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Listen to this siteWednesday 26 September 2007
Meeting held in Conference Room A, Aviation House, Kingsway, London
Expert Group
Paul Brantom, Chair – Vice Chair of Veterinary Residues Committee (VRC) and member of the Advisory Committee on Animal Feedingstuffs (ACAF)
Ed Komorowski – Dairy UK Ltd
Tim Hampton – Milk Link, Quality Standards Manager
Jack Kay – Veterinary Medicines Directorate (VMD)
Paul Neaves – Independent specialist consultant in retail and food services
Phil Sketchley – National Office of Animal Health (NOAH)
Food Standards Agency
Tim Foster – FSA, Head of Primary Production Division
Chris Pratt – FSA, Head of Hygiene Policy and Legislation Unit
Geraldine Hoad – FSA, Head of Dairy Hygiene Branch
Chelvi Leonard – FSA, Dairy Hygiene Branch, minutes
Karen Pratt – FSA, observer
Apologies for absence
Neil Cutler – National Farmers’ Union and member of VRC
Matthew Sharman – Central Science Laboratory (CSL), York – UK National Reference Laboratory
Keith Lawrence – Elanco, and member of VRC
David Lock – Local Authorities Coordinators of Regulatory Services (LACORS)
1. The Group was informed that the FSA had attended a meeting with Thierry Chalus from the European Commission to discuss the progress both FSA and DG SANCO were making on the issue of testing of milk for antibiotic residues. The Commission had begun by explaining that due to the ongoing Bowland Dairy Products Ltd court case they were constrained in what they could discuss with Member States. They outlined the meetings they had hosted, or had planned, with the dairy industry, manufacturers of antibiotic testing kits, National Reference Laboratories (NRL) and the Chair of the International Dairy Federation (IDF) Standing Committee on Analytical Methods for Additives and Contaminants. The Commission had said it wishes to share the outcome of these discussions with other Member States but re-emphasised the constraints of the Bowland court action. The Commission was aware that in a number of other Member States the result of a screening test is confirmed using a second, different, screening test. However, the situation was viewed as being different to the Bowland situation as the milk was not being placed on the market between the tests. Mr Chalus agreed there is a need for test kit manufacturers to meet the market need for tests that quickly and accurately assess whether there is antibiotic present above the maximum residue limit (MRL).
2.
EK informed the Group that the European Dairy Association (EDA) will be sending a paper to the Commission on current practices in the European Union (EU) industry.
EK stated that in many Member States (MS) the result from the initial rapid antibiotic test is confirmed by the Delvo® Test and if this test fails then the milk is rejected. The Chair said it would be useful to have this evidence documented.
PN confirmed that this was the practice discussed at the IDF meeting. EK agreed to circulate the letter to Group members when available.
Action: Ed Komorowski to circulate the EDA letter
3. GH informed the Group that the Animal By-Products Regulations (EC) No 1774/2002 were under review in the EU with a focus on reducing administrative burdens and identifying problem areas, and that they are currently undergoing consultation. Defra was in the process of preparing a response and it was agreed that it would be useful to circulate a copy of that response to Group members.
Action: Geraldine Hoad to obtain the Defra response and circulate
Item ii) Adoption of Agenda
4. The agenda was adopted without comment.
Item iii) Minutes of 4th Meeting and Matters Arising
5. The minutes were agreed in principle, pending addition of the IDF meeting at para. 5 and the addition of 'veterinary medicines mark of authorisation holder (MA holder)' at para. 18, point 3.
CP clarified that the drafting notes would be removed before placing the minutes on the website.
Action:
Chelvi Leonard to amend and circulate the minutes
6. Several Action Points from previous meetings were reviewed:
Action point 39 : PN gave a verbal report on the IDF Meeting in Munich. The week began with presentations on analytical strategies and two case studies were discussed - one being Bowland. PN had presented a short history of the case - about which very few delegates from around the world had heard. The view among the audience was that a positive initial rapid antibiotic test may be repeated using the same method. In the event of a positive result in the repeat test a different confirmatory test may be undertaken. The result of this test may then be used to make a decision about the milk. Delegates wanted this approach to continue. Some participants at the IDF meeting indicated that when milk was rejected by one buyer, it may sometimes be sold on to another buyer. It was indicated that in France, milk is tested by independent laboratories; the COPAN test is used and if the tanker fails the test, the milk is sent for incineration. It appeared that most use Beta Star or SNAP followed by Delvotest®.
PN gave a brief summary of the presentation by Wim Reybroeck from the Institute for Agricultural and Fisheries Research (ILVO) in Belgium. In Belgium all milk tankers and bulk tanks are tested as required by their regulations and there is a system for farm investigation in cases of antibiotic failures. The whole regime is funded by the industry and Government. Mr Reybroeck had indicated that in Belgium the main cause of antibiotic failures is deliberate tampering. The rate of antibiotic milk failure is between 0.1 – 0.2 % for ex-farm, bulk tank samples.
Action point 43
:
EK reported on the two meetings he had had with various manufacturers of antibiotic test kits. The purpose of these meetings was to discuss the availability of controls for use with the kits.
Most of the kits have some form of control to validate the result (be it positive or negative control).
One kit manufacturer did not agree with the need for controls and would be explaining the reasoning for this in writing in due course.
A point of emphasis from the meetings had been that users should follow the kit manufacturers’ instructions. EK would circulate a note of these meetings to the Group Members.
Action: Ed
Komorowski
Action Point 46
:
PS reported on a meeting of the Danish Dairy Association (DDA) which took place on 3rd May 2007.
The Delvo® system is used and if a positive antibiotic result is obtained, the milk is retested.
The milk producer is fined if a positive result is obtained. The failure rate in Denmark is 0.1% (where 80% of these are related to accidents or errors in the use of veterinary medicines but 4% were found to be below the MRLs when positive results were confirmed). The DDA recommends increasing the withdrawal period for animals being treated with antibiotics to lower the milk failure rate.
PS will circulate the data from the meeting to the Group.
Action: Phil Sketchley
Action Point 52 : In the absence of Matthew Sharman, CP provided a brief update on the Community Reference Laboratory (CRL)/NRL meeting with the European Commission. There had been poor attendance by MS at this meeting. In most MS, Beta-lactams are the focus of antibiotic testing. The CRL had suggested working towards producing a test that would allow a suite of residues to be tested for at the same time, however those present were sceptical about the feasibility of this. TF added that the NRLs meeting had focused on testing methods used by national control bodies in their national monitoring programmes rather than on day-to-day testing by industry or the enforcement bodies. It was noted that the analysis methods used were different across MS.
Action Point 47 CP also reported that Neil Cutler had sent a message to say he had not yet heard from the Committee of Professional Agricultural Organisations in the European Union (COPA) about their views on testing milk for antibiotics, but he would be pursuing this.
Back to top7. The first draft of this paper had been revised and the Chair requested that the discussions should concentrate on the new additions with a view to finalising the paper at this meeting. The following comments were made:
Action: Geraldine Hoad to amend and circulate Guidance and review consistency of the terminology in the two papers.
Back to topTo develop guidance on the procedures to be followed for the reporting of antibiotic test failures and on the actions to be taken by industry and the enforcement authorities as a consequence of an antibiotic failure
Minor changes to the text were agreed and would be incorporated in the final document.
Action: Chris Pratt to amend and circulate the guidance
Details of the form MLA 2, used for reporting breaches of the MRLs under the Suspected Adverse Reaction Surveillance Scheme (SARSS), would be included.
There was a discussion of the term 'placing on the market' and its meaning in the legislation. In this context there was discussion of two scenarios:
The first is where private testing of milk by producers in the course of day-to-day operations reveals that milk contains antibiotics, and such milk is disposed of at the farm. In this case it was considered unnecessary for AHDH to be notified as this is normal husbandry practice in conformity with requirements. However, it was considered to be good practice for producers to record testing and any consequential actions in the interests of being able to demonstrate compliance.
The second scenario, which is more complex, is where purchasers/processors test samples taken from tankers arriving at their premises (ie the milk has already left the farm of origin but has not yet been accepted for purchase) and these show positive for antibiotics. In this case it was considered that the purchaser/processor should notify the local authority (LA) of the failure as the LA is responsible for monitoring disposal in accordance with ABP legislation. This route of notification would apply equally if a test on a purchaser/processor silo yields a positive antibiotic test result. In the context of ensuring any necessary corrective actions by the producers whose milk had led to the failed antibiotic test, it was noted that the purchaser/processor will have notified the producer of the failure (whether via the collector or directly) because of the arrangements for paying for the milk. In turn the producer should be responsible for notifying AHDH, who would then take the appropriate follow-up action.
DEFRA would be consulted on issues concerning disposal of antibiotic contaminated milk.
Action: Geraldine Hoad
9. There was an exchange of views about the frequency of reporting antibiotic failures in milk to the competent authorities. TH suggested that this information could be supplied monthly (as more frequent notifications would be difficult for purchasers to administer), and that a standard notification letter could be set up. It was questioned, however, whether monthly notifications would potentially delay AHDH’s follow-up action. It was agreed that the FSA would need to reflect further on the frequency of notification taking account of the need to consider risks and proportionality, and that the views of the competent authorities (LAs and AHDH) should be sought. This would be done as part of the stakeholder consultation.
10. The Chair suggested that details of MRL breaches could be placed on the Veterinary Residues Committee (VRC) website. It was noted that the Statutory Surveillance Programme results are routinely published on the VRC website, and agreed that reference to this would be included in the procedures guidance.
Back to top11. It was noted that issuing the guidance would keep stakeholders abreast of developments in the UK. Otherwise, it was considered premature to consider strategy in advance of knowing the European Commission’s plans. The importance of continuing industry liaison with the European Commission was reaffirmed.
Back to top12. No immediate horizon scanning issues were identified. It was agreed that the Group would finalise both guidance documents by e-mail. The Chair and members agreed that the Group should be put on a virtual footing for the time being, with a view to reconvening as necessary, for example when discussions in Europe are about to commence.
Back to top
13. The final layout of the Milk Quality Forum’s poster giving practical guidance on avoiding antibiotics in milk was discussed.
PS asked if the FSA would be willing to have its logo on the poster and TF agreed (pending the agreement of Communications Division).
Action: Geraldine Hoad
14. In line with the decision reported at paragraph 12 above, no date was set for a further meeting. It was noted that members of the Group are free to request discussion of specific issues at any time, and that further meetings could be convened as appropriate.
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