Guidelines for Australian and New Zealand Sprout Producers
Guidelines for Australian and New Zealand Sprout Producers
Update 7 July 2008 – Prepared by Australian New Zealand Sprouters Association
NOTE – These Guidelines do not replace any regulatory or customer requirements.
The Guideline requirements are as follows.
1. HACCP based Food Safety Program
All ANZSA (sprouters) members must implement a HACCP based food safety program (FSP) under Codex Alimentarius Commission Guidelines. These must be audited at least annually by an accredited Third Party Auditor and must include all requirements of the Food Standards Code as well as regulatory and industry requirements. Additional customer requirements may be applicable for some producers.
NB – The following sections of the Food Standards Code apply.
2 Pre Production Seed Sampling and Testing – CCP for HACCP Plan
This will follow the ISS guidelines – as statistically verified by SARDI at the request of the NSW Food Authority.
The Newington Group has classified Sprouts into four risk categories:
Category A – alfalfa;
Category B – all others incl Sunflower;
Category C – Snow Pea shoots/sprouts.
Category D – Sprouts/shoots grown using a growing medium.
All seed used for sprouting must be sampled and tested prior to use in production.
On receipt the seed shipment should be inspected for evidence of rodent contamination and/or breakages. Producers should develop supplier specifications as part of their HACCP FSP to ensure that seed is cleaned, packaged, stored and shipped in a manner the reduces any potential cross contamination. Bags should be in good condition with no holes or tears.
Category A will be subjected to more stringent sampling and testing, i.e.:
For each shipment of Alfalfa seed sprouter will obtain a minimum of a 25g sample from each bag per shipment (minimum of 3 kg sample) This can be done on receipt of seed at the facility or by having the supplier sample the seed and the sample being tested by a producer. This level of sampling has been statistically been shown to provide a 99.9994% chance of capturing a pathogen.
For Category B, C & D the seed shipment is to be randomly sampled to obtain a minimum of 3 kg seed (providing a 99.9994% chance of capture).
Reference – ISS Seed Screening Procedure as statistically verified by SARDI
Samples must then be grown out for at least 48 hours. A 1 litre sample of the spent irrigation water is then collected and sent to an accredited laboratory tested for salmonella. The required result shall be Not Detected/100ml.
If pathogens are found to be present the seed is to be rejected and returned to the supplier. The producer is to advise the Seed Supplier of the result and ANZSA of the seed line and the supplier to reduce the chances that this seed could find its way into the sprouting industry.
3 Category D Seeds
Category D Products are any sprout or shoot that is produced using a growing medium, eg soil, bark, etc
Sprouters using these methods must use sterilised growing medium or submit their product to more regular verification testing.
4 Seed Sanitation protocol – CCP for HACCP Plan
Category A seeds will be sanitised with a minimum of 5000 ppm available chlorine at pH 6-7 with approx water/seed ratio of at least 2:1 for a minimum of 10 min. Seed should be agitated to ensure all seed surface is in contact with the sanitising solution.
NB – This level is less than that recommended by the FDA and required by NSW Food Authority. We are currently looking at validating this level.
Category B seeds will be sanitised by 2000 ppm available chlorine – as required by NSW Food Authority Guidelines
Category C seeds will be sanitised by 1000 ppm available chlorine
Category D seeds – if using unsterilised growing medium there is little point in sanitising the seed.
Producers must verify these levels as part of their FSP. The Newington Group Committee is continuing to examine how to validate these levels. It is hoped that future research may assist. These levels may be adjusted subject to further research and validation. We are hoping to get some guidance about the acceptable method of validating alternatives. It should be noted that there is a generally accepted necessity to obtain a 3-5 log reduction in bacteria to show that sanitation is effective.
5 Verification testing protocol
Verification Testing to include the following as a minimum requirement:
Spent Water Testing:
On a monthly basis a 1 litre composite sample of spent irrigation water is to be collected from each process. (This water sample is to be collected from at least 50% of the crop being sampled after at least 48 hours of growth)
The exception would be the germinated beans which generally take less than 48 hours to grow.
This is to be tested for Salmonella – Nil Detected in 100ml
Final Product Testing:
Each Month samples for each product process are to be sent to a laboratory to be tested. It is recommended that products are sent for testing at end of shelf life
Products are to be tested for
Salmonella – Nil Detected
Listeria Monocytogenes – Nil Detected
E Coli – <3 cfu/gm
Product Testing Annually
FSANZ testing requirement – 5 samples of each process
Products are to be tested for Salmonella
Requirements for Category D Seeds
If not using sterilised growing medium the following is required
Spent Water Testing – Fortnightly
Final Product Testing – Fortnightly
In addition to the other tests.
If a producer is not using town water it is recommended that they test the water used to water crops on a regular basis for Salmonella and E Coli. ANZSA recommend the use of potable water ONLY.
Testing to verify GHP
Testing final product forstaphylococci – 3 Monthly
Testing for B Cereus
I would also recommend that product (or incoming seed) is occasionally tested for bacillus cereus – (which has shown up in testing in NSW – this is an indication that seed is dirty and not being cleaned properly. It may be worth investigating the test for B Cereus as a supplier requirement. I am still researching which seed is most at risk.
NB – By all accounts B Cereus can be eliminated with thorough washing and sanitation.
Seed Sampling and Testing
At this stage the sprout industry is cognizant that we are unlikely to be able to influence the practices of the seed industry in any significant way. While there are some seed producers /processors willing to work with the industry this is going to be a long term project and does not assist the sprout producers in the immediate. Therefore the ANZSA Committee decided that the onus had to come back to the sprout producers to implement current best practice in terms of seed safety.
Seed Sanitation levels
As you are aware the NSW Food Authority requires sprouters in NSW to use 20 000ppm Free Chlorine for sanitation of Alfalfa Seed. Many producers have advised of the problems that this can cause in terms of OH&S, seed viability, etc.
The Committee reviewed a number of research papers which has looked at various seed sanitation procedures and the general consensus was that no sanitation method had conclusively proven to guarantee a “kill step”. It was also difficult to determine effectiveness as most of the research had been conducted on artificially inoculated seed and the growing methods, etc, rarely reflected the realities of a commercial sprouting environment.
It was also felt that the initial recommendation of the USFDA to use 20 000ppm had been made some time ago, before the industry had started developing seed sampling and testing protocols and improved verification procedures. It was the opinion of the members of the Committee that this had been by way of an “idiot proof quick fix” at a time when the US was having multiple problems and there was little time to research other options.
We also considered the USFDA rationale for the log reduction requirements:
APPENDIX 3 — RATIONALE FOR 5-LOG REDUCTION PERFORMANCE STANDARD RECOMMENDATION
Limited quantitative data is available on the level of foodborne pathogens present in seeds used for sprouting. Quantitative analyses performed on seeds associated with illness attributed to sprout consumption found pathogen levels ranging from <1 – 6/100 g of seed (Inami and Bryant, 1999). Therefore the worse case scenario for seed contamination was assumed to be 1 pathogen/10g of seed. It was also assumed that fifty kg of seeds is the amount of starting material for each batch of sprouts. This yields an initial level of 5,000 pathogens per batch of sprouts. Thus, a 1- log treatment reduction will yield 500 pathogens/batch; a 2-log treatment 50 pathogens/batch; a 3- log treatment 5 pathogens/batch; a 4-log treatment 0.5 pathogens/batch (one batch out of every two will contain a pathogen); and a 5-log treatment 0.05 pathogens/batch (one batch out of every twenty will contain a pathogen).It is realized that the actual extent of risk reduction achieved will likely be greater than this because the extent of initial contamination and the amount of seed used per batch of sprouts will typically be less than the values assumed in the current worst case calculation.
The rationale for the 5 log reduction in the USFDA document states that a batch of seed is assumed to be 50kg). In actual fact (at Parilla) the size of a batch of Alfalfa for the purposes of sanitation is no more than 6kg. So by the rational stated below – the worst case scenario for seed contamination would be 600 pathogens per batch of sprouts. Based on this rationale our interpretation of the required reduction would 3 log – not 5 log.
A recent paper (attached) suggests that pathogens do not grow to similar levels in a commercial operation as they can in home/lab sprouting situation. In commercial settings the sprouts are watered more frequently and the core temperatures kept lower than has occurred in many research projects. The paper suggests that it may well the actual process which assist to reduce the growth of pathogens in a commercial environment.
Another paper (attached) suggested that 2000 ppm was as effective as 20 000ppm. We decided to err on the side of “more is better”.
ANZSA is hoping that future work with FSANZ and ISC, etc will assist us to develop a validation procedure that is acceptable to the regulators and producers and which will address the concerns of organic sprouters and sprouters that may prefer not to use these high levels of chlorine.
Category C – These products are not always considered to be sprouts (rather seedlings) as the shoot is actually cut away from the seed and roots. We were not aware of any major issues with these products in any of the literature. In fact, Snow Pea Shoots are not always classified as sprouts – however the Committee felt that they should be addressed but with an appropriate risk assessment.
This has been altered from the first draft as much of the feedback was that the graded testing program in the initial proposal did not adequately address the high risk nature of the product/processes.