8. Safety Parameters

Provision, Limits, Testing Methods

Foodstuff/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). No entries apply to alcoholic beverages.

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

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

Figure 2. Screenshot from Standard 1.6.1-3 (5) [1]: testing methods

Category

Alcoholic beverages

Same as "General Food" above. 

Same as "Category" above.

Provision, Limits, Testing Methods

Foodstuff/General Food

Standard 1.4.1 – Contaminants and natural toxicants [4] in conjunction with Schedule 19 – Maximum levels of contaminants and natural toxicants [5] describe the requirements for contaminants and heavy metals.

The maximum levels of metal contaminants [5] only set limits for foods listed in the table in Clause S19-4. This does not include alcoholic beverages. Therefore, the applicable specification for ingredients/food would be as described in Figure 3. 

Figure 3. Arsenic and heavy metals from clause S3-4 from ref [5]. 

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

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

Natural toxicants are shown in the table to S19-6 [5]. 

Category

Alcoholic beverages

Same as "General Food" above. 

Same as "Category" above.

Provision, Limits, Testing Methods

Foodstuff/General Food

Pesticides are considered to be AgVet chemicals defined as substances used in agricultural chemical products [6] per Figure 4 below. 

Figure 4. Definition of Agvet chemical from clause 1.1.2- 2 (3) of ref [6]

Therefore, the information here also applies in Section 8.4 below. Clause 1.1.1—10(6)(d) of the FSC [7] 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. Agvet chemicals in foods for sale from clause 1.1.1- 10 (6) of ref [7]

Permissions for Agvet chemical residues are given in Standard 1.4.2 – Agvet chemicals [8] and Schedule 20 [9] and 21 [10]. 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 [9] and [10] 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. 

Category

Alcoholic beverages

Same as "General Food" above. 

Product
Whisky

Same as "Category" above.

Provision, Limits, Testing Methods

Foodstuff/General Food

Please refer to Section 8.3 above.

Category

Alcoholic beverages

Same as "General Food" above.