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The chemical residue and contaminant status of New Zealand foods

Meat and meat-product production

New Zealand’s second-largest export (after dairy products) is meat and meat products, amounting to NZ$4.6 billion in 2007. Between 80% and 90% of New Zealand’s meat production is exported (lamb, mutton and beef). Lamb is the top-ranking meat export with sales around NZ$2.3 billion.

Production of chicken meat has doubled over the last ten years and is expected to continue growing. Chicken meat accounts for 95% of total poultry production, nearly all of it for domestic consumption.

Deer farming has grown rapidly in the past 20 years and New Zealand has also become the major world supplier of farmed deer meat (venison) and deer velvet.

Ensuring safety in the marketplace

Under the APA and the Food Act, NZFSA is empowered to ensure the safety and wholesomeness of meat destined for the domestic and export markets. This is done by registered veterinarians and meat inspection personnel who examine and monitor slaughtering and processing operations.

The APA imposes registration requirements on exporters, slaughter and processing operations, cutting, packing and dressing operations, and on by-product premises and export cold stores. It can impose penalties for submitting animals for slaughter that contain residues that exceed maximum permissible levels.

Under the APA, NZFSA’s role focuses on setting risk-management outcomes and having an overview of the whole risk management system, rather than prescribing in detail how businesses should deliver acceptable animal products.

For the meat sector, NZFSA’s Verification Agency verifies that any risk management systems are operating in accordance with requirements.

Supplier statements

Buyer/seller communication is an important component for domestic assurance. In New Zealand this communication is effected by an Animal Status Declaration (ASD) form, which is a legally mandated form authorised by NZFSA. The ASD covers cattle, deer, sheep, goats, horses, alpacas, llamas, ostriches and emus. A separate ASD covers pigs.

An ASD must be completed for all animals sent for processing. It must be completed for all animals (except alpacas and llamas and for certain horses) moved from one property or salesyard to another property or salesyard or property where there is a different person in charge. The ASD is to be completed by the person in charge of the animals.

Supplier statements are required for poultry, possums, farmed fish, wild mammals and game when these are presented for processing. The declaration or statement must contain information relating to the health and residue status of the animals presented for slaughter (eg, veterinary medicine treatment, hormonal growth promotant status for cattle).

Any supplier who makes a declaration in respect of animals not born on their property must consider those animals as having been treated and potentially suspect if they’re presented within a set default withholding period. Animals presented for slaughter with unclear treatment declarations will be considered as having a suspect residue status and may be retained and samples taken and analysed for chemical residues.

The programmes identify when and why controls may not be working. Regulatory reactions to identified ‘control failures’ are aimed at motivating not just the individual but the whole sector responsible for that control, to ensure the necessary adjustments are made to achieve regulatory conformance.

In New Zealand the relevant controls and practices ensuring that chemical residues in food do not breach the regulatory thresholds include:

• effective border controls on imported chemicals

• an agricultural compound and veterinary medicine registration system based on international standards and requirements that meets producers’ needs, and so eliminates any possible motivation to use non-assessed products or apply assessed products in a non-assessed manner

• restricted distribution, through the veterinary profession, of certain categories of veterinary medicines

• farming systems that require minimal chemical input and export-focused suppliers of high-quality products

• industry codes of practice and training

• the use of movement control on farms as a management tool where non-compliant residue levels have been detected

• prosecution that may result in financial penalties as provided for under the APA.

When considering New Zealand’s testing programmes, it must be recognised that significant differences in animal husbandry – hence agricultural-compound use patterns – occur between New Zealand and most other countries.

The extensive pasture-based nature of New Zealand farming systems, coupled with a temperate climate and freedom from many of the world’s animal diseases, mean a relatively low use of most veterinary medicines within New Zealand.

As such, differences will exist between New Zealand’s controls and residue testing programmes and those of its trading partners. However, these do not detract from the effectiveness of the programme in delivering in an equivalent manner, animal products that comply with residue requirements.

The types of compounds included in the monitoring programme and the number of samples to be analysed are relevant to New Zealand farming practices and overseas market access requirements, as are the controls, audits and enforcement practices. Historical testing results which have thus far shown current controls to be effective are also taken into consideration.

National Chemical Residue Programme

The National Chemical Residue Programme is a statistical risk-based residue programme that has been operating since the mid-1960s. It monitors the chemical residue status of animals sent for slaughter and processing, and provides domestic and export consumer confidence in the meat and meat products New Zealand produces.

The programme analyses a wide range of contaminants and agricultural compounds, which enables NZFSA to provide overseas regulatory authorities with assurances about the residue status of New Zealand animal products that are exported. Similar assurances may be provided for domestic products.

The National Chemical Residue Programme is designed to:

• assess the effectiveness of the controls and practices that ensure the levels of chemical residue of slaughtered animals, and the animal products produced from them, are safe and conform with regulatory residue thresholds

• identify when and why industry/national controls and practices have failed to provide the required conformance and then ensure that appropriate corrective procedures are implemented

• identify instances where contaminants or agricultural compounds in animal products are found not to comply and remove, as far as is practical, any affected product from the human food chain

• implement traceback and investigative procedures to identify the cause of any non-conforming residues and contaminants

• allow for intensive surveillance testing of at-risk animals to eliminate any future residue non-conformances from the identified risk source

• generate information on chemical contaminants in meat, seafood and bee product sectors to enable industry and NZFSA to provide credible assurances, communicate effectively with stakeholders, negotiate equivalence of access, and mitigate risks to trade.

The programme has five distinct elements:

• Monitoring – a random selection of a valid number of samples from clinically normal animals that assesses annual residue prevalence in the national population, or monitoring of samples in accordance with specific market access requirements

• Surveillance – involves selective targeting of animals presented for slaughter that are suspected of posing a higher risk of containing chemical residues

• Species Verification – is designed to assess the truth of identity in labelling boneless meat, farmed deer and wild game products. The programme involves a random sampling scheme operated at meat export premises, processing premises and coldstores

• Research and Development – are individual projects designed to enhance the overall capability of the national programmes. They include the contracts for developing new analytical methods and surveys that assess risks that may be associated with particular contaminants or practices

• Special programmes – include, for example, on-site rapid screen tests and the Hormonal Growth Promotant (HGP) Control Programme.

All chemical residue analysis performed on samples is undertaken by NZFSA-approved laboratories, using approved methods that have been validated according to international or approved protocols. Laboratories are required to use both screening and full confirmatory methodologies for analysis of Inter Laboratory Comparison Programme samples.

Monitoring programme for animals presented for slaughter

New Zealand uses internationally accepted statistical sampling rates to detect chemical residues in animals sent for slaughter unless there is a particular market access specification that allows or requires a different sampling regime.

The types and numbers of animals to be sampled and chemical residues to be analysed depend on the risk profile of the agricultural compounds and veterinary medicines used. Factors taken into account for any one compound or class of compounds include:

• toxicity of the compound

• husbandry practices

• extent and pattern of use of the chemical (risk-prone times)

• persistence in the environment (risk-prone areas)

• previous monitoring frequencies and results (including geographical location of sampling sites)

• availability of a practical regulatory analytical method

• international concern about residues of the compound

• particular regulatory requirements of international markets.

Compounds included in the routine monitoring programme include steroidal substances, hormonal growth promotants (both registered and non-registered), antibiotic and antibacterial compounds, anticoccidials, non-steroidal anti-inflammatory substances, beta agonists, thyreostatic agents, anthelmintics, pesticides, ectoparasitic substances, vertebrate poisons and environmental contaminants such as organochlorines and some elements.

Sampling and testing animals for chemical residues takes place when the animals are sent for slaughter. Confidential sampling plans are issued by NZFSA’s Verification Agency (VA) every two months with six rounds per year. Sample numbers within a two-monthly plan are roughly weighted to slaughter numbers during that period. All sample details are entered into a secure database. The database is used not only for samples taken in accordance with a random monitoring programme, but also for surveillance samples, species verification samples and survey samples.

A unique sample number is then allocated to the sample record. This number is transcribed on to a sample label before it’s packaged, frozen and sent to the laboratory. Laboratory personnel are then able to identify the record in the database and complete the database record as it relates to sample receipt and analysis information.

Samples are the common edible tissue, kidney, liver muscle, fat depending on which tissue has the highest residues (the marker tissue). Additionally for certain compounds, blood and urine from both live and slaughtered animals is sampled and bile from slaughtered animals. Occasionally hair and retina are sampled. Samples are frozen prior to despatch to the laboratory and are analysed on a wet-weight basis.

Reporting of results is done directly to NZFSA’s web-based database.

Surveillance programme for ‘at risk’ animals

The surveillance programme specifically targets animals for testing that are considered to pose a higher risk of containing chemical residues than animals in the general population. This may include:

• animals from suppliers/properties where non-conforming residues have previously been identified in the monitoring programme

• animals that present with injection site lesions

• animals that present with clinical conditions for which a veterinary medicine may have been used just before slaughter

• those animals that an animal products officer has any other reason to suspect may have been exposed to agricultural compounds or veterinary medicines in a non-compliant manner

• bobby calves assessed at ante-mortem inspection as potentially having been treated with an antibacterial compound.

NZFSA VA residue programme coordinators (RPCs) are responsible for coordinating the activities of the programme at the premises and farm level. They are directly accountable to the Director (Standards) at NZFSA, and perform their tasks in accordance with documented procedures.

Analytical results that require further action are forwarded from the laboratory to the relevant RPC for immediate action.

Corrective action procedures

Where residues are identified in excess of the threshold for a particular compound, a traceback is initiated and the finding investigated.

At the same time the supplier’s details, the class of animal at risk, and the non-compliant compound are placed on a Surveillance List. The list is circulated to the NZFSA VA technical supervisors and company management of all licensed meat premises for residue surveillance purposes.

The supplier is notified in writing by the RPC that their name and property have been placed on the Surveillance List and the actions that will be taken by NZFSA.

Subsequent lines of animals submitted for slaughter from the same supplier are retained and a proportion tested for the compound that was found to be non-compliant. Product disposition judgments are made when analytical results are available.

In some situations NZFSA may consider prosecuting offenders and, where appropriate, animals may be subject to movement restrictions. This means they cannot be moved from a property without NZFSA authorisation and may be specially marked.

At the time of result notification, tracebacks are carried out by the NZFSA VA technical supervisor at the premises where the animal was presented for slaughter. Further investigation is carried out by the RPC at the time of suspect listing to:

• determine the cause of the residue finding

• inform and advise NZFSA of possible actions to be taken and to coordinate the handling of suspect animals presented for slaughter.

This traceback involves examining the Animal Status Declaration (ASD) or Supplier Declarations, which detail all the supplier’s animal treatments within a recent specified period (depending on the species); telephone interviews with the supplier and the supplier’s veterinarian if necessary and, possibly, an on-farm investigation.

The suspect-listed supplier must provide a statement that highlights which farming system(s) failed to deliver the animals suitable for slaughter and which farming systems have been improved or instigated to prevent a recurrence.

The initial findings may be referred to NZFSA’s Compliance and Investigation Group assessors if the breach is considered significant and warrants further action. Under the APA, fines of up to NZ$100,000 for individuals and NZ$500,000 for corporate bodies can be imposed upon conviction.

Once there is clear demonstration that subsequent animal products from the offending property remain consistently below the threshold for the previously non-conforming residue, the supplier’s name is removed from the Surveillance List and the supplier is advised in writing.

Species Verification programme

NZFSA’s Species Verification programme is designed to verify the authenticity of the species from which boneless meat and processed meat products have been derived.

Boneless meat includes boneless manufacturing meat, bulk-packed cuts and individually wrapped cuts, as well as edible skeletal muscles (including cheek and neck trimmings) and diaphragmatic and oesophageal muscles.

Premises that store or process boneless meat and are US-listed are included in the Species Verification programme. (The Species Verification programme is included in the United States overseas market access requirements.)

NZFSA issues a sampling plan on a bi-monthly basis that lists the premises or businesses that are selected for sampling purposes. The sampling plan is strictly confidential to NZFSA VA technical supervisors involved in sampling and is kept secure at all times. Cartons from which a sample is taken are retained until test results have been reported, to facilitate traceback.

Research and Development programme

This aspect of the National Chemical Residue Programme is designed to progressively increase its overall capability to provide government, agricultural industries and consumers with a highly effective and credible analytical and consultancy service.

Projects include development of new analytical methods, improvements to existing methods such as testing for more chemicals as one procedure, keeping abreast of international trends by attending international meetings, literature review, consultancy advice, and surveys. Surveys are targeted sampling and analytical schemes that may be operated in addition to the monitoring and surveillance programmes to determine the presence, distribution, prevalence and/or significance of particular contaminants.

Special programmes

Special programmes include those designed for a specific purpose that fall outside the parameters of the other programmes.

In this category, NZFSA has approved a proficiency testing programme for NZFSA VA and official assessors conducting on-site screening tests for sulphonamide residues in bobby calves (SOS test). This programme is managed by AsureQuality Limited.

Before animal product officers or official assessors can perform the SOS test on regulatory samples, they must complete a training programme and meet and maintain a specified standard of competence and proficiency.

The Hormonal Growth Promotant (HGP) programme is designed to ensure that all cattle lawfully treated with HGPs are identified using a special orange ear tag and the animal identification number for that animal is registered on a central database. The list of animal numbers is supplied to processors so that at the point of processing the animal can be identified as having been being treated with HGPs or not. The animal identification system, the orange ear tag and the ASD each complement the other to ensure that product from HGP treated animals is not exported to markets where the substances are banned, such as the EU.