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AgVetLink December 2002

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Milk withholding period statement wording

The wording of the milk withholding period (WHP) statement for veterinary medicines has been an issue of some confusion in the past. The meat withholding period statement is able to be expressed clearly - it is simply a statement of the period of time that must elapse before treated animals may be slaughtered to produce meat or offal for human consumption.

However, the milk statement is more complicated because it attempts to state not only the time in hours or days that must elapse before milk is presented for human consumption, but also the number of milkings that must elapse to ensure herd milk compliance with the relevant maximum residue limits. In relation to this, the ACVM Group would like comment on two points of concern.

1. The relationship between withholding period hours and milkings

The current statement reads: 

"Milk intended for human consumption must be discarded during treatment and for 'x' hours ('x' milkings) following the last treatment" 

which may be shortened to: 

"Withholding period: Milk 'x' hrs or 'x' milkings".

The assessed number of milkings and the assessment for a WHP assumes that a 12-hourly cycle is in place and the correct interpretation of the statement requires that the hours and number of milkings are congruent. In addition, the intent of the statement is to express the actual time that milk must not be sent for human consumption. The con-sequence is that if a product has a 36 hour milk withholding period (i.e. milk must be discarded for 36 hours) the correct number of milkings that should appear on the label is 2 (i.e. milk must be discarded for 2 milkings but may be sent for human consumption on the third milking following treatment, provided 36 hours has elapsed).

The ACVM Group recognises that there has been some inconsistency in the use and label wording of the milk withholding period in the past. In an attempt to ensure that all labels give clear and unambiguous milk withholding period directions the following statement is proposed as the preferred method of expression (with numerical example): 

"Milk intended for human consumption must be discarded during treatment and for 36 hours (equivalent to 2 milkings) following the last treatment. Milk may be taken for human consumption at 36 hours (3 milkings)" 

which may be shortened to: 

"Withholding period: Milk 36 hrs equivalent to 2 milkings".

It is recognised that this statement is longer than that currently required and that it may present some logistical problems with respect to space on labels. In consequence we are seeking input from industry on this matter.

2. The contribution to milk residues of an individually treated animal

Some labels have a withholding period qualification on them referencing milk residues in individual animals. Milk withholding periods are not assessed on an individual animal basis and the withholding period for any individually treated animal is the same as that for the whole herd. The current label advice that appears on some products to test individual animal milk prior to returning the milk from that animal to the human food chain is deemed irrelevant and unnecessary. The ACVM Group proposes that such statements will no longer be approved and will not be carried forward with ACVM Act transfers.

If you have any comments or concerns on these issues, please send them in writing by 15 January 2003 to: 
Jennie Yee 
Assessor (Technical Standards - Veterinary Medicines) 
ACVM Group 
New Zealand Food Safety Authority 
Post Office Box 2835 
WELLINGTON 
Email: jennie.yee@nzfsa.govt.nz  

Product ingredients (oral nutritional compounds) on public register

The ACVM Group wishes to advise that for products such as oral nutritional compounds, unless otherwise requested by the registrant, all active ingredients and their concen-trations are placed on the public register (website).

The ACVM Group will, however, align the website details as closely as possible to what is required on the label, especially for products where the disclosure of information could result in a commercial dis-advantage.

Requests should be made in writing to Maree Zinzley, Programme Manager (Operations) PO Box 2835, WELLINGTON 
Email: (maree.zinzley@nzfsa.govt.nz)