Analysis of Submissions: Discussion Paper; Inclusion of Porcine in the NMD and; proposed amendment to the Animal Products (National Microbiological Database Specifications) Notice 2008 and Schedule 1 Technical Procedures

Inclusion of Porcine in the NMD

No.

Clause

Submission comment¹

NZFSA Response

1

Section 1.2

We disagree with the second sentence in the first paragraph [“Fundamentally, it addresses the need for the development of a standardised microbiological sampling programme for the porcine industry”] All primary processors are currently required to operate a risk management programme (RMP) under the Animal Products Act. Their current RMP data, already a regulatory requirement, can demonstrate microbiological quality.

Risk Management Programme (RMP) data collected by operators use varying microbiological sampling programmes and methods. Having a standardised microbiological sampling and testing programme for the whole pig processing industry facilitates the collation and comparison of data. This will support the needs of the entire industry whilst also satisfying RMP requirements for individual premises.

3

Section 1.2

We submit that there would not be any more benefits than those currently gained by meeting RMP specifications under the Animal Products act 1999. Secondary processing customers already require end product testing from us as processors.

6

1.2

“The porcine industry needs a standardised microbiological sampling programme”.

As one of the largest pig processors we would dispute this claim. We have a microbiological database stretching back over 20 years which provides us with an excellent understanding of our processing capabilities and allows us to detect wayward trends. We would assume that every other pig plant has some form of microbiological sampling in place as we would all be operating under Risk Management Plans by now. It would be difficult to understand how any plant would have their RMP registered if they weren’t conducting routine microbiological testing.

NZFSA acknowledges that the majority of pig processors are performing microbiological testing. It is difficult to compare the data across the whole of the pig industry as it has been gathered using different sampling regimes and methods of analysis.

The NMD programme is designed to gather data in a standardised way for the purposes of statistical analysis and observation of trends and thus will meet the needs of the whole industry.

8

Section 1.2

The imposition of sampling regimes simply for the sake of collecting more data must be avoided at all costs particularly, in the case of food safety programmes, if there are no associated public health benefits.

The benefits for public health will be knowledge gained of the contribution of porcine to Salmonella in New Zealand, which will include the provision of isolates for New Zealand antimicrobial initiatives and support the Uncooked Comminuted Fermented Meat (UCFM) Standard 2008. The UCFM standard itself was put in place to protect the health of New Zealanders.

1

Section 1.2

We disagree with the first sentence in the second paragraph [“The data can be used by operators to contribute to a number of other microbiological monitoring programmes by both gathering on-going process data and microbiological performance targets.”] We understand that primary processors currently monitor process capability via their established microbiological testing, now required within their RMPs.

Participation in the National Microbiological Database allows operators to compare their performance to a national industry benchmark. This adds to industry knowledge for development of quality management and improvement strategies.

1

Section 1.2

Similarly we disagree with the second sentence of the second paragraph [“It will also provide a national profile to demonstrate the suitability of New Zealand porcine product for international trade”] Currently export of New Zealand pork is very minor, due to New Zealand’s industry size and cost of production. Export initiative however have not been hampered by porcine not being present on the NMD because plants have been able to use currently available microbiological data.

The use of the National Microbiological Database helps to demonstrate the equivalence of systems between New Zealand and overseas markets, which is hard to justify when a major species, pigs, is not included. The National Microbiological Database has the benefit of ensuring that consistent microbiological standards are being maintained by industry. On the occasions when Salmonella has been detected in meat there have been questions about the status of other meat species including pork especially from the international markets.

8

Section 1.2

...where any industry is contributing to the NMD and any regulatory authority wishes to use this data for purpose other than those agreed to during the development of the NMD, the industry should be able to refuse, without prejudice, for that data to be used.

NMD data may be used under the mandate of the NZFSA for purposes of research to protect the public health. NZFSA is cognisant of the effect that the misuse of any released data may have on industry and has procedures to ensure that the data is anonymised to protect the identity of contributors.

1

Section 1.2

Comparison with imported meat: we are unaware of any initiative to set up microbiological standards for imported meat.

NZFSA cannot set standards for imported foods that are not already applied for foods produced in New Zealand.

6

Section 1.2

“It will provide a microbiological standard against which imported product could be compared”.

There is no need for NMD for this purpose. In the pre-NMD days the old MAF would call for plant data to establish national “baseline studies data”. We would be more than happy to provide the 20 years of data we have for such a study if other processors did the same.

“Will permit a robust risk analysis to be undertaken across NZ”

As above we don’t need the NMD for this reason, a robust risk analysis could be done via a baseline study using current available information.

NZFSA realises that some individual premises may have substantial data, but the pork industry as a whole does not. Industry data currently available has not been collected using the same analytical methods or sampling procedures and it is not possible to collate or compare for the whole industry.

6

1.2

“Will give industry confidence in their hygienic slaughter & dressing processes”.

With our 20 years of data we have that confidence already. Whilst other processors may not have data stretching back that far they will be building up their own databases as time goes by.

Past experience with the meat industry, especially with developments arising from the 1995 MegaReg proposals by the US, highlighted the need for a standardised programme across the whole New Zealand meat industry for hygienic slaughter and dressing processes.

1

Section 2.2

…asks where the performance target ‘After 5 years 30% decrease in Salmonellosis’ came from and how it was justified..

In the NZFSA Statement of Intent 2008-2011, three foodborne illnesses were targeted as being high priority due to their contribution to the number of cases of foodborne disease in New Zealand. The success of the strategies is measured by the Salmonella performance target. The 30% decrease in salmonellosis target reflects similar aspirational targets promulgated overseas and will allow a comparison with the UK and USA. The performance target may be found in Section 6 NZFSA Strategic Framework of the Statement of Intent published in July 2008 at:

http://www.nzfsa.govt.nz/about-us/accountability-documents/statement-of-intent/2008/soi-2008-2011.htm

.

1

Section 2.2

From the data available to date, it would seem that New Zealand pork is at worst, a very minor contributor to salmonellosis, even the food borne component. We respectfully suggest that while an ideal approach to risk management may be to collect base data to populate a starting model, the costs of such an ideal approach may undermine the sustainability of an industry. There may be other cost effective approaches to achieve the end goal of ‘safe and suitable food’.

There is little data available in New Zealand to indicate the proportion of salmonellosis cases that are attributable to the consumption of pig meat. The robust source attribution studies that would be required are expensive. The NMD programme provides a standardized monitoring system to establish the prevalence of salmonella at the primary processing level in a systematic way across industry at the least expense.

NZFSA agrees that pigs should be monitored for Salmonella over a finite testing period within the framework of the NMD. Porcine Salmonella testing should be conducted on a weekly basis for 12 months to develop a robust data set. Weekly Salmonella testing will be required for 52 weeks following the implementation date of the NMD porcine programme. After this 12-month period operators may choose to voluntarily monitor for Salmonella and report the results to NMD Controller. The NZFSA will review the data and consult stakeholders on future approaches.

6

Section 2.2

The NZFSA Salmonella Strategy is a worthy objective. We support such work but believe that cases of Salmonellosis from the consumption of pork would be insignificant. Generic E. coli is used in our microbiological sampling programmes as an indicator of pathogens and very low levels of detections would tend to suggest there isn’t a pathogenic problem in pig processing.

For this reason we don’t routinely analyse pig samples for Salmonella. We would be happy to conduct such testing for a finite period to prove this point but once again this doesn’t need to be done via a NMD.

1

Section 3

..NMD for porcine on a voluntary basis would be an appropriate position. This would mean that those primary processors who wished to change their microbiological testing could adopt the NMD process if required. Secondary processors particularly manufacturers of UCFM could continue to work with primary processors to assure themselves of the microbiological quality of pork.

This is not appropriate. For any standardised monitoring programme for the whole of industry, such as the NMD programme, to be effective all operators must participate. Full participation of all the operators facilitates the collation and comparison of data and adds to quality assurance and improvement strategies.

Full participation ensures that UCFM manufacturers can be guaranteed a common standard of microbiological control overseen by the regulator at all times.

3

Section 3

We have no issues with the compulsory participation in a porcine NMD where it is a market access requirement…As a New Zealand Standard, however, option 3.1 (Voluntary participation) would be the preferred pathway to follow.

The NMD has been a New Zealand Standard since 2005; this was to prevent the application of a second set of microbiological standards and to ensure product is fit for purpose for domestic and overseas markets concurrently.

6

Section 3.2

“Under the requirements of the premises’ RMP there should be a mechanism for the microbiological evaluation of pigs to validate the selection of CCP’s for HACCP/PMP so that compliance with the APA can be consistently achieved”.

This statement is the key point of the discussion document and supports out claim that the tools are already in place for pig processors to have a microbiological sampling programme in place.

A standardised monitoring system across all the pork industry permits the CCPs selected to be validated and for compliance with the APA to be more consistent. This has benefits for the individual operator and also for the whole industry to compare more readily which interventions are the most effective.

8

Section 3.3

..it is imperative that the pig industry be mandatorily included in the NMD as suggested in Section 3.3 (Option three – Mandatory inclusion of porcine in NMD). In the absence of the inclusion of porcine, it is impossible to argue that the regulatory framework for the microbiological monitoring of major meat species is either equitable or consistent.

NZFSA agrees with this point.

1

Section 4.1.1

..potential food safety risk associated with the illegal slaughter of pork, compared to regulated product. Illegal slaughter was estimated to be around 70,000 carcasses in around 1990.

Occurrences of the illegal sale of pork should be officially reported to NZFSA CIG so that appropriate actions can be undertaken by NZFSA.

1

Section 4.2

..concerned about the burden of comparison between plants, given that currently only 9 premises kill pigs, (a further plant has ceased pig slaughter in Jan 2009). Of these plants, 2 kill less than 10,000 pigs per annum.

The NMD is not based on the volume of throughput. NZFSA has always worked with industry to minimise the level of microbiological testing whilst ensuring statistical validity to permit valid external and internal benchmarking. NZFSA acknowledges that processors with very low throughput will incur disproportionately greater costs. By the use of a ‘Very Low Throughput’ (VLT) criterion NZFSA is proposing the VLT premises monitor for Salmonella, APC and E. coli by sampling 1 pig (all 3 sites). Salmonella testing will be required for 52 weeks from the implementation date of the programme.

6

Section 4.2

“The NMD is a process control tool used to ensure the microbiological standards of hygienic slaughter and dressing”

If this is the case then the uptake of a porcine NMD should be on a voluntary basis as some processors already have such “process control tools” in place.

The submission of data on a voluntary basis will not give an appropriate review of porcine microbiological status across the whole of New Zealand.

6

Section 4.2

The NMD by its very nature is a prescriptive document but this is obviously necessary for gaining continued access to key overseas markets. For that reason alone the NMD is essential. When it comes to pigs though there is no need for overseas market access and so making it “mandatory” for pig processors is going totally against the grain of the Regulatory Model & APA principles.

Although very little pork is exported there is an expectation from these markets that an NMD system is being applied for pigs as for other meat species, particularly with respect to Salmonella sampling. NMD provides assurances to all of our markets including New Zealand.

2

Section 4.2

[paragraph 2 bullet point 3] Random rotational sampling between different classes of pigs…we are only processing Porkers and Trimmers, with no suckers or choppers required. We only kill pigs in the last run of the day Mondays and Wednesdays.

The NMD only applies to the classes of pigs that your premises produces on each day of production. Your premises is only processing one class of pig with respect to NMD. (assumption being that Trimmers fits under Porkers, rather than Baconers). To comply with the random sampling programme you only need to make a random choice from the processing days, runs and classes available each week. In this case it would be a random choice between Monday and Wednesday, a single random time selected from the total time available in the last run for processing of both porkers and trimmers – recording the class each time as Porkers. As your premises is only conducting day shift, and you must sample each processing week, you will be required to sample day shift every processing week.

See also section 2.11 in the Draft NMD Schedule particularly 2.11.1.1, 2.11.2.1, 2.11.1.3, 2.11.1.4 and 2.11.1.5

1

Section 4.6

..performance Targets set in the Salmonella Strategy....what is the process to adjust the performance targets as information comes to hand?

The NZFSA Salmonella Strategy has not been finalised and performance targets are still to be defined for porcine at this stage.

3

Section 4.6

Is there any evidence to suggest that porcine meat (at the carcass level) is a major contributor to salmonella outbreaks? Process protocols such as scalding and singing would strongly preclude this

Evidence of potential contamination from pork was found in studies during 2002.

1

Section 4.7

Imported pork:….query the statement ‘There is likely to be an increase in the amount of pig meat imported into New Zealand’. Figures for the year ending 2008 (year to September) showed growth of New Zealand product and a decrease of imported product.

This statement is based upon information included in the consultation issued by Biosecurity New Zealand in 2007 on four draft Import Health Standards (IHS) for pig meat and pig meat products. On 7 April 2009 MAF Biosecurity New Zealand (MAFBNZ) issued provisional Import Heath Standards (IHSs) for pig meat, pig meat products and by-products from Canada, the EU, Mexico and the USA. The four provisional IHSs include risk management measures based on a risk analysis on porcine reproductive and respiratory syndrome (PRRS) virus in pig meat. The 2006 risk analysis concluded that the risk of PRRS in imported meat is non-negligible, and the following measures were recommended to manage the identified risk:

§ Pig meat must be either from a country free from PRRS;

§ or treated prior to import by approved cooking or pH change;

§ or in the form of consumer-ready cuts.

Further information is available from: http://www.biosecurity.govt.nz/media/07-04-2009/provisional-ihs-pig-meat

6

Section 4.7

“Therefore a national standard must be set first”.

If a porcine NMD is part of the “NZ Standard” then will that apply equally to imported pork? Ie presumable pork would only be able to be imported from overseas processors participating in an “equivalent microbiological sampling programme”.

The importation of pork into New Zealand is covered by the Imported Food Review (IFR). New Zealand cannot require an overseas country to put in a microbiological programme if New Zealand doesn’t have one ourselves.

1

Section 4.8

..concerned about the assumption that existing microbiological programmes will be replaced by the proposed NMD. Why is this required? What is the justification? Furthermore if this in fact the case, then there will be additional cost involved in amending RMPs.

If operators wish to continue their existing programmes they may. But the NMD programme will meet the review of processing microbiological requirements.

Replacing an existing microbiological programme with NMD will require a minor amendment to an operator’s RMP, which may incur a service fee.

2

Section 4.8

The extra costs that this weekly sampling will incur to us means the price of processing pigs for the local market will increase substantially.

Currently: 3 pigs sampled costing approximately $170.00 month.

Proposed Increase to: 3 pigs sampled $190.00 week or $760.00 monthly

The cost of sampling 3 carcasses will represent an additional cost of $0.06/kg

NZFSA agrees that cost for Very Low Throughput (VLT) participants is proportionately too high and will reduce the VLT sampling programme to one pig per week with 3 sites sampled and analysed to be conducted; APC, E. coli and Salmonella. Salmonella testing will be required for 52 weeks from the implementation date of the programme.

6

Section 4.8

“It is expected that operators will replace their existing sampling with the NMD programme”

After 20 years of microbiological monitoring, our existing programme provides a good indicator on how our processing is operating.

Undertaking NMD will provide microbiological monitoring for regulatory requirements for each operator and will allow comparability and benefits across the whole of industry. Operators may choose to run additional microbiological programmes for commercial purposes.

NMD Notice

No.

Clause

Submission comment²

NZFSA Response

7

Clause 4

In the section headed Interpretation, Broiler chickens are defined as a male or a female chicken kept primarily for meat production with the exception of poussins…request that this definition is modified to also exclude birds over 60 days of age.

Disagree; the small proportion of production in New Zealand that are over 60 days and processed as broilers for human consumption need to included.

NMD Schedule

No.

Clause

Submission comment³

NZFSA Response

7

Section 1.1

Table 1 on page 6 …states for poultry “Exporting to the EU is prohibited unless prior notification is obtained from the Director General”. ..change to read “Premises are not eligible to export to the EU unless prior notification is obtained from the Director General”

Similarly….the statement “Exporting to the US is prohibited” for both poultry and ducks, geese and guineas is reworded tor ead “Premises are not eligible to export to the US”

…notes that for game estates the statement used is “No negotiated entry requirements”

The wording is as required to meet market access obligations.

5

Section 2.5

I believe it is over the top to require weekly salmonella testing for porcine. Porcine Salmonella should in Group 1.

Agree; To achieve the purposes of a baseline survey for Salmonella testing will be required once per week for 52 weeks only from the implementation of the porcine NMD programme.

4

Section 2.8.5

..the anatomical descriptors are currently omitted from the porcine section.

Agree; these need to be included.

7

Section 2.5.4

Section 2.5.4 …requires poultry processors to review their process and livestock salmonella status immediately on breaching the US Standard specified in Section 2.5.3….in the interests of fairness and equity that Section 2.5.4 is moved to Section 6.7.2

Will review, at present Section 6.7.3 references Section 2.5.4

7

Section 2.8.5

..that the size of the sampling is 25cm². ..in contrast to other red meat species , porcine carcasses do not have their skin removed as part of the dressing process. Instead the carcasses are subjected to a flaming process to remove hair from the carcass…it is unlikely that much microbiological contamination will remain on the external surfaces of a porcine carcass….alternative sampling sites inside the carcass should be considered

The sampling sites were determined in 2002 by consideration of current industry practices, sites used by industry. This study took into account sites and template sizes recommended in the MegaReg 1995 and other international publications. Analysis of results was undertaken and the most appropriate sites and sample size for New Zealand industry were determined.

7

Section 3.1

..supportive of the proposed changes included on page 51, in Section 3.1 (Manufacture of Diluents for Sampling and Analysis).

Thank you for that supportive statement. The amended wording relates to the 400mls of ssBPW for all poultry rinses and addition of sodium thiosulphate to diluents where chlorinated antibacterial agents are used on carcasses prior to sampling.

7

Section 3.4.3

The second sentence of …”One whole carcass sample of the set taken on the day of sampling will be analysed for Salmonella”… is now redundant and can be removed.

NZFSA disagrees. It is important to state at that place in the document that one whole carcass sample of the set taken on the day will be analysed for Salmonella.

7

Section 3.4.3.1

..rinsing should be changed back to one minute. This would bring the procedure back in line with that used in the United States.

NZFSA disagrees. It is vital that two minutes are used to ensure better Campylobacter recovery. One minutes rinsing was applied when only Salmonella and E. coli sampling was conducted. Two minutes rinsing is necessary to maximise recovery of Campylobacter without using a separate carcass for sampling; such that E. coli and Salmonella can be analysed from a single sample.