Improving the classification system in England and WalesSAGB Annual Conference 17 May 2011

Linden JackFood Hygiene Policy BranchHygiene and Microbiology Divisionlinden.jack@foodstandards.gsi.gov.uk

Summary

Why should we review the current classification system?Identifying improvementsInitial conclusionsProposalsNext 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 harvestersClearly practical difficulties with applying current system, many of which are long term issuesDelays in response to high results (downgrades) can have a major impact on industry but questionable whether provide additional public health protectionCurrent system is very resource intensive and need to justify resource allocated to classifying and monitoring shellfish harvesting areasData shows classification for around two-thirds of beds is stableClimate 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 2011Identified 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 yearsPhased introduction of changes to demonstrate progress and embed principles which will support the improved systemNeed to establish internal process for implementing improvements which takes account to the Government s approach to better regulationAlso 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 protocolsEnforcement 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 cocklesFurther work to clarify proposal as we may have misunderstood comments at the stakeholder meetingNeed 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 productCould support a risk-based approach and allow resources to be targeted at areas where there is a greater riskWill 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 protectionToo 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 neededDeveloped 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 delayProtocol 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 classificationsReview current protocol and consider practices in other countries to develop a more practical approachWill consider protocol used in Scotland and whether this can be adapted for use in England and WalesWill 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 affectWould 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 flexibleGood communication and working relationship between harvester and local enforcement officer essentialSampling 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 scheduleWould support a more actively managed classification system and reduces resource spent on investigating high resultsWill discuss with stakeholders to learn more about current practice and risk management approaches applied by harvestersBegin 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 classificationNeed 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 managementThis 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 norovirusNeed 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 investigationsInitial 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 methodologyWe know harvesters have long held views on the unsuitability of the MPN method for testing shellfishExpect 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 problemLimitations 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 certainFocus 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 groupsDiscuss further with stakeholdersIdentify most effective LAGs and share best practiceOngoing projectFSA to facilitate discussions and other partners take forward?

Next steps

Next steps

Actively working on several proposals continue taking these forwardStart discussing proposals that require further consideration or clarification before they can be progressed with Agency colleagues (including FSA lawyers) and external stakeholdersClarify procedures for consultation and implementing changesDevelop overall project plan, including work plan for individual proposals so review is managed and progress monitoredDevelop 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 areasWidely recognised reducing contamination in shellfish waters will reduce the food safety risks associated with shellfish.Activities taken forward by Defra Cleaner Seas ForumMinister led Committee which is actively working to improve water quality in shellfish and bathing watersFSA and SAGB are members of the forum

NorovirusPriority in FSA s strategic plan and included in our work to reduce foodbornes diseaseExisting research projects (FSA and defra) and FSA developing research programme on virusesEuropean 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 TeamSAGB, individual harvesters, local authorities, technical experts and defra colleagues for their positive support and contributions

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