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IKE Scenario 06-05:
Verification of Water Activity (Aw) In Shelf Stable RTE Jerky Products
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Objective: To provide clarification to the Inspection Program Personnel regarding the acceptability of Aw criteria which are different from those addressed in the Compliance Guidelines for Meat And Poultry Jerky Produced By Small and Very Small Plants, dated December 2004 (Jerky Compliance Guidelines) and the Compliance Guidelines to Control Listeria monocytogenes In Post-Lethality Exposed Ready-To-Eat Meat and Poultry Products, dated October 2004 (Listeria Compliance Guidelines). These documents, respectively, recommend 0.80 Aw or less to control pathogen growth as well as to prevent the production of mold and mold toxins and 0.85 Aw or less in order to achieve shelf stability in the finished product.
You are an Enforcement Investigation and Analysis Officer (EIAO) and you arrive at an establishment to conduct a food safety assessment (FSA). The company manufactures several RTE products including beef jerky. You utilize the EIAO Food Safety Assessment (FSA) methodology described in FSIS Directive 5100.1 (dated 09/30/2005) and review the establishment's hazard analysis, HACCP plan, and supporting/decision making documents related to the production of jerky.
During the assessment you realize that the water activity critical limit value which the establishment is using (i.e. 0.82 Aw) is different from that which is recommended in the Jerky Compliance Guidelines for controlling pathogens. You understand that the establishment's decision to achieve this, or any, Aw levels must be based entirely upon the food safety concerns being addressed by each individual operation. You also understand that the compliance guidelines have no regulatory basis and that the regulations do not require the finished product to achieve a specific Aw level.
You continue evaluating the design of the food safety system and determine that the establishment is using Appendix A to support that their lethality process is sufficient to destroy Listeria monocytogenes. In addition, the establishment has ensured that there will be no growth of pathogens during the commercial shelf life of the product by using validated lethality and stabilization processes which are capable of achieving 0.82 Aw. The establishment has International Commission on Microbiological Specifications for Foods (ICMSF) (1996) documentation which shows that the growth of additional pathogens of concern (i.e. Salmonella, Staphylococcus aureus and Clostridium perfringens) are inhibited at levels below 0.83 Aw. You determine that this documentation supports their selection of 0.82 Aw as their critical limit to reduce outgrowth of pathogens of concern.
The establishment has elected to address the issue of mold growth by spraying the finished product with a 2.5 % solution of potassium sorbate and then placing an oxygen absorption packet in each package of finished product.
When you review the validation data, you note that the establishment has validation data which supports that 0.82 Aw, in their product, results in shelf stability. This is consistent with the Listeria Compliance Guidelines which indicates that levels below 0.85 Aw are suitable to achieve shelf stability. The establishment also has scientific documentation which supports that mold will not grow on the product as a result of the combined use of potassium sorbate and oxygen absorbers.
Based on the information you reviewed, you determine that the company's HACCP plan, as designed, will be effective in producing a safe product even though it achieves a level of Aw which is different than the criteria addressed in Agency guidelines.
Email comments to Ike@fsis.usda.gov.
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