Regulations, food safety

Microbiological shelf life (MSS) of foods: what has changed on April 29, 2024!

01

Oct

Microbiological shelf life (MSS) of foods: what has changed on April 29, 2024!

Published on: 01/10/2024

Since 29/04/2024,IT DGAL/SDSSA/2024-270has replaced IT DGAL/SDSSA/2019-861, relating to the validation of the microbiological shelf-life of foods. 

The aim of this technical instruction is to provide a didactic framework for validating and verifying the Microbiological Shelf Life (MSL) of foods. 

Nevertheless, this new version highlights the differences between validation and verification of DVM, and reinforces the overall framework of the approach by incorporating systematic re-evaluation procedures and rigorous documentation. 

This new IT reminds us that professionals (manufacturers or final packagers) are responsible for determining the date (BBD: Use By Date or MDD: Minimum Durability Date) that will be affixed to the finished product. 

Reminder: the shelf-life of a food is the length of time during which a food complies with microbiological limits (regulatory criteria and FCD) for safety microorganisms (pathogens) and health microorganisms (responsible for spoilage). This shelf-life is influenced by a number of parameters: initial contamination of the food, environmental contamination, process, packaging and storage conditions. The description of the food on microbiological and physicochemical grounds is a key factor in determining the shelf-life. In addition, the MVD must take into account consumer behavior, with a safety margin. Finally, the MVD must be validated during product development and before marketing, and must also be justified to the official control services, then verified afterwards. Several tools are available to professionals for these stages (e.g. ageing tests, growth tests, predictive microbiology).  


Here is an overview of the main improvements in this new note: 



  • Validation of the DVM includes not only ageing tests, but also systematic reassessment in the event of significant changes (composition, manufacturing processes, packaging). In addition, verification is defined as a procedure distinct from and complementary to validation, which is carried out a posteriori.

  • Initial validation of the DVM must include ageing tests, and any significant modification to the product or process requires further validation. Continuous verification must be integrated into the Sanitary Control Plan (SCP).

  • Introduction of an EFSA flowchart to help companies determine the right shelf-life profile (BBD or DDM).

  • The special case of Listeria monocytogenes now refers to DGAL/SDSSA Technical Instruction 2023-27 on regulatory provisions concerning the danger of Listeria monocytogenes applicable to the production and marketing of ready-to-eat foodstuffs of animal origin or containing them. The information is divided into (i) ready-to-eat foods that do not allow the growth of Listeria monocytogenesand (ii) ready-to-eat foods allowing the growth of Listeria monocytogenes.

  • The Instruction explicitly introduces the possibility of validating intermediate criteria under certain conditions, in particular the demonstration that contamination remains below a threshold of 100 CFU/g throughout the shelf-life.

  • Operators must retain this documentation, and also ensure that historical self-monitoring data and the results of verification procedures are incorporated into the PMS.

  • Traceability of actions relating to this approach (e.g. historical self-checking data, results of validation and verification procedures, reporting/declaration in the PMS) by operators is vital.


Companies are invited to read the entire technical instruction. 


Dossier de durées de vie microbiologiques: le CTCPA supports you


Given the diversity of the tools and situations encountered, the DGAl called on the agro-industrial technical institutes of theACTIAexperts in food microbiology, of which the CTCPA is a member. As an ITAI and member of the RMT Qualima, the CTCPA can support you in your shelf-life validation procedures, via personalized consulting and training. The CTCPA laboratory in Avignon (84) is part of the a network of recognized laboratories, supervised by ANSES and set up by the DGAl, to conduct challenge tests Listeria monocytogenes (growth potential). 

Don't hesitate to contact our team of microbiology experts, with support from our teams of technologists as required. Find out more about our laboratory: Food microbiology laboratory (ctcpa.org)

Contact: Microbiology laboratory - microbiologie.contact@ctcpa.org 
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