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Listen to this siteWednesday 16 May 2007
Note of third meeting, 2pm, 12 March 2007, 88 Kingsway, London.
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
David Lock Local Authorities Coordinators of Regulatory Services (LACORS)
Keith Lawrence ELANCO, and member of VRC
Matthew Sharman Central Science Laboratory (CSL), York – UK National Reference Laboratory
Jack Kay Veterinary Medicines Directorate (VMD)
Paul Neaves Independent specialist consultant in retail and food services
Food Standards Agency
Tim Foster FSA, Head of Primary Production Division
Chris Pratt FSA, Head of Hygiene Policy and Legislation Unit
Ana Miljkovic-Brake FSA, Pesticides, Veterinary Medicines and Biocides Branch
Geraldine Hoad FSA, Head of Dairy Hygiene Branch
Vincent Greenwood FSA, Pesticides, Veterinary Medicines and Biocides Branch
Sharon Young FSA, minutes
Apologies for absence
Phil Sketchley National Office of Animal Health
Neil Cutler National Farmers' Union and member of VRC
Eric Crutcher VMD
Welcome and update
1. The Group heard that the Commission’s Bowland Decision had been repealed following a vote in the Standing Committee on 21 February.
The repeal decision had been implemented throughout the UK. The revocation was on the basis that Member States (MS) had disposed of all Bowland curd cheese produced prior to last October’s decision.
2. At the same meeting, the Commission outlined a series of meetings to look into the issue of antibiotics in milk. These started on 2 March with a meeting with the European Dairy Association (EDA) and Eucolait; meetings with test kit manufacturers and National/Community Reference Laboratories would follow. The Commission will then take stock and liaise with MSs as necessary, which could be in May/June. Although there was no UK representative at the meeting with EDA, the Group was reassured that the UK industry would be involved in all EDA discussions on the subject.
3. The Group expressed some concern that the UK may not be able to influence discussions early enough. This would be borne in mind in the context of advising FSA on strategic handling matters.
Adoption of Agenda
4. The agenda was adopted without comment.
Minutes of 2nd Meeting and Matters Arising
5. The Group was content for the minutes to be published as drafted.
Action: FSA
6. The following matters arising are not covered elsewhere on the Agenda: Paragraph 2: David Lock was thanked for attending on behalf of enforcement bodies. The question of a Defra representative was still to be pursued.
Action: FSA
Action: Phil Sketchley
Terms of Reference (ToR)
7. The Group discussed whether pressing ahead with the development of guidance ahead of what the Commission may be planning would cause problems. It was agreed that by giving the matter serious attention through the Group, and by delivering on the objectives in the ToR, it gave the UK an opportunity to prepare a considered case and thus complement the work of the Commission.
8. It was suggested that it would be helpful if, based on their own contacts, Group members would keep the Group up to date with any developments, particularly in the EU, relevant to the work of the Group.
Action: All members
9. The Group agreed to remove the word 'level' from point 3 of the ToR and to place the ToR on the website.
Action: FSA
Guidance on Positive Results in Rapid Screen Tests
10. The Group discussed the format of the proposed guidance. It agreed the function of the Group was to provide advice to the FSA on what constitutes a positive result in a rapid screen test. The Agency would use this advice to put out guidance to stakeholders. The Group agreed that its advice to the FSA should go into more detail, including a glossary of terms, but should be generic and not recommend individual test kits.
11. The draft paper raised some detailed areas for discussion. In particular, the Group touched on the issue of trying to produce a positive control test and difficulties in doing this (for rapid beta lactam tests a negative control may simply indicate that the test hasn’t worked properly rather than any problem with the milk). Further discussion focussed on concerns that a negative result would only illustrate the milk has passed screening for the specific antibiotics the test was designed for and none of the rapid 10-minute screening tests on the market tested for a comprehensive suite of antibiotics. Furthermore, none of the tests currently worked at the MRLs for all the antibiotics they were designed for.
12. The Group agreed that the Commission’s Interpretive Note implied that any retest to verify an original rapid (10 minute) test result must be performed using the same test. Within this constraint, the guidance produced by the Group would consider whether there is scope for any flexibility.
13. It was agreed that it would be difficult to prepare the guidance within the confines of the meeting and, instead, guidance would be prepared by email. All non-FSA members of the Group agreed to be involved, with the Chairman co-ordinating the work to prepare guidance by Easter.
Action: Chair and Group members
Guidance on Procedures following and antibiotic test failure
14. The Group suggested some areas to be added to the draft framework document prepared by the FSA – the addition of individual animal testing, farmer quality payments system and silos at Item (4) and reference to HACCP.
15. It was agreed that the document should address a wide variety of scenarios, from on-farm testing of individual animals and on-farm processors to bulk testing at large processors. It should set out what procedures need to be in place in each scenario to test and dispose of milk which fails testing, the role of enforcement bodies in each case and what needed to be reported to whom. The role of VMD’s SARSS reporting should also be included. It was noted that most dairy herds will have been treated with antibiotics at some stage because of the high incidence of mastitis and so many producers would have procedures in place to test individual animals for antibiotic residues.
16. The Group concluded that a grid or table setting out different scenarios may be most appropriate.
Action: Chris Pratt to develop guidance for next meeting
17. It was noted that preparation of an Industry Guide relating to compliance with dairy hygiene requirements in EU law was currently being led by Dairy UK Ltd. It was suggested that any guidance emanating from the Group would need to be reflected in that Guide. A document provided earlier by Tim Hampton about managing antibiotics in the supply chain would be circulated.
Action: FSA
Correlation between test kits and commonly used antibiotics
18. The Group considered a number of papers from different sources which gave information on the antibiotics that various test kits were designed to detect, the MRLs of veterinary antibiotics and high level information on the quantities of antibiotic groups used in the UK.
19. There was general agreement that the papers were useful background information but only reinforced the Group’s view that no test worked specifically at the MRLs of all the antibiotics it was designed for, nor was any test able to detect all antibiotics in use. VMD were asked by the Chair if it were possible to get any information on the extent to which aminoglycosides were administered in mixtures with beta-lactams. Aside from this, the Group did not require any further information at this stage.
Action: VMD
20. The status of the documents produced for this item was clarified. The documents were considered as working documents for the Group’s information only, and it was noted that some information they contained had run out of date.
Prescription and use of antibiotics in dairy animals
21. Paul Neaves invited comments on his paper which was used at training courses and looked at issues such as types and classification of antibiotics, withdrawal periods, MRLS, testing and the various organisations involved.
22. It was suggested that the slide on withdrawal periods was changed to state that all veterinary medicines have MRLs, that CSL was added to the slide on statutory surveillance, and that some mention was made of the Microbiological End Point (MEP), ie the point where residues present below the MRL cease have any effect on gut flora.
Action: Jack Kay/Keith Lawrence to provide note on MEPs to Paul Neaves
Strategy Issues
23. It was considered likely that identifying any strategic issues would follow on from the proposed guidance. There was some discussion about the practicality of the regime the Commission has adopted, and that it appeared not to be implemented and enforced elsewhere in the EU. Ed Komorowski commented that industry was destroying milk with antibiotic levels below the MRLs, and questioned whether problems had been demonstrated with the previous arrangements. It was further noted that pasteurisation destroys beta lactams. It was up to the Group to come up with practical guidance under the current regime which set out the systems which should be followed when dealing with milk failing a rapid antibiotic screen test.
24. The Group agreed that statutory surveillance programme data from other MS on antibiotic testing were scant, and were not known to be published. Results from tests carried out under the UK surveillance programme are available online.
Action: Matthew Sharman to provide link to UK data
25. Group members were asked to be alert to information from other MS, particularly in relation to confirmatory testing of milk which has failed a rapid (10 minute) antibiotic screen test.
Action: All members
Horizon Scanning Issues
26. Again, it was considered that horizon scanning to identify issues such as gaps in evidence would come out of work on the proposed guidance.
Other business
27. There is now a website for the work of the Group: http://www.food.gov.uk/foodindustry/farmingfood/vetmeds/testingmilk/
Group members reported some difficulty in finding this through the FSA's main search function.
Date of next meeting:
28. The next meeting will take place in week commencing 23 April 2007, members will be canvassed for appropriate dates.
Action: FSA
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