Minutes of the Molluscan Shellfish Safety Committee - 12th June 2018
Minutes of a meeting held in the Red Cow Moran Hotel, 12th June 2018.
- FSAI: David Lyons (Chair), Maria Meghen
- SFPA: Brian Nolan, Aileen O’Sullivan (SFPA)
- MI: Dave Clarke, Conor Duffy, Sinead Keaveney
- BIM: Vicky Lyons, Trish Daly (items 1-4c)
- Loughs Agency: Sarah MacLean
- EPA: Liam O’Suilleabhán
- Irish Water: Valerie Hannon, Maeve O’Reilly
- Industry: Richie Flynn (ISA)(items 1-4c), Ray Harty (IOPG)
- Apologies: Paul Duane (SFPA), Paul Hickey (HSE), Finian O’Sullivan (ISA), Terence O’Carroll (BIM), Jeffrey Fisher (MI), Andy Mulloy (Industry), Pat Mulloy (Industry)
DL welcomed the attendees and there was a round table of introductions. DL congratulated SK on her recent promotion to Shellfish Microbiology Team Leader.
1 Minutes – 12th March 2018
MM noted an amendment to the draft minutes from FOS on customer sampling of product. DL noted that any additional comments on the MSSC minutes should be forwarded within the next week and that the agreed minutes will go on the FSAI website. Update: The agreed minutes are available on the MSSC section of the FSAI website.
Further to a request from RF, CD provided an update on MI work on TTX. He reported that the MI has carried out analysis on 507 samples to date. Two samples were sent to the EU RL for confirmatory testing and have been reported as negative. They were tested by Elisa and LC-MS. He noted that the LCMS is very sensitive. CD noted that no positives have been identified to date. CD noted that the MI has purchased a new machine which is due next month. The current machine is old and not v sensitive. The MI will establish the method on the new machine and then consider the future analysis plan.
RF asked if the TTX results to date have been sent to EFSA. CD said that there is no call for data at the moment but the MI will supply the data when requested to feed into any future data reviews. CD noted that there is a laboratory ring trial planned for this year, with 9 laboratories expected to take part.
RF noted that the EU Aquaculture Advisory Council has submitted a position paper to the EU. The paper, ‘Presence of Tetrodotoxin in shellfish, 28/06/2018’ is also available on its website (aac-europe.org/en/). RF stated that the document calls for more research before regulation is considered. He noted that the French Authorities have also started testing for TTX.
COP for Biotoxins
MM noted that a new draft of the COP is in preparation and has been circulated to the SFPA and MI. The update will reflect the changes to the way results are reported on the HABS website and expand on the explanation of sampling frequency and production period.
Action: MM to initiate a review of the COP for Biotoxins for the next MSSC meeting
Draft Guidance on Norovirus
DL noted that he is drafting guidance on norovirus for use by the oyster industry. He undertook to circulate it to the MSSC after he has received feedback from the Irish Oyster Packers Group.
Action: FSAI to circulate draft norovirus guidance for the next MSSC meeting.
2 Standing Items
2a Update on Microbiology
BN reviewed the microbiological sampling report for Quarter 1, 2018 and the elevated microbiology results for 2018 to date. He noted there had been 14 out of range results compared to 7 in the same period in both 2017 and 2016. He highlighted the high number of out of range results in April and May 2018. A link to heavy rainfall prior to sampling has been identified for many of the results along with changes to agricultural practices.
BN noted that the draft shellfish classification documents have been circulated for comment. The annual classification meeting will be held in Clonakilty on the 26/06/18. (Update: The 2018 classification is now available on the SFPA website. BN noted that Harrylock Bay, Waterford Harbour has been awarded a preliminary A classification for razor clams. The area is already classified for surf clams.
RF thanked BN for all the useful information. He noted the importance of the investigation of out of range results and making use of local knowledge. He noted the two peaks in out of range results in autumn 2017 and spring 2018 which were associated with periods of bad weather. He noted that prompt follow-up sampling after an elevated result is very important but that resampling within the same calendar month can be challenging to achieve.
RF suggested that IW should be represented at the classification meeting, as it would give the organisation an insight into the issues and help to allocate funding for Wastewater treatment plant (WWTP) improvements. DL noted that the EPA or IW are welcome to attend the classification meeting and to be involved in the general process, although he noted that if there is a query with an elevated result then the time to raise the issue is at the time it is originally reported.
RF noted the increased emphasis on our marine resources on the Wild Atlantic Way and increased focus on water tourism. MOR noted that IW does feed into the overall water protection process. VH agreed noting that shellfish waters are a driver for WWTP investment along with bathing waters and the amenity value. She noted that all relevant factors are weighted in the assessment for funding, noting that it is the Energy Regulator who decides on the allocation of capital investment (see 4d below).
LOS noted that EPA wastewater discharge licences are now in place and they allow action to be taken where there are issues. He noted that the public can lodge a complaint if they have a concern. In the first instance they should contact IW and then if it is not resolved they can contact the EPA. LOS acknowledged the importance of organisations such as SFPA in bringing issues to the EPA’s attention.
RF acknowledged that a benefit of the MSSC is that it is a regular point of access to all the relevant stakeholders. He noted the importance of the how the MSSC structure facilitates a link between outcomes from shellfish monthly monitoring and the water investment process.
2b Toxicity Summary Report
DC presented the Toxicity Summary Report noting the first closures in 2018 were due to ASP in the South West in April. These were followed by one DSP closure in May and five areas in early June. There was one management cell decision in April for mussels in Castletownbere. DC noted that 90 bays are sending in biotoxin samples at present. CD reported that there has been one PSP result in pacific oysters of 300 µg/kg (the limit is 800 µg/kg). He noted that mussels would normally have a higher uptake of the toxin than oysters.
VH posed a question about the positioning of phytoplankton sampling points in bays. DC noted that the sampling points for each area are identified to give the best picture and over time the MI has found a natural variation in the toxin profile between adjacent bays.
As there has been a significant increase in demand for biotoxin results for production areas harvesting or intending to harvest the MI has requested samples arrive in the laboratory no later than Wednesday each week to allow for reporting in the same week. The MI operates a three day turnaround from sample arrival to reporting on https://webapps.marine.ie/HABs.
Action: SFPA to remind samplers to submit shellfish samples by Wednesday each week for reporting the same week Update: Shellfish delivery reminder circulated on the 31/07/18.
3 Biotoxin Programme
3a HABS – Overview and next steps
DC reviewed the successful roll out of HABS 2 to date. The new database has been in development over the last 2 years and has now replaced the original HABS database which was launched in 2001. He noted that the new front end was launched at the end of 2017 and the phytoplankton platform was launched last month. He noted that paper is no longer used in the two phytoplankton laboratories and demonstrated that real time phytoplankton information is now available on-line. The new system provides increased efficiency and decreased turnaround times. He noted that the sample rejection procedure is now seamless and that QC is ensured.
DC also provided an outline of the next steps in the project. The focus will now be on decreasing the sample turnaround time through optimising data transfer. RF asked about industry access to the real-time sample status. DC pointed out as soon as a sample is received anyone with internet access can see that it has been logged. He demonstrated the https://webapps.marine.ie/HABs web page which shows the latest sample date for each production area. He suggested that this would be particularly useful for areas with multiple samplers, so everyone will know that a sample has been received. DC noted that some phytoplankton results were published at 8:30am recently as there was concern due to rising toxicity. Results will only be available when they have been quality approved. SML thanked the MI for the new HABS application, saying that the additional information was very useful. She noted that the improvements have made her liaison with industry much easier.
RH asked if phytoplankton limits could be shown on the HABS phytoplankton graph in the same way that toxin limits are shown. DC explained that cell count limits are not set for phytoplankton, and noted that any level of a toxic species could indicate a bloom is imminent.
The meeting congratulated the MI as at the end of March its Azadinium spinosum PCR method became the first in the world to be accredited under ISO 17025. RF queried if the MI plans to use molecular methods for the identification of any other phytoplankton. DC and CD noted that other possible uses are for Pseudonitzschia australis, Alexandrium and other Azadinium species. They noted that the molecular methods are used for confirmatory testing and will not replace the microscope method.
4. Microbiology and Virology
4a Resolutions from the workshop of the Shellfish Microbiology NRLs
SK noted that the EU RLs are not in a position to provide proficiency testing (PT) schemes immediately. It is their responsibility but there will be a delay in delivery of this service. The MI has decided to continue using CEFAS for matrix specific PT for E. coli, salmonella and viruses. CEFAS will continue to provide shellfish matrix-based PT on a commercial basis after it ceases to be an EU RL.
DL queried the CEFAS laboratory’s longer term plan. SK noted the laboratory may look for more international collaborations, possibly working with the FAO. It was noted that the National Food Agency, Uppsala, Sweden is now the EU RL for foodborne viruses.
4b EURL guidance on norovirus testing
The CEFAS EU RL has developed guidance for industry on the assessment of commercial virus testing laboratories. A long and a short version of the guidance have been produced.
SK noted that the MI is available to assist any laboratory that wishes to invest in establishing the norovirus method. VL noted that a feasibility study has been carried out. It was noted that there is also a market for the analysis of horticulture samples such as strawberries.
4c Notification/Communication of Wastewater Incidents
VH circulated a copy of her presentation on wastewater (WW) incident reporting. She explained that wastewater incident notifications are required under 2 sets of legislation; the Urban WW Regulations and the WW Discharge Authorisation Regulations. She explained what constitutes an incident, the notification requirements and the incident categorisation system. VH noted that the EPA is the supervising authority for the legislation, originally supervising the local authorities directly, and then IW when it was established. She noted that all paperwork on licences, audits and enforcement documents are available to the public on epa.ie.
VH noted there are 3 types of incidents – potential, planned O&M (operations and maintenance) works and confirmed incidents. Each licence has a set ELV (emission limit value) and when this is breached the incident must be notified. She noted that the ELV rules for WW can be complicated and vary between licences. She noted that the rules are clearer for drinking water as no tolerances are allowed.
VH noted that some storm water overflow (SWO) discharges are reportable and noted that three year assessments are carried out. Emergency overflows are always notified and preferably in advance. It was noted that while many SWOs operate as designed and are appropriately screened, the location of all SWOs is not known and there is a lot of work to be done on this area. LOS noted that if an SWO is discharging in dry weather then it is not operating correctly. He said that there is a plan to put event monitors on key SWOs. There was a discussion on the quality of SWO discharge. SWO discharges should not result in a breach of water quality standards, including shellfish water quality, as they should be dilute discharges. VH noted that another source of pollution is septic tanks attached to one off houses that are not operating correctly.
She explained that incidents are ranked 1-5 with category 1 not having an impact on water quality. She noted that a Category 3 incident, where possibly untreated WW is discharged to a river, is rare event and only 3 or 4 have occurred nationally in the last few years. There have been no category 4 or 5 incidents. She noted there were 2,361 incidents reported to the EPA in 2017 and 1,455 of these were recurring incidents. VH noted improvements such as improved reporting system, an IT management system for WW reporting and training for key staff in LAs, WWTPs and IW.
RH highlighted that operational problems at WWTP can be linked to key staff taking leave. He noted that a sampling programme run by BIM has shown spikes that link to bank holidays and other holiday times. VH noted that there is a requirement for holiday cover and they are continuing to look at ways to improve reporting. LOS said that if there is a concern about a discharge that IW should be contacted as soon as possible in the first instance. He also noted that the WW licence requires that incidents should be informed as soon as possible. VH said IW has an on call and out of hours service, which allows it to respond to incidents. She noted that the WWTP operators inform IW about incidents who will then inform agencies. RF said the national system should be improved so FBOs are quickly informed as soon as possible. RH agreed noting the real risk to FBOs when their product is affected. DL noted that the short time frame between harvesting and placing product on the market (both within the EU and in third countries) necessitates a rapid reporting of incidents. RF noted the pressure facing FBOs where they have to invest in a depuration plant even when they have good quality water.
DL and BN both noted the improved incident reporting. BN noted the good co-operation that has been established between IW and SFPA. He noted the historical lack of WW infrastructure investment and that there continue to be significant population centres without proper WW treatment.
4d IW Improvement Programmes
MOR presented information on IW improvement programmes relevant to shellfish. The IW improvement programmes aim to improve compliance to WW discharge authorisations, such as where UV is required under the licence. The current programme is the 2017-2021 Capital Investment Programme. MOR provided a review of projects including sewer rehabilitation, disinfection, WW Pumping Station telemetry, storm tanks and inlet works. Drainage Area Plans are developed to review the risks to the WW system within a drainage area. The plans can take a few years to develop but can then be used on an ongoing basis. MOR noted that all relevant factors are weighted in the assessment for funding and the request for funding is submitted to the Commission for Energy Regulation (cru.ie/water) who is responsible for deciding on the allocation of capital investment.
BN queried how population changes are factored into planning. MOR replied that factoring in growth is important in the planning process. Domestic, commercial and industrial growth are considered. LOS noted some new plants that will help to improve water quality in shellfish areas. He noted that shellfish waters are an identified priority set by the EPA for IW.
DL noted the good turnout at the events particularly the final event in Kilmore Quay. He noted the feedback in the evaluation sheets was positive and some suggestions for future events. Another set of events might be run in 18 months time after the EFSA study has been published. He thanked SFPA, BIM, MI and ISA for assistance running the events.
DL noted that this is a standing item for FSAI meetings. He noted that the first tangible impact of Brexit has been the change to the arrangements for the EU RL for Monitoring Bacteriological and Viral Contamination of Bivalve Molluscs.
Shellfish Document Fraud
BN reported on the successful SFPA prosecution of fraud relating to Shellfish Gatherers Documents. He noted that this complex case first came to the attention of the SFPA in 2013 and involved several Member States. The implicated documents were forged in 2012 and 2013. Update: SFPA has issued a press release on the successful prosecution. DL congratulated BN and the SFPA on the successful prosecution.
Next MSSC meeting (update): The location of the final MSSC meeting of 2018 has been confirmed. It will be held on Tuesday the 20th November at 11am in the Cork Airport Hotel.