In June 2011 the EFSA Panel on Biological Hazards (BIOHAZ) and the Panel on Contaminants in the food chain (CONTAM) published a scientific opinion about the scientific validity of the studies submitted by the FSA on the safety of burnt skin-on sheep meat. It was concluded that the hazard identification presented in the studies submitted by FSA did not cover all potential biological and chemical hazards and the studies were considered insufficient to conclude that the burnt fleece skin-on sheep carcasses were suitable for human consumption and provide the same safety level as conventionally produced skin-off carcasses. In June 2012 FSA requested EFSA to provide clarifications about this scientific opinion on a number of issues i) the effect of the process on vegetative microbiological pathogens, ii) the method of sampling for microbiological examination, iii) the increased risk from bacterial spores, iv) the adequacy of control treatments, v) the production standards of wool length and cleanliness of animals; and vi) dioxins, PCBs (Polychlorinated Biphenyls), PAHs (Polycyclic Aromatic Hydrocarbons), PAHs and heterocyclic amines. The intention of FSA is to produce a protocol for future studies based on the EFSA recommendations. The present scientific report contains the reply by EFSA to the requests received by FSA.
Firstly FSA requested for guidance about the evaluation of the effects of the process on vegetative pathogens. EFSA replies that, in order to assess the product safety, the hazard profile and the food safety goals should be defined and a setting of pathogen-related targets for chilled carcasses has to be considered. EFSA recommends that the type and number of samples to be tested should be representative enough and adequate in number to cover the potential variability in the distribution of the microbial hazards on the surface of the carcass before and after singeing.
Concerning the method of sampling, the standard sampling techniques are approved only for skinned carcasses, so this cannot be used on burnt fleece skin-on carcasses for process hygiene assessment nor for microbiological safety assessment.
FSA asked clarifications about the possible increased risk from spores for skin-on carcasses compared to skin-off carcasses. The identification of spore and sporeforming bacteria as possible hazards should be justified and, if these hazards were included, this should be supported by a proper risk assessment. EFSA underlined that the safety of “burnt skin-on” sheep carcasses should be addressed compared to “conventional skin-off” sheep carcasses within the same category of animals, including age. This implies that adequate controls and treated samples have to be included in all experiments, so that the results of the study can be statistically assessed.
FSA further asked clarifications about the EFSA conclusion that it would not be possible to achieve a standard of “clipped, clean and dry” for animals that will be processed into skin-on sheep. It was stressed by EFSA that the variability of fleece conditions was not explored and assessed or not explained properly. It is recommended to include these aspects if further studies are undertaken on this subject. The fleece status should have been identified as Critical Control Point (CCP), indicating clear critical limits, monitoring procedures and corrective actions.
With regard to chemical hazards, the FSA sought further clarifications in relation to dioxins and PCBs, PAH and Heterocyclic amines. EFSA stated that analyses for dioxins would be useful to give an indication of their potential formation during the singeing process and moreover, it was are recommended to normalize the samples concerning skin to muscle meat ratio for a better comparison of results. EFSA wanted to stress that no recommendation was provided to perform analyses for PCBs.
EFSA concluded that the differences in the PAH concentrations from the FSA study in potentially hazardous chemicals is rather limited and that the differences in the PAH concentrations indicate a considerable variability in the process. It was recommended further standardized analyses which should be normalized concerning skin to muscle meat ratio.
As temperature up to more than 500°C could be reached during the singeing and toasting process using a hand-burner, local overheating may result potentially affecting not only skin surfaces but also some inner tissues of the carcass, particularly in the cut/split areas. The local overheating of meat directly exposed to the torch may generate heterocyclic amines. EFSA concluded that analyses for these carcinogenic compounds would be useful at least to give an indication of their potential formation.