CURRENT ISSUES RELEVANT TO THE AUSTRALIAN SEAFOOD INDUSTRY
Issues under discussion at Codex
Below are a list of issues currently under discussion at Codex that are relevant to the Australian Seafood Industry. SafeFish welcomes any technical advice, comments or input around these issues. A comprehensive report that contains more detailed information on these issues is compiled by SafeFish every quarter, to access the most recent report please click here.
- Methylmercury - Reducing Maximum Level (ML) in Fish
- Histamine - Reducing ML and implementing control guidance
- Ciguatoxins - New standard under development
- Food Additives - Alignment of standard
- Non Dioxin-like PCBs - Review and potential inclusion in Code of Practice
- Fish Oils - Establishment of new standard including setting limits for Arsenic and Lead in Fish Oil
- Lead - Review of ML for Lead in Fish
- Korean SPS Notification - Establishment of limit for Isoeugenol (active ingredient in clove oil)
- Hong Kong SPS Notification - Establishing/reviewing limits for metallic compounds in fish
- Indian SPS Notification - Changing MRLs for antibiotic use in fish
Methylmercury– Proposal under consideration to significantly reduce maximum level in fish
The CCCF have been discussing methylmercury limits since 1992. In 2013, they agreed that consumer advice should not be developed at the international level and was more appropriate at the domestic level. SafeFish was active in comparing the proposed methylmercury levels to those documented in Australian fish, but noted that the global database on contaminants contained little information from Australian fish stocks. In 2017 CCCF agreed to establish Maximum Levels (MLs) for methylmercury in a number of at-risk fish species based the ALARA principle (As Low As Reasonably Achievable). SafeFish continued to advocate and recommended to Codex Australia that if MLs were developed then they should be based on a risk-benefit approach, acknowledging the importance of fish consumption for positive health benefits as well as the risk associated with methylmercury. The initial proposed MLs of 0.3 mg/kg were based on risk only, and would have resulted in an unacceptably high rejection rate (more than 50% for some Australian caught predatory fish). Input from SafeFish also recommended that if MLs were developed using the ALARA principle, then a rejection rate of 2-3% should be used. After much debate, CCCF agreed in March 2018 to establish the following MLs:
|Fish Species||Proposed ML for Methylmercury (mg/kg)|
CCCF also agreed to discontinue the work to set an ML for swordfish (as a consensus could not be reached) and for amberjack (as the average methylmercury levels were sufficiently low). The existing Guideline Levels for methylmercury in fish and predatory fish will also be revoked. Given the implementation of these limits and the discussions that have taken place around this compound, it should be noted that other importing destinations may now also begin testing for methyl-mercury in imported products as a result.
SafeFish provided a submission to Codex Australia for consideration after consultation with the industry around the potential impact of implementing the levels above, and this was fed into the international EWG. It is understood that there will be further opportunity to provide comment and feedback prior to the March 2018 meeting. The global database currently contains little information from Australian fish stocks. Industries that may be impacted by the proposed MLs should consider obtaining information on methylmercury levels in their product for submission to this database. Please advise SafeFish if you have any data on mercury in your product, or would be prepared to obtain this in the near future.
Scombrotoxin fish poisoning (SFP) is a common cause of fish poisoning that occurs in humans. SafeFish has been contributing to the Codex guidance on controlling histamine formation that will be included as a new section in the Code of Practice (CoP) for Fish and Fishery Products. The guidance was adopted by the Codex Alimentarius Commission in July 2018 and will be formally included in the CoP for Fish and Fishery Products following the required amendments to other sections in the CoP that contain technical guidance on histamine and the revision of the histamine provisions within the relevant Commodity Standards.
A copy of the guidance document is available here and will only apply to marine finfish species (e.g. Scombridae, Clupediae, Engraulidae, Coryphaenidae, Pomatomidae and Scomberesocidae) that present the greatest potential for developing hazardous levels of histamine.
The CoP for Fish and Fishery Products and will state that harvest vessels should implement a histamine control system including monitoring and record keeping that provides documented evidence of control. If histamine control records are not available to a receiving establishment, then histamine testing will become a critical control point for receivers.
CCFH is now in the process of reviewing the histamine sections within the relevant Commodity Standards, including sampling plans. The current Codex health-based safety limit for histamine of 200 mg/kg in any sample tested will remain. The histamine decomposition (quality) limit of 100 mg/kg based on the average (mean) of sample units tested will also remain. With good hygienic practices the achievable level of histamine in fish products should be less than 15 mg/kg.
Ciguatoxins – New standard under consideration
The Codex Committee for Contaminants in Food has requested the FAO/WHO direct JECFA (Joint expert committee on Food Additives) to assess risk of Ciguatoxin. The FAO/WHO have identified that ciguatera fish poisoning is an issue that increasingly affects the tropical and subtropical regions of the Pacific and Indian Ocean, as well as the Caribbean Sea. Over the last 10 years ciguatera poisonings accounts for the majority of food safety outbreaks related to seafood in Australia (OzFoodNet data). Ciguatera was considered a high priority issue in the 2016 SafeFish Prioritisation process for technical work. In 2017, CCCF made a request to FAO/WHO for scientific advice to support either the future establishment of MLs for C-CTX-1 and P-CTX-1 and/or the development of risk management guidelines. FAO/WHO have subsequently released a joint call for data on ciguatera poisonings. In light of this, SafeFish initiated a working group with the objective of facilitating the collection and collation of available Australia data in response to the FAO/WHO call.
In March 2018, SafeFish facilitated a teleconference bringing together fourteen participants (from industry, regulatory bodies and research facilities) with expertise on ciguatoxins. The teleconference identified available Australian data that was suitable to collate (including ownership, method of collection and resources of collection). SafeFish then worked with data owners to compile a submission, ensuring the outputs of FAO/WHO risk assessment will be relevant to the Australian situation (see below Platform 4: Communication and Extension – Technical Research Extension Activities for more information). An exciting outcome of this process was that by gathering these experts together for this work, it has formalised a partnership arrangement where all participants have agreed to be involved in facilitating future research relating to ciguatera.
Alignment of Food Additives – Notification of changes to a variety of seafood products
Food additives in 10 frozen seafood commodity standards and for canned shrimp and prawns are to be aligned to the General Standard for Food Additives (CODEX STAN 192-1995). The list of approved food additives and maximum permitted level within the individual commodity standards (above) will be replaced with reference to permissions listed within the General Standard for Food Additives (CODEX STAN 192-1995). The alignment will mean that any additive that is not permitted in the GSFA will also not be allowed to be used in the relevant commodity standards.
Non Dioxin-like PCBs – Revision to cover non dioxin-like PCBs in food and feed
In 2015 the Joint FAO/WHO Expert Committee on Food Additives (JECFA) assessed the toxicity of non dioxin-like PCBs and concluded that based on the available data non dioxin-like PCBs are unlikely to be a health concern for adults and children, but for breastfed infants the safety margin would be expected to be lower. It remains important that efforts are undertaken to reduce or prevent human exposure to non dioxin-like-PCBs. In 2015 CCCF agreed to review the Code of Practice for the Prevention and Reduction of Dioxin and Dioxin-like PCB Contamination in Food and Feeds (CAC/RCP 62-2006) to evaluate if non dioxin-like PCBs could be included. CCCF have recommended that non dioxin-like PBCs be include in the Code of Practice. The practices to reduce the presence of dioxin-like PCBs are also applicable to non dioxin-like PCBs, i.e. there should be no significant change to the current Code.
Fish Oils – New standard for fish oil, maximum level for arsenic and lead under consideration
CCFO have developed a draft Standard for Fish Oils and in March 2017 agreed to forward the draft Standard for Fish Oils to CAC40 for adoption at Step 8. The draft Standard will apply to fish oils that are presented in a state for human consumption. Aspects of the standard will apply to crude fish oils. CCFO have requested CCCF to consider to develop maximum levels for arsenic and lead in fish oils for inclusion into the General Standard for Contaminants and Toxins in Food and Feed (CODEX STAN 193-1995).
The Joint FAO/WHO Expert Committee on Food Additives (JECFA) has identified that there is no safe level of lead and consequently there is a need to maintain the levels of lead in food at the lowest achievable levels, in particular to protect vulnerable populations groups. The 10th session of CCCF (April 2016) agreed to establish an eWG to review the ML for lead in fish in the General Standard for Contaminants and Toxins in Food and Feed (CODEX STAN 193-1995). The eWG extracted data from the GEMS/Food database for samples collected and/or analysed between 1995 and 2016. The eWG recommended that the current ML for lead in fish of 0.3 mg/kg be maintained. This compares to the current domestic level in the FSANZ Food Standards Code of 0.5 mg/kg.
WTO Sanitary & Phytosanitary (SPS) Notifications
Korean SPS Notification (July 2018)
In February 2017 Korea issued a SPS notification that a new Korean MRL for isoeugenol (active component within Aqui-S or clove oil) is being established at 0.01 mg/kg. This MRL came into effect on July 1st 2018 and is currently being enforced by local authorities. The current MRL in Australia for isoeugenol is 100 mg/kg for fish (excluding molluscs or crustaceans). In July 2018 DAWR released a Market Access Advice relating to the implementation of the MRL for Isoeugenol in Fish, to access this please click here. For the SPS notification, please click here. In addition to this the United States Food & Drug Administration (FDA) released a GAIN report in October 2017 which provides an overview of the Korean Seafood Market. For this report, please click here.
Hong Kong SPS Notification (August 2018)
SafeFish has been advised that Hong Kong are in the process of implementing the adoption of Codex MLs for metallic contamination in different food/food groups and will come into effect in November 2019. This will impact fish, crustaceans, molluscs and other aquatic animals. Some of the proposed amendments will be stricter than Australian domestic (FSANZ) and Codex MLs. For more information relating to the proposed amendments, please click here.
Indian SPS Notification (August 2017)
India has issued an SPS notification informing parties that they are proposing to change the Maximum Residue Limits (MRLs) and the use of a large number of antibiotics and other pharmacologically active substances. For the SPS notification, please click here.