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Minutes of the Molluscan Shellfish Safety Committee - 16th March 2023

Date: 16/03/23
Location: Videoconference 

  • FSAI: David Lyons (chair), Karen McCullagh (KMcC)
  • SFPA: Aileen O’Sullivan, Gary McCoy, Susan Coughlan, Sarah Buckley (SB)
  • MI: Conor Duffy, Sinead Keaveney (SK), Pat Costello, Dave Clarke, Annaclare McCarthy, Agnieszka Rupnik, Frank Armstrong, Amanda Curtin
  • IFA: Teresa Morrissey, John Harrington, Colin Whooley, Willie Murphy (WM)
  • BIM: Vicky Lyons, Joanne Gaffney (JG)
  • EPA: Liam O’Suilleabhain
  • HSE: Paul Hickey
  • Industry: Pat Mulloy (PMu), Patrick Murphy, Tristan Hugh-Jones (THJ), Kian Louet-Fiessler (KLF) 
  • Apologies: Finian O’Sullivan (FO’S) Brian Murrinane (BM)

1.    Minutes of previous meeting (13th October 2022)

DL noted that Christine King had moved within FSAI and was no longer working in the marine and seafood areas.

Item 1a

PMu asked requested an update on sample feedback, particularly in relation to Shellsan results back to sampler. SFPA advised that results go out on a monthly basis to ports and FBOs, and the possibility for wider distribution is currently under review. An update will follow in due course.

2.    Standing items

a.    Update on Shellfish Monitoring Coordination (SFPA report)

GMcC updated the meeting on sampling activity thus far for 2023 and provided an overview of the 2022 Classification Monitoring Programme (see attached).

CTB Sampling Arrangements

PMu queried the current arrangements for sampling CTB. The current arrangements are not facilitating production because they are not generally workable. Timely results are needed to ensure safe production. GMcC replied that decisions around sampling arrangements needed to involve the local port as well as SFPA HQ, and that the concerns expressed at the meeting would be relayed, with a view to seeing if arrangements could be varied. SC mentioned that the issue fell under her remit and undertook to review the arrangements and follow up directly with PMu and IFA-Aqua. 

Queries were raised about the next sample to be taken and submitted. The arrangements for this would also need to be reviewed. SFPA undertook to discuss and provide a response to IFA-Aqua as soon as possible. JG volunteered BIM’s availability to help with any potential resolution to the issue.

b.    Toxicity Summary Report including Production Area Closures (MI)

PC gave the MI’s toxicity report

DC provided an update on proposed changes to the National Phytoplankton Monitoring Programme. Staffing changes necessitate water samples previously handled by the Bantry Laboratory being routed to Galway for examination and analysis. The effective date of this change will be the 17th April 2023. Industry and other stakeholders have been advised, and the measure has been communicated to both the SFPA and the FSAI.
JH acknowledged the good work done over the years by the Bantry lab and expressed the hope that any change would be temporary.

3.    Microbiology and virology update

a.    Norovirus mitigation measures (KLF/CO)

KLF provided a presentation on the work undertaken on his sites and their experience with norovirus mitigation measures. Norovirus had declined as an issue during the pandemic but there had been noticeable increase as public health measures were eased. 

THJ commended the work done and acknowledged the importance the support of the MI played in helping with the management of norovirus. THJ offered to share their experience and particularly the differences found between native and rock oysters, with rock oysters tending to accumulate more viruses than native oysters. 
SK noted the observation regarding rock oysters was interesting but further work would be needed to get more insight into the reasons why. It was also noted that preventing pollution was by far the best way of dealing with norovirus, rather than management of it.

KLF suggested that more sharing of data between producers would help everyone learn quicker and improve practices in the area.

AO’S updated the meeting on proposals on European Commission’s proposals on norovirus limits and other developments on the topic.

b.    Sanitary surveys and sampling points / RWB Sampling Points

GMcC provided some background on Roaring Water Bay (RWB). A recent sanitary survey recommended the removal of existing sampling points in favour of new sampling points. The survey also recommended variations to the boundaries of the production areas.

TM queried the establishment of two representative monitoring points (RMPs) and why the previous point was no longer considered to be representative. GMcC explained that the survey suggested that given the area’s topography, inputs etc two RMPs were justified but that they may be rationalised to one if future data supported such a move. Data, as received, will be reviewed. Once sufficient data has been accumulated then further decisions will be made.

TM thought better positioning of the RMPs was needed to better reflect production in the area.

CW expressed concern about the representativeness of the two RMPs. The existing sampling point has served the area well and the experience of producers over the years bears that out. Furthermore, that work needed to be directed towards maintaining the areas “A” status given the impact losing it would have on local production. The survey was recognized as a useful piece of work but the application of it was causing concern, especially on the question what is fair in the circumstances.

JH suggested that greater use of hydrographic surveys could help better inform sanitary surveys and the delineation of production areas rather than using arbitrary, geographically prominent points. DL pointed out that there would be a cost, and potentially significant cost in the context of a sanitary survey, to carrying out hydrographic work. JH answered that they were often not that expensive, especially where all that was required was a desk-top survey using existing data.

CW suggested that sampling should continue at the old sampling point, as well as the new RMPs, to allow a valid comparison to be made. He also suggested that RWB not be split, as there was no need in the industry’s view to do so.

c.    Preliminary Classification

A query was raised in relation to the Gearhies site. The site was previously classified, the area subsequently went dormant before its classification was removed. The area is now effectively unclassified, despite being previously classified. A gatherer is now looking to bring the area back into production, but the prevailing position seems to be that a sanitary survey would be required, despite the requisite number of samples necessary to obtain a preliminary classification being submitted. Clarification on the need for a sanitary survey was requested by TM.

GMcC provided the legislative context, noting that sanitary surveys are required prior to classifications being issued. This point is also covered in the relevant Community Guide to Good Practice. TM asked why this had not been brought to producers’ attention much earlier? 
GMcC noted that there had been communications issued in relation to sanitary surveys. AO’S noted that the requirements relating to sanitary surveys were contained in legislation from 2019. AO’S offered to shared the relevant legislation.

DL noted that the requirement for a sanitary survey went back beyond 2019, but that the 2019 legislation provided more detailed requirements. DL suggested the issue be discussed “off-line” with relevant interested parties. 

TM directed the meeting’s attention towards the requirements set out in the Irish Code of Practice on Microbiological Monitoring of Production Areas, relating to preliminary classifications, which she suggested the Gearhies site was meeting with the submission of the required samples.
SK reminded the meeting that sanitary surveys were intended to inform the location of representative monitoring points for sampling.

ACTION:- DL to arrange further discussions with SFPA, MI and IFA-Aqua

4.    Draft Shellfish Gatherers Registration Document

GMcC shared details of the SFPA’s proposals for changes to the Shellfish Gatherers Registration Document to reflect recent legislative changes to allow for intermediate operators. GMcC showed an example of the new document and highlighted some new sections now included in the document.

The content is intended to reflect the requirements of the legislation with a layout that will be familiar to gatherers in Ireland.

VL asked what the status of the new document was. GMcC explained it was at an advanced stage and would be rolled out very soon. She further suggested some additional communications might be needed so gatherers would know when and how to use them, to avoid and minimise confusion.

TM asked if the guidance notes associated with the new GRD been updated to reflect comments submitted by IFA-Aqua? GMcC as far as possible details are included to help fill out the forms but the format limited the amount of information that could be provided. A further comprehensive guidance document will be published in due course.

5.    AOB

a.    BIM/ IFA Aquaculture Oyster Industry Workshop 2023

Details on the upcoming a.    BIM/ IFA Aquaculture Oyster Industry Workshop 2023 were provided to the meeting.