Skip to main content

Minutes of the Molluscan Shellfish Safety Committee - 9th November 2023

Location: Videoconference 

  • FSAI: David Lyons (chair), Una Walton (minutes)
  • SFPA: Emma McLoughney, Aileen O’Sullivan (AO’S), Michelle Moloney (MM), Sarah Buckley, Susan Coughlan, Niall O’Rahelly
  • MI: Patrick Costello (PC), Dave Clarke (DC) Sinead Keavney (SK), Felix Sproll, Conor Duffy (CD)
  • IFA: Teresa Morrissey (TM), John Harrington (JH), Finian O’Sullivan (FO’S)
  • BIM: Vicky Lyons
  • Industry: Patrick Murphy (PM), Kian Louët-Feisser (KLF) Dean Murphy (DM), Ciaran McGonigle (Loughs Agency) 
  • Irish Water: Charlotte Picard (CP)
  • HSE: Peter Gaffey

Apologies: Joanne Gaffney (BIM), Richard Donnelly (BIM), Tristan Hugh-Jones, Pat Mulloy, Carla McNeil (Irish Water)

1. Minutes and matters arising from the last meeting (17th August 2023)

Item 2b Bantry Lab: 

FO’S questioned whether Bantry lab samples constitute 7-10%, and DC clarified around 7 out of the 75 weekly samples are from the Bantry region.,. DC noted that the figure can vary from week to week.

TM asked about the recruitment for the Scientific and Technical Officer (STO) position in the phytoplankton laboratory and the effectiveness of mitigation measures and training. 

DC explained that there was a temporary manager position opened between an employee leaving and the new recruits joining to ensure the smooth operation of phytoplankton monitoring. The new analysts are trained and deemed competent in the test method but are under close monitoring and additional training due to sample variations. Ongoing monitoring and further training are in place to ensure consistency, with all available resources utilised to prevent any impact on turnaround times.

In response to TM's inquiry about the timeline for the Marine Institute's return to a full count, considering the analysts' training and confidence, DC mentioned a potential return towards the end of the year.  

The previous minutes were agreed. They will be posted to the FSAI website in one week, if there are any comments in the meantime, please send them to 

2. Standing Items

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

MM provided an update on the sampling activity for 2023 and presented an overview of the Q3 2023 Classification Monitoring Programme (refer to the attached documents).

Niall O’Rahelly introduced himself as the new Shellfish Environmental Manager and his role in coordinating the sanitary surveys.

TM inquired about the commitment to completing Bantry Gearhies by the end of the year. NOR expressed the intention to conduct a shoreline survey with a target completion date in early January.

Classification System

JH asked about Ireland's current classification system, expressing concerns about its effectiveness given the impact of climate change on the predictive value of three-year data. JH proposed preparing a position to influence EU legislation, advocating for a longer-term solution. He suggested looking at global practices, separating data influenced by animal and human faeces, and starting anew for a more accurate and realistic system over the next five years.

Key Discussion Points: 

  • DL acknowledged ongoing proposals to review the COP and suggested relaying this feedback up the chain for further consideration at COP review. DL emphasised the intention to provide feedback to the European Commission. 
  • DM queried flexibility within the current classification setup and expressed doubts about the reflective nature of a three-year dataset.
    • DL illustrated potential flexibility within the current system, using rainfall results as an example. Proposed the possibility of excluding anything three standard deviations outside the average. 
    • If a rainfall event falls outside this range, it could be excluded from the decision-making process for the given year but remains in the dataset to recalculate the average for subsequent years. DL highlighted the need for careful consideration, noting that periods of excessively dry weather should also be considered in potential changes.
  • FO’S questioned the shift to PCR testing. Concerns were raised about anomalies impacting producers and public health.
  • AO’S provided information that the Commission is reviewing legislation and engaging with Member States. SFPA will attend a meeting on this matter, and updates will be shared.
  • SK emphasised the primary objective of classification is safeguarding public health from pathogens present in animal and human waste entering the marine environment. While acknowledging a higher risk from viruses, SK explained that the classification program, based on E. coli, effectively reduces the risk of bacterial pathogens from animal waste. However, challenges persist with norovirus. Managing and controlling sources of contamination are crucial aspects of the classification program across the EU.
  • SK stressed the need for a comprehensive review in the future, considering how rainfall is factored into the classification process. 

PM questioned MSSC's role in preventing pollutant sources from entering the bay. DL advised that one of the MSSC's roles is to provide information, and the EPA and Uisce Éireann sit on the MSSC. 

DL mentioned that the Uisce Éireann panel is looking for more panel attendees and suggested involving IFA, providing them with their contact information. 

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

PC provided an update on the MI’s toxicity report (attached).

PSP update

PC noted that there was a PSP event in May 2023 and then another spike in week 33. In Week 34, quantifiable concentrations of PSP toxins detected from Castlemaine Harbour. In week 35, PSP at nearly one and half times the regulatory limit in oysters from Cromane East. 

DC raised concerns about the PSP levels observed in Castlemaine Harbour, highlighting the occurrence of a second intoxication within the same year, which has not been observed before since PSP monitoring began in the 1990s.  The double occurrence prompts a thorough investigation into the underlying causes. While the Marine Institute can leverage the PSP Safe project for this inquiry, additional resources will be crucial for continuous monitoring.

Phytoplankton as an early warning system (IFA)

FO’S highlighted that the Phytoplankton as an early warning system is not functioning and called for a review. FO’S suggested the review could involve a shift to monthly sampling of flesh sampling at certain times of the year for better system management and use of resources. 
DC agreed with FO’S, stating the following points:

  • A review of the National Phytoplankton Monitoring Programme is overdue, given that the MI has used the same method since the 1980s due to legislative requirements. 
  • Phytoplankton analysis was not designed as an early warning system but provides real-time data about specific points in time. DC explained that the sampling points are often where shellfish are, aiming to correlate with what shellfish consume. 
  • The phytoplankton alone is not sufficient as an early warning system and needs to be combined with satellite data, modelling, and molecular analysis. 
  • A comprehensive review is needed and exploration of available technologies to transform the current system into a proper early warning system. 

CD emphasised the crucial role of phytoplankton testing in providing valuable information to the Marine Institute. Phytoplankton serves as an indicator of events in surrounding bays, offering insights into biotoxins. 

DL advised it's worth having a look at how phytoplankton sampling is done to see if there are different ways of doing it that would make it more responsive, more efficient, and bring it more up to date with patterns of production. 

FO’S emphasised that if there are other methods, and we shouldn't have to wait for legislation. There should be more openness, and if there's data available, we should start using it. DL suggested this to be taken up at the COP review of the Irish Shellfish Monitoring Programme. 

3. Microbiology and Virology 

Norovirus Data 

KLF presented a graph of Norovirus prevalence in productions areas (Irish Oyster Packers Group), covering the period from October 2017 to August 2023. KLF highlighted the significance of the data, emphasising that it represents a substantial amount of information collected by the Marine Institute over the last 7 years. Norovirus was identified as the most critical concern affecting numerous oyster producers, particularly during the winter months.

KLF suggested that the solution to the issue lies in the removal of the source of contamination and stressed that this is not only crucial for the Irish industry but also important for maintaining Ireland's global reputation as a premium producer of quality food. 

DL noted ongoing discussions with regulatory bodies responsible for wastewater management. It was acknowledged that the primary course of action is to continue raising these issues with the relevant authorities who have decision-making power.

TM raised a query regarding how the MSSC and the Shellfish Industry can influence regulatory bodies in decision-making, particularly in determining priorities. DL emphasised the importance of maintaining a dialogue at various levels, whether through IFA aquaculture, contacting Uisce Éireann, or participating in stakeholder engagement i.e., when capital plans are released for consultation. 

AO’S advised that there is going to be an LBM working group meeting before the end of the year and Norovirus will be a topic for the agenda. SFPA will provide an update after that meeting.

JH queried if a coastline bay map could be drawn up and emphasised that land and farming adjacent to shellfish production has to be prioritised for infrastructure development and incentives to get farmers to operate in such a fashion that allows the objectives of the Shellfish Water Directive to be achieved.

Norovirus limit 

FO’S inquired if Ireland has an upper limit in mind for norovirus. AO’S clarified that Ireland can't stipulate a limit when there is currently no limit in the legislation. However, all food business operators handling oysters have identified norovirus as a hazard in their food safety management system. 

SK noted that in relation to the slide presented by KLF, it is the maximum levels detected in a 12-month period, a worst-case scenario. Regarding the standard for norovirus, the commission have not worked out at what stage to apply a standard, and if the standard be applied at the production area or at the end product. In both scenarios, there is a lot of real data so any impact on FBOs can be ascertained. 

4. AOB

Sanitary Survey Session

DL provided an update on the Sanitary Survey Session. 
Action: The team will check with the availability of the speaker from CFAS and confirm a date for the sanitary survey session within the coming weeks. 
UPDATE: The sanitary survey session took place on Thursday 8th of February 2024. 

MSSC Meetings 2024

UW will send out a schedule for meeting next year. DL noted that it would be preferable to have some of the meetings in person.