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Listen to this siteWednesday 7 March 2007
Note of first meeting 10.30 am, 21 December 2006, at Aviation House, London.
Tim Foster FSA, Chair, Head of Primary Production Division
Chris Pratt FSA, Head of Hygiene Policy and Legislation Unit
Geraldine Hoad FSA, Head of Dairy Hygiene Branch
Ana Miljkovic-Brake FSA, Pesticides, Veterinary Medicines and Biocides Branch
Paul Brantom Independent consultant, Vice-chair of VRC and ACAF
Jack Kay VMD
Ed Komorowski Dairy UK
Tim Hampton Milk Link
Neil Cutler NFU and VRC member
Paul Neaves Independent specialist consultant in retail and food services
Apologies for absence
Eric Crutcher VMD
Matthew Sharman CSL
1. Tim Foster thanked participants for agreeing to sit on this group, whose broad remit would be to advise the Agency in relation to the scientific and practical issues associated with antibiotic testing of milk in preparation for discussion of these matters in Europe. Tim explained the background issues, which centre on the Bowland case, and with which most were familiar.
2. It was further explained that, in the interests of independence, the Agency would intend to facilitate, not drive, the work of this group. The group would be asked to establish its own terms of reference at the second meeting, informed by the general discussions at this first meeting. The Agency would, however, provide a draft for comment. Tim Foster thanked Paul Brantom for agreeing to take the chair at future meetings.
Action: FSA
3. Group membership was discussed and it was agreed to invite Phil Sketchley from NOAH onto the group. It was also agreed to approach LACORS to field a representative to cover enforcement aspects, and that a representative of the Dairy Hygiene Inspectorate could be co-opted (as could any other expertise) according to need.
Action: FSA
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4. It was agreed that the minutes of each meeting should be placed on the FSA website. Other information may be put on, too, subject to discussion.
Action: FSA
5. It was noted that the AOAC Research Institute in the United States has done a lot of work on testing and validation of certain antibiotics in milk. The group would need to consider how far this should be researched.
Matters arising
6. A range of other information was mentioned and or discussed and it was agreed to circulate copies to members to inform future discussions. This information included work of FSAI, the Hannah Institute and the AFSSA CRL validation of the Beta Star test for beta lactams. Members were also familiar with other evaluation work, such as on the COPAN test. This may be subject to commercial release constraints and approaches would be made to see if this work could be released to the group.
Action: FSA and members as appropriate
7. Paul Neaves briefly outlined the work of the International Dairy Federation on evaluating testing methodologies for ABs in milk. The group would need to consider whether it wished to interact with IDF, and if so, how, as part of its work.
Matters arising
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8. Although the current guidance, which in practice gave effect to the AB policy change in the UK, had served its immediate purpose, it was clear from stakeholder reactions that fuller guidance would be needed. This would need to address issues such as which food business operator is responsible for notifying the competent authority of an antibiotic test failure, the relevant competent authority and its role on receipt of such notification, and what ensuing actions should be expected of producers/processors in the event of an AB failure. It was also agreed that there is a need to clarify what constitutes a negative result in a rapid (10 minute) antibiotic test, bearing in mind practical and reliability issues associated with such tests. The group should consider the issues as well as the best means to disseminate agreed guidance (such as from FSA or Industry Guide under Reg 852/2004). Ed Komorowski and Tim Hampton would put some ideas on paper.
Action: Ed Komorowski and Tim Hampton
Matters arising
Back to top9. There was some background discussion about current tests and testing regimes. Beta Star is the main test kit in current use in the UK. Charm MRL and Snap are also used. All are rapid 10-min test for β-lactams. Milk buyers generally use Beta Star on collection. Current UK procedures are to use two Beta Star tests. Delvo and Copan are microbial inhibitor tests. Copan is the national reference test in France. DELVO is also used on farm by producers for specific purposes (on treated cows' milk) and by milk buyers for the Quality Payment Scheme.
10. It was mentioned that testing frequency in other member states is generally less than the UK. Tests are carried out every week in UK, while in other MSs only 2-3 times a month.
11. Tim Hampton would circulate some MDC data about AB testing statistics. Members were advised of the commercial nature of this information and requested to handle it accordingly.
Action: Tim Hampton
Back to top12. The group was informed that BRC audits at cheesemaking companies in France and Germany had found the new EU AB milk policy was not being implemented. Protocols showed that milk failing a rapid 10-minute screen could be used to produce cheese, providing it had passed a subsequent microbial inhibitor test. This practice was being recorded as a non-conformance in the audit. It was too early to say what repercussions this audit outcome would have, both in industry and with the regulators, and the group would wish to remain abreast of developments.
Matters arising
13. The European Dairy Association has written to the European Commission confirming the use of this '2 step procedure' and requesting how they should now be operating for best practice. It was not known how the Commission would respond. The group will wish to keep in touch with developments.
Matters arising
14. Tim Foster indicated that the FSA would need to consider lobbying the Commission in the light of this information and ensuing developments.
Action: FSA
Back to top15. The question was raised as to how veterinary medicinal treatment withdrawal periods are set, and whether withdrawal periods remain valid in the light of testing sensitivity improvements over time. No particular conclusions were reached. The group may wish to reflect further on this.
Matters arising
16. It was noted that Commission Decision 2002/657 does not specify validated tests to determine which individual antibiotics are actually present in the milk, and at what levels. Instead, it lays down performance criteria for any methods that are used.
Back to top17. It was commented that the UK's statutory testing of milk for veterinary medicine residues rarely finds antibiotic residues.
18. The three UK National Reference Laboratories in this area are co-ordinated by an NRLs-liaison group led by VMD and chaired by Jack Kay. There did not appear to be similar co-ordination in other member states.
Back to top19. To be confirmed: probably in late January 2007. The intention is to have two or three meetings over a short space of time, that is, within 2-3 months.
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