Page 39 - FoodFocusThailand No.204 March 2023

STRONG QC & QA

heat-resistant toxins, some pathogens are resistant to producer can apply for the certification number from the Thai
heat and can grow after heating, especially spore- FDA in accordance with regulations for non-controlled food
creating bacteria. Therefore, food producers need good issued by the Ministry of Public Health, such as food for domestic
knowledge about the source of pathogens, purchase consumption or community enterprise. The producer can meet
raw ingredients from reputable sources, apply good community enterprise product standards or the criteria for
production standards, and assurance of their Microbiological Quality of Food and Contact Containers Food
production process to ensure that their products are Issue 3, which are deemed sufficiently safe for domestic
entirely sterilized with heat. consumers.

Microbial Food Safety Under the American
FSMA Standards
Introducing new ingredients to food production in the
United States is challenging for producers and More Information Service Info C005
legislators of quality and safety control laws, especially
pathogens for novel food. For this reason, the Food
Safety Modernization Act (FSMA), related to current เอกสารอ้างอิง / References
good manufacturing practices, hazard analysis, and • เกณฑ์์คุุณภาพทางจุุลชีีววิทยาของอาหารและภาชีนะสััมผััสัอาหาร ฉบัับัที� 3
risk-based preventive controls for human food (2560) สัำานักคุุณภาพและคุวามปลอดภัยอาหาร กรมวิทยาศาสัตร์การแพทย์
regulation, requires that the production of new food กระทรวงสัาธารณสัุข http://bqsf.dmsc.moph.go.th/bqsfWeb/wp-content/
uploads/2017/Publish/e-book/micro-ISBN60.pdf
without a clear production standard needs reviews on • Stephanie Nguyen, Adam Woodworth. 2022. Determining Microbio
hazard control measures to ensure the safety of the logical Performance Standards for Food Safety. Food Safety Magazine.
food, especially heat sterilization that needs to be https://www.food-safety.com/articles/7941 : Access on 12 Feb 2023.
sufficient for reducing germ level to acceptable levels • FDA CFSAN. 2018. “Appendix 1: Potential Hazards for Foods and
and meeting the performance standard during Processes.” Hazard Analysis and Risk-Based Preventive Controls for
production. This is to ensure minimal microbial Human Food. https://www.fda.gov/media/99581/download
contamination of the food; for example, the low acid
canning process has a performance standard--12 D
concept—to minimize the level of Clostridium
botulinum spore.
Performance standards for each product can be
considered from lab tests or risk-based pathogen
modeling. Suppose the producer cannot refer to
scientific-based theories to support their production
standard; they have to show their scientific study
results and create their performance standards. The
USFDA declares the adoption of standards for some
food products, for example, the minimum five-lock
reduction performance standard, to minimize the
amount of pathogen on eggshells through
pasteurization. The law is widely accepted among
pasteurized egg producers in the United States and
serves as the starting point for the USFDA’s allowance
of production standards without scientific data.
Nevertheless, this standard is not universally applicable
to all products, as pathogens related to production
standards must be specific to the products and directly
harmful to the consumers’ health. Major pathogens
used for production standard enactment are shown in
Figure 1.
Currently, Thailand has no enforced law requiring
producers to create performance standards. However,
export producers, especially to the United States,
need production standards to build confidence and
certify production safety. However, for domestic, the

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