e word “natural” should not be used except where it is specifically permitted by legislation e.g. ‘natural flavouring’.
Will my product be safe if I take out the nitrite?
Safety cannot be taken for granted unless a full validation of the new preservation system in the food is carried out. Nitrate has been traditionally used to prevent meat products from causing botulism caused by the harmful bacterium, Cl. botulinum. The removal of nitrite can be likened to the removal of a hurdle to the growth of Cl. botulinum. To maintain the safety of the food, another similar hurdle must be used to replace nitrite or otherwise the ‘height’ of the remaining hurdles has to be increased to prevent Cl. botulinum from growing. For example, to reinstate the safety of the food you may have to reduce the shelf life and/or increase the salt level (and therefore increase the water activity: Aw) and/or decrease the pH and/or add a different preservative. In effect you will have to reformulate the product, validate the shelf life and readjust the HACCP system to ensure the food can be manufactured safely on a consistent basis.
A useful document was produced by CCFRA in 2009 called “The manufacture of vacuum and modified atmosphere packaged chilled foods: a code of practice. 2nd edition”, which provides good guidance to manufacturers.
What is botulism?
Clostridium botulinum is a bacterium that exists in soils and is found throughout the environment. It produces spores which have great resistance to heat and chemical disinfectants. Cl. botulinum can be found in many raw foods including meat and is capable of producing a potent neurotoxin (poison that affects the functioning of brain and nerves) as it grows. The neurotoxin can kill at very low levels if victims are unable to seek immediate treatment. This condition is known as botulism.
For the purposes of this FAQ there are two main forms of Cl. botulinum called Type I and Type II. Type I Cl. botulinum spores are the most heat resistant but cannot grow below 10ºC. Type II Cl. botulinum spores are less heat resistant than Type I spores but can grow at temperatures as low as 3ºC. Both types of Cl.botulinum do not thrive in the presence of air and are therefore considered strict anaerobes.
How does nitrite prevent botulism?
Nitrite, in combination with salt and pH, is used in cured meats to ensure their safety with respect to a number of pathogens including Cl. botulinum. To cause illness, spores of Cl. botulinum have to be able to germinate and then grow in the meat product until a point at which botulinum toxin is produced by the bacteria. Nitrite exerts a concentration-dependent antimicrobial effect in meat products, including inhibition of the outgrowth of spores of Cl. botulinum. The antimicrobial effect is also pH-dependent, increasing ten-fold for each unit fall in pH. In its review of nitrite, the EFSA Biohazard Panel in 2003 concluded that between 50-150 mg/kg nitrite is necessary to inhibit the growth of Cl. botulinum. The panel concluded that the ingoing amount of nitrite into the product was the important preservation factor.
What must I do to satisfy the competent authorities that my product is safe and labelled correctly, if I remove the sodium or potassium nitrite/nitrate from my meat product and replace it with an alternative ingredient that is also a source of nitrite/nitrate?
The competent authorities are the government bodies charged with ensuring compliance with the food law. Where sodium or potassium nitrite/nitrate has been removed from the meat product and replaced by an alternative ingredient that is also a source of nitrate/nitrite, the competent authority will require the food business operator to prove that the alternative ingredient is not having a preservative effect in the final product. The competent authority may request inter alia:
(a) Full analytical results showing the levels of nitrate/nitrite in the meat product at the start and end of shelf life and the variability in those levels over several batches
(b) Demonstrable evidence that the alternative ingredient is n