Draft - Canadian requirements for determining the equivalence of food microbiological methods of analysis
Notice
On November 4, 2023, Health Canada and the Canadian Food Inspection Agency pre-published in the Canada Gazette, Part I the Regulations Amending Certain Regulations Concerning Food Additives and Compositional Standards, Microbiological Criteria and Methods of Analysis for Food. The following document is proposed to be incorporated by reference into the Food and Drug Regulations as part of the proposal.
How to provide comments on this document: To learn more about this regulatory proposal, including how to provide feedback on this document, please go to Consultation on the proposed Regulations Amending Certain Regulations Concerning Food Additives and Compositional Standards, Microbiological Criteria and Methods of Analysis for Food.
Date published: November 4, 2023
Table of Contents
- Purpose
- Demonstration of equivalency
- Requirements for qualitative and quantitative methods of analysis
- Additional requirements specific to qualitative methods of analysis
- Additional requirements specific to quantitative methods of analysis
- Requirements for colony identification methods
Purpose
This document defines the performance parameters and sets out other requirements that shall be met to determine that a method is equivalent to a microbiological reference method, for the purposes of Division 30 of the Food and Drug Regulations.
This document does not replace existing method validation guidelines from Health Canada for microbiological methods of analysis.
This document is published and maintained by Health Canada and is incorporated by reference into Division 30 of the Food and Drug Regulations.
Demonstration of equivalency
To determine if an alternative method is equivalent to a reference method set out in column 2 of the Table of Microbiological Reference Methods for Food, that method shall be validated using procedures that will provide sufficient evidence to evaluate the performance of the method against its respective microbiological reference method using performance parameters described in this document.
Requirements for qualitative and quantitative methods of analysis
Requirements for selectivity studies
Inclusivity study
The ability of the method to detect a wide variety of strains representing the target microorganism (inclusivity) shall be demonstrated by:
- Testing at least 50 pure strains of the target microorganism, except for Salmonella methods for which testing at least 100 pure cultures of different serotypes of Salmonella is required.
- Selecting strains that cover the range of diversity of the target microorganism, such as biochemical characteristics, serotypes, phage types and geographical distribution.
Exclusivity study
The ability of the method to resist interference by cross-reactivity with non-target microorganisms likely to be found in the tested food (exclusivity) shall be demonstrated by:
- Testing at least 30 pure strains of non-target microorganisms, including:
- strains that are suspected to cause interference;
- strains naturally occurring in food tested; and
- strains closely related to the target microorganism.
Selectivity studies (inclusivity and exclusivity) can be omitted for methods such as aerobic plate counts and total plate counts, where the level of natural microorganism of a food commodity is measured.
Relevant food
The ability of the method to detect target microorganisms in foods typical of the samples to be tested, including foods that may present a challenge to the performance of the method, shall be demonstrated. A sufficient number of foods shall be tested, to have a proper representation of the diversity of that food.
Relevant strains
The ability of the method to detect target microorganisms shall be demonstrated using strains likely to be detected in the foods tested.
Relevant stress
The ability of the method to detect target microorganisms in a stressed state shall be demonstrated only when the manufacturing processes or conditions of the food are likely to cause injury to the target microorganism.
Relevant equilibration
The ability of the method to detect target microorganisms shall be demonstrated after the food (inoculated with the target microorganism in a stressed or unstressed state, as appropriate) has been stored at the normal storage temperature for that food, for a relevant period, as follows:
- Frozen food: at least 2 weeks at -18°C or less
- Refrigerated food: at least 48h at 2–8°C
- Food stored at room temperature: at least 2 weeks at 20–25°C
Additional requirements specific to qualitative methods of analysis
A qualitative method of analysis is a method whose result is either that the target microorganism is detected or not detected either directly or indirectly in a unit of mass or volume.
Inoculation levels
The ability of the method to detect target microorganisms shall be demonstrated using two inoculation levels. The low level of inoculation shall result in a fractional recovery of positive samples, which is as close as possible to 50% (acceptable range: 25–75%) and confirmed positive by the microbiological reference method. The high level of inoculation shall result in all or nearly all samples testing positive.
Co-inoculation
When detection of the target microorganism may be impeded by the presence of non-target microorganisms, the ability of the method to detect target microorganisms in the presence of non-target microorganisms shall be demonstrated.
Number of samples
The ability of the method to detect target microorganisms shall be demonstrated using a sufficient number of contaminated samples for each food. The number of samples shall provide high probability of detecting a difference in performance between the alternative method and the reference method.
Performance parameters
The method shall meet or exceed the following performance parameters when compared to the corresponding microbiological reference method set out in column 2 of the Table of Microbiological Reference Methods for Food:
- Sensitivity ≥ 98%
- Specificity ≥ 90.4%
- False negative rate < 2.0%
- False positive rate ≤ 9.6%
- Efficacy ≥ 94%
- Level of detection (LOD) of the method must be comparable to or exceed the lower limit of detection of the reference method.
Additional requirements specific to quantitative methods of analysis
A quantitative method of analysis is a method where the result is the quantity of the target microorganism in a unit of mass or volume, measured either directly, or indirectly, for example through colour absorbance or impedance.
Performance parameter
The method shall meet the following performance parameter when compared to the corresponding microbiological reference method set out in column 2 of the Table of Microbiological Reference Methods for Food:
- Strict equivalence between the alternative method and reference method covering the range of target microorganism concentrations set out in columns 5 and 6 of the Table of Microbiological Criteria for Food shall be demonstrated based on recognized statistical approaches.
Requirements for colony identification methods
A colony identification method is a method used to confirm the identity of target microorganisms that have been isolated as pure colonies on agar media.
Requirements for selectivity studies
Inclusivity
The ability of the method to detect a wide variety of strains representing the target microorganism (inclusivity) shall be demonstrated by:
- Testing at least 100 pure strains of the target microorganism, except for Salmonella methods for which testing at least 150 pure cultures of different serotypes of Salmonella is required.
- Selecting strains that cover the range of diversity of the target microorganism, such as biochemical characteristics, serotypes, phage types and geographical distribution.
Exclusivity
The ability of the method to resist interference by cross-reactivity with non-target microorganisms likely to be found in the tested food (exclusivity) shall be demonstrated by:
- testing at least 50 pure strains of non-target microorganisms, including:
- strains that are suspected to cause interference;
- strains naturally occurring in food tested;
- strains closely related to the target microorganism.
Performance parameters
The method shall meet or exceed the following performance parameters when compared to the corresponding microbiological reference method set out in column 2 of the Table of Microbiological Reference Methods for Food:
- False negative rate ≤ 1%
- False positive rate ≤ 2.0%
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