Minutes of the Molluscan Shellfish Safety Committee - 21 May 2025

Location: Online

Attendees

• FSAI: David Lyons, Una Walton 
• SFPA: Niall O'Rahelly, Susan Coughlan, Aileen O’Sullivan, Marc Shorten, Emma McLoughney, Sarah Buckley
• MI: Bill Dore, Conor Duffy, Felix Sproll, Patrick Costello
• IFA: Teresa Morrissey
• BIM: Gary McCoy, Vicky Lyons
• EPA: Liam Ó Súilleabháin 
• Industry: Patrick Murphy, Tristan Hugh-Jones, Dean Murphy
• Loughs Agency: Steve Schreck
• Uisce Éireann: Sarah Casey
• Apologies:  Sinead Keaveney, Dave Clark, Joanne Gaffney, Finian O’Sullivan

1. Minutes and matters arising from the last meeting (06.03.25)

Sample delivery:

• Internal consultations and direct contact with An Post have resulted in lobbying for a dedicated point of contact.
• Additional labelling measures are being introduced to better identify and prioritise shellfish samples.
• A tracking mechanism and dedicated client manager are now in place to strengthen the sample delivery and escalation process, particularly in the lead-up to the high-risk December period.

DM (Industry) welcomed the engagement but reiterated concerns regarding potential delays in December, referencing previous incidents. Suggested exploring alternative options such as private couriers or taxis during peak periods.

MS clarified that hand delivery is permitted under the Code of Practice (CoP) but must be agreed on a case-by-case basis between SFPA and the Marine Institute (MI).

DL (FSAI) acknowledged the improvements, especially regarding labelling and account management, and noted the existing flexibilities for handling urgent deliveries.

TM (IFA) expressed frustration that issues often only get addressed reactively, particularly late on Fridays. Requested that a concrete logistics plan for December be developed in advance.

DL suggested IFA submit a proposal for review and supported the call for a consistent approach across all bays.

MS confirmed openness to practical solutions and advised that samplers should check tracking the day after dispatch and notify him directly if issues arise.

DM asked for clarification on the hand delivery protocol whether local sampler managers should notify their line managers in advance. MS confirmed this is typically managed by the appointed sampler manager.

AOS advised that a consistent approach to hand delivery will be considered during the upcoming COP review.

Existing Fisheries & Classification

GMcC (BIM) advised that BIM is supportive of reopening the fishery in question. Discussions are ongoing with MI to develop a management plan, which will facilitate progression of the reopening process.

Water quality

GMcC reported on the Roaring Water Bay meeting held on 20.05.2025, which was well-attended. A summary of the key points raised will be circulated in the coming month.
PM raised the following concerns:

• Emphasised that isolated pollution events do not necessarily reflect the overall water quality of a bay.
• Called for greater accountability from agencies to prevent such incidents, as they compromise shellfish suitability for consumption.

LÓS (EPA) clarified:

• Pollution events should be reported to the relevant agency.
• General pollution incidents should be reported to the Local Authority.
• If the event involves an EPA-regulated activity, the EPA will investigate directly.
• Emphasised the importance of clear responsibility and timely agency response.

PM(Industry) also highlighted:

• The distinction between desktop assessments and real-world pollution incidents.
• Frustration among producers when isolated activities (e.g. dredging) negatively affect classification, despite not being indicative of the bay’s overall status.
• Referenced legal obligations under the Water Framework Directive and the need for balanced interpretation to protect producer interests.

DL advised as usual; the minutes will be published on the website, any amendments should be forwarded to UW (FSAI) within the coming week.

2.    Standing Items

2a.    Update on Shellfish Monitoring Coordination (SFPA)

MS (SFPA) provided an update on the sampling activity to end of April 2025 (refer to documents attached).

• Sampling Activity: SFPOs collected 540 microbiological samples in 2025 to the end of April (April 30th, inclusive) as part of the Microbiological Monitoring of Bivalve Mollusc Production Areas.
• Out-of-Range Results: To April 30th, there were 8 (1.5%) samples collected which gave out-of-range results.
• Annex B: A summary of the out-of-range or elevated results for January to April 2025 is provided in Annex B.

Sanitary Surveys

• The new contractor (Aqualicense) for delivering sanitary surveys has been onboarded. They have streamlined the sanitary surveys with a more efficient approach to the desktop review. The new report style can be viewed in the most recent Cleggan Bay sanitary survey published last week.
• The remaining sanitary surveys to be published in 2025 are Wexford Harbour, Templenoe, Ballyness Harbour and Cork Harbour.

Out of Range Results

This year’s average for out-of-range shellsan results as a percentage of the total number of samples analysed (1.5%) is lower than previous year’s averages (generally 3 to 4% over the full year), however this year’s data is only a single quarter so far and this may be expected to move closer to the norm as the year progresses.

2b.    Toxicity Summary Report including Production Area Closures (MI)

• Two site closures occurred in early April, the first closures in over a year, due to mussel samples exceeding the regulatory ASP limit: Ardgroom (CK-AM-AM) – 24.5 µg/g, Kilmakilloge (KY-KE-KE) – 27.9 µg/g. These closures were short-lived; toxin levels returned to below the limit by the following week.
• A Management Cell was convened on 9th May 2025 for Ballinakill. The decision was made to reopen the site based on available data.
• DSP: No samples tested above the regulatory limit for DSP between March and May 2025.
• Low-level quantifiable AZA concentrations (0.01 µg/g) were detected across various coastal regions (West, Southwest, South, Southeast).
• An ASP event occurred in Bantry Bay in March 2025, with Domoic Acid levels approaching but not exceeding the regulatory limit (20 µg/g), so no closures were required there.
• Due to the elevated cell counts of Pseudo-nitzschia seriata complex, particularly in the Southwest and later in the Northwest (Week 19 onward), the MI requested additional sampling in some areas to assess the need for increased sampling frequency.

3. Microbiology and Virology 

Rainfall Criteria:

• Under the current classification system, producers can submit evidence or information to request exclusion of individual sample results that they believe are unrepresentative of the production area. This system allows for flexibility and consideration of a wide range of justifications (e.g. pollution events, unusual weather patterns, operational issues).
• DL cautioned that shifting to a more statistics-driven approach, such as automatically excluding results outside 3 standard deviations from the mean, would eliminate much of this flexibility.
• The technical guide referred to in discussions “Microbiological Monitoring of Bivalve Mollusc Harvesting Areas: Technical Application” assumes access to detailed, comprehensive rainfall data for all catchment areas, which may not be available, particularly in more remote locations.
• FSAI's position is to retain the current system, which allows for the use of contextual judgment and producer submissions, rather than moving toward rigid statistical thresholds. This maintains responsiveness and fairer classification decisions.

TM expressed concern that rainfall thresholds sometimes appear arbitrary and may shift over time and urged for a pragmatic approach, noting that it’s counterproductive to argue over minor rainfall amounts (e.g. 2mm) when large rainfall events have clearly occurred.

DL acknowledged that a change in approach would necessitate defining new thresholds and rules, and reiterated that the current system enables producer submissions to be reviewed on a case-by-case basis.

MS (SFPA) raised the concern that excluding samples based on statistical criteria (like standard deviation) might result in legitimate low-end results being removed, which could unfairly benefit certain areas while disadvantaging others. He emphasised SFPA’s role is to monitor and report, not to police pollution events. Stakeholders are encouraged to report incidents and make submissions promptly when they believe a result is anomalous.

DM (industry) highlighted an area with two sampling points showing clear differences, and suggested the area might need to be split for better classification accuracy. DL and MS confirmed that splitting a CPA has been done before, and the process should start by submitting a formal request to SFPA.MS advised that such submissions will be considered, although an immediate decision may not always be possible. MS noted that a sanitary survey is the first step to allow any such changes to a classified production area and so a sanitary survey should be requested as a first/early step in any such change to a classified production area’s sampling approach.

DL concluded by proposing that the current approach continue for now, with the option to review it again in future.

Norovirus:

BD (MI) provided an overview of the current Norovirus situation:

• Significantly elevated Norovirus infection levels were recorded in the community during the past winter compared to the previous year.
• These high levels have continued into the current period, although a gradual decrease is now being observed. This pattern remains higher than typical seasonal expectations.
• BD noted this is the second consecutive year of extended Norovirus activity into the summer months, which may be linked to a different strain. Importantly, this does not suggest previous strains have disappeared.
• While community infection rates remain high, Norovirus levels in oysters have stayed low, likely aided by recent dry weather conditions and the absence of wastewater overflows. However, MI remains cautious and is monitoring the situation closely.
• To respond to the evolving situation, the MI has designated several “sentinel sites” in more polluted areas around Ireland. These sites are being sampled weekly to provide better insight into environmental Norovirus presence and to track trends within the community.

GMcC asked for clarification regarding these sentinel sites specifically, whether the samples are collected pre- or post-depuration. BD confirmed that samples are taken directly from the harvest areas, not post-depuration, to better detect environmental contamination.

THJ (Industry) commented on the value of the sentinel testing and asked about progress on a previous suggestion to share Norovirus data with the EPA when levels are high.

BD noted that discussions have taken place regarding data sharing with the EPA, but any such transfer would require producer consent, due to the commercial sensitivity of the data. The intention is to ensure that relevant agencies are informed, on behalf of producers, where appropriate.

DL added that this issue had previously been discussed with oyster producers:

• Much of the available Norovirus data is post-depuration or not representative of the actual water body.
• A technical solution is needed to determine how and what data can be shared with the appropriate authorities.

DM (Industry) asked whether these results are available to others or only to the individual producers.

BD clarified that the data is not currently public, as it can be linked back to individual producers. However, there are ongoing discussions about publishing the data in an aggregated (non-identifiable) format.

DL reiterated that there is currently no regulatory standard for Norovirus and the data collected are private, non-official samples taken by producers, which are commercially sensitive.

TM agreed, adding that:

• In some bays, only one producer may be operating, making the data highly sensitive.
• While there is understandable caution about sharing such data, there is also recognition of its value. A collaborative solution should be developed to manage data transparency and sensitivity.

DL emphasised that any public sharing of data must be controlled and accompanied by proper context, including expert interpretation and commentary. The goal is to publish high-quality, meaningful Norovirus data, and the process is moving in the right direction.

4. AOB

GMcC suggested that information and feedback from MSSC should be shared with river basin groups, such as those active in the Southwest Rock region. Emphasised the importance of cross-agency collaboration and recommended inviting representatives from relevant groups to participate in meetings.

DM commended BIM’s regional testing initiatives in the Southwest:

• BIM has been carrying out environmental and shellfish testing across six key areas.
• The initiative is helping local farmers better understand the water environment and is considered a major step forward.

GMcC confirmed BIM is conducting this work on a regional basis and the resulting data can be viewed online.Those interested can request access to the data via a shared link. The project is well-aligned with broader needs, such as identifying key spawning events, mortality events, and seed availability. It is considered a valuable, coordinated effort.