ARCHIVED - Consultation Report: Response to the draft Recommendations for Management of the Risks Related to the Consumption of Donairs and Similar Products (Gyros, Kebabs, Chawarmas and Shawarmas)

Prepared by the Federal/Provincial/Territorial (FPT) Donair Working Group:

Health Canada
Canadian Food Inspection Agency
Public Health Agency of Canada
British Columbia Centre for Disease Control
Alberta Health and Wellness
Calgary Health Region
Capital Health (Edmonton and area)
Ontario Ministry of Agriculture, Food and Rural Affairs
Nova Scotia Department of Agriculture and Fisheries

June 2008

¹ For the purposes of this document the term donair refers to all other similar products including Gyros, Kebabs, Chawarmas, and Shawarmas.

TABLE OF CONTENTS

1.0 Overview

1.1 Background
1.2 FPT Donair Working Group
1.3 Purpose of the Consultation
1.4 Data Collection

2.0 Detailed Analysis

2.1 Respondent Demographics
2.2 Stakeholder Groups
2.3 Responses to Recommendations

2.3.1 Production Recommendations
2.3.2 Cooking and Serving Recommendations
2.3.3 Cooling and Storage Recommendations

3.0 Discussion and Conclusions

3.1 Common Themes
3.2 Closing Comments

4.0 Appendix

1.0 Overview

1.1 Background

In Canada, donairs are usually made with beef, though chicken and lamb donairs are also common. There are two distinct types of donairs. The first type of product (commonly referred to as donairs or gyros) is made with ground meat that is formed into a cone shape and frozen. The second type of product (commonly referred to as chawarmas or shawarmas) is made with thin, whole cuts of meat that are marinated before being stacked on a vertical skewer. For the purposes of the consultation, all of these products are collectively referred to as donairs.

Donairs are produced at manufacturing facilities and at restaurants or other food service establishments that cook and serve the product. The processing conditions for donairs, whether prepared in a manufacturing facility or a restaurant, vary according to factors such as the company size, production volume, level of facility automation, and the presence or absence of a food safety control system.

Regardless of the type of facility or method of manufacture, raw donair cones are cooked at restaurants on vertical broilers which may be gas powered or electric. The typical counter top broiler consists of vertical heating elements protected by a stainless steel housing. The heating unit is enclosed around the rear of the cooker and the cone sits on an open rotating meat skewer in front of the heat source.

Some donairs prepared at the manufacturing level are fully cooked in either smokehouses or ovens (in loaves), or in water vats (in cones) before being distributed for sale to food service operators. These products are not included in the scope of the recommendations or the consultation.

1.2 FPT Donair Working Group

The FPT Donair Working Group was formed in the spring of 2005 in response to the first documented outbreak of food-borne disease in Canada linked to the consumption of donairs. In 2005 and 2006 there were three subsequent food-borne illness outbreaks in Canada also linked to the consumption of donairs. The working group reports to the FPT Food Safety Committee which is a government committee that provides leadership, advice and recommendations on food safety policy in Canada.

The purpose of the FPT Donair Working Group is to:

1. evaluate current Canadian processing, preparation and handling procedures for donairs prepared at both manufacturing facilities and food service establishments;
   
2. evaluate relevant Canadian and international research, reported food-borne disease outbreaks and existing guidance to industry;
   
3. identify possible factors that may contribute to the risk of development of food-borne illness associated with these products; and,
   
4. develop recommendations for the safe processing, cooking and handling of donairs.

1.3 Purpose of the Consultation

From May to September, 2007 the Donair Working Group consulted with food safety authorities (Federal / Provincial / Territorial Agriculture & Health, Regional Health Authorities), manufacturers of donairs and donair broiler equipment, food service establishments, food associations, and other interested parties. The purpose of this consultation was:

• to engage with stakeholders to increase awareness and understanding of the risks associated with the processing, cooking and handling of these products; and,
• to obtain input on proposed options to reduce those risks.

1.4 Data Collection

A list of relevant stakeholder email addresses was obtained from Health Canada and consultation questionnaires were sent electronically to solicit feedback. Those stakeholders representing the members of the FPT Food Safety Committee further distributed the consultation documents within their jurisdictions. The detailed consultation questionnaires are provided in the appendix. The consultation occurred between May and September, 2007.

2.0 Detailed Analysis

2.1 Respondent Demographics

The consultation yielded 43 responses from a broad range of stakeholders. Raw written data was analysed and tables and graphs were produced to illustrate responses by category. As indicated in Figure 1 the majority of responses came from Ontario, Nova Scotia and Alberta. Two respondents did not disclose their location. No responses were received from the Territories, Quebec, Newfoundland & Labrador and Prince Edward Island.

2.2 Stakeholder Groups

The most commonly represented stakeholder groups (Figure 2) included food safety regulators (63%) and industry members (30%). For the purpose of comparing responses by stakeholder category, related respondents were assigned to a single group:

• the industry category includes respondents that identified themselves as restaurants serving donairs, donair manufacturers, donair broiler manufacturers, and food associations.
• the food safety regulator category includes respondents from provincial health and agriculture departments, regional health authorities, public health inspectors and health associations.
• the other category includes academics, consultants and other interested parties.

Table 1 provides a detailed breakdown of the different stakeholder sectors and the number of respondents from each. The number of responses (62) indicated below is greater than the total number received (43) because respondents were permitted to self-identify using multiple categories if applicable.

Table 1 : Specific breakdown of the stakeholder groups identified

2.3 Responses to Recommendations

Participants were presented with thirteen (13) specific recommendations relating to production, cooking and serving, and cooling and storage of donairs. The tables below provide a short description of the individual recommendations only. Please refer to the appendix for excerpts from the Consultation Questionnaire that contains the detailed recommendation proposals presented to stakeholders for feedback. In each case the respondents were asked the following questions with instructions to provide further comments when providing a negative answer:

• Do you agree with the recommendation?
• Is the recommendation feasible?

For each section below the responses are presented as a percentage of agreement with the recommendation itself, and the feasibility of its implementation. Further, the columns indicate those responses for all stakeholders as well as for stakeholders from industry alone (note that the industry responses are also included in the first group). The working group considered this method of analysis relevant in order to more finely understand where implementation issues may play a role in this industry.

2.3.1 Production Recommendations

There was very strong general support for the 5 production recommendations though many respondents expressed concerns regarding the feasibility of recommendations #4 (cone forms) and #5 (cone size). In the case of cone forms there were concerns expressed regarding the availability and cost of the forms, the potential for cross-contamination in food service establishments, and the resistance of operators to implement their use. In the case of the cone size recommendation (as small as possible) there were concerns expressed regarding inspection, the capacity of existing broiler machines, and the volume of business in donair establishments.

2.3.2 Cooking and Serving Recommendations

There was strong support for the recommendation that a secondary cooking step be implemented for these products (#6). For recommendation #7 there was a great deal of concern expressed about the quality issues (surface drying and charring) that would be inherent in fully cooking a cone on a vertical broiler prior to slicing. There were mixed results regarding how an operator could demonstrate that an alternative method of cooking was sufficient to reach appropriate temperatures (#8) with many respondents identifying the difficulties inherent in taking adequate temperature measurements, monitoring and assessing an alternative cooking process.

2.3.3 Cooling and Storage Recommendations

Cooling and storage recommendation #12 received the highest support while #13 received the least. The economic issue involved with disposing left over product was clearly expressed by many stakeholders. The results for recommendations #9, #10 and #11 were mixed. It was noted that recommendation #10 (a secondary cooking step applied after slicing) received a very low level of support from industry, though the recommendation to apply the same secondary cooking step during the cooking process (#6) was relatively well received by industry. Further analysis of the comments received indicated that a prime concern with recommendation #10 was the time that it would take an operator if performed at the end of the day.

3.0 Discussion and Conclusions

3.1 Common Themes

Because donairs are produced at both large and small manufacturing facilities, and at the food service level where they are also cooked, the consultation involved a large spectrum of industry stakeholders and the corresponding food safety jurisdictions that regulate them. There were challenges encountered with the initial clarity of the terminology that was used in the consultation questionnaire to communicate the intent of the recommendations to a broad audience whose members operate within different regulatory environments.

There were a number of recommendations that caused food safety regulators to express concerns regarding enforcement should that recommendation be implemented by their jurisdiction.

There were a number of recommendations to which industry stakeholders expressed concerns regarding economic impact , time required, quality of product, and willingness of operators to adapt to non-traditional methods of cooking and serving.

3.2 Closing Comments

There was strong agreement with the recommendation for a secondary cooking step. Respondents generally felt that this particular step would be a practical control point to ensure the product has been cooked to an adequate temperature before being served to consumers. Many of the respondents who indicated disagreement with this recommendation were either concerned with a) how this step would be practically implemented (ie. how would the operator take temperature readings of the slices, what methods would be used, how would it be enforced, etc.) or b) the time required for an operator to apply the secondary cooking step at the end of the day during cooling and storage.

Overall, thoughtful feedback was provided that helped the FPT Donair Working Group to support decision making, evaluate the proposed options and develop practical recommendations for industry and food safety regulators to reduce the food-borne illness risks associated with donairs and similar products. The proposed recommendations were amended to a significant degree based on consultation responses and final recommendations were presented to the FPT Food Safety Committee (FPTFSC) in June 2008.

4.0 Appendix

Excerpts from the Consultation Questionnaire:
Recommended Guidelines for the Safe Processing, Cooking and Handling of Donairs and Similar Products (Gyros, Kebabs, Chawarmas and Shawarmas)

Cone Production

Recommendation #1 (Ingredient/Supplier Verification)

Manufacturers should establish specifications for the microbial quality of all ingredients and suppliers should be required to demonstrate adherence to those specifications. Food service establishments should source meat from inspected establishments and other ingredients from approved and reputable sources. Meat trim of unknown microbial quality should not be used.

If no to either question please explain or describe other options or comments.

Recommendation #2 (Hygiene and Sanitation)

Donair cone production should be carried out under proper hygienic conditions. An effective and documented cleaning and sanitation program should be in place.

If no to either question please explain or describe other options or comments.

Recommendation # 3 (processing temperature)

Processing should be carried out under conditions which minimize exposure of the product to temperatures above 4°C (40°F).

If no to either question please explain or describe other options or comments.

Recommendation #4 (cone forms or molds)

For ground meat donairs, the use of forms or molds should be used (instead of meat packing by hand and without a mold) in order to achieve a more consistent product and therefore contribute to a more predictable cooking process.

If no to either question please explain or describe other options or comments.

Recommendation #5 (cone size)

The donair cone should be made or purchased as small as possible in order to reduce the amount of partially cooked product remaining at the end of the day. The cone size used should also be based on the specifications of the cooking unit.

If no to either question please explain or describe other options or comments.

Cooking and Serving

Recommendation # 6 (secondary cooking step)

All portions sliced from a donair cone that has not been fully cooked by a recognized method* should undergo a secondary cooking step designed to achieve a temperature of 71°C (160°F) for 15 seconds in the case of beef, lamb, and pork or 74°C (165°F) for 15 seconds in the case of chicken.

* A recognized method is one that is consistent with local regulations or guidelines established by the responsible food safety authority (e.g. Public Health Authority). The method used should involve a science-based rationale involving verifying that an acceptable internal temperature has been reached. A variety of different secondary cooking methods are acceptable (e.g. grilling, broiling, etc.) provided they can achieve the stated temperatures in the slices.

If no to either question please explain or describe other options or comments.

Recommendation # 7 (precook entire cone before slicing)

The entire donair cone should be cooked to an internal temperature of 71°C (160°F) for 15 seconds for beef, lamb and pork donairs and 74°C (165°F) for 15 seconds for chicken donairs before any product is sliced from the cone.

If no to either question please explain or describe other options or comments.

Recommendation #8 (alternative cooking methods)

Food service operators should use an alternative cooking and slicing method (other than those in recommendations #6 and #7 above) only when they have demonstrated that the internal temperature of the sliced portion has reached 71°C (160°F) for 15 seconds for beef, lamb and pork donairs and 74°C(165°F) for 15 seconds for chicken donairs. The method used to monitor the internal temperature should be approved by the responsible food safety authority and temperature readings should be taken before slicing.

If no to either question, do you have alternative options or comments to suggest? If describing an alternative cooking method please indicate if it has been scientifically evaluated and by whom.

Consultation Question (research on alternative internal temperature / cooking time combinations)

Would your facility or organization be interested in participating in a research initiative to establish a science-based internal temperature / cooking time protocol for donairs? Such an initiative would be industry lead though government support may be available.

Yes____     No ____

If yes, please provide your contact information and any other comments so that the Working Group may contact you regarding research development.

Cooling and Storage

Recommendation # 9 (fully cook and slice before storage)

At the end of the day the remaining partially cooked donair cone should be fully cooked to an internal temperature of 71°C for 15 seconds for beef, lamb and pork donairs, and 74°C for 15 seconds for chicken donairs, before being sliced into smaller portions for cooling.

If no to either question please explain or describe other options or comments.

Recommendation #10 (Apply a secondary cooking step to slices before storage)

At the end of the day the cooking and slicing process should continue for the remaining partially cooked donair cone until the entire cone is sliced. All portions removed should undergo a secondary cooking step designed to achieve a temperature of 71°C for 15 seconds in the case of beef, lamb, and pork donairs or 74°C for 15 seconds in the case of chicken donairs before storage.

If no to either question please explain or describe other options or comments.

Recommendation #11 (slice till frozen core reached)

At the end of the day the remaining partially cooked donair cone should be sliced until the frozen core of the cone is reached. If the centre of the cone has thawed, the entire cone should be cooked and sliced. The remaining (frozen) core of the cone should be re-frozen immediately for use the following day. Note: The slices removed from the cone should undergo a secondary cooking step as in recommendation #10.

If no to either question please explain or describe other options or comments.

Choosing from Recommendations 9, 10, and 11, which do you prefer?

Recommendation 9   _____
Recommendation 10   _____
Recommendation 11   _____

Recommendation #12 (alternative cooling and storage methods)

Food service operators should demonstrate that the cooling method and equipment being used at their establishment are capable of lowering the product temperature to 20°C within 2 hours and then to 4°C within 4 hours after being removed from the heat source (broiler).

If no to either question please explain or describe other options or comments.

Recommendation # 13 (discard partially used cones)

At the end of the day, any remaining partially cooked cones should be discarded.

If no to either question please explain or describe other options or comments.

Choosing from Recommendations 12 and 13, which do you prefer?

Recommendation 12   _____
Recommendation 13   _____