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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
Summary

Why should we review the current classification system?
Identifying improvements
Initial conclusions
Proposals
Next Steps
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)
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.
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
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.
Shorter Term
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
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.
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
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
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
Medium/longer term options
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.
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
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.
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.
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.
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.
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?
Next steps
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?
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
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
Linden Jack (2011)
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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
  • 26. This document was created with Win2PDF available at http://www.win2pdf.com. The unregistered version of Win2PDF is for evaluation or non-commercial use only. This page will not be added after purchasing Win2PDF.