Colin Warwick (The Crown Estate) - “Harvesting in Harmony”
Linden Jack (2011)
1. Improving the classification system in
England and Wales
SAGB Annual Conference 17 May 2011
Linden Jack
Food Hygiene Policy Branch
Hygiene and Microbiology Division
linden.jack@foodstandards.gsi.gov.uk
2. Summary
Why should we review the current classification system?
Identifying improvements
Initial conclusions
Proposals
Next Steps
3. Why should we review the classification
system?
Need a robust system which protects public health, is practical
to apply and does not place a disproportionate burden on
shellfish harvesters
Clearly practical difficulties with applying current system, many
of which are long term issues
Delays in response to high results (downgrades) can have a
major impact on industry but questionable whether provide
additional public health protection
Current system is very resource intensive and need to justify
resource allocated to classifying and monitoring shellfish
harvesting areas
Data shows classification for around two-thirds of beds is stable
Climate is such that key interested parties are more likely to be
receptive to changes in current system (better
regulation/resource constraints)
4. Identifying improvements
SAGB/FSA joint workshop for harvesters/Local Authorities in
November 2010 provided opportunity for industry and
enforcement authorities to engage in review process and
generated proposals/suggestions for improving current
classification.
Carried out an initial assessment of output from workshop and
presented this to Technical Expert meeting 2 February 2011
Identified areas for further consideration and timescale for taking
these forward. Majority suggestions from initial workshop being
investigated further.
Some areas can be progressed relatively quickly while others
need further evidence collation and, in some cases, further
research before they can be assessed fully.
5. Initial conclusions
Development and implementation improvements to the
classification system is a long term project.
Expect whole process to take at least 3 years
Phased introduction of changes to demonstrate progress and
embed principles which will support the improved system
Need to establish internal process for implementing
improvements which takes account to the Government s
approach to better regulation
Also need to work with FSA lawyers to make sure revised
classification complies with the legislation
6. Proposals
Proposals seem to fall into categories:
Short term issue already under consideration or that can be
assessed and, if appropriate, implemented within the next year
or so. Many of these are procedural issues and/or principles
that can be embedded into the system to support the improved
classification process.
Medium/Long term proposals where collation and assessment
of evidence is needed before an option can be considered fully.
Have an extensive evidence base but further research may be
needed in some cases.
8. Use of data from sampling and testing carried
out by harvesters
3 scenarios for sampling and testing:
Data from harvesters samples and testing to be used to allocate
classification
Harvesters collect samples on behalf enforcement authorities which are
then tested according to enforcement authority protocols
Enforcement authorities collect and test samples
Same protocol should be used for all samples taken to generate
data for the classification. Testing procedures and methods also
need to comply with the legislation.
Protocol has been developed and are currently seeking views
from local authorities, harvesters and other stakeholders.
Would like harvesters to pilot the protocol to make sure it is
practical.
Establish mechanisms for using data from harvester sampling
and testing and verification by enforcement authorities
9. Blanket C Classification beds where product is
going for heat treatment or long term relaying
Main application would be for cockles
Further work to clarify proposal as we may have misunderstood
comments at the stakeholder meeting
Need to understand the different scenarios and implications of C
classification e.g around customer specifications and there may
be sensitivity over handling and portrayal of product
Could support a risk-based approach and allow resources to be
targeted at areas where there is a greater risk
Will aim to discuss with stakeholders during this financial year
but will be prioritised against other proposals.
10. Develop new approach for dealing with high
results
High results can have a major impact on harvesters but it is
questionable whether downgrading areas (as required by the
legislation) some time after the event adds to public health
protection
Too much resource is spent investigating high results when is
difficult to prove whether these were associated with a one-off
event. Should shift focus so take more proportionate reactive
response to high results.
High result should still be investigated but should consider e.g.
temporary closures with agreed protocol for re-opening rather
than downgrading area.
Needs acceptance that continued monitoring may show water
quality is deteriorating and downgrade will be needed
Developed approach for long term classification system and
plan to use this as a pilot. Expect to finalise protocol and issue
for comment within the next few months
11. Review sanitary surveys and applications for
new beds
Need to reduce the time taken to classify new beds and
preparation of sanitary survey makes significant contribution to
the delay
Protocol developed to allow new species and beds in existing
production areas to be classified more quickly. Issued for
comment 2 March 2011.
Please comment on protocol and let us know if we need to do
anything more on this.
Development of protocol/guideline for reviewing sanitary surveys
needs further consideration before proposals can be developed
12. Seasonal classification
Consider whether we can make more use of seasonal
classifications
Review current protocol and consider practices in other
countries to develop a more practical approach
Will consider protocol used in Scotland and whether this can be
adapted for use in England and Wales
Will pay particular attention to facilitating Seasonal A
classifications
14. Use of indicator species
Consider using mussels indicator species to classify all beds in
a production areas.
Has benefits for a simplified approach to classification and
possible resource savings.
Need to review existing evidence and assess impact of using
indicator species e.g. How many harvesting areas would this
affect
Would hope to initiate the review of evidence this year but will
take time to complete. May need to produce an impact
assessment and issue formal consultation.
15. Sampling schedule should be more flexible
Good communication and working relationship between
harvester and local enforcement officer essential
Sampling to be consistent with harvesters own risk assessment
e.g during heavy rainfall, CSO release or other pollution events
prevents harvesting.
Provision for harvesters to collect samples would allow more
flexibility in sampling schedule but would need to establish
criteria for sampling schedule
Would support a more actively managed classification system
and reduces resource spent on investigating high results
Will discuss with stakeholders to learn more about current
practice and risk management approaches applied by
harvesters
Begin taking this forward this year but likely to be a longer term
work stream
16. Risk-based sampling frequency and sampling
locations
Generally have a monthly sampling plan for harvesting areas.
Benefits to establishing a risk based sampling frequency
possible taking account of data available on bed, other beds in
the area and end product testing by the harvester.
Should also consider whether its possible to extend the area
covered by individual monitoring points so there are fewer points
in an area.
Supports risk based approach for the classification
Need to consider with colleagues in science team and other
technical experts before can develop plans for taking this
forward.
Will need to balance the resources needed to provide necessary
evidence to support development of a risk based sampling plan
with possible benefits.
17. Active management of shellfish beds
Consider options which would allow the active management of
harvesting beds and develop guidance on applying risk based
measures to support active management
This is a very long term project that requires further research to
provide evidence base to support proposals.
Would need to compete with other Agency research priorities
e.g. Campylobacter, Listeria moncytogenes and norovirus
Need to look to working with other partners if we are to deliver
this. Would be a very significant multi-partner project.
18. Developing sanitary surveys as an active
management tool
Sanitary surveys are very resource intensive but information
they contain is not generally used once classification has been
established except perhaps in outbreak investigations
Initial discussions with defra have indicated they and the
Environment Agency require similar information to be gathered.
We are exploring with defra how the sanitary surveys could be
developed into an active management tool for all parties with an
interest in water quality in shellfish production areas.
19. Change in testing methodology
We know harvesters have long held views on the unsuitability of
the MPN method for testing shellfish
Expect to issue a letter allowing use of impedence as a
validated alternative method in very near future.
Stakeholder workshop suggested harvesters do not always have
full confidence in the data used to establish classification and
have concerns about laboratory performance. Not clear whether
isolated cases or more wide spread problem
Limitations on microbiological testing and the nature of the
contamination mean it is possible that results from duplicate and
repeat testing will give differ so benefits of duplicate/repeat
samples are not certain
Focus should therefore be on providing a robust data set that
gives accurate reflection of the contamination levels in the area
and laboratory performance needs to be assured.
Increased confidence in the classification system and a more
proportionate response to high results may help address
concerns on this issue but need to consider further.
20. Local Action Groups
Clarify role and representation of local action groups
Discuss further with stakeholders
Identify most effective LAGs and share best practice
Ongoing project
FSA to facilitate discussions and other partners take forward?
22. Next steps
Actively working on several proposals continue taking these
forward
Start discussing proposals that require further consideration or
clarification before they can be progressed with Agency
colleagues (including FSA lawyers) and external stakeholders
Clarify procedures for consultation and implementing changes
Develop overall project plan, including work plan for individual
proposals so review is managed and progress monitored
Develop plan for continuing stakeholder contributions
Stakeholder Discussion Forum?
SAGB meetings?
LAGs?
Another workshop in November?
23. Related work (outside scope classification
review)
Improving water quality in shellfish harvesting areas
Widely recognised reducing contamination in shellfish waters
will reduce the food safety risks associated with shellfish.
Activities taken forward by Defra Cleaner Seas Forum
Minister led Committee which is actively working to improve
water quality in shellfish and bathing waters
FSA and SAGB are members of the forum
Norovirus
Priority in FSA s strategic plan and included in our work to
reduce foodbornes disease
Existing research projects (FSA and defra) and FSA developing
research programme on viruses
European Food Safety Authority published opinion on viruses
next year
24. Acknowledgements
FSA colleagues in particular Claudia Martins, Sylvia
Ankrah, Mariam Aleem and the Science and
Knowledge Team
SAGB, individual harvesters, local authorities,
technical experts and defra colleagues for their
positive support and contributions
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