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Molluscan Shellfish Safety Committee - 26th May 2020

Location: Videoconference - GoToMeeting
Date: 26th May 2020 at 11am

  • FSAI: David Lyons (Chair), Christine King 
  • MI: Sinead Keaveney, Conor Duffy, Dave Clarke, Patrick Costello
  • SFPA: Aileen O’Sullivan, Brian Nolan, Miche├íl O’Mahony 
  • IFA: Finian O’Sullivan, Teresa Morrisey
  • Irish Water: Clare Cremin, Valerie Hannon
  • BIM: Geoff Robinson, Trish Daly, Vicky Lyons, Joanna Gaffney
  • EPA: Liam O’Suilleabhain
  • Industry: Pat Mulloy (Connemara Seafoods), John Harrington (Kush Shellfish), Kian Louet-Feisser (Carlingford Oyster Company)
  • Apologies: Paul Hickey (HSE), Joe Silke (MI), Paul Duane (SFPA), Andy Mulloy (Industry), Maeve O’Reilly (Irish Water), Kate Harrington (Irish Water)

1. Review of previous minutes (24th March 2020)

Clare Cremin and Patrick Costello were present at the previous MSSC, and spelling error in Pay Mulloy’s name.

Action: CK to add names to attendance list and correct typos
Update: Completed (27/05/20)
Please send any further fact corrections to Christine
Minutes were agreed and will be posted next week.

2. Brexit

DL noted that the draft Brexit agreement has been circulated. The FSAI Brexit team is working through this document, highlighting any issues around food control, BIPs etc and the practicalities of implementing such arrangements to communicate back to the Commission. If the UK wish to seek an extension to the transition period the request must be with the Commission by the end of June.

3. Standing Items

a) Update on shellfish monitoring coordination (SFPA)

BN talked the group through the SFPA Sampling Coordination Document, Annex A Micro Sampling Report May 2020 and Annex B Elevated results Jan - May 2020. 

The key points to note are:

  • 385 shellfish samples submitted in Q1 as part of official monitoring of classified bivalve mollusc production areas in Ireland
  • 26 additional samples submitted as part of the Sanitary Surveys for Gweedore, Drumcliff and Sligo Bay 
  • 14 out of range results to date in 2020 (approx. 3.6% of samples taken)
  • Biotoxin monitoring currently;
    • Weekly sampling frequency for Mussels on all coasts.
    • Fortnightly sampling frequency for Scallops from classified areas. 
    • Bantry and Kenmare Bays - Weekly sampling frequency for all shellfish other than Mussels
    • All other production areas - Monthly sampling frequency for all shellfish other than Mussels.
    • Weekly sampling frequency for PSP monitoring Cork harbour (Mussels initially).
  • 2020 review of classifications;
    • Dataset for this year’s review is Jan 2017 – Jan 2020
    • Draft review of classified LBMs completed 13th May, all observations/comments to be received by 19th June, implementation team meeting 24th June.

BN noted that there is an error in the dataset for Waterford Estuary. It was incorrectly reported that Harrylock Bay was closed for surf clams due to a court order. This has now been corrected and the amended documents have been circulated. Harrylock Bay surf clam production area is in compliance and is to be returned to a full A classification.

FOS raised the issue of the out of range result from Bantry on 27th January 2020 which was discussed at the last MSSC, he reiterated that this will affected the classification of this area in the 2021 review of classifications. PM added that one bad test from one day of the year can have a significant impact on a production area for the rest of the year, and perhaps in such cases of out of character results retest should be considered. 

FOS queried if the labs retain samples, and if so, following an out of character result could PCR tests be run on the sample for Norovirus. SK clarified that labs don’t retain samples for re-testing as E.coli tests must be carried out within 48 hours of sampling. 

SK noted that E.coli moves out of shellfish faster than Norovirus which explains why differences in E.coli concentrations can be seen in follow-up samples. Additionally Norovirus test results cannot be used for the classification of production areas, only E.coli results are relevant and E.coli may be present due to contamination of waters with animal waste as well as human waste. 

BN explained that in EU legislation there is a margin of tolerance for A classified areas – 20% of results can be >230MPN, but not more than 700MPN, there is no other way to obtain an A classification, unless you apply for a seasonal A classification. Out of range results cannot be discarded without a verifiable reason and submissions should be made in the normal way. 

DL noted that the FSAI support the procedure of making submissions with the relevant evidence to dispute out of character results, and that the current system works well and has stood up to audits etc. 

VH clarified that there has been no issue with the wastewater plant in Bantry, there have been occasional issues with a pump station in Bantry and these issues are reported and followed up when they occur. She also noted that Irish Water conduct investigations at the request of the SFPA when they are advised of out of character results. 

JH queried if Inland Fisheries Ireland are contacted in relation to out of character results and potential spillages? BN stated that the SFPA have very little contact with IFI. JH noted that this might be a missed opportunity as many issues are reported to the IFI. DL queried whether the IFI report significant incidents to the EPA. LOS commented that the EPA are notified of any incident as defined under the EPA’s license i.e. from EPA authorised premises. Such notifications are shared with Irish Water and corrective actions are taken as required. 

FOS queried whether the length of time a storm overflow system is activated is recorded. LOS confirmed that generally they are not recorded, but Irish Water have plans for increased monitoring into the future. VH confirmed that there is a national storm water overflow programme being rolled out. DL concluded that when a producer is putting in a submission, they can include whatever evidence is available to them, a specific list of acceptable evidence would cause issues for people in certain areas who may not have access to particular data.

b) Toxicity Summary Report (MI)

PC presented the Shellfish Safety Report. In summary, there were 4 site closures in the South West in week 22 (DSP event). There was an ASP event in the South West in April, however no samples went above the regulatory limit for Domoic Acid and therefore no closures. All samples submitted in April/May for AZP, PSP and PTX/YTX were < LOD or N.D. There was one Management Cell decision to change the status of Clew Bay North to open.

4. Biotoxin Programme

DC noted that two samples were rejected this week due to postage delays, this is likely due to issues that An Post are experiencing due to Covid-19. 

a) Habs 2 Biotoxin Module

DC noted that the development of Habs2 has been suspended, however some work is ongoing on improving the current version. In the last meeting there was a discussion around changing how late samples are recorded on the Habs system i.e. is it possible that they are not displayed as closed/expired. DC confirmed that this has been amended and will be released in the next deployment, however, delays due to covid may impact this.
This item can be taken off the agenda for the next MSSC.

b) Phytoplankton sampling – rationalisation of areas

DC noted that last year approx. 4000 samples of phytoplankton were analysed last year for the monitoring of shellfish production areas, which is above requirements and puts a strain on available resources. Therefore, the MI are proposing that a number of areas are amalgamated for phytoplankton sampling, based on similarities and consistencies between their historical data, including:

  • Skerries – Malahide
  • Rosslare – Curracloe
  • Sherkin North - Sherkin West
  • Snave – Bantry Middle
  • Newtown – South Chapel
  • Gouleenacoush – Cleandra
  • Carrigaholt – Paulnasherry
  • Clifden – Mannin
  • Killary Outer – Killary Middle – Killary Inner – Killary Approaches
  • Drumcliff – Sligo Harbour

DC stated that a risk assessment will be conducted for this and circulated for comment. The aim is to reduce samples coming in by approx. 15 samples per week.

FOS commented that he doesn’t see an issue with the amalgamation of Newtown and South Chapel. However, there may be issues with amalgamating Snave and Bantry Middle, as if there is a toxicity event in one it does not always immediately affect the other, and therefore this may lead to unnecessary early closure of areas. DC clarified that the MI will still accept samples from other sites, and they won’t be deemed “closed for sampling”, to avoid unnecessary closures.

GR queried whether one year of data is enough to validate the consolidation, as there is variability from year to year and perhaps the data could be randomly audited against data from other years. DC stated that because the MI only do a full species identification on half of their sites this would be difficult to do. Instead, they are focusing only toxic species. 

BN queried whether there is a case to be made for grouping biotoxin monitoring in these areas too. DC replied that there are no plans to amalgamate shellfish production areas, only phytoplankton sampling.

BN queried how sampling of amalgamated sites would be coordinated i.e. if the businesses in the primary sampling site are not harvesting and therefore not sending samples, how will the businesses in the other sites know that they need to send their own sample? DC confirmed that the MI will be able to add a programme to the Habs site which will notify producers if a sample hasn’t been sent.

BN queried whether there would be a series of separate phytoplankton maps? DC stated that there won’t be separate maps for phytoplankton sampling areas as this would cause confusion.

DC mentioned that the amalgamated areas will be linked on Habs website so that results will be displayed for all areas.

DL requested that if anyone has any further comments, they send them to DC in writing in the next 2 weeks. DL queried when this would begin to be implemented. DC noted that there is some development to do within the Habs database and website, hopeful that it will be up and running in coming months but need to discuss with applications development team.

c) EU scallop biotoxin update

DC explained that the EFSA are investigating the efficacy of shucking scallops in the removal of toxins – Domoic acid and Lipophillic toxins. As part of this the MI were asked to collate their datasets for domoic acid and lipophilic monitoring programmes for scallops and a dataset of approx. 27 000 results was submitted to EFSA on 26th May 2020. The results of this study will be important to see if we can reduce the amount of testing that we are currently doing on scallops. 

FOS queried what was the objective of this study? DC explained that Ireland is not implementing Regulation 226/2002 and this has been picked up in FVO audits and infringement proceedings have been taken against Ireland. This research may contribute to a change in this legislation if it shows that shucking scallops adequately removes risks to the customer, allowing for only the parts of the scallop going on the market to be tested, rather than the whole animal. MOM added that while Ireland are hopeful that this will result in change of legislation in favour of shucking scallops, it may also go the other way.

DL queried what are the next steps in this? MOM responded that by the end of January 2021 EFSA must come back with an opinion on whether shucking is effective in the removal of lipophilic biotoxins and what would the limit be. EFSA then have a further 6 months to answer the question in relation to ASP. Following a positive outcome from EFSA there would be discussions on whether this should be included in legislation.

5. Microbiology and Virology

a) Impact of EU Commission proposal on Norovirus on end-product oysters as found in BIM risk-management study

SK gave a presentation of the results obtained so far (October 2017 - March 2020) in the BIM Norovirus risk-management study in relation to the EU proposal for a limit of 500cpg Norovirus in shellfish, with the obligation to test 10% of batches dispatched between November – April. This data is not representative of all Irish dispatch centres, only those in the Irish Oyster Packers Group (JG noted this is approx. 50-75% of dispatch centre but gives an indication of the impact that this proposal will have on Irish shellfish producers. The results indicate that (for the relevant months Nov – Apr):

  • 5.2% of all end product would fail to comply
  • 2.1% of Class A end products would fail to comply
  • 9.1% of of seasonal Class A and Class B end products would fail to comply

SK noted that data collected during the EU baseline survey of norovirus in oysters (separate study) from November 2016 to October 2018 indicated during the winter months almost 25% of B Class production areas contained Norovirus at concentrations >1000cpg vs. only 1.7% of A Class areas. Depuration to achieve concentrations of <500cpg is generally only successful when the initial concentration is <1000cpg.

FOS queried whether these results are consistent with the results from the EU baseline survey. MOM stated that the comparable EU figure for the 5.2% reported by SK for the Oyster Packers Groups is 2.1% and that Irish producers will be more than 2x more affected than the average EU producer. MOM also noted that the 500cpg limit is beneficial as currently some EU countries buying Irish Oysters expect there to be no Norovirus present, resulting in RASFFs etc. 

FOS queried whether it is likely that there will be any +/- tolerance in the 500cpg limit. MOM stated that this level of detail has not yet been discussed, however as yet there has been no mention of having a level of tolerance to this limit.

KLF expressed concern over a hard limit of 500cpg from a producer’s point of view in relation to the increased potential for recalls etc. MOM stated that the current proposal isn’t 100% clear on what level of recall will be required if a sample is found to have >500cpg Norovirus, and it has been communicated to the Commission that clear risk-based information is required from a commercial point of view. MOM also stated that there has been a general acceptance that this limit needs to be moved from Regulation 853/2004 to Regulation 2073/2005, which would oblige the Commission to frame the limit with clarity on how it applies to batches before/after the test batch and gives potential for tolerance to be included.

VL queried whether all dispatch centres would be required to test product under the proposed legislation. MOM confirmed that it will apply to all approved dispatch centres, further detail provided in General Overview of Norovirus Proposal. 

JG mentioned that she has raised the issue of Norovirus through the National Technical Advisory Group for the Water Framework Directive, who have accepted that this requires more attention and it may be time to initiate an expert group for shellfish waters. JG stated that she would keep the group informed on any developments in this area. DL thanked JG.

b) Shellfish classification 2020

As discussed in section 3a) above.

6 Covid-19 and potential impacts on statutory monitoring programmes

DL gave an update for the FSAI. All staff have been working from home since mid-March. Looking into how official controls and supervision can be delivered post-lockdown. As yet, Ireland have not had to avail of Regulation (EU) 2020/466 which gives flexibility to member states in terms of delivering official controls during the Covid-19 pandemic. It is likely that the current system of official control inspections will need to be modified, either through the use of PPE or other arrangements, and the FSAI have sent out a survey to the official agencies to gather information on their experience with official controls so far during the pandemic. 

DC gave an update for the MI. Lab services over the past 11 weeks have been operating as normally as possible and all statutory monitoring services have been provided. Approx. 1/3 reduction in samples coming in for biotoxin analysis, but phytoplankton sampling has remained consistent. DC reiterated that there have been delays with An Post deliveries, which has resulted in some sample rejections. In order to try prevent delays in results, particularly for those on weekly sampling frequencies, DC suggested that samples are taken and sent at the beginning of the week. SK noted that there has been no disruption to E.coli test labs and sample levels remain the same. Norovirus sampling has naturally reduced over the last 11 weeks as we are coming out of winter season.

BN gave an update for the SFPA. Operating as near to normal as possible. There is a skeleton staff in HQ and port offices but the majority of staff are working from home. Virtual food safety inspections for premises are being trialled and vessel inspections are being conducted from the quay wall, rather than boarding vessels. There was an interruption to classification monitoring in the South West due to social distancing issues on boats, but this has been resolved. Classification sampling and verification of biotoxin sampling are both being conducted as normal. Official control samples from premises has ceased as some labs unavailable due to Covid testing. AOS added that risk assessments are being conducted in order to put procedures in place for safe, physical inspection of premises.

TM and FOS thanked the agencies for working with the industry to keep sampling and testing going.

7. AOB

DL mentioned that if there are any training events that people would like to see to send him an email and he will pass it on to the FSAI training department, as there is some scope for additional virtual training events to be put on.

Next MSSC to take place on Tuesday 28th July at 11am via videoconference.