Food Sampling & Analysis - III

Statutory and Regulatory Requirements

The central requirement of any regulations or codes which concern sampling, is that they include details of the steps to be taken to ensure that any sample procured is a “fair sample” that accurately reflects the constituents of the bulk material being sampled. The procedure by which a product or substance is sampled for enforcement purposes is of prime importance and must satisfy any statutory requirements. This is to ensure that the sample will constitute valid evidence in any subsequent court proceedings. Thus it is mandatory to follow all the statutory and regulatory requirements set by the specific food regulatory authority of the country concerned. There are various limitations and regulations are published for the public awareness of such matters which must be followed whenever you are taking samples for the propose of analysis to understand the safety or quality of the food concerned.  

The basic principles that must be addressed in sampling are as follows:

1. The sample should represent the food as sold to the consumer and each part of a divided sample should be truly representative of the original
2. Where divided, all parts of the sample must individually be representative of the food and of each other
3. The sampling process must not alter the sample in any way that might affect the analysis
4. Storage and transportation of the sample must not alter it in any significant way – whether through contamination, loss, deterioration or other means.
5. What follows is further practical guidance on food sampling to ensure that the results can be used to enforce the law in a sound manner.

 Reasons for Analyzing Foods

Foods are analyzed by scientists working in all of the major sectors of the food industry including food manufacturers, ingredient suppliers, analytical service laboratories, government laboratories, and University research laboratories.

In addition, food manufacturers and producers would need to satisfy themselves that any sample taken for analysis is sufficiently representative of the food for the analytical result to be meaningful. This is true whether the data are to be used as the basis of labeling declarations, assurance of compliance with legislative or other standards such as ISO 22000, monitoring of production as part of HACCP (Hazard Analysis and Critical Control Points), or for routine quality control.

Regulations and Guidelines

Codex Committee on Methods of Analysis and Sampling

The Codex Committee on Methods of Analysis and Sampling (CCMAS) defines criteria for Codex methods of analysis and sampling and coordinates the work of Codex with other international groups working in methods of analysis and sampling and quality assurance systems for laboratories.

CCMAS specifies reference methods of analysis and sampling for Codex Standards and considers and endorses methods of analysis and sampling proposed by Codex Committees, except those related to pesticide residues and veterinary drugs in food, the assessment of microbiological quality and safety in food and food additives. It also considers issues submitted to it by the Codex Alimentarius Commission and defines procedures, protocols and guidelines for quality assurance systems and assessment of proficiency for food laboratories.

Existing Codex Standards

Standards relating to methods of analysis and sampling that have been endorsed and adopted into the international food code include:

1. Recommended Methods of Analysis and Sampling
2. Methods of Analysis and Sampling for Fruit Juices and Related Products
3. Guidelines on Performance Criteria and Validation of Methods for Detection,Identification and Quantification of Specific DNA Sequences and Specific Proteins in Foods

Government Regulations and Recommendations

Any of the government regulations and recommendations are designed to maintain the general quality of the food supply, to ensure the food industry provides consumers with foods that are wholesome and safe, to inform consumers about the nutritional composition of foods so that they can make knowledgeable choices about their diet, to enable fair competition amongst food companies, and to eliminate economic fraud. There are a number of Government Departments Responsible for regulating the composition and quality of foods, i.e., in US, the Food and Drug Administration (FDA), the United States Department of Agriculture (USDA), the National Marine Fisheries Service (NMFS) and the Environmental Protection Agency (EPA). Each of these government agencies is responsible for regulating particular sectors of the food industry and publishes documents that contain detailed information about the regulations and recommendations pertaining to the foods produced within those sectors. It is common for most of the governments around the world.  These documents can be purchased from the government or obtained on-line from the appropriate website.

Permit Guidelines

A permit is required whenever a food facility is open for business. Any time food sampling occurs, it must be done in a permitted food facility such as a food establishment, mobile food preparation unit, mobile food facility or temporary food facility. Any food preparation of the samples must be done in a permitted food facility that has been permitted to allow the type of food preparation proposed. For example, a food establishment, which is permitted to sell prepackaged food only, may not offer samples that require food preparation.

Sampling may occur from a mobile food facility only if the foods being sampled are allowed to be sold from a mobile food facility and the food meets the requisite packaging requirements. It is better to contact the local enforcement agency for specific information on the types of foods that may be sampled from a mobile food facility. Sampling from a mobile food preparation unit or temporary food facility may occur if the samples are prepared and kept within the structural confines of the facility or are properly prepackaged, held at appropriate temperatures and are supervised. The enforcement agency may issue a permit to the retail food sample employee or company as necessary to assure that the food is prepared in a pure, safe and unadulterated manner.

Structural Guidelines

A large amount of food sampling is done by people who are not employed by the retail food establishment. Instead, they are employees of a company that is contracted by the manufacturer of the product or food establishment to conduct sampling at various retail outlets. Since these employees are not employees of the food establishment, a written agreement must be provided between the food establishment and the sampling company. The written agreement must indicate that the employees of the sampling company will have available for their use the sanitary facilities of the food establishment to properly wash, rinse and sanitize the equipment they are using, wash their hands as needed and generally clean up the area where the sampling took place. The agreement must be kept by the food sampling employee to be provided to the enforcement agency upon request. The local enforcement agency may require a separate utensil washing/prep area if there is a significant amount of sampling by non-food establishment workers within the food establishment.

Standards

Government agencies have specified a number of voluntary and mandatory standards concerning the composition, quality, inspection, and labeling of specific food products.

Mandatory Standards

Standards of Identity – These regulations specify the type and amounts of ingredients that certain foods must contain if they are to be called by a particular name on the food label. For some foods there is a maximum or minimum concentration of a certain component that they must contain, e.g.,  peanut butter must be less than 55% fat, ice-cream must be greater than 10% milk fat, cheddar cheese must be greater than 50% milk fat and less than 39% moisture.

Standards of Quality – Standards of quality have been defined for certain foods (e.g., canned fruits and vegetables) to set minimum requirements on the color, tenderness, mass and freedom from defects. e.g., Standards of Fill-of-Container; These standards state how full a container must be to avoid consumer deception, as well as specifying how the degree of fill is measured.

Voluntary Standards

Standards of Grade – A number of foods, including meat, dairy products and eggs, are graded according to their quality, e.g. from standard to excellent. For example meats can be graded as prime, choice, select, standard etc according to their origin, tenderness, juiciness, flavor and appearance. There are clear definitions associated with these descriptors that products must conform to before they can be given the appropriate label. Specification of the grade of a food product on the label is voluntary, but many food manufacturers opt to do this because superior grade products can be sold for a higher price. The government has laboratories that food producers send their products too to be tested to receive the appropriate certification. This service is requested and paid for by the food producer.

On the other hand, there are number of standards such as ISO 22000, FSSC 22000, BRC, ISO 9001, IFS, etc., which are requesting confirmation and validation of the implemented standard where you have to carry out initial raw material quality and microbial testing as well as for the end products sampling. These tests are carried out to ensure that the implemented standard is operating up to date and no hazards are transferred to end products.