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AgVetLink August 2003

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Proposed list of allowable levels of nutrients with known therapeutic uses

The ACVM Group has had continued compliance problems with oral nutritional compounds that contain substances that at certain levels can be considered nutrients and, at other levels, therapeutic substances. Most problematic was the ‘neutraceutical’ group that includes glucosamine, chondroitin sulphate, shark cartilage, deer velvet and green lipped mussel extract. Such products were being marketed as treatments for a range of diseases, predominantly arthritis and joint disease.

Under the ACVM Act any veterinary medicine making claims to treat or prevent diseases of pain and distress are registered and the claims assessed. In order to manage the claims being made for these products it was necessary to deal with these as therapeutic substances or non-nutritional such that all products containing them at any level currently require registration. This policy was notified in the October 2002 AgVetLink.

It is recognised that at low levels some of these substances may have nutritional properties and their inclusion at those levels in veterinary medicines could be considered to be purely to achieve the provision of a ‘normal’ diet. The ACVM Group attempted in the past to accommodate this recognition by providing the opportunity for registrants to supply information to demonstrate the appropriate nutritional levels so that they could be included on the GRAS list. It is now recognised that the GRAS list is not the most appropriate tool to manage this issue.

In consequence, the ACVM Group intends to establish a list of allowable levels of nutrients with known therapeutic uses in exempt oral nutritional compounds. The list will facilitate the inclusion of non-therapeutic levels of such substances in animal feeds including pet food so that, provided no therapeutic claims are made in relation to the inclusion of the substances, they will be considered exempt from the requirement for registration.

The details of the format and construction of the list are yet to be finalised. However, the ACVM Group will take the lead in setting the nutritional levels. An opportunity will be provided for set levels to be challenged, but such challenges will be considered only if supportable by data. Any veterinary medicine containing quantities of the listed substances in excess of the determined levels will continue to require registration.

 

2003/04 New Zealand Total Diet Survey

The 2003/04 New Zealand Total Diet Survey is underway. Collection of food samples commenced the week beginning 28 July 2003.

Additional resources committed to the survey have allowed a number of enhancements over the previous survey.

These include:

• increasing the number of samples from 2440 in the 1997/98 survey to 4400;
• analysis of sodium and iron across all foods tested;
• for the arsenic, cadmium, iodine, iron, lead and sodium analyses and the multi-residue pesticide screen, all foods will be analysed as individual regional foods (i.e., there will be analytical results for each region over two seasons) or as individual brands (i.e., there will be analytical results for each of the four national brands over two seasons);
• dithiocarbamate fungicides (DTCs), mercury and selenium will also be analysed as individual regions or brands for the foods that are analysed (e.g. grains and cereals are not analysed for mercury or DTCs and margarine oil and salad dressing are not analysed for selenium);
• a mix of individual samples and some composite samples will be analysed using the acid herbicides screen.

The NZFSA has created a page on its website for the Total Diet Survey  (www.nzfsa.govt.nz/science-technology/research-projects/total-diet-survey/index.htm). Quarterly raw data reports will be posted on the website and interested parties notified. The first quarterly report is expected to be released around mid November and the second report around mid March 2004.

 

Public consultation on ONC standard

Comments on the Draft Standard for Oral Nutritional Compounds are requested. It is available on the website ( www.nzfsa.govt.nz/acvm/publications/discussion/standards-guidelines/) now.

Public discussion will close 15 September 2003.

All comments should be sent to:
Chris Boland 
ACVM Group 
New Zealand Food Safety Authority 
PO Box 2835 
WELLINGTON 
Email: christopher.boland@nzfsa.govt.nz