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Molluscan Shellfish Safety Committee - 24th March 2020

  • FSAI: David Lyons (Chair), Christine King
  • SFPA: Brian Nolan, Paul Duane, Miche├íl O’Mahony, Aileen O’Sullivan
  • MI: Dave Clarke, Sinead Keaveney, Conor Duffy, Joe Silke, Patrick Costello
  • BIM: Vicky Lyons, Geoff Robinson
  • Irish Water: Maeve O’Reilly, Valerie Hannon, Claire Cremin
  • IFA: John Harrington, Teresa Morrissey, Finian O’Sullivan
  • LA: Sarah McCLean
  • Industry: Pay Mulloy (Connemara Seafoods), Kian Louet-Feisser (Carlingford Oyster Company), Des Moore (Belle Isle Seafoods)
  • Apologies: Trish Daly (BIM), Barry Fox (LA), Patrick Murphy (IS&WFPO), Liam O’Suilleabhain (EPA), Paul Hickey (HSE)

1. Review of previous minutes (16th July 2019)

Please send any fact corrections/typos to Christine via email (
DC to send update in relation to clarification of section 3b) with regard to PSP in Castlemaine harbour.
Update: Dave Clarke sent update on 06/04/20 and this was added to the minutes from 16/07/19
VH noted an error in the previous minutes – she was present but noted as an apology.
Update: This has been amended.
TM queried bays still appearing as closed on HABs when they have not been closed for toxicity reasons, for example when a sample has been submitted but has yet to be analysed. DC explained that if a sample is late the system automatically labels the bay as closed/expired – this should not happen if samples are submitted on time. PM queried if this could be changed from ‘closed/expired’ to ‘waiting’.
Action: DC to review this and circulate ideas for comment. May take time due to potential need for additional programming.

2. COVID-19 and potential impact on statutory monitoring programmes

TM gave an update on how COVID-19 is impacting industry, key points as follows:

  • COVID-19 crisis has had a dramatic and severe impact on demand for seafood and the price of seafood in EU markets
  • Major logistics and transport issues, including increased cost for transport and border closures
  • Several processing plants have closed up
  • Restaurant closures in France and Spain have severely impacted Irish shellfish industry
  • Still a small amount of oysters going to the French market. Chinese markets are re-opening but logistics and transport issues are impacting ability to access these markets
  • Potential food safety issues surrounding unmoveable, landed stock
  • Trying to get a clear picture of who intends to harvest and go to market over coming weeks
  • As the situation is constantly developing and changing it is difficult to predict how the coming weeks/months will play out

DL noted that there are a number of potential issues that we may face in Ireland which may also impact ability for harvesting/marketing of LBMs, such as difficulties in collecting samples, transport of samples and lab analysis due to staff shortages, lack of resources, closures of certain businesses/areas etc. DL stated that we need to consider what is the minimum essential information required to keep the industry moving. This is to avoid an absence of information a barrier when markets and businesses are starting back up. Prioritising areas of work and sampling will be vital.

DC commented that the MI are taking everything on a day-by-day basis. So far there has been no major disruptions to sampling, analysis and communication of results. However, he noted that the MI are highly dependent on a number of key resources including staff availability, access to the labs themselves, the services of An Post and the services of contractors for shucking. JS noted that the MI may be asked to assist in virus testing for COVID-19. If this situation arises COVID-19 testing will take priority over other work.
CD and SK noted that biotoxin analysis and Norovirus analysis are both operating as normal for now.
JH queried MI decisions to stop accepting hand delivered samples as a precautionary measure during the COVID-19 crisis. He suggested that hand delivered samples could be left at back door to comply with social distancing rules. DC confirmed that individuals can contact the MI if they urgently need to hand deliver samples, however samples cannot be left at back door as this would go against QC procedures.
PD noted that official control samples have been reduced at the request of the labs. So far there has been no issues with the collection of LBM and water samples for biotoxin and phytoplankton analysis. BN has sent an email to industry requesting that they only send samples for analysis if they are intending to harvest and has assured them that the management cell of the MSSC will facilitate the rapid reopening of any expired areas when markets begin to restart.

PM queried whether all members of the management cell have a substitute or alternate, should they fall ill. DL confirmed that contact details of all management cell members and their deputies have been circulated.
DM queried what permissions oyster farmers will have in the case of more stringent controls/lockdown situation. TM stated that she has been liaising with DAFM for fisheries/shellfish to be considered essential work as there are animal health and welfare requirements to be considered. She is working on a document which she will circulate to all members in the coming days.

FOS queried the importance of phytoplankton sampling as this time of year could see a number of ASP events developing. DC agreed and noted that Bantry is currently being monitored as numbers are rising. DC stated that phytoplankton sampling should be considered a priority, even if shellfish sampling isn’t taking place, as this information will help to guide management cell decisions.

SK noted that Norovirus season is coming to an end which should see reduced sampling. VL noted that there has been an increase in the number of customers requesting Norovirus results.

KLF noted that although Norovirus season is coming to an end customers may continue to request Norovirus results due to fears over COVID-19, VL agreed with this. SK proposed that she prepare a note to outline the differences between COVID-19 and Norovirus for the Oyster Packers Group, as increased Norovirus sampling after the season ends would be a waste of resources. DL mentioned that any communications relating to COVID-19 must be approved by the Dept. of An Taoiseach.

FOS queried whether there is potential for COVID-19 to be contracted through shellfish consumption. SK noted that there are some clear differences between COVID-19 and Norovirus i.e. Norovirus is a gastro illness and therefore is shed in faeces, while COVID-19 is a respiratory illness. There is some evidence of COVID-19 shedding in faeces however the concentrations are unknown, but assumed to be low. Knowledge and understanding of virus is still at early stages. MOM noted that this question is may be considered by the Biosafety Sub-Committee of the FSAI’s Scientific Committee and it is possible that a more formal risk assessment and comments may follow.

3. Brexit update

The UK have left the EU and we are currently in a transition period which will end on 31/12/20. As it currently stands there is no indication that the UK will seek an extension to this. DL noted that discussions are ongoing at a technical level and the FSAI and SFPA have received documents from the commission for comment.

4. Standing items

a. Update on shellfish monitoring coordination

BN talked the group through the SFPA Sampling Coordination Document, SFPA Annex A Micro Sampling Report March 2020 and SFPA Annex B Elevated results Jan - Feb 2020.
Key points to note:

  • 2019 saw a slight increase in the percentage of out of range micro samples from 2018 and the 10-year average.
  • No changes to biotoxin sampling frequency as yet.
  • Recommendations are currently with the MI for review – review date may be pushed back due to COVID-19.

VL queried the out of range results recorded for Bantry on 27/01/20. BN noted that the reason for these results has not been identified. VH commented that there is no infrastructure in Snave that may have impacted water quality. Heavy rainfall between 25th and 27th January may have impacted this. No incidents reported for this area for January.

FOS also queried the out of range results in Bantry, stating that the area has a good record and the following samples were clear. SK proposed that Snave be put on a priority list of SFPA sanitary surveys to try and identify the root cause of this. BN agreed with this and noted that out of range results were also recorded in this area in August and September 2017. SFPA will discuss in-house.

b. Toxicity summary report including production area closures

DC noted that they are not in a position to conduct molecular analysis due to COVID-19.
There are currently no closures in operation. DSP has bee noted to be present in some areas in very low concentrations, but the main issue of concern remains ASP in the south-west. This is being monitored carefully, both through shellfish and phytoplankton analyses.

5. Biotoxin programme

a. HABs 2 biotoxin module

DC noted that there is a bug in the system which is impacting how the maps are viewed, this is due to be resolved shortly. DC also noted that the next release of HABS is due in 2-3 weeks. This will include the ability to download biotoxin graphs from 2002 to 2020 to excel.

b. Phytoplankton sampling – rationalisation of areas

DC noted that 3950 samples were analysed in 2019. Due to this high number the MI are looking to combine some areas, which will reduce samples by 20 samples/wk. This will allow for full species count on all samples, giving more info. Full document will be completed on this and circulated for comment.

6. Microbiology and virology

a. Norovirus management

FOS queried if there were any changes coming down the line with regard to norovirus testing and legislation.
SK noted that Norovirus management is currently being addressed through a BIM-funded project with the Irish Oyster Packers Group. This has been extended until 31/03/2021. 

b. EU Norovirus discussion, proposals and potential limits

MOM noted that there have been 2 meetings to date in relation to LBM legislation and DG SANTE are looking to introduce a Norovirus limit in oysters. A limit of 500cpg at point of dispatch during winter months has been proposed, or alternatively Oysters may be labelled as not for live/raw consumption.

TM queried if Commission require consensus/majority vote from MS to implement. MOM noted that a qualified majority would be needed to oppose the legislation, however it is currently at WG level for co-decision.
KLF queried if there would be flexibility on the 500cpg limit to prevent recalls if producers receive a result slightly above 500cpg, similar to E.coli results for classification. This was discussed and the general consensus was that system used for E.coli classification might not be comparable to Norovirus testing in oysters.
AOS believes that the limit that is set will be a strict limit. SK noted that there is still a lot of work to be done on this, but any agreed limit will require the use of a standardised method which will be set out in legislation.
MOM noted that the level of 500cpg will result in approx. 1% failure rate across EU (or 2.5% failure rate in Winter months). This may be marginally higher for Ireland due to the climate. 

c. Shellfish classification 2020

Recommendations are with SK for review, following this the recommendations will be published/circulated.

7. AOB

Next MSSC is scheduled for Tuesday 26th May 2020, location and time TBC.