MINUTES OF THE FORTY THIRD MEETING OF ACAF HELD ON 24 SEPTEMBER 2008
Chairman Dr Ian Brown
Members Dr Dozie Azubike
Dr Paul Brantom
Dr Bruce Cottrill
Mr Barrie Fleming
Dr Gil Domingue
Professor Nigel Halford
Mrs Heather Headley
Mr Edwin Snow
Mr Marcus Themans
Secretariat Mr Keith Millar (Secretary) – Food Standards Agency
Miss Mandy Jumnoodoo – Food Standards Agency
Mr Raj Pal – Food Standards Agency
Assessors Mr Tim Franck – Food Standards Agency
Mrs Jayne Griffiths – Food Standards Agency, Wales
Mr Stewart Herd – Food Standards Agency, Scotland
Mr Stephen Wyllie - Defra
Dr Glenn Kennedy – Agri-Food & Biosciences Institute, Northern Ireland
Officials Ms Janis McDonald – Veterinary Medicines Directorate
Mr Tim Foster – Food Standards Agency (part)
Dr Ray Smith – Food Standards Agency
Mr Gerard Smyth – Food Standards Agency, Northern Ireland
Mrs Cerys Palmer-James – Food Standards Agency, Wales
Speaker: Mr Simon Renn – Defra
1. The Chairman introduced Mr Edwin Snow who had recently joined the Committee as the feed industry member. He invited Mr Snow to say a few words about his career history. Mr Snow said that he was a trained analytical chemist and that he currently worked at Noble Foods as the technical manager in their Animal Feeds Division. He is a member of a number of industry committees including the Agricultural Industries Confederation’s (AIC) Legal and Scientific Affairs Committee.
2. The Chairman welcomed visitors to the ACAF meeting and reminded them that there would be an opportunity to ask questions at the close of the meeting.
3. Apologies for absence were received from Mr Tim Brigstocke, Ms Diane McCrea, Professor Ian Givens, and Mr Richard Scales.
4. The Chairman announced that in May 2008 Her Royal Highness the Princess Royal had presented Mr Tim Brigstocke with the Royal Association of British Dairy Farmers’ Princess Royal Award. The honour was made for his outstanding services to the dairy industry. In his absence the Chairman on behalf of the Committee congratulated Mr Brigstocke on his award.
5. Following requests for nominations for a Deputy Chairman at the last meeting, the Chairman announced that Dr Bruce Cottrill had been successfully nominated, and he had agreed to act as the Committee’s Deputy Chairman.
Agenda Item 1 – Declaration of Members’ Interests
6. Members of the Committee were asked to declare any relevant changes to their entries in the Register of Members’ Interests or any interest in items on the agenda. Mr Snow declared an interest under Agenda item 3. Dr Brantom, Mr Fleming and Mrs Headley declared interests under Agenda item 7. The Chairman stated that he had recently taken up a position at Oxford University as Director of Occupational Health and Honorary Consultant Physician to the Oxfordshire Primary Care Trust.
Agenda Item 2 – Draft Minutes of the Forty Second Meeting (MIN/08/02)
7. The minutes of the meeting held on 3 June 2008 were adopted subject to a minor amendment. This was in the first sentence of paragraph 50: to change ‘feed manufacturer’ to ‘feed materials’.
Agenda Item 3 – Codes of Practice for the control of Salmonella in animal feeds
8. The Chairman invited the Defra Assessor, Mr Stephen Wyllie, to provide a presentation on work aimed at revising the Codes of Practice for the Control of Salmonella in Animal Feeds.
9. Mr Wyllie started his presentation by explaining the history and origins of the Codes. The Ministry of Agriculture, Fisheries and Food (MAFF) originally published the Codes in 1989 in co-operation with industry in response to the salmonella in eggs crisis. The codes were revised in 1995 to refer to Hazard Analysis Critical Control Points (HACCP), and later to refer to Defra rather than MAFF. The presentation focused on three codes which are relevant to feed.
10. Mr Wyllie explained that the legislation relevant to the codes included the Zoonoses Directive 2003/99 (monitoring), the Zoonoses Regulation 2160/2003 (risk management) and the Feed Hygiene Regulation 183/2005. These pieces of legislation place increasing importance and emphasis on salmonella controls. Mr Wyllie noted that, from 1 January 2009, if poultry laying flocks are tested positive for S. typhimurium or S. enteriditis, eggs produced by these birds will have to be heat treated prior to going for human consumption.
11. The three codes of practice for the control of salmonella in feed cover:
• storage and transport of feed compounds, materials and additives;
• production of feed materials and feed additives; and
• production of compound feeds.
12. Mr Wyllie provided a brief overview of the main sections of the codes, including their purpose, definitions, HACCP/Good Practice, premises and storage (pest control, storage, on livestock units, construction and layout, operations), equipment, vehicles, cleaning, bacteriological monitoring, actions when salmonella is isolated, records, personnel and legislation.
13. Mr Wyllie then explained that the codes were integral parts of the three AIC feed assurance schemes (UFAS , FEMAS , and TASCC ). Compliance with the codes by scheme members is checked during annual audits. Mr Wyllie noted that code compliance is also a feature of many farm assurance schemes (e.g. home mixers who are members of the Lion Code for egg production). Mr Wyllie also noted that the codes were also referred to in AIC and GAFTA trade contracts. The codes are indirectly used for example retailer assurance schemes that may require feed used to comply with UFAS (and therefore also with the codes). The codes are also used as training documents and as an accepted industry standard. Non-compliance may be quoted in litigation. With the increased impact of zoonoses legislation this may become a more significant issue.
14. The feed industry is supportive of the codes, and their attendant government recognition demonstrates independence from any particular feed or livestock industry.
15. Mr Wyllie stated that updating of the codes was triggered following the introduction of industry assurance schemes subsequent to the original issue of the codes in 1989. Since the codes were first issued, zoonoses legislation (2003/99 and 2160/2003) has been introduced throughout the EU. Additionally, the Feed Hygiene Regulation (183/2005) provides for the setting of relevant microbiological criteria. Although these criteria have yet to be set, it was decided (by Defra and FSA) that it was appropriate to proceed with a revision of the Codes. The existence of an up-to-date code may assist the UK negotiating position in Brussels.
16. It was hoped that the codes will provide a greater understanding of the need to control salmonella, and hence better compliance with targets set under zoonoses legislation. Also, more reporting and serotyping of incidents, including environmental screening, may lead to a better understanding of the epidemiology of salmonella in the feed and livestock industries.
17. Mr Wyllie said that, subject to agreement from Ministers a twelve-week consultation exercise ending in January 2009 would be undertaken. It was envisaged that the revised codes would be published in February 2009. This was dependent on the number and extent of the comments received during the consultation.
18. Mr Wyllie said the Committee would be a formal consultee, and that both Defra and the AIC would welcome the Committee’s association with the revision. Both organisations would appreciate formal endorsement of the codes by the Committee as this would enhance their status.
19. The Chairman thanked Mr Wyllie for his presentation. He then invited members of the Committee for their comments, including whether they were able to endorse the codes. Mr Wyllie in response to one member’s concern, that the presentation did not cover farmers and farm assurance schemes, said that the codes were updates of existing versions which had existed for a number of years. He confirmed that the farming industry will be included in the consultation. Mr Wyllie hoped that the updated codes would be flexible enough to be used by both farmers and industry. One member of the Committee stated that the updated codes took on board relevant requirements for the egg industry.
20. Several Members of the Committee expressed concern about the possibility of having insufficient time to fully consider the revised codes prior to possible endorsement. The ACAF Secretary thanked Mr Wyllie and colleagues for their hard work on revising the codes. He said that the Food Standards Agency would also be considering endorsement of the codes. He pointed out that endorsement of the codes could occur after they are published. All relevant stakeholders would be given the time and opportunity to submit comments. The ACAF Secretary suggested, and it was agreed, that the Committee should review the codes at its December 2008 meeting. It was agreed that in the interim the Defra assessor via the Secretariat would answer any points the Committee wished to clarify.
21. The Chairman suggested it would be useful if the consultation document could confirm the geographic coverage of the codes, e.g. if they were on a UK basis.
Agenda Item 4 – EC Regulation on Marketing and Use of Feed – Oral update
22. The Chairman invited Mr Franck to provide the Committee with an oral update of developments that have occurred since the last meeting of the Committee held in June 2008.
23. Mr Franck reported that five Council Working Group meetings had been held: two under the Slovenian Presidency and three under the French Presidency. The next meeting would be held on 25/26 September 2008. Mr Franck said that the negotiations were proceeding well. He said the principal issue was the existing requirement to declare the ingredients of compound feeds by their percentage weight of inclusion. Mr Franck confirmed that the Commission’s proposal if adopted would repeal this requirement. Feed ingredients would then only need to be labelled in descending order of weight. Discussions so far indicated that a large majority of Member States were in favour of the repeal of this provision.
24. Mr Franck stated that the Commission’s proposal also included a requirement for the inclusion of a freephone number on pet food labels to enable purchasers to obtain more detailed information on additives and ingredients of pet foods. As this requirement has unreasonable cost implications for small and medium businesses, it has been amended to enable pet food manufacturers to use other methods of providing the information (such as via websites or through correspondence).
25. Annex III of the proposal contains tolerances for analytical ingredients (e.g. protein, moisture). The Commission has agreed to review the tolerances prior to the adoption of the Regulation.
26. Mr Franck said that the negotiations were on-going and some issues had yet to be resolved. He pointed out that that a number of Member States were in favour of a proposal where additives, which are subject to maximum permitted levels, are incorporated in feeds the name and active substance level of such additives must be declared on the label.
27. Mr Franck confirmed that the UK negotiators were seeking a harmonised approach to the regulation of nutritional supplements such as boluses, drenches and pastes. This issue had yet to be resolved and the Commission was examining various proposals from Member States such as additional labelling requirements and a harmonised procedure for their regulation via the authorisation framework for dietetic feeds.
28. Mr Franck then reminded the Committee that the proposal maintains many of the derogations that are contained in the existing legislation. One notable omission relates to feeds with a moisture content of more than 50%. Under existing legislation, the labels of moist feeds do not need to declare for example, protein or moisture content. This is because of the difficulty in carrying out accurate analyses for such constituents. Mr Franck confirmed that the UK negotiators were pressing for the derogation to be reinstated.
29. Mr Franck reported that the French Presidency wanted the Council of Ministers and European Parliament to adopt a common position on the proposal by December 2008. It was hoped that the adoption of the proposal would be at first reading and before the European Parliament elections in June 2009.
30. The Chairman thanked Mr Franck for his update and asked whether ACAF could help influence the negotiations. Mr Franck confirmed that the UK negotiators would welcome the Committee’s views and their feedback so far had been extremely helpful. He noted that the Annexes to the draft Regulation could be modified under Standing Committee procedures and there was a lot of effort being made behind the scenes, including lobbying of the European Parliament.
31. One Member of the Committee sought clarification on whether there was any backup solutions should the derogation on moist feeds not be retained. Mr Franck confirmed that Council Working Group negotiations were still continuing and that should the derogation not be retained, representations to the European Parliament could be made.
32. Finally, Mr Franck agreed to provide the Committee with a further update at its meeting on 3 December 2008.
Agenda Item 5 – Presentation on work and remit of the Farm Animal Welfare Council (FAWC)
33. The Chairman introduced Simon Renn, Assistant Secretary to the Farm Animal Welfare Council (FAWC), who had agreed to provide the Committee with a presentation on the work of this organisation. Mr Renn explained that the FAWC was an independent advisory body established by the Government in 1979. Its terms of reference are to keep under review the welfare of farm animals on agricultural land, at market, in transit and at the place of slaughter; and to advise the Government of any legislative or other changes that may be necessary.
34. The full Council convenes three times a year, with standing committees and working groups meeting more frequently. These groups undertake detailed analysis of the topics identified in FAWC’s Strategic Plan for 2006 -2010. The Council communicates its findings to Ministers via letters, opinions and long term reports. The FAWC also has links with various committees within the UK and Europe, including the European Food Safety Authority. It also has strong links with over 750 stakeholders.
35. Mr Renn described the typical stages during FAWC’s investigations, prior to publication of a report. This includes, an initial consultation, literature and information search, practical visits (to farms, etc), collection of evidence, and preparation of draft reports which are discussed with stakeholders prior to publication. Following publication, the Government takes a final decision on the implementation of any recommendations that have been made. These can be incorporated into legislation and welfare codes.
36. The FAWC’s philosophy is that an animal's welfare, whether on farm, in transit, at market or at a place of slaughter should be considered in terms of 'five freedoms'. These freedoms define ideal states rather than standards for acceptable welfare. They form a logical and comprehensive framework for analysis of welfare within any system, together with the steps and compromises necessary to safeguard and improve welfare within the proper constraints of an effective livestock industry.
• Freedom from Hunger and Thirst - by ready access to fresh water and a diet to maintain full health and vigour.
• Freedom from Discomfort - by providing an appropriate environment including shelter and a comfortable resting area.
• Freedom from Pain, Injury or Disease - by prevention or rapid diagnosis and treatment.
• Freedom to Express Normal Behaviour - by providing sufficient space, proper facilities and company of the animal's own kind.
• Freedom from Fear and Distress - by ensuring conditions and treatment which avoid mental suffering.
37. Mr Renn noted that between 1992 and 1998 reports on broiler chickens, sheep, turkeys, outdoor pigs, farmed fish, laying hens, dairy cattle and broiler breeders had been published by FAWC. Issues raised in the reports included better regulation, risk management and political dilemmas. Mr Renn said that the FAWC was currently investigating the interactions between the economics of livestock production and farm animal welfare in the UK.
38. Mr Renn said that the FAWC had reported on farm assurance scheme labelling in respect of welfare provenance and is currently considering education, communication and how knowledge of animal welfare is transferred. Mr Renn referred to FAWC’s long term goals in farm welfare. These included putting an end to unnecessary mutilations, improved enforcement, national and international recognition of welfare issues, verification of assurance claims, due diligence by retailers and education and training of stockmen.
39. Mr Renn concluded his presentation by saying that the FAWC’s aim is for every animal to have “a life worth living and a fair deal for all”.
40. The ACAF chairman thanked Mr Renn for his interesting presentation. He and the other Members of the Committee praised the work of the FAWC as it enabled consumers to become better aware of animal welfare issues and thus make informed choices when buying meat and other animal products.
41. The Committee felt that animal welfare issues should be taught in schools enabling students from an early age to become familiar with issues such as free range and organic food. They also agreed that the reports produced by the Council needed to be more high profile. The Defra Assessor said that FAWC had no statutory powers and that if a person wanted to report a welfare problem they should inform their local animal health office.
Agenda Item 6 – Forward Work Programme Review (including Horizon Scanning)
42. Miss Jumnoodoo pointed out that the Committee had last discussed its future work at its thirty-ninth meeting on 11 September 2007. She said that prior to the meeting, paper ACAF/08/13 had been circulated to Members. Annex I of the paper set out the Committee’s current work plan. She asked the Committee whether there were any items they considered had already been looked at thoroughly and therefore could be deleted from the work plan. Also, Annex II of the paper outlined suggestions for new work. The Chairman invited the Committee to discuss the contents of the proposed 2008/09 forward work plan.
43. The Committee agreed that all items listed under Annex I should be retained in the 2008/09 work plan. They had the following additional comments on individual items in Annex I.
• Item 1. The manipulation of animal feed to enhance the nutritional value of food - this area covered the work currently being carried out by Professors Givens and Napier under the Lipgene Project. It was also noted that a workshop on future food production for healthier eating was to be held in 2009. The workshop is being organised by the General Advisory Committee on Science (GACS) Secretariat.
• Item 2. Non-feed use of additives (boluses, additives in water etc) - there was a need to introduce specific controls on the composition and use of boluses. Currently, there were no standardised regulations for these products. The ACAF Secretary pointed out that the UK had worked hard to achieve a harmonised position during negotiations on the Marketing and Use on Feed proposal. He welcomed the views of the Committee on this issue which would help the UK negotiating team.
• Item 3. Aquaculture – this item was deemed relevant to item 1 in relation to long chain fatty acids in fish diets. The question of fishmeal as a sustainable source of feed material and appropriate alternatives was an important issue for consideration by the Committee.
• Item 7. The Scientific Advisory Committee on Nutrition’s Vitamin A Report – the European Food Safety Authority (EFSA) was considering recommendations on Vitamin A and that the conclusion in the form of an Opinion was due shortly.
• Item 10. Feed issues relating to organic production - the ACAF Secretary pointed out that Defra has responsibility for this area of work and that if any significant developments occurred in this area, the ACAF Secretariat would arrange for a presentation by a Defra official.
• Item 12. Potential carry-over of allergens from animal feed into derived animal products - the ACAF Secretariat has been working with the Food Standards Agency’s Allergen Branch and a scoping study to determine the prevalence of peanuts in animal feeds would commence shortly. The Agency would be asking for the assistance of the animal nutritionist member of the Committee during this scoping study.
• Item 13. EC’s intention requirement to phase out coccidiostats and histomonostats as feed additives - Mrs McDonald (Veterinary Medicines Directorate), referring to the update she gave to the Committee at its June 2008 meeting, said the Commission Report on the Regulation and use of Coccidiostats concluded that the status quo should be maintained. There were neither impacts nor implications for changes in existing legislation. For this reason, the VMD considered it unnecessary to carry out a formal consultation on the conclusions of the Report. Nevertheless, the VMD had circulated the Report to stakeholders and invited them to submit comments. Mrs McDonald confirmed that the Office of the United Kingdom Permanent Representative in Brussels (UKREP) had advised her that the European Parliament and the Council of Ministers were expected to consider and give a view on the Report. If these two bodies endorse the Report, there would be no further action required. However, should these bodies disagree, as there are no legislative proposals, they would have to instigate a whole new process.
• Item 14. Biofuels - this item was to remain in the work plan. There was a possibility that the Committee would visit a biofuel facility at its out of town meeting in Wales in June 2009.
• Item 19. Establish if there are any feed implications from the research work to assess the potential for multiple residues of pesticides and veterinary medicines in food to produce effects on human health - it was suggested that this item should be given greater priority during 2008/09.
• Item 23. EFSA work in relation to animal feed – the ACAF Secretary noted that the Committee was at the forefront of building and maintaining good working relationships with EFSA.
44. The Committee then considered suggestions for new work, which was listed in Annex II of paper ACAF 08/14. Their comments were as follows.
• Item 1. The use of pre-and pro-biotics in animal feed – it was agreed that this item should be included in the new work programme. An initial discussion should be held before further investigations, including a presentation, are sought.
• Item 2. Categorisation of non feed additives – this item had been discussed under Agenda item 4.
• Item 3 and 4. TSE controls / Meat and bone meal - it was agreed that the SEAC Secretariat should be approached with a view to providing ACAF members with a presentation on the current position. The ACAF Secretary asked the Committee to state what the presentation should cover. The Committee agreed that the presentation should include the following information:
o the epidemiology;
o the current position in the UK, Europe and the rest of the world;
o how the problem has been changed/corrected;
o links to animal feed;
o separation of the implications for animal/human health and ethics; and
o whether there is a risk to animal and human health.
• The Defra Assessor noted that it had been suggested that his colleagues should also provide a presentation. It was therefore agreed that the Defra Assessor should liaise with both his colleagues and the SEAC secretariat to ensure the Committee is given a presentation at its meeting on 3 December 2008.
• One member of the Committee said that the views of retailers should not be forgotten and that the Committee should also give some thought to its education role.
Action: Defra Assessor/Secretariat
• Item 5. By-products - it was agreed that this item will continue to be monitored.
• Item 6. Consequences for the feed industry of potential shortages resulting from problems such as asynchronous approval of GM products and biofuel production – this item was ongoing in other sections of the Committee’s work plan.
• Item 7. Proposals to establish maximum limits for coccidiostats in non target feed - this item had already been considered.
Agenda Item 7 – Herbal Additives
45. The Chairman said he considered this to be an important area and invited Dr Ray Smith to introduce paper ACAF/08/16. Dr Smith explained that the paper was in two parts. The first part summarised the Committee’s work over the last eight years (Annex I to V of the paper) and included presentations on discussions on veterinary use and on human uses of herbal products, with the emphasis on medicinal effects in animals.
46. Dr Smith pointed out that the second part of the paper invited the Committee to consider the work recently done by EFSA. He said that this work emphasised feed additive use. However, he acknowledged that the EFSA document did not appear to have come directly from the FEEDAP Panel itself, but from a seconded group of experts. The report was available on the EFSA website. The main part of the EFSA report consists of a series of monographs for 42 plant species and should be helpful to potential applicants by providing a format that could be used in applications for other plant species. Dr Smith pointed out that EFSA had identified eight areas that applicants need to address when submitting feed additives applications.
47. Under earlier feed additive legislation, herbal extracts, tinctures, etc could be generally used as feed flavours – with no specific authorisation required. However, under the new feed additive legislation such products require specific authorisation, with dossiers required to be sent to the European Commission by the start of November 2010. It is likely that some herbal products have other beneficial effects. For example, they may be offered as alternatives to recently banned antibiotic growth promoters. Dr Smith said this activity would not be covered by an authorisation as a feed flavour; authorisation for use as a zootechnical additive would need to be obtained.
48. Dr Smith drew the Committee’s attention to recently published guidance (in Regulation 429/2008) on how applicants should compile dossiers for herbal products. The Agency’s view is that the plants themselves (as opposed to extracts or products based on a concentration of active substances), or products that are based on the plant with minimal processing (e.g. drying, chopping, or grinding) are not subject to feed additive controls. Dr Smith stated this was in accordance with the requirements of EC Regulation 429/2008.
49. Dr Smith invited the Committee to consider the work undertaken by EFSA and to consider the impact that it may make on animal nutrition and the feed industry.
50. The Chairman said that he was pleased to see that herbs could still be used per se providing that no medicinal claims are made. One Member of the Committee said that the EFSA report came “out of the blue” and it was likely that the report was commissioned via a contract. The Member concerned thought that the FEEDAP Panel would consider the Report in due course.
51. Mrs McDonald confirmed that if products made medicinal claims, they would need approval as veterinary medicines. The VMD would need to carefully consider such claims under the relevant marketing and authorising legislation. One Member of the Committee said the feed industry had been concerned about the plethora of substances which are added to feed mixes, but are not declared in the blend of ingredients listed on the label.
52. It was suggested that confidence might be improved if some regulatory control of such practices was introduced. Another Member of the Committee noted that if one or more products were added then the resulting product would be considered as a compound feed, and therefore declaration of the ingredients would be required. Some Members of the Committee were concerned that if regulatory controls were imposed, some useful products could disappear from the market. They were interested to know what had instigated EFSA’s interest in such products, which had been freely available and used for years. Dr Smith said that under the EC Feed Additives Regulation (1831/2003) there was an authorisation requirement for feed flavours which takes effect in 2010. If these flavourings were not supported by an application for authorisation submitted by November 2010 they would be removed from the official EC Register of authorised feed additives.
53. The Chairman concluded that the Committee had a mixed view about this subject and suggested that it should await the views of the FEEDAP Panel before concluding its consideration. The Committee agreed this course of action.
Agenda Item 8 – GM Issues
54. The Chairman invited Dr Brantom to provide an update on GM issues since the last Committee’s meeting in June 2008. Dr Brantom reported that the GM Sub-Group had considered two issues.
55. The first issue was the provision of comments on the updated guidance document for the risk assessment of genetically modified plants and derived food and feed. Dr Brantom pointed out that this was an extensive document focusing on the approach to risk assessment. The document consisted of 128 pages and a comprehensive and exhaustive review by the Sub-Group had not been feasible. Nevertheless, the Sub-Group had provided some comments as stated below.
• The distinction between genetic change brought about solely by cross-breeding is totally excluded from scrutiny while such change resulting from biotechnology is subject to the most detailed examination.
• Many of the updates to the previous guidance were associated with refinement of experimental procedures in testing programmes. The difficulty with much of the proposed detail is that it is driven by hypothetical rather than demonstrated practical value. There did not appear to be any experimental proof that any of the procedures that are conducted are suitable to detect effects of concern, since all the screening to date has not succeeded in unequivocally identifying such effects. Although the methods are not really suited to the task it is recognised that they are the only ones currently available.
• From a toxicological perspective it was refreshing to see clear guidance on the irrelevance of acute data on novel proteins, but it was difficult to see why the extensive justification applied to 90-day studies for whole product is not matched by a similar justification for 28-day studies on the novel proteins. Without such justification it would appear that the testing of the novel proteins should also be extended to 90 days.
• The treatment of the GM product prior to use in feed needs to be considered in deciding the relevance of studies. For example, products may be heat-treated prior to use, resulting in complete destruction of any novel protein. In such a case it is questionable whether generating toxicological data on the novel protein has any value either for consumer, target species or the environment.
56. The second issue was the review of the second annual report on general surveillance for GM Maize 1507 in the EU. The Sub-Group was asked to provide comments on any points of concern, arising from the surveillance work and asked whether they wanted to see future documents. Dr Brantom explained that a reply had been drafted which confirmed that the Sub-Group could not identify any areas of concern, and unless there were any positive findings the Sub-Group did not need to see any future reports.
57. The ACAF Secretary confirmed that the European Commission had recently authorised Bayer’s GM soyabean Liberty Link (A2704-12) for use as animal feed and human food but not for cultivation. He added that the next Standing Committee meeting (GM Section) would take place on 29 September 2008. At that meeting there would be a review of emergency measures on LL 601 rice from the USA and the state of play on emergency measures on Bt63 rice from China. The meeting would also consider the Commission’s plans for a ‘technical solution’ in respect of the low level presence of non-authorised GMOs. The ACAF Secretary stated that there was currently a zero tolerance within the EU. He thought that the solution was likely to be linked to limits of detection (possibly between 0.1% – 0.5%). The ACAF Secretary said if no solution was found there was a risk that there could be future feed/food shortages within the EC.
58. The ACAF Secretary then mentioned that, in response to a request from the Cabinet Office’s Strategy Unit, the Agency intends to publish an analysis of the extent to which changes in the market are putting a strain on the regulatory system for GM products (including animal feed) and the implications for UK consumers. The Agency would be working with Defra on this task and will be holding a series of relevant stakeholder meetings throughout October 2008. The ACAF Secretary will be chairing meetings with farming and feed organisations. Invitations to these meetings were being sent out to relevant stakeholders.
Agenda Item 9 – Matters Arising from Minutes of Previous meetings
59. At the Committee’s June 2008 meeting, the ACAF Secretary drew the Committee’s attention to a paper on the Food Standards Agency’s website providing statistics on GM animal feed. He agreed to send the Committee an updated version of this paper. The Chairman confirmed that the link to this paper was sent to Committee members on 20 June 2008. The ACAF Secretary said that a version of the document had been on the Agency’s website for a number of years and the statistics contained in the paper were regularly updated.
60. The Chairman recalled that, at its March 2008 meeting, the Committee had considered a draft position paper on biofuels. During discussions it was noted that materials destined for biofuel production could potentially be diverted for use in animal feed. It was suggested that the Animal Feed Law Enforcement Liaison Group (AFLELG) should be asked to consider whether there were any gaps in the controls on feed materials from the biofuels industry.
61. Miss Jumnoodoo confirmed that following its meeting on 16 September 2008 the AFLELG Secretariat had provided a note which had been circulated to members of the Committee as ACAF paper 08/17. AFLELG members had agreed that there was adequate legislation in place to control the use of biofuels and their co-products in the event of them being diverted into the feed chain. Existing legislation contains sufficient powers to allow enforcement officers to deal with any situation where feed law requirements had not been complied with. However, the Group thought it was important that biofuel companies should be reminded of the legislation that applies to biofuel products when they are marketed for feed use, and of biofuel companies’ responsibilities as feed business operators. The Group agreed that the Food Standards Agency should write to organisations representing the biofuels industry, explaining the requirements of animal feed legislation. A copy of the letter would be sent to local authorities, and the Department of Agriculture and Rural Development, Northern Ireland, who are responsible for the enforcement of feed legislation, to remind them of the need to include biofuel companies, as appropriate, in their control programme.
62. The AFLELG agreed that if enforcement agencies became aware that current legislative controls on animal feed were not adequate for dealing with the diversion of biofuels or their co-products they should bring this to the attention of the Food Standards Agency.
Agenda Item 10 – Any Other Business
Responsible Use of Medicines in Agriculture Alliance (RUMA)
63. The Chairman reported that he had given a presentation to RUMA at its meeting on 25 June 2008. The presentation covered the challenges for farm animal medicines and human health. It focused on veterinary drugs and residues, antibiotics and antibiotic resistance, antibiotic growth promoters and antibiotic resistant ‘superbugs’. The Chairman said his presentation was well received and offered to make copies available on request.
Consultation on the future of the Veterinary Medicines Directorate (VMD)
64. Mrs Janis McDonald made a short oral statement on the public consultation on the future of the Veterinary Medicines Directorate. She stated that one of the key recommendations of the 2005 Hampton Review was aimed at reducing the Government’s inspection and enforcement functions and making them simpler and more customer focused. Mrs McDonald said that a business case had been prepared covering the options for the future of the VMD. Having considered the business case, Defra Ministers were keen to seek views on two options regarding the future of the VMD. These were:
• merger with another regulatory body, such as the Animal Health executive agency of Defra, the Health and Safety Executive (HSE) or the Medicines Healthcare Products Regulatory Agency (MHRA); and
• retention as an executive agency of Defra, with Trading Fund status in the future.
65. The consultation ends on the 28 November 2008.
66. The Chairman thanked Mrs McDonald for her overview and asked for ACAF to be updated on developments.
Possible occurrence of Deoxynivalenol (DON) in the 2008 UK harvest
67. Dr Bruce Cottrill introduced this item and stated that cereal grains that were currently being harvested wet could be contaminated by mycotoxins. There could also be the possibility that if the grains were not contaminated during harvesting, they could be contaminated during subsequent storage.
68. Dr Ray Smith of the Agency’s Animal Feed Unit reported that the Agency had been working with the food and feed trade on this issue and had been proactive in providing advice on how levels of mycotoxins can be minimised.
69. So far this year there had been slightly higher reporting of DON in wheat consignments compared to 2007. There had been 73 reports of DON compared with a total of 66 in 2007. Dr Smith said that approximately 3% of consignments at flour mills had been rejected due to the level of DON being above the 1.25 mg/kg maximum permitted level for DON in wheat flour. Generally, these consignments had been diverted for use in animal feed. Dr Smith said that there was no statutory maximum limit for DON in wheatfeed. However, there was a guidance value of 8 mg/kg for cereals and cereal products. For compound feeds the limit is 5 mg/kg (0.9 mg/kg for pigs, 2 mg/kg for kids, lambs and calves).
70. The Agency’s assessment of the situation was that where DON was being found in wheat the comparatively low levels dectected did not represent a significant risk to either animal or public health. Dr Smith said the feed trade was aware of the possibility of other mycotoxins being present in these grains. The feed industry will be carrying out some relevant monitoring work.
71. The Chairman asked whether mycotoxins in feeds detected over the guidance levels were destroyed. Dr Smith said that this was not necessarily the case as these were not statutory maximum limits.
72. One member of the Committee said that the Home Grown Cereals Authority carried out surveillance twice a year for a range of contaminants including mycotoxins. He added that if mycotoxins had significantly contaminated feed this would result in feed intake problems.
Presence of antimicrobial substances in by-products from the bioethanol industry destined for animal feeding
73. Dr Ray Smith drew members attention to recent reports from the Rapid Alert System for Food and Feed (RASFF) on the presence of monensin (an authorised coccidiostat) in spent yeast and similar products from bioethanol production from Brazil that have been imported for use in animal feeding. Dr Smith noted that in general the levels found have been in the region of 1-5 mg/kg. However, in a few cases other levels above 5 mg/kg have been found. The issue was discussed at the 18-19 September 2008 meeting of the Standing Committee on the Food Chain and Animal Health (Animal Nutrition Section). It was agreed, on the basis of recent EFSA opinions, that very low residues of monensin in these feed materials represent no significant risk. However, it is likely that maximum permitted levels will be introduced – these are expected to be similar to the tolerances to be made for carry-over of coccidiostats in non-target feed (i.e. 1-4 mg/kg).
74. The Chairman drew the Committee’s attention to the following information paper.
• EC Developments (ACAF/08/15).
Dates of future meetings
75. The Chairman informed the Committee that the next meeting would be held on 3 December 2008 in the Food Standards Agency’s Aviation House offices in London. Professor Colin Blakemore, Chairman of the General Advisory Committee on Science (GACS) will provide a presentation on the work and remit of GACS at this meeting.