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Draft guidance for consultation: Less than thoroughly cooked beef burgers

Source control method

What the source control method is and how it can be used for LTTC beef burgers.

Last updated: 27 January 2022

Overview of the method

This method starts with beef/minced beef/beef burgers being bought from a supplier which has controls in place to ensure the reduction of harmful bacteria. Examples of controls include lactic acid rinsing of meat cuts, steam surface treatment, separation of storage and equipment to avoid cross contamination, and enhanced microbiological sampling. Research has shown that appropriate source controls can result in at least a two-log reduction in bacteria.

Beef burgers are then cooked to a time/temperature combination which will result in a four-log (99.99%) reduction in bacteria, so overall a six-log reduction can be achieved. 

A consumer message is used to alert consumers, particularly vulnerable groups, to the increased risk of eating less than thoroughly cooked (LTTC) beef burgers.

Best practice
Businesses may wish to appoint an expert food safety consultant as this is a complex process and must be carefully controlled.

The information below lists some points to consider at each step of the source control method. More detail is given further on in the guidance.
 

Step 1: Purchase

  • supplier specifically approved for the production of minced meat or beef burgers to be less than thoroughly cooked
  • specific controls in place at suppliers (for further information see Annex 4)
  • supplier’s food safety management system specifically takes into account that product will be LTTC
  • product specification
  • microbiological testing

Step 2: Delivery to caterer

  • food safety intake checks
  • temperature
  • cross-contamination
  • product must comply with specification
  • ‘use by’ date
  • malformed/misshapen burgers

Step 3: Storage

  • temperature
  • cross-contamination
  • burgers becoming misshapen

Step 4: Preparation

  • temperature
  • cross-contamination

Step 5: Cooking

  • validated system for reducing bacteria by at least four-logs

Step 6: Service

  • consumer message

Purchase
 

Best practice
It is best practice to buy minced beef, beef burgers or patties from a supplier that has been specifically approved by FSA or an LA to supply products that will be less than thoroughly cooked. Approved premises which supply minced meat or burgers to be less than thoroughly cooked must have specific approval for this activity. The list of approved less than thoroughly cooked meat establishments in the UK will assist businesses with finding a suitable supplier.

There are specific hygiene standards that apply to suppliers of minced beef or beef burgers to be less than thoroughly cooked and these are summarised in Annex 4.

Suppliers of minced beef or beef burgers, which will be less than thoroughly cooked using the source control method, must have appropriate procedures in place which reduce the risks associated with raw beef. Suppliers must specifically identify relevant pathogens, such as salmonella and STEC, as hazards in their food safety management system (FSMS). There must be evidence that suppliers have identified and put in place controls for these hazards and that they monitor and verify that the controls are effective on an ongoing basis. Annex 4 provides further information about appropriate HACCP-based food safety management systems.

Some suppliers may be exempt from approval, in which case the catering business serving the LTTC burgers must be able to demonstrate that their supplier meets the stringent hygiene standards that would be required of a LTTC approved establishment. Annex 4 provides further information about these hygiene standards and appropriate HACCP-based food safety management systems.

Best practice
It is best practice that suppliers are audited to ensure that appropriate controls are in place.

Product specification

The catering business must be able to demonstrate that appropriate product specifications are in place. Examples include:

  • using cuts of meat least likely to be contaminated with pathogens of concern
  • not sourcing meat from geographical areas with high levels of STEC in cattle
  • making burgers a consistent shape, size and thickness, so that safety controls such as cooking times are easy to apply
  • using packaging which does not squash or misshape the burgers
  • using strict temperature controls and ensuring the cold chain is maintained to limit the growth of harmful bacteria
  • avoiding cross-contamination at all stages

Validation and verification of the FSMS at suppliers

Sampling and testing regimes are needed to validate and verify controls as part of the FSMS. The regime must include specific corrective action that will be taken in the event of unsatisfactory results. Although sampling is not a guarantee of the safety of a product, it is an important means of verifying that the FSMS is effective. 

Microbiological sampling requirements for businesses that mince meat

Microbiological sampling is required for minced meat/beef burgers that will be less than thoroughly cooked, including when the beef is minced at a catering business.

The requirement for businesses to carry out sampling for minced meat/beef burgers that will be less than thoroughly cooked is included in:

The Regulation provides specific microbiological criteria for salmonella levels in minced meat and meat preparations to be consumed raw. These criteria also apply to minced meat and meat preparations which are to be less than thoroughly cooked, including minced meat with seasoning or additives, formed into burgers.

The catering business serving LTTC beef burgers must be able to demonstrate that this sampling has been carried out and that the results comply with the regulations.  

Note: Businesses that produce minced meat or meat preparations to be less than thoroughly cooked using the source control method must always carry out sampling, regardless of volume. The exemption in the regulations for small amounts of minced meat and meat preparations does not apply.

The FSMS must also consider controls for hazards other than salmonella, including STEC. Additional verification sampling may be required, alongside the criteria in the regulations. There must be procedures in place for the appropriate corrective action to be taken if the results are unsatisfactory.

If sampling results show that STEC are confirmed as present in a batch of minced meat or meat preparations, that batch of meat must not be used for burgers that will be less than thoroughly cooked, due to the risk to public health. More information about sampling for STEC and what to do in the event of presumptive or unsatisfactory results.

Delivery to caterer

Some points to consider:

  • if the product is delivered above the maximum temperature limit that has been set and detailed in the FSMS, the delivery must be rejected  
  • the delivery must be placed into chilled storage as soon as possible, so the cold chain is not interrupted
  • the ‘use by’ date must be checked on arrival and if it has expired, the food must be rejected
  • during transport, meat or burgers to be less than thoroughly cooked should be separated from other raw meat and food, to reduce the risk of cross-contamination
  • if the delivery does not meet the product specification, such as size and shape, it must be rejected
  • the planned monitoring and verification checks and the proposed staff training must be validated to make sure they will achieve effective control
  • delivery intake procedures must be verified on a routine basis; monitoring records and any corrective actions taken should be checked by management
Best practice
It is best practice for catering businesses to carry out microbiological sampling of uncooked minced beef or beef burgers they have received from the supplier. This is to verify they are meeting the required microbiological criteria.

Storage

Some points to consider:

  • fridges must be large enough and of a suitable grade to hold the required volume of product at the correct temperature
  • temperatures must be monitored using calibrated equipment and records  kept
  • products must be used within the supplier’s specified shelf life
  • minced beef or beef burgers bought in fresh must not be frozen before use, unless instructions are provided by the supplier
  • products to be less than thoroughly cooked must be stored separately from other foods, including other raw meat products and ready-to-eat foods
  • if the shape and size of the burgers, and/or the manner in which they are stacked or packaged, has been specified, then storage at the catering establishment must not affect this
  • management must make routine verification checks of storage practices to ensure that temperatures are being monitored and recorded correctly and remain within the set limits, staff are using the designated storage areas correctly and any corrective action required is being taken and recorded
  • if any deviation from the documented storage procedures is observed, the root cause of this should be determined and addressed to ensure the same issues do not recur
Best practice
It is best practice to store products to be less than thoroughly cooked in a separate, designated fridge.

Production of beef burgers by the catering business

When catering businesses make the burgers themselves, the following points need to be considered:

  • the burgers must be labelled with a suitable shelf life, this date should be determined by a HACCP validation study
  • burgers to be less than thoroughly cooked cannot be prepared in the same area at the same time as any other raw meats, the work surface must be thoroughly cleaned and disinfected between uses, detailed guidance on cleaning and disinfection can be found in the E. coli cross-contamination guidance
  • complex equipment such as mincers must be designated for products to be less then thoroughly cooked only and other pieces of equipment, such as knives and chopping boards, must also be designated, unless they can be completely dismantled, thoroughly cleaned and heat disinfected
  • designated utensils and equipment must be stored in a location where they are not at risk of contamination
  • controls must be monitored as specified in the FSMS, for example, the time burgers are out of the fridge, or the temperature of burgers at the end of processing may need to be checked and recorded
  • the preparation methods must be validated before they are introduced to make sure they are going to work, it may be helpful to consider the following questions:
    • Is the preparation space adequate?
    • Is the right equipment available?
    • Will safe temperatures be maintained?
  • management must regularly verify that all food safety management procedures, monitoring and validation of processes are working, temperature records and corrective actions should be checked to ensure they are accurate
  • microbiological testing is legally required if the caterer minces meat to be less than thoroughly cooked, and specific legislation applies
  • if any deviation from the documented procedures is observed, the root cause for this should be determined to ensure the same issues do not recur
Best practice
It is best practice to:
  • prepare burgers during times when the kitchen is quiet, as it is likely to be cooler and staff are less likely to be distracted by other tasks 
  • use separate, designated equipment and surfaces for the preparation of burgers/patties to be less than thoroughly cooked
  • remove meat from the fridge only when staff are ready to mince the meat and/or form the burgers, staff should work on small batches at a time and place finished batches in the fridge before starting on another 
  • handle the meat as little as possible, to prevent it from becoming warm, any equipment used should not be hot, for example after being washed in a dishwasher 
  • use a chilled room or a cool area of the kitchen as this will help keep meat cold and if any ingredients are added to the burger they should be as cold as possible before being used, e.g. onions

Cooking

The cooking process will be a critical control point  in the FSMS and critical limits must be identified. The proposed time/temperature combination must be validated to show that a four-log reduction in bacteria will be achieved. Further validation is needed to show that the proposed cooking method will consistently achieve the validated time/ temperature combination.

Validation and verification of the time/temperature combination

When validating and verifying the proposed time/temperature combination to show that it will result in a four-log reduction in bacteria, evidence may be gathered as below. The list is not exhaustive and there may be other ways to provide evidence.

Challenge testing

Challenge testing can be used to show that the cooking method will result in a four-log reduction of bacteria. Challenge testing is the deliberate addition of specific microorganisms to monitor their growth and/or survival in a product. Microbiological testing should be carried out by a laboratory accredited to ISO 17025 and the methodology used by that laboratory should also be accredited. A list of accredited laboratories can be found on the United Kingdom Accreditation Service’s (UKAS) website. Laboratories will be able to advise on tests in further detail.

Scientific data

It may be possible to use existing scientific and/or technical data to support validation and challenge testing. For example, some businesses will have a number of identical establishments, equipment and products. It may be that a validation for one establishment is suitable for the other establishments.

It may also be possible to use wider industry validation data if methods are similar. In this situation, it would be important to consider factors such as:

  • time and temperature
  •  ingredients
  • fat content
  • uniformity of composition
  •  the size and shape of the burger
  • the heating method

Modelling

Potentially, mathematical modelling could be used to support validation and challenge testing. There must be sufficient data to predict the effects of different treatments. Factors such as size, ingredients and the expected level of contamination must be considered.

Note: If changes are introduced to the method or product specification, for example a new piece of equipment is provided, or a new supplier or product specification is used, then the process must be re-validated.

Verification sampling

Microbiological sampling after cooking can be used to verify that the system in place is working as intended. When planning a sampling regime, the following matters may need to be considered:

  • quantity of LTTC beef burgers served
  • controls in place
  • purpose of the sampling regime
  • pathogens being tested for
  • against what parameters the final sample results will be compared
  • sample size to be tested each time
  • frequency of sampling

It is important to recognise the limitations of sampling. For example, a result that reports the absence of STEC does not necessarily verify that all the burgers are free from STEC. If STEC was not present in the burger that was sampled before cooking, it will not be present after cooking, regardless of the controls in place.

Validation and verification of the cooking method

The cooking method must be validated before it is introduced to show that the proposed time/temperature will be achieved consistently. Once the cooking method has been validated and it is introduced, businesses must verify that the time/temperature combination is being met consistently.

Temperature checks

Points to consider for temperature checks:

  • the temperature at the centre of the burger will need to be tested, as this is likely to be the last part of the burger to reach the required temperature
  • the type of probe thermometer used must be suitable and instructions must be followed, it must be calibrated according to instructions to ensure it gives an accurate reading
  • the probe thermometer must be cleaned and disinfected before and after each use to reduce the risk of cross contamination
  • temperature monitoring records should be kept demonstrating that this CCP is under control, in accordance with the FSMS
  • monitoring records should be verified by management, in accordance with the FSMS
  • the method used to check burger temperatures should be verified on a regular basis by observation, in accordance with the FSMS
  • staff must be able to be identified and retrained if management identify any issues with records
  • verification checks should be recorded along with any corrective actions taken, in accordance with the FSMS

Cooking time check

The validated cooking method may entail burgers being cooked for a certain amount of time to achieve the time/temperature combination. Various factors need to be considered when using time checks:

  • the type and temperature of equipment used - different grills and flat tops operate in different ways and some will have cold spots that will affect cooking time
  • the number of burgers cooked together may affect cooking time
  • heat will distribute at different rates through burgers with different thicknesses, fat content and ingredients
  • the temperature of the burger before cooking - a burger removed from the fridge at 1°C will take longer to heat to core temperature than a burger at 5°C, the ambient temperature of the kitchen may also affect cooking time
  • if  timers are used to monitor the time taken to cook burgers, the number of timers needed will depend on the number of burgers to be cooked at the same time and whether every burger is timed, a maximum cook load may need to be set

Validation of cooking time

If the cooking time is used to assess whether the beef burgers are cooked to an appropriate time/temperature combination, this system must be validated before it is introduced. This would involve checking that the correct temperature of the burger has been achieved after it has been cooked for the set time.

If anything changes which may affect the cooking time, such as the cooking equipment or the supplier of the burgers, the method must be validated again.

Verification of cooking time

It is important that the time taken to reach the required time/temperature is verified regularly. To verify that an adequate time/temperature has been achieved, a burger must be cooked for the set time. Then the core temperature must be checked. If cold spots on the cooking plate/grill have been identified, the verification must be carried out in the known cold spot.

Consideration must also be given as to how the above process will be recorded.

 


We are consulting on this draft guidance. Take part in our burgers guidance consultation.