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Minutes of the Molluscan Shellfish Safety Committee - 21st June 2023

Location: Videoconference

  • FSAI: David Lyons (chair), Una Walton (Minutes)
  • SFPA: Gary McCoy (GMcC), Susan Coughlan, Sarah Buckley (SB) Emma McLoughney
  • MI: Conor Duffy (CD), Sinead Keaveney (SK), Patrick Costello (PC), Joe Silke, Jonathan Kelly
  • IFA: Teresa Morrissey (TM), John Harrington (JH),
  • BIM: Vicky Lyons, Joanne Gaffney (JG), Patricia Daly
  • HSE: Paul Hickey
  • Industry: Pat Mulloy (PMu), Patrick Murphy (PM), Tristan Hugh-Jones (THJ), Conor Graham, Sean Gallanagh, Conor Graham
  • Irish Water: Charlotte Picard
  • FSA NI: Jenny Duckett
  • Apologies: Carla Mcneil, Aileen O’Sullivan (SFPA), Dave Clarke, Patrick Caffey (HSE), Peter Gaffney, Richard Donnelly (BIM), Finian O’Sullivan

1. Minutes and matters arising from the last meeting (16th March 2023)

DL introduced Una Walton who recently joined the Enforcement Policy Team as Christine Kings replacement.

PM raised concern over sanitary survey sampling and the legal definition of classification of a bay. DL advised this will be discussed during Roaringwater bay agenda point.

PMu acknowledged the SFPA for coming up with a workable solution for the sampling in Castletownbere Harbour.

DL noted that further offline discussions taken place with Industry re changes to the National Phytoplankton Monitoring Programme.

Since last meeting, the SFPA participated in IFA BIM Industry Workshop providing more information and clarity in terms of the changes to the shellfish registration document.

2. Standing Items

a. Update on Shellfish Monitoring Co-ordination (SFPA)

GMcC provided a Microbiological Monitoring update and overview of Q1 2023 classification monitoring program results, Biotoxin Sampling Frequency, and the 2023 Sanitary Survey Programme (attached).

  • Annex 1 (attached) gives indication of the Q1 2023 results, a total of 383 microbiological samples were taken. Sheet 2 provides a breakdown of monthly figures from Jan to May 2023 taken for each Port area. 665 samples taken so far.
  • Annex B (attached) provides log of elevated results. SFPA detected 14 (2.1% of all results) out of range results between Jan to May 2023. Similar trend noted to previous out of range results recorded in 2022, 2021, 2020 during the same period. GMcC highlighted that out-of-range results can be due to unusual weather events or at local instance giving rise to spikes and contamination appendicular times.
  • The SFPA will conduct 10 more sanitary surveys of existing shellfish production areas over the next 2 years. All planned surveys are listed in report.
  • The 2023 Review of Shellfish Classifications meeting will be held online on the 28th of June and GMcC thanked everyone who provided submissions which are under review. TM noted preference to have this meeting in person going forward.

Representative Monitoring Points

PM informed the meeting that external consultation was sought to review the interpretation of the regulation regarding sampling and monitoring of the bay. There is a concern that introducing new representative monitoring points based on the sanitary survey will change the risk profile of the area negatively, increasing the chance of an event being missed, which could lead to a risk to consumer health. DL advised that the samples are taken to characterize the water body and are not treated as a risk management tool.

Roaringwater Bay – sanitary survey & RMP (IFA)

TM raised 3 points on behalf of producers in Roaring water Bay.

  • Hydrographic Surveys and their role in Sanitary Surveys:

GMcC informed that SFPA contacted Aquafact to discuss possibility of use in identifying RMP locations, however, there’s a significant cost associated and budget for 2-year tranche already in place. Further discussions to continue to look at different approaches to determine RMP locations such as reviewing salinity data. JG acknowledged cost of Hydrographic Surveys and suggested reaching out to the Marine Institute to inquire about the West Coast Model.

Action: DL to discuss with Marine Institute about potential modelling.

UPDATE: SFPA reached out to the MI regarding hydrographic surveys however, there is no local data available for Roaringwater Bay. SFPA is exploring alternative means to obtain salinity data in that area.

  • Market size mussels from RMP and stock limitations:
    GMcC advised that there is scope in the guidance that allows for taking samples within 200 meters of the RMP area if there aren't market size mussels in the RMP area. Suggested having a further discussion with Castletownbere and Roaringwater Bay on this topic. TM emphasised the point that if there are no market size mussels within 200 meters of the monitoring point to sample, how does that point represent the bay.
  • Old sampling locations:
    GMcC noted that the previous RMP location was there for the last 30 years, and the purpose of the sanitary survey is to identify the most representative monitoring points in a production area. The report received from Aquafact determined that RMP1 and RMP2 were likely more representative of the production area. The use of the old sampling point could cause conflicting issues down the line as this point was not identified as the most representative point.
    DL highlighted that using the old sampling point would use up lab capacity, and the sampling point can be varied depending on the availability of stock. It is not unusual in sampling programs to have a degree of geographic flexibility as to where the sample is taken. Using the data from the old sampling location increases the potential for bringing in data that can confound future decision-making.

JH emphasised the need for presentation on the broader classification of a bay which includes selection of sampling points part of which includes sanitary survey. DL agreed alternative perspectives beyond what’s required in the legislation and guidance can be looked at in the session.

Action: DL to organise a session on sanitary surveys and classification to provide clarification on the process and discuss potential scenarios.

UPDATE: Suitable date and time being arranged.

SK provided an environmental perspective on some issues with shellfish production areas. The Shellfish Waters Directive is under the responsibility of the Department of Housing, Local Government, and Heritage. There is a delay in terms of the Shellfish Waters Directive being subsumed by the Water Framework Directive, which has not taken place yet. The Department of Housing is currently undertaking a process to look at how they can integrate the Shellfish Waters Directive under the Water Framework Directive, and several agencies are providing them with information on that.

JG suggested that EPA should attend this meeting going forward as they have a role. DL will consider how to engage with EPA more effectively.

Bantry Gearhies – pre-classification (IFA)

TM requested clarification on a number of points relating to Bantry Gearhies such as if data that's 12 months old be used and if stock can be placed on site pre classification.

DL advised that the data can be used and wouldn't be excluded based on time but excluded on the basis of where the samples were taken from in relation to the RMP. Data that is less than 3 years old and originating from the vicinity of the RMP could, potentially, be used to inform preliminary classifications going forward.

DL noted that the second question should be answered by Aquaculture Licensing as to whether they would allow shellfish to go out under the license, even though the area isn’t listed as a production area. The requirement is clear in the legislation that a new classification requires a sanitary survey before it can be issued, and classification needs to be in place or at least a preliminary classification before the area can be listed as a production area. At this point, it would come under the supervision of SFPA, and harvesting and all the other activities related to food production can take place.

Gearhies Boundaries

JG suggested that the extent of the proposed Gearhies area should be reviewed. This could expedite this process while not prejudging the outcome of the sanitary survey. DL agreed there’s an opportunity and that the new Gearhies site doesn't have to map to the same arrangement previously. The boundaries of all production areas are available to be discussed and modified to reflect what goes on in terms of production and producers are welcome to submit a proposal on this.

PM raised concerns around the methodology of picking a sampling site based on the contaminants from the shoreline. DL advised there are arrangements within the guidance to allow for the fact that if a RMP is identified and there aren't shellfish in the immediate area, that there is flexibility such as the 200-meter allowance. SK offered technical perspective that when it comes to a representative monitoring point, the location of where the shellfish are grown is considered. The monitoring points are always within where the shellfish are grown.

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

PC gave the MI’s toxicity report.

  • PC advised of closure in Youghal bay for DSP and a management cell closure in Castlemaine Harbor. This management cell decision was made on the 9th of June due to samples of C.gigas from research project being twice the regulatory limit and assigned a closed pending status for all species in the area.
  • PC advised sites around the West and Northwest Coasts sampled to highlight levels of AZA still being observed and as a trend the levels of the Azadinium are still being identified in the phytoplankton samples and baseline levels of AZP observed in chemical testing.
  • No samples tested above regulatory levels for DSP until week 19 at Killary Harbour. In week 23, Spisula solida from Youghal Bay tested for 0.24 μg/g and levels of DSP concentrations observed in the SW at Inner Bantry Bay sites.
  • No ASP events detected this year. Some levels observed in samples from the West and the Southwest for the last couple of months. The phytoplankton is complementing the shellfish sampling that is still there in the water which is below regulatory levels.
  • PC advised there's a management cell in place for Castlemaine Harbor, and this was as a result of the complimentary work done on the PSP Safe Project, which showed results above the regulatory limit. Results awaited this week. The phytoplankton jumped up between the 15th to 29th of May and then after that levels rose in the flesh.

TM raised concern about making management cell decisions based on research samples and running the 2 programmes in parallel. PC noted it a good thing to compliment the National Monitoring Programme particularly in this bay with this serious toxin. CD highlighted that it shows the variability of PSP in the Bay and it's the information has been shared with the management cell and they can decide what to do with the results.

Processing Shellfish

CD reminded the industry of the risk when putting a processed product on the market that contains lipophilic toxins present below the regulatory limit. There is still a risk that the other analogs present can be converted back into the regulated toxins during processing. There are 50 plus analogs with different toxicity rates, and only three are regulated. For example, for DSP and their esters, the processing of shellfish increases the extraction efficiency of these toxins and can lead to an increase in toxin levels. The industry needs to be aware of this as it may pose a risk to their product, especially if it's exported and tested abroad.

PM queried if a precautionary approach is taken to the regulatory level set and if someone would get sick if they ate shellfish at the current regulatory limit. CD informed that EFSA carried out a review of the limits for all the regulatory toxins and recommended they should be reduced. CD is in agreement with the Commission's view that the current regulatory limits give adequate protection to the consumer. CD noted that the level for PSP is high, and they have recommended a lower level. This feeds into the management cell decisions discussed earlier in the meeting.

3. Microbiology and Virology

No update.

4. Tracefish (Conor Graham, ATU)

CG presented presentation to explain Trace-Fish project.

CG is leading this project in Atlantic Technological University in Galway. This project is regarding the development and application of traceability tools for Irish shellfish and fish that are of economic and conservation concern.

PM queried if the project samples processed product. CG advised that processed products are not sampled, however this is something that could be looked at down the line.

5. AOB

a. Inorganic Arsenic (IFA)

TM advised that the European Commission is seeking to set a threshold for inorganic arsenic in all foodstuffs, not just seafood. The Dutch authorities are collecting more data to establish a threshold for shellfish. CD advised that there is data on arsenic available in the Marine Institute, and to put in a data request through the Marine Institute website.

b. Shellfish Safety Workshop 17th October 2023

Programme and agenda to follow. SK confirmed the workshop is an in-person event at the Marine Institute.