Improving the classification system inEngland and WalesSAGB Annual Conference 17 May 2011Linden JackFood Hygiene Policy BranchHygiene and Microbiology Divisionlinden.firstname.lastname@example.org
SummaryWhy 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 practicalto apply and does not place a disproportionate burden onshellfish harvestersClearly practical difficulties with applying current system, manyof which are long term issuesDelays in response to high results (downgrades) can have amajor impact on industry but questionable whether provideadditional public health protectionCurrent system is very resource intensive and need to justifyresource allocated to classifying and monitoring shellfishharvesting areasData shows classification for around two-thirds of beds is stableClimate is such that key interested parties are more likely to bereceptive to changes in current system (betterregulation/resource constraints)
Identifying improvementsSAGB/FSA joint workshop for harvesters/Local Authorities inNovember 2010 provided opportunity for industry andenforcement authorities to engage in review process andgenerated proposals/suggestions for improving currentclassification.Carried out an initial assessment of output from workshop andpresented this to Technical Expert meeting 2 February 2011Identified areas for further consideration and timescale for takingthese forward. Majority suggestions from initial workshop beinginvestigated further.Some areas can be progressed relatively quickly while othersneed further evidence collation and, in some cases, furtherresearch before they can be assessed fully.
Initial conclusionsDevelopment and implementation improvements to theclassification system is a long term project.Expect whole process to take at least 3 yearsPhased introduction of changes to demonstrate progress andembed principles which will support the improved systemNeed to establish internal process for implementingimprovements which takes account to the Government sapproach to better regulationAlso need to work with FSA lawyers to make sure revisedclassification complies with the legislation
ProposalsProposals seem to fall into categories:Short term issue already under consideration or that can beassessed and, if appropriate, implemented within the next yearor so. Many of these are procedural issues and/or principlesthat can be embedded into the system to support the improvedclassification process.Medium/Long term proposals where collation and assessmentof evidence is needed before an option can be considered fully.Have an extensive evidence base but further research may beneeded in some cases.
Use of data from sampling and testing carried out by harvesters3 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 protocols Enforcement authorities collect and test samplesSame protocol should be used for all samples taken to generatedata for the classification. Testing procedures and methods alsoneed to comply with the legislation.Protocol has been developed and are currently seeking viewsfrom local authorities, harvesters and other stakeholders.Would like harvesters to pilot the protocol to make sure it ispractical.Establish mechanisms for using data from harvester samplingand testing and verification by enforcement authorities
Blanket C Classification beds where product isgoing for heat treatment or long term relaying Main application would be for cockles Further work to clarify proposal as we may have misunderstood comments at the stakeholder meeting Need 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 product Could support a risk-based approach and allow resources to be targeted at areas where there is a greater risk Will aim to discuss with stakeholders during this financial year but will be prioritised against other proposals.
Develop new approach for dealing with high resultsHigh results can have a major impact on harvesters but it isquestionable whether downgrading areas (as required by thelegislation) some time after the event adds to public healthprotectionToo much resource is spent investigating high results when isdifficult to prove whether these were associated with a one-offevent. Should shift focus so take more proportionate reactiveresponse to high results.High result should still be investigated but should consider e.g.temporary closures with agreed protocol for re-opening ratherthan downgrading area.Needs acceptance that continued monitoring may show waterquality is deteriorating and downgrade will be neededDeveloped approach for long term classification system andplan to use this as a pilot. Expect to finalise protocol and issuefor comment within the next few months
Review sanitary surveys and applications for new bedsNeed to reduce the time taken to classify new beds andpreparation of sanitary survey makes significant contribution tothe delayProtocol developed to allow new species and beds in existingproduction areas to be classified more quickly. Issued forcomment 2 March 2011.Please comment on protocol and let us know if we need to doanything more on this.Development of protocol/guideline for reviewing sanitary surveysneeds further consideration before proposals can be developed
Seasonal classificationConsider whether we can make more use of seasonalclassificationsReview current protocol and consider practices in othercountries to develop a more practical approachWill consider protocol used in Scotland and whether this can beadapted for use in England and WalesWill pay particular attention to facilitating Seasonal Aclassifications
Medium/longer term options
Use of indicator speciesConsider using mussels indicator species to classify all beds ina production areas.Has benefits for a simplified approach to classification andpossible resource savings.Need to review existing evidence and assess impact of usingindicator species e.g. How many harvesting areas would thisaffectWould hope to initiate the review of evidence this year but willtake time to complete. May need to produce an impactassessment and issue formal consultation.
Sampling schedule should be more flexibleGood communication and working relationship betweenharvester and local enforcement officer essentialSampling to be consistent with harvesters own risk assessmente.g during heavy rainfall, CSO release or other pollution eventsprevents harvesting.Provision for harvesters to collect samples would allow moreflexibility in sampling schedule but would need to establishcriteria for sampling scheduleWould support a more actively managed classification systemand reduces resource spent on investigating high resultsWill discuss with stakeholders to learn more about currentpractice and risk management approaches applied byharvestersBegin taking this forward this year but likely to be a longer termwork stream
Risk-based sampling frequency and sampling locationsGenerally have a monthly sampling plan for harvesting areas.Benefits to establishing a risk based sampling frequencypossible taking account of data available on bed, other beds inthe area and end product testing by the harvester.Should also consider whether its possible to extend the areacovered by individual monitoring points so there are fewer pointsin an area.Supports risk based approach for the classificationNeed to consider with colleagues in science team and othertechnical experts before can develop plans for taking thisforward.Will need to balance the resources needed to provide necessaryevidence to support development of a risk based sampling planwith possible benefits.
Active management of shellfish bedsConsider options which would allow the active management ofharvesting beds and develop guidance on applying risk basedmeasures to support active managementThis is a very long term project that requires further research toprovide evidence base to support proposals.Would need to compete with other Agency research prioritiese.g. Campylobacter, Listeria moncytogenes and norovirusNeed to look to working with other partners if we are to deliverthis. Would be a very significant multi-partner project.
Developing sanitary surveys as an active management toolSanitary surveys are very resource intensive but informationthey contain is not generally used once classification has beenestablished except perhaps in outbreak investigationsInitial discussions with defra have indicated they and theEnvironment Agency require similar information to be gathered.We are exploring with defra how the sanitary surveys could bedeveloped into an active management tool for all parties with aninterest in water quality in shellfish production areas.
Change in testing methodologyWe know harvesters have long held views on the unsuitability ofthe MPN method for testing shellfishExpect to issue a letter allowing use of impedence as avalidated alternative method in very near future.Stakeholder workshop suggested harvesters do not always havefull confidence in the data used to establish classification andhave concerns about laboratory performance. Not clear whetherisolated cases or more wide spread problemLimitations on microbiological testing and the nature of thecontamination mean it is possible that results from duplicate andrepeat testing will give differ so benefits of duplicate/repeatsamples are not certainFocus should therefore be on providing a robust data set thatgives accurate reflection of the contamination levels in the areaand laboratory performance needs to be assured.Increased confidence in the classification system and a moreproportionate response to high results may help addressconcerns on this issue but need to consider further.
Local Action GroupsClarify 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 stepsActively working on several proposals continue taking theseforwardStart discussing proposals that require further consideration orclarification before they can be progressed with Agencycolleagues (including FSA lawyers) and external stakeholdersClarify procedures for consultation and implementing changesDevelop overall project plan, including work plan for individualproposals 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 areas Widely recognised reducing contamination in shellfish waters will reduce the food safety risks associated with shellfish. Activities taken forward by Defra Cleaner Seas Forum Minister led Committee which is actively working to improve water quality in shellfish and bathing waters FSA and SAGB are members of the forumNorovirus Priority in FSA s strategic plan and included in our work to reduce foodbornes disease Existing research projects (FSA and defra) and FSA developing research programme on viruses European Food Safety Authority published opinion on viruses next year
AcknowledgementsFSA colleagues in particular Claudia Martins, SylviaAnkrah, Mariam Aleem and the Science andKnowledge TeamSAGB, individual harvesters, local authorities,technical experts and defra colleagues for theirpositive support and contributions
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