Expert Group on Testing of Milk for Antibiotic Residues second meeting: 2 February 2007

Paul Brantom Chair, Vice-chair of Veterinary Residues Committee (VRC) and member of the Advisory Committee on Animal Feedingstuffs (ACAF)
Paul Neaves Independent specialist consultant in retail and food services
Ed Komorowski Dairy UK Ltd
Tim Hampton Milk Link – Quality Standards Manager
Neil Cutler National Farmers – Union and VRC member
Matthew Sharman Central Science Laboratory, York (CSL) (UK National Reference Laboratory)
Phil Sketchley National Office of Animal Health (representing the animal medicines industry)
Keith Lawrence ELANCO and member of VRC

Food Standards Agency

Tim Foster FSA , Head of Primary Production Division
Chris Pratt FSA, Head of Hygiene Policy and Legislation Unit
Ana Miljkovic-Brake FSA, Pesticides, Veterinary Medicines and Biocides Branch
Vincent Greenwood FSA, Pesticides, Veterinary Medicines and Biocides Branch, minute taker

Apologies for absence

Eric Crutcher VMD
Geraldine Hoad FSA, Head of Dairy Hygiene Branch
Jack Kay VMD

1. The meeting opened with a welcome to all, particularly new members Phil Sketchley and Keith Lawrence.

2. It was confirmed that an approach had been made to LACORS for representation in the future. Jack Kay suggested (via submitted comments) that a Defra policy official is invited to join the group.

Action: Chris Pratt to pursue both points

3. The group was advised that the Suspect Adverse Reactions Surveillance Scheme (SARSS) required that bulk tank antibiotic failures should be reported using the 'yellow form'. It was noted that SARSS reports are not mandatory (except for drug manufacturers). However, despite the UK generally being better at making such reports than others, it was thought that relatively few bulk milk tank antibiotic failures are reported. It was agreed to produce a paper for the group explaining the requirements of the SARSS scheme – to be written by FSA in liaison with the Veterinary Medicines Directorate (VMD).

Action: Geraldine Hoad in liaison with VMD

4. Phil Sketchley agreed to circulate the Regulations and Guidance on Pharmacovigilance.

Action: Phil Sketchley

5. In the light of discussions at this meeting, it was agreed that the draft terms of reference would need adjusting drawing on the notes on aims and issues accompanying the draft terms of reference, in particular to include references to developing guidance and a strategy in relation to handling the planned discussions in the EU. A reference to horizon scanning would also be included.

Action: Chris Pratt to amend and circulate for comments

Last Meeting Minutes

6. A number of minor revisions to the draft minutes of the first meeting were agreed.

Action: Secretariat to amend and circulate

7. It was noted, regarding paragraph 15 (concerning legislation), that Malcolm Pott undertook some of the review of Veterinary Medicinal Products.

Action: to be further discussed

8. The potential for the continuing use of antibiotic-contaminated milk in other countries of the EU was confirmed. It was considered that the pressure to process such milk would be greater where it came from within the same company group as opposed to an independent source. In relation to paragraph 12 of the previous minutes, it was noted that the audit non-conformances had been cleared by the companies concerned on the basis that the EDA's letter to the Commission of 19 December 2006, about practices in respect of antibiotic milk, constituted an appropriate response.

9. Withdrawal periods following the antibiotic treatment of cows were discussed. It was noted that withdrawal periods are set for individual animals and not herds, and that due to a change in methodology the periods are now longer than previously. The group agreed that if treatments are carried out in accordance with the product licences, and withdrawal periods are followed, milk in a bulk tank should not fail antibiotic screening. The group considered that non-observance of withdrawal periods for an individual cow within a herd would be unlikely to result in non-compliance of milk in a bulk tank. It was not known how many bulk tank failures are due to a breach of the withdrawal period, but it was thought that most were due to non-wilful errors or misunderstandings. The Chair concluded that the group could now put withdrawal period issues aside.

10. It was mentioned that there was anecdotal 'evidence' that the Government in Ireland had written to dairies about the new way to apply the antibiotic requirements of dairy hygiene legislation. The group would find it helpful, in undertaking its work, to see that advice.

Action: Chris Pratt to contact Irish Government contacts

11. The group discussed the papers 'Practical Solutions to Testing Tanker Loads of Milk for Antibiotics' and 'Strategies for the control of antibiotic residues in bulk milk', prepared by Ed Komorowski and Tim Hampton respectively. It was agreed that the group should endeavour to produce two essential pieces of guidance. The first would explain what constitutes a positive result in a rapid antibiotic screen test. For this, it was suggested that the two papers be combined to address both technical and practical issues including the use of positive and negative controls. It was emphasised that it would not accord with good practice to ignore a positive screen test result unless it could be shown why that result was suspect or incorrect. It was agreed to consider a role for flow charts in this guidance.

Action: Ed Komorowski and Tim Hampton to draft

12. The second piece of guidance would address procedures to meet the regulatory requirements following a positive antibiotic screen test result, wherever it occurs in the distribution chain. This would cover reporting to the competent authorities and the resultant actions expected of each stakeholder involved.

Action: FSA to draft

13. The group considered that once the guidance is finalised it should be drawn to the attention of the European Commission. The handling and timing of this would need to be considered, taking account of the need to produce and implement the guidance in good time.

14. The Chair asked whether a list of antibiotics in common use in the dairy industry in the UK was available, and if so whether it could be correlated with the antibiotics detected by the available test kits. There is information of the NOAH website, which the FSA will search out. Tim Hampton would circulate an industry document which would also be of value. The VMD has published sales data for each veterinary medicines type and this will also be collected.

Action: FSA and Tim Hampton

15. A wall chart has been prepared by the Milk Quality Forum for use by producers setting out advice on how to avoid antibiotic residues in milk. This is to be passed to group members.
Action: Phil Sketchley

16. The sensitivity and detection range of Beta Star was discussed in relation to the CRL validation document. It was agreed that Beta Star is more sensitive than the MRL in a significant number of cases. It was noted that Beta Star would be positive to Cloxacillin, which is widely used in the UK, at six times below the MRL. It was further noted that there were antibiotics that the screen would not detect when present above the MRL. It was agreed that there is a probability that a positive result using Beta Star indicates a breach of the MRL, but that the CRL validation data do not show this to be a high probability, nor does it show what the probability is.

17. One further point that arose in discussion, namely that none of the available rapid screening tests is designed specifically to detect antibiotics at or around the MRL although in some cases they do, by chance. Thus, although in some cases positive results are not indications of a safety concern they are nevertheless taken by the dairy industry as the trigger for further action.

18. It was noted that the use of intra mammary antibiotics represents the biggest risk in terms of the quantities of antibiotics that might find their way into the milk supply. It was thought likely to be of value to circulate material explaining how dry cow therapy works. Paul Neaves mentioned a PowerPoint presentation he had produced on the use and monitoring of antibiotics in the UK. This would be circulated to group members for comment.

Action: FSA and Paul Neaves

19. The issue of breakdown products of antibiotics was mentioned, and it was questioned whether, and if so how, these are taken into account when establishing MRLs for veterinary medicines.

Action: FSA

20. The possibility of inviting a representative of the testing kit manufacturers into the Group was discussed. It was not known whether they have a representative organisation. Paul Neaves sits on an International Dairy Federation committee where kit manufacturers are present, and will raise the matter there.

Action: Paul Neaves

21. Has been arranged for 12 March at 2pm. Venue and agenda to be confirmed, although it was agreed that the agenda should include discussion of the sales figures for antibiotics published by VMD last December.