8. Safety Parameters

Provision, Limits, Testing Methods

Foodstuff/General Foods

“Miscellaneous/ General food”

Standard 1.6.1 – Microbiological Limits in Food [1] in conjunction with Schedule 27 – Microbiological Limits in Food [2] describes end-point microbiological criteria that are applied to determine the safety of a food lot or batch. However, these do not cover microbiological limits for all foods since only those foods entered in [2] have specific limits (e.g., dairy, and meat products).  

While most food products do not have a microbiological standard, additional guidance is available in the Compendium of Microbiological Criteria for Food [3]. This describes how manufacturers can set process hygiene criteria and microbiological guideline material to set their internal microbiological specification for the foods they manufacture (Figure 1 below).

Figure 1. Screenshot from ref [3]: FSANZ approach to setting microbiological specifications

The Compendium [3] has a chapter on ready-to-eat foods. These are defined in Standard 3.2.2- 1 [4] (refer to Figure 2). The requirements for these vary depending upon the components in such foods. 

Figure 2. Screenshot from Standard 3.2.2- 1[4]: definition of ready-to-eat food

Testing methods applied in relation to the limits in [2] are the relevant methods of Australian Standard AS5013 or equivalent [1] (refer to Figure 3). These do not necessarily apply to microbiological analyses in [3]. In this case, validated test methods should be used.

Figure 3. Screenshot from Standard 1.6.1-3 (5) [1]: testing methods

Provision, Limits, Testing Methods

Foodstuff/General Foods

“Miscellaneous/ General food”

Standard 1.4.1 – Contaminants and natural toxicants [5] in conjunction with Schedule 19 – Maximum levels of contaminants and natural toxicants [6] describe the requirements for contaminants and heavy metals.

The maximum levels of metal contaminants [6] only set limits for foods listed in the table in Clause S19-4. This does not include ‘all foods’ or bakery products. Therefore, the applicable specification for ingredients/food would be as described in Figure 7 (reproduced below, from Section 3.2 of this report). Analytical methods from any of the sources listed in Figures 5 and 6, as relevant, could be applied.

Copy of Figure 7. Screenshot from Schedule 3- 4: Arsenic and heavy metals. 

Non-metal contaminants are shown in the table to S19-5 [7]. The relevant contaminants are:

• Acrylonitrile (all foods) – NMT 0.02 mg/kg
• Vinyl chloride (all foods except packaged water) – NMT 0.01 mg/kg 

Natural toxicants are shown in the table to S19-6 [7]. The relevant contaminants are:

• Pulegone (confectionery) – NMT 350 mg/kg
• Hydrocyanic acid (confectionery) – NMT 25 mg/kg 
• Hydrocyanic acid (marzipan) – NMT 50 mg/kg 

Note: The relevance of confectionery is that icings and frostings are grouped under this food category in Schedule 15 [7]. The above limits can be applied to raw materials, with release specifications for the final foods based on expected levels from the raw material input.

Provision, Limits, Testing Methods

Foodstuff/General Foods

“Miscellaneous/ General food”

Pesticides are considered to be AgVet chemicals defined as substances used in agricultural chemical products [8] per Figure 4 below. 

Figure 4. Screenshot from Clause 1.1.2- 2 (3) [8]: Definition of Agvet chemical

Therefore, information here also applies in Section 8.4. Clause 1.1.1—10(6)(d) of the FSC [9] states that a food for sale must not have, as an ingredient or a component, a detectable amount of an AgVet chemical or a metabolite or a degradation product of the AgVet chemical, unless expressly permitted (Figure 5). 

Figure 5. Screenshot from Clause 1.1.1- 10 (6) [9]: Agvet chemicals in foods for sale

Permissions for Agvet chemical residues are given in Standard 1.4.2 – Agvet chemicals [10] and Schedule 20 [11] and 21 [12]. Schedule 20 sets limits for foods where an AgVet chemical was applied to an ingredient while Schedule 21 applies where an AgVet chemical is potentially present in a food that arose from environmental sources, and not from direct or indirect use of an AgVet chemical on food.

Since it is difficult to construct a pesticide release specification using the information in [11] and [12] due to substances being entered as individual chemicals and not based on potential chemicals in an individual food, manufacturers should use the data from their raw material suppliers to set a specification with respect to pesticides in a food product. The specific type of food needs to be checked and as a first case “all other foods except animal commodities” may apply. DAFF has a useful resource ‘fruit and vegetable residue screen’ [13] which lists pesticides that it uses for testing of imports of such commodities. This is based on the information in [11] and may be useful in deciding a food product’s release specification. It should be noted that bakery products do not usually have the screen applied by DAFF.

Provision, Limits, Testing Methods

Foodstuff/General Foods

“Miscellaneous/ General food”

This is the same as the information in Section 8.3 above. An AgVet chemical is defined as a substance used in agricultural or veterinary products [8]. 

It would be expected that any AgVet chemical present in a food for sale would be present due to direct or indirect use in raw material, or for environmental sources. The same logic applied in relation to setting a release specification in Section 8.3 applies. It should be noted that the inclusion of an AgVet chemical limit in a food specification would only be required based on the expected presence of the chemical.

Provision, Limits, Testing Methods

Foodstuff/General Foods

“Miscellaneous/ General food”

The rules for food contact materials used in packaging are principles-based and not prescriptive. Clause 1.1.1- 10 (10 and 11) of the FSC [9] provides broad guidance in relation to the packaging of food for sale (Figure 6). 

Figure 6. Screenshot from Clause 1.1.1- 10 (10 and 11) [9]: Packaging requirements

This applies to the packaging of food imported from overseas (Figure 7).

Figure 7. Screenshot from Clause 1.1.1- (12) [9]: Packaging requirements for imported foods

Standard 1.4.1 [5] and Schedule 19 [6] provide a mechanism for FSANZ to regulate specific chemicals that can migrate from packaging that may pose a risk to human health and safety. Schedule 19 [6] includes a number of maximum levels (MLs) for chemicals associated with migration from packaging, including vinyl chloride, tin (canned foods) and acrylonitrile. 

• Acrylonitrile (all foods) – NMT 0.02 mg/kg
• Vinyl chloride (all foods except packaged water) – NMT 0.01 mg/kg. 

In addition, Standard 3.2.2 [4] sets out requirements for food businesses (including manufacturers, importers, and retailers) in Australia regarding the packing of food (Figure 8). 

Figure 8. Screenshot from Clause 3.2.2 - 9 [4]: Food packaging during the production of food for sale

The Safe Food Australia guide [14] provides further information on food packaging in Part 9 of the guide.