Modernist-Cuisine-Vol.-1-Small

UNDERSTANDING
THE FDA RULE BOOK
3
For more on the cooking, storage, and freezing
temperatures specified by FDA rules, see the
tables on pages 184 and 186.
Although many chefs associate
frozen seafood with poor quality,
proper handling and quick freezing
can preserve taste and texture.
Broadly speaking, health officials take two
approaches to food safety rules. One approach is
to make specific rules for various food typesin
particular, to specify time-and- temperature
combinations for cooking. The other, more general
approach is simply to say, “Cook sufficiently to
destroy pathogens.”
The FDA takes the first approach, giving very
detailed standards for a wide range of foods.
Indeed, the FDA’s Food Code constitutes the most
detailed list of food safety specifications in the
world as of this writing. The European Union and
most of its member states tend to take the opposite
approach, requiring restaurants and other commercial
food establishments to serve food that is
safe without giving much guidance about how to
achieve that safety.
One can argue the merits of either approach.
The FDA Food Code has some entries that are
rather puzzling and seemingly not supported by
science. In those cases, the detailed approach
requires U.S. cooks to follow rules that may be
unwarranted. Chefs in Europe must satisfy the
health department, but they can decide how to
achieve compliance on a case-by-case basis.
You could counter that the FDA rule book is
more useful and informative because it gives the
chef very specific guidelines and imposes
a national standard that, ideally, prevents local
authorities from running amok with their own
discordant rules. In practice, however, local
regulations commonly depart from the national
standard, and local authorities do run amok from
time to time (see The New York Sous Vide Hysteria,
page 188).
We’ve reproduced many of the FDA’s time-andtemperature
standards in the pages that follow.
The principal set of rules, reproduced on page 184,
is remarkably detailed and covers even uncommon
foods such as baluts, a Southeast Asian specialty
that consists of cooked chicken or duck eggs that
each contain a partially developed embryo.
The FDA has special requirements for wholemeat
roasts: in addition to the temperature of the
food, the air temperature for dry still and dry
convection ovens must meet certain specifications.
Humidified ovens, including combi ovens,
steamers, and cook-and-hold ovens, are not
required to meet any air-temperature specifications,
although the FDA still provides a temperature
recommendation as well as suggestions for
relative humidity.
Sous vide cooking is covered by special FDA
rules. Although the basic time-and- temperature
regulations are the same as those for more conventional
cooking, the sous vide-specific rules
include fur ther requirements for storage.
Raw foods are also governed by FDA regulations.
In the case of raw fish, the FDA requires that
susceptible species be frozen to kill anisakid
nematodes and related parasites before being
served. You can legally serve most other foods raw,
but not to susceptible people and not without a
warning. Oddly, raw plant-based foods are exempt
from these requirementsan unfortunate distinction
given that plants can be just as contaminated
as food of animal origin.
Analysis of FDA Regulations
Although the FDA does not give a rationale for
most of its standards, we can gain a better understanding
of them with the aid of some basic
scientific principles. One in particular is the basic
assumption in virtually all food microbiology that
thermal death curves for bacterial pathogens are
straight lines on a semilog graph.
In plain English, this means that, when
a specific amount of bacterial reduction is plotted
logarithmically against the combinations of
temperature and time required to achieve it, the
resulting line should be straight. For an example,
look at the thermal death curve for Salmonella
shown on page 187. Such lines offer a consistent
basis of comparison for the parameters that
produce a desired reduction in bacteria numbers.
As that figure shows, if you plot a curve from
the data in the FDA’s cooking table for whole-meat
roasts, you get essentially the same curve as the
6.5D thermal death curve for Salmonella in beef.
In principle, this plot should be a straight line, but
the FDA’s decision to round off to the nearest
minute and nearest degree has made the line a bit
bumpy. And one point on the graph is much more
problematic than the others: the last one.
At 70 °C / 158 °F, the FDA 2009 Food Code
lists a corresponding cooking time of 0 seconds,
and other FDA documentation lists it as “< 1
second.” The previous temperature in the code,
69.4 °C / 157 °F, corresponds to a cooking time of
14 seconds, so there’s a sizeable decrease in time
between that point and the last one for a temperature
difference of just 0.6 °C / 1 °F. In fact, the final
data point is downright wrong if it’s meant to represent
actual reductions in populations. The real
cooking time for a 6.5D drop for Salmonella at
70 °C / 158 °F is 11 seconds.
This error is potentially dangerous because
cooking meat for less than a second at 70 °C /
158 °F does not produce anything close to a 6.5D
reduction in Salmonella. On the other hand, even
the true value of 11 seconds is quite brief; one
could argue that the relative difference in time is
not important. Indeed, this is exactly what FDA
officials told us when this discrepancy was brought
to their attention. They had basically “rounded
down” from 11 seconds to 0 seconds. But then why
not round 14 seconds or other values in the table
down to zero also?
We point out this error to remind cooks that the
“experts” don’t get everything right. Anybody can
make mistakes, including government bureaucrats,
so it behooves a cook to have an understanding
of food safety that goes beyond the specifications
in the rule book. Unfortunately, there are
many other examples of inconsistencies, inaccuracies,
and caprice in the official regulations that
govern food safety.
The data curve in the FDA time-andtemperature
table for egg dishes and for ground,
minced, injected, or mechanically tenderized
meats (red line in FDA Time-and- Temperature
Curves, page 187) also follows the 6.5D Salmonella
curve. For reasons that aren’t clear, however,
The FDA Food Code for 2009 is an
exhaustive but imperfect attempt to
prevent foodborne illness with detailed
regulation.
182 VOLUME 1 · HISTORY AND FUNDAMENTALS
FOOD SAFETY 183