Minutes of the Molluscan Shellfish Committee - 29th of November 2016

• FSAI: David Lyons (Chair), Maria Meghen 
• SFPA: Brian Nolan, Bernard O’Donovan, Aileen O’Sullivan,
• MI: Jeffrey Fisher, Dave Clarke, Bill Doré, Conor Duffy, Joe Silke, Sinead Keaveney,
• HSE: Paul Hickey
• BIM: Terence O’Carroll, Vicky Lyons
• Irish Water: Valerie Hannon
• ISA: Richie Flynn, 
• Processing: Pat Mulloy
• Apologies: John Harrington (ISA), Finian O’Sullivan (ISA), Andy Mulloy (Processing), Liam O’Suilleabhán (EPA)

DL welcomed the attendees and thanked the MI for hosting the meeting. There was a roundtable of introductions. The agenda item on production period was deferred and industry is to develop a proposal on it.

DL acknowledged the sad passing of Donal O’Callaghan, National Director of Seafood in the SFPA, who was an active member of the MSSC. He noted that Donal was a wonderful colleague and that his calm approach and positive outlook had assisted the committee many times, in particular during intense discussions. The Committees’ thoughts are with his family and friends at this difficult time. 

1. Minutes of the last meeting, 13th of September 2016

The minutes of the previous meeting were accepted with one change. 

DL updated the Committee that an SFPA norovirus investigation report will be forwarded to the Hong Kong Authorities when additional sample results are available. BN reported that he had followed up on the two areas whose had high results had been discussed at the last meeting and the results are consistent with their long term pattern.

On the possible sludge pollution event noted at the meeting, PH noted that the HSE should be informed about these types of events as they can request the investigation of pollution events and the instigation of Public Health measures, where bathing waters are involved.

On the improvements to the MI HABS system, RF has received feedback from industry that in areas with poor coverage the new maps are very slow to load on mobile devices. DC is looking into a change that will allow a faster load.

2. Standing Items

2a. Update on shellfish sample co-ordination

BN presented the SFPA report on sample co-ordination. He noted that 1,204 shellfish microbiological samples were collected to the end of quarter 3, 2016. The out of range results for January – November 2016 (#34) show a similar trend to 2014 and 2015 and all were good years. The current biotoxin frequencies are weekly for mussels on all coasts, scallop fortnightly and all other species are monthly. 

During November the SFPA has been sampling under the Shellfish Waters Directive. A total of 59 shellfish samples will be taken by SFPOs nationwide for analysis of trace metals and organohalogens. This sampling is carried out alongside the routine monitoring and the work is carried out in conjunction with the MI. Shellfish sampling under the EFSA Baseline Survey also commenced this month. 

2b. Toxicity Report Summary

DC presented the toxicity report summary for September - November 2016. He noted that DSP continued to keep some areas within inner Bantry Bay closed up until mid-October but all areas are now open, and no carryover or new closures are expected. There was a one off high ASP result in scallops from Ballinakill. 

JS noted that it had been an unusual year, with low toxicity of both DSP and AZP. AZP did not bloom this year. The MI ran a cruise to look at Azadinium distribution, but couldn’t find it in any water samples. There were lots of nutrients around if the AZP had bloomed. Razor clams and oysters showed some ASP toxicity in low levels on west coast. 

There were 6 management cells so far this year. 2 earlier in the year related to phytoplankton submissions and 4 were related to missed sample frequencies. 

2c. Microbiological Criteria & Classified Bivalve Mollusc Production Areas

DL noted the previous meeting action on the Committee to highlight the changes dues to the new microbiological legislation and the importance of investigating anomalous results. He noted that the changes were being highlighted at the SFPA Breakfast Information Events and at the recent BIM Oyster Workshop in Sligo. The SFPA will be updating the Code of Practice on Microbiological Monitoring to reflect changes in EU Guidance when they are finalised.

3. Microbiology and Virology

3a. EU Baseline Survey on Norovirus 

BN has produced sampling advice for the production areas and the dispatch centre that have been picked at random for sampling. The dispatch centre that was randomly chosen is not handling oysters at present so the SFPA may identify a second dispatch centre to sample. BN acknowledged the assistance of the MI with establishing the sampling programme. SK noted that all samples to date were compliant with the temperature requirements on arrival. DL noted at the BIM Oyster Workshop a request was made that FBOs receive the results. MI will report to SFPA and they will then communicate the results. 

BD announced that a norovirus culture method is now available (Replication of human noroviruses in stem cell–derived human enteroids). He said that this is an exciting development and it will provide many new opportunities including the differentiation between infectious and non-infectious particles. The culture method will give additional information to the PCR results, and will allow assessments to be made on the impact of UV and other treatments. RF noted that a norovirus culture method was very interesting news. One of the researchers involved in the culture method is scheduled to speak at the ICMSS Conference Galway in May 2017. The MI is in discussions with the culture method researchers in relation to becoming involved in a related project. 

4. Biotoxin Programme

4a. Tetrodotoxin (TTX)

AOs reported on the last EU Expert WG meeting in which the Dutch explained the background to the actions taken on TTX. They used the precautionary principle to set the limit. The UK risk assessment did not agree with the Dutch. The Dutch are only testing Dutch product at the moment. Ireland is supporting the Commission request for an EFSA opinion on the issue. Ireland has noted that NLD cannot impose restrictions on imports and has also asked that Irish product not be affected. CION will decide on the next steps when it has received the EFSA opinion.

JS noted that he was invited to attend a Dutch meeting of researchers on TTX. He noted that there are different approaches to setting a limit. He noted that the safe limit is unknown at the moment but there has only been one case of illness linked to TTX and that was following consumption of a gastropod in Spain. The EU CRL is available to assist with method development. RF noted that industry is meeting the Dutch authorities next week.

4b. EU Scallops Proceedings

DL informed the meeting that Santé F (formerly FVO) does not agree with the approach of the Irish Authorities on the control of scallops and CION is in the process of launching infringement proceedings against Ireland. Ireland has received a letter of infringement from CION and the Irish Authorities are working to reply to this. CION’s interpretation differs from Ireland’s in relation to the legislation as CION maintains that whole scallop must be tested while Ireland tests the parts that are placed on the market. Cion maintains that if we are not testing the whole scallop then we need to have a restricted harvest. Ireland’s offshore fishery would make the CION interpretation difficult to implement. 

BN noted that industry is very compliant with the current system and he also noted the migratory nature of the fishery with landings into various MS. There is no link to cases of human illness, despite the large tonnage of scallops landed. He noted the scallop abductor muscle can be exported to the USA without testing. AOS noted that the UK supports Ireland and has noted that CIONs interpretation of the system is not workable. They are moving towards allowing restaurants to arrange their own testing. 

JS said it was not feasible to use the standard biotoxin method for the scallop fishery as this would require a trip to the offshore beds to take samples to open the area. JS noted that different MS could have different statuses for the same ICES rectangle. JS and DL explained why the Irish Authorities believe that Decision 226/2002 is optional while CION wants Ireland to use it. JS explained that CION is misinterpreting the word OR in Regulation 853/2004. CD pointed out that the derogation has a line about being updated when new available evidence.
Action: DL undertook to keep the MSSC informed of developments

5. AOB 

5a. Irish exports of oysters

BOD proposed that, in an environment of evolving norovirus controls where Irish exporters do not know what tests their product will be subject to and in order to minimise the risk to them, industry would consider a voluntary code of practice for norovirus depuration of exports. He noted that this proposal to depurate is not required under the legislation but it would help reduce the risk to exporters. TOC noted that 70% of Irish product is dispatched for depuration in other MS. BOD acknowledged that while depuration doesn’t solve a problem completely but it reduces the inherent risk.

BD noted that depuration reduces levels but it is not a magic bullet. There is also a need to manage the production area and risk management is the primary approach. Industry is working on management strategies. He noted that there are already some recommendations on norovirus in the depuration guide and risk management could be added to the COP for microbiology. He would have concern that blanket advice on depuration may not give benefits despite the increased cost. 

TOC noted that to depurate everything would create a problem for industry who have made a big effort with branding and also for smaller operators. He noted that Australia went down route of depuration and there was still an outbreak. AOS noted the SFPOS encourage FBOs to include norovirus risk in their FSMS. VL noted the need to consider depuration capacity and costs. PM noted that while industry relies on testing, FBOs have no control over their exported product.

RF thanked BOD and noted it’s a complicated issue. He noted the classification system is legally binding and is what we have to reply on. Introducing depuration has been suggested before but it lets the polluters off the hook. Industry is moving towards pre-packed products and A class areas are a huge selling point. JF agreed and noted that in Washington State there is a focus on improvement of shellfish water quality.

5b European Maritime Fisheries Fund (EMFF)

RF noted problems with the European Maritime Fisheries Fund (EMFF) set up to compensate FBOs for loss of earnings in exceptional circumstances. There is no detail on how to calculate income for a claim if an FBO is closed for 4 months. There is a limit of €500,000 p/yr. and it’s a gamble for industry as there is no option to claim a second time. RF said that the scheme seems unworkable although he noted that a new version of scheme is due out. 

5c 2017 Schedule of MSSC Meetings, proposed dates

Proposed dates for the MSSC meeting in 20017 were circulated.
Action: FSAI to circulate the dates via email for comment. Update: Proposed dates circulated and agreed dates are now available on the MSSC landing page.

2017 Schedule of MSSC Meetings 

Last reviewed: 21/3/2017