later date (for instance sandwiches). This may include businesses that vacuum pack portions for sale to other food businesses.
  • Catering or cook-chill facilities which produce or purchase RTE meat or poultry and then slice it up into smaller portions and vacuum-package it for supply to customers at other sites, regardless of whether these sites are owned by the same business or this is done under contract.

Regulators

The Standards capture both primary production and food business activities

Primary producers engage in the making, manufacturing, producing, processing and/or handling of RTE meat. Most RTE meat producers are regulated and accredited by Biosecurity SA (Primary Industry and Resources SA).

Food business activities covered by the RTE meat Standards will be regulated by Local Government and SA Health under the Food Act 2001. A small volume of production by a food business, followed by vacuum packing, will be regulated by SA Health

Businesses that are not covered by Standard 4.2.2 Poultry Meat and Standard 4.2.3 Meat must comply with Chapter 3 of the Code, and will be inspected by Local Government.

Food Safety Management System

A Food Safety Management System is the systematic examination of your business’s processing operations. It allows you to identify potential hazards and implement control measures to address the hazards.

Your business's Food Safety Management System must be verified (audited) as per the assigned frequency, which will be between 3 to 12 months, based on the performance of the business.

Food safety requirements for business

If unsure if your product can or cannot support the growth of Listeria, the default position is that your products can support the growth of Listeria, and therefore your business must implement a Food Safety Management Statement.

Requirements for RTE that can support Listeria

  • requires a Food Safety Management System, for example HACCP (Hazard Analysis Critical Control Points) - based plan
  • the Food Safety Management System must be audited by SA Health.

Requirements for RTE that cannot support Listeria

  • requires the documentation and monitoring of specific Good Manufacturing Practices (GMPs), and Good Hygiene Practices (GHPs) including:
    • cleaning program and schedule
    • hygiene practices and policies
    • pest control program
    • preventative maintenance
  • the documented GMPs and GHPs will be inspected by the Local Council (or SA Health) at a frequency of 3 to 12 months, depending on compliance history.

Determining if growth of Listeria can occur

Guidance from Codex provides the following examples of certain factors that can control the growth of Listeria monocytogenes in RTE foods1:

  • A pH below 4.4
  • An Aw <0.92
  • A combination of factors (pH, Aw), for example the combination of pH < 5.0 with Aw <0.94

1 Codex Alimentarius Commission (2007), Guideline on the Application of General Principles of Food Hygiene to the Control of Listeria monocytogenes in Foods, CAC/GL 61 – 2007

Frequently asked questions

Why is Listeria monocytogenes such an issue?

The Standards require implementation of a Food Safety Management System as the likelihood of introducing pathogenic bacteria like Listeria monocytogenes, during production or handling of RTE meats, is very high. This becomes more of an issue when the time period between producing, vacuum packing and consumption is extended, allowing pathogens to grow to levels that will cause food poisoning.

Listeria monocytogenes is a very robust organism in RTE meats, and is of particular concern because of its high mortality rate in vulnerable populations including the elderly, pregnant women, young children and immuno‑compromised people.

It can grow in refrigeration temperatures, under low oxygen conditions and is salt tolerant2. At 4 to 5°C it doubles its population every day, and it prefers to grow under vacuum pack conditions than in the presence of oxygen. In long shelf-life products such as vacuum-packed RTE meats, there is the potential for it to grow to numbers that will cause food poisoning.

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Do all food businesses that produce or sell RTE meats need a Food Safety Management System?

No. The following business will be inspected by Local Government Environmental Health Officers against the requirements of Standards 3.2.2 and Standard 3.2.3:

  • restaurants, cafes, canteens, takeaways, caterers or any commercial kitchen that sells or uses RTE meat for direct consumption.
  • supermarkets, butchers, delis or other retailers that slice RTE meat and only wrap for direct consumption or sell RTE meat in original packaging.

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How do I know if I need to implement a Food Safety Management System or document Good Manufacturing Practices and Good Hygiene Practices ?

An Environmental Health Officer or SA Health representative may identify your business as being affected and will give you a Self-Assessment Tool to complete and return to SA Health.

If you require assistance with completing the Self-Assessment Tool, or if you have any questions about how your business is affected, contact SA Health's Food Safety and Nutrition Branch.

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How does my business comply with this Standard?

Food businesses are responsible for:

  • implementing a suitable Food Safety Management System or documenting Good Management Practices and Good Hygiene Practices
  • ensuring appropriate records are kept to demonstrate compliance
  • contacting SA Health to arrange compliance audits if you are required to implement a Food Safety Management System
  • contacting your local Environmental Health Officer if you are required to document Good Manufacturing Practices and Good Hygiene Practices.

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How will SA Health help my business comply?

SA Health has developed a Food Safety Management System template for food businesses that vacuum pack RTE meats.

Additionally, SA Health will offer initial support to affected businesses on how to comply with the requirements.

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What will happen at an audit and how often will my business be audited?

Your auditor will assess your Food Safety Management System for adequacy at the first and subsequent audits. Businesses are responsible for any auditing costs that may be incurred.

The initial audit frequency may be 6 monthly. The outcomes of two audits will be required to establish a compliance history that can allow for the adjustment of audit frequency.

The auditor may adjust frequency based on performance after this time in the range of 3 to 12 months. For example where a business performs well audits may be reduced to annually, however, if a business performs poorly audits may more frequent.

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What are the fees?

Audits: Contact SA Health's Food Safety and Nutrition Branch for details.

Inspections: As per the individual Council.

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What happens if my business stops producing and vacuum packing RTE meats?

Your business will revert to a Council inspection against Chapter 3 of the Code.

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What businesses do Biosecurity SA (PIRSA) look after?

The following businesses are regulated by Biosecurity SA (PIRSA) under the Primary Produce (Food Safety Schemes) Act 2004:

  • RTE meat manufacturers
  • butchers who produce RTE meats
  • butchers.

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PIRSA is already monitoring the business, does that mean SA Health or Local Government audits or inspections are not required?

Not necessarily. PIRSA may be regulating a specific area of the business, for example the butcher within a supermarket; however they will not be regulating a Service Deli that is vacuum packing RTE meats.

Contact SA Health or Local Government to confirm the requirements of your specific business activities.

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Meat & Livestock Australia (2015), Guidelines for the safe manufacture of smallgoods 2nd Edition, Meat & Livestock Australia Ltd

Definitions

Refer to Standard 4.2.3 Meat for further examples and definitions.

Ready-to-eat

Meat products intended to be consumed without further heating or cooking, and includes: 

  • fermented meat
  • pâté
  • dried meat
  • slow cured meat
  • luncheon meat
  • cooked muscle meat including ham and roast beef
  • other RTE meat that is susceptible to the growth of pathogens or the production of toxins.

Producer

A food business who engages in the making, manufacturing, producing, processing and/or handling of ready to eat meat for retail sale.

Handling

Slicing, shaving or dicing, where it is followed by the packaging of the product in a modified atmosphere package.

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