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This article was published in 1998
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ISSUES ASSOCIATED WITH CHEMICAL RESIDUES AND EXPORT MEAT

Reg Butler, Principal Veterinary Officer, Food Policy Branch, AQIS (with acknowledgment to San Ng and Angelo Valois, Food Policy Branch, AQIS, for providing extracts from previous papers that have been incorporated into this paper)

SUMMARY

Exports of Australian meat are worth more than $3 billion each year. The value of product sold on the domestic market is roughly the same. When it comes to production and inspection, meat is amongst the world's most intensively regulated foods.

It is not surprising then that overseas authorities, industries and consumers demand that meat exports consistently satisfy their requirements. The major regulatory constraints on the export of meat from Australia are the requirements of our customers (i.e. the authorities in the countries to which Australia exports).

Overseas authorities demand that Australia regularly demonstrates the integrity of its meat production and inspection system, including chemical residue performance. Overseas consumers are often extremely sensitive to perceived risks with meat safety that can affect purchasing / marketing policies of importers and drastically reduce consumption.

The regulation of chemical residues and promotion of Australia's meat exports is dependant on a complicated set of inter-relationships between primary producers, processors, and different levels of government. If one link in this chain fails in a 'sensitive market', our overseas customers will lose confidence in Australian meat, threatening more than $3 billion in export income. Depending on the degree of sensitivity of the Australian consumer, the local market could be similarly affected.

You here today are an integral part of this system, being at the coal face of extension and regulation of agricultural and veterinary chemicals.

WTO/SPS - Implications for chemical residue standards

The WTO was established on 1 January 1995 and followed the "Marrakesh Declaration" of 15 April 1994, which affirmed that the results of the Uruguay Round of GATT would "strengthen the world economy and lead to more trade, investment, employment and income growth around the world".

On 1 January 1995, Australia was among 76 governments which joined the WTO. As at 1 January 1997. there were 129 members of the WTO. The majority of Australia's meat trading partners are WTO members, the exceptions being Taiwan, China, Saudi Arabia and a few others.

The WTO is committed to:

The Agreement on SPS is one of a number under the WTO. By accepting the WTO Agreement, governments agree to be bound by the rules in all of the multilateral trade agreements attached to it, including the SPS Agreement.

All countries maintain measures to ensure that food is safe for consumers, and to prevent the spread of pests or diseases among animals and plants. These SPS measures can take many forms, such as requiring products to come from a disease-free area, inspection of products and setting of Maximum Residue Limits (MRLs).

As the results of the Uruguay Round will reduce the incidence of other barriers to trade, governments have become more concerned that SPS measures might increasingly be used for protectionist purposes. The SPS Agreement is designed to close this potential loophole. It sets out clearer and more detailed rights and obligations for food safety and animal and plant health measures which affect trade.

The Codex Alimentarius (Latin, meaning Food Law or Code) Commission (CAC or Codex for short) is the international body responsible for the execution of the Joint FAO / WHO Food Standards Program. Established in 1962, the Program is aimed at protecting the health of consumers and facilitating international trade in foods.

The SPS Agreement encourages governments to "harmonise" or base their national measures on the international standards, guidelines and recommendations developed by WTO member governments in other international organisations. For 'food safety' issues (including chemical residues), Codex is recognised by the SPS Agreement.

Sanitary (human and animal health) and phytosanitary (plant health) measures are applied to domestically produced food or local animal and plant diseases, as well as products coming from other countries.

Countries may adopt stricter standards or, if no standard exists, whatever standard they wish. However where a country develops its own standard, it can be called upon to justify the standard on scientific grounds.

The standards must be based on risk assessment supported by scientific evidence. A consistent approach to risk management is required and measures adopted must be the least trade restrictive possible. Equivalence is also recognised and countries can argue that while controls over food production may differ, the outcomes of the control measures are equivalent. Transparency is the key point and new standards must be advised in advance so that others have a chance to comment if they wish. The SPS agreement also provides for a dispute settlement mechanism in cases where a country's food standards are 'challenged'.

CHEMICAL RESIDUES - Why they are important to our meat exports

In a study in 1995 by Terry Nicholls of the BRS, the relative risks to trade facing the Australian meat industry were ranked using the criteria:

The ranking and relative risk show that chemical residues are an important consideration.

  1. Microbiolgical contamination
  2. Self-regulations failure
  3. OCs
  4. Regulatory failure
    Antimicrobials
    Illegal growth promotants
  5. Anthelmintics
    Plant toxins
    Meat substitution
  6. Non-tariff trade barriers HGPs
  7. OPs
    Insect growth regulators
  8. SPs
  9. Heavy metals
  10. Metal shot
  11. Miscellaneous chemicals

The international food safety situation has seen the increasing incidence of food borne illness caused by pathogenic microorganisms, and chemical residues in food, emerge as the main public health concerns of the food industry in the late twentieth century. Some countries have also identified the incidence of natural toxins in foods as an emerging concern.

In recent times the range of issues that have been considered under the umbrella of food safety has been broadened and become much more complex. Such issues in many countries may be driven by consumers' concerns and perceptions. Consumers in general are becoming more sophisticated and demanding when it comes to food safety, and their concerns are becoming much finer.

For example consumer anxiety can arise from an alleged carcinogen, or the hypothetical public health risk of an emerging disease such as BSE, even in countries which are known to be free of this disease. In general consumer groups in Australia tend to be less demanding of Government on such issues than in many overseas countries. These countries may also be our most important and valued customers for some of our agricultural produce (e.g. USA, Japan, South Korea, Taiwan and EU).

Concerns can also be driven by other interest groups in countries that are seeking to protect local industry from imports. In some countries there are also sophisticated groups that actively agitate against specific agricultural industries, such as the meat industry. These groups are typically well organised, well funded and may seize on relatively minor problems in the agricultural industries of exporting countries to meet their own ends.

These lobby groups, often aided by extensive media coverage and the ensuing public reaction, can bring intense pressure to bear on Governments in regard to perceived food safety issues. As a result, Government policy on the safety of imported food can be strongly influenced by these domestic concerns as well as by 'sound science'.

Even if there is no Government reaction on a perceived food safety concern, adverse publicity can have a profound effect on both food retailers and the public. This can result in retailers removing "suspect" foods from sale and cancelling forward orders of produce, or the public avoiding "suspect" foods, or a combination of these two factors. Publicity on CFZ in Japan had exactly this effect in late 1994.

In many cases modern food safety concerns are pushing the boundaries of knowledge, particularly in the areas of epidemiology and analytical methods. As a result these concerns arc becoming more difficult for Government and Industry to deal with and will inevitably lead to food standards of increasing complexity.

DIFFERENCES IN MRLS - A hazard to human health?

There is little doubt that detection of chemical residues in food above domestic or international standards causes public concern and can threaten international trade. However, the issue of whether MRLs should be treated as strict limits, or with a further margin of flexibility comes back to the key question: Are differences in MRLs a hazard to human health or are they issues for risk management and risk communication?

There is a compelling argument to treat MRLs strictly as trading standards. The level that MRLs are set at, the national and international level, is dependent on local and / or regional Good Agricultural Practices (GAPs) / Good Practice in the Use of Veterinary Drugs (GPVDs). National GAPs / GPVDs can vary significantly between countries. At the international level (Codex), the setting of MRLs is also dependent on national GAPs / GPVDs, and while this policy could be expected to result in higher MRLs than national MRLs, in reality this expected trend is balanced by importing countries arguing for the lowest MRLs possible.

We need to recognise that MRLs, though important trading standards which reflect on local and / or regional GAPs / GPVDs, have no intrinsic food safety value. It is the Acceptable Daily Intake (ADI) / Acute Reference Dose (ARD) which are measures of innate toxicological potential for agricultural and veterinary chemicals. Moreover, ADIs not only transcend international frontiers, but to a large extent there is already much common ground on ADIs and how they are calculated. For the vast majority of agricultural and veterinary chemicals, the ADI is acknowledged as providing a conservative margin of safety allowing for differences in sensitivity within the human population, and between human and animal species.

The approach to differences in MRLs between trading partners should be one which encompasses sound risk assessment and risk management principles. The health risk end-point should be the ADI. The approach to determining the safety of imported food commodities should be based upon agreed and internationally accepted criteria for predicting dietary intake of chemical residues, with the intent being to more closely estimate the actual residue intake from the food supply.

Sound risk management decisions involving health and safety aspects of food standards can only come about through the application of transparent and sound scientific risk assessment methods. To promote the transparency and credibility of the risk assessment process, it is important that decisions be thoroughly documented, including all supporting data.

Finally, risk communication has been defined as "an interactive process of exchange of information and opinion on risk among risk assessors, risk managers, and other interested parties". If we consider that people rank risks based on:

then the issue of perceived versus actual risk has to be addressed by governments through the dissemination of factual information. However this is often easier said than done, especially when the complications of media 'beat-ups' and adverse publicity arise.

DIFFERENCES IN MRLS - What are we doing about it?

Recent developments have significantly strengthened the scientific evaluation process on which Codex MRLs are based. However, rejection of product at the point of import can and does occur because of differences in MRLs between countries and despite the existence of Codex standards. Therefore, additional mechanisms need to be established within Codex to further facilitate international trade, while at the same time maintaining the highest degree of consumer health protection possible.

It is clear that for Codex MRLs to be relevant to the objective of facilitating international trade, they must be comprehensive, and able to reflect current chemical use practices in agriculture, while ensuring health and environmental aspects are addressed.

Australia is pursuing various options for further facilitating international trade by the elaboration of appropriate guidelines which could be applied in situations when either Codex MRLs are non-existent or when importing countries apply non-scientific default tolerances (frequently zero or near to zero) which could be considered in breach of WTO disciplines.

The initiatives fall under two headings.

(a) Bilaterally negotiating temporary tolerances with trading partners.

This concept would apply in situations where no importing country MRLs have been established for particular commodity / residue combinations and default tolerances apply. It aims to establish a procedure under which "the doors can be kept open" to trade while more permanent solutions are negotiated. This proposal does not involve acceptance by the importing country of any consignment of product containing residues above the level of the established MRL of the exporting country and / or Codex MRL. Moreover, this would be consistent with the SPS Agreement procedures (default tolerances do not necessarily comply with SPS requirements as they are an automatic application of a tolerance [frequently zero or near to zero] without scientific justification).

It is important to note that this proposal does not suggest automatic acceptance by an importing country of an exporting country's MRL; it does however, pave the way for an orderly exchange of relevant data so that an importing country can undertake its own risk assessment and satisfy itself about the exporting country's MRL.

(b) adoption of "interim" MRLs by Codex

A novel approach for facilitating international trade would be for the CAC and relevant Codex Committees to investigate the possibility of creating a new Temporary Maximum Residue Limit (TMRL) or "interim" MRL category for either a chemical not listed in the Codex system or a commodity not listed for a chemical already in the Codex system, but which is registered under an 'approved' registration system. Of course, this listing would only be temporary, and subject to review by expert committees of the available toxicology and residue data from Codex member countries which have registered the chemical.

A practical example of how this mechanism could work is to briefly outline the case of the ixodicide fluazuron, which is registered in Australia. Import tolerances at the same level as the Australian MRL (7.0 mg/kg ) have been achieved for fluazuron in the US Japan and Taiwan (negotiations are continuing with South Korea) after the toxicology/residue data was assessed by their respective national authorities. In effect, we now have a chemical which has not only been assessed by the registering country (Australia), but which has also has been independently peer-reviewed by three other international agencies. Therefore, there is a case for Codex to consider the possibility of creating a new category for chemicals such as fluazuron until the normal evaluation process (which can take some years) eventually assesses the chemical. Countries would still be able to conduct their own risk assessments and dietary intake calculations to assess whether the MRL was considered safe for its consumers, but this would be a more rational approach than having 'zero' default tolerances operate in world trade.

It will be interesting to see how efforts to progress these delicate issues progress over the next few years.

THE COST OF SYSTEM FAILURE

Statistics on meat production from the major livestock species are detailed below (1997-1998 forecasts).

Numbers on farms (million) Numbers Slaughtered Exports ($millions) Exports(ktonnes) Main Customers
Cattle 26 9 2,500 770 Japan US ROK Taiwan
Sheep 120 32 600 230 US EU Japan Saudi Taiwan
Pigs 2.5 5 ? 10 Asia Pacific Islands
Poultry - 342 ? 12 Asia Pacific Islands

Australia exports meat to over 100 countries. Many of these are considered 'sensitive countries' that have sophisticated import controls (including chemical residue testing), and domestic lobby groups that actively campaign against foreign food imports. Such countries include the USA, Japan, South Korea, Taiwan and the EU.

Clearly either an isolated violative chemical residue detection, or clusters of detections, have the potential to adversely impact on trade. This was clearly demonstrated by the CFZ incident where Japanese supermarkets removed all Australian beef from their shelves. There are also other examples where isolated microbiological findings at import testing, or animal disease incidents that have received wide press coverage have resulted in official, unofficial and commercial barriers to our meat exports.

CONCLUSION

As world trade liberalisation continues to develop, and more export competitors emerge from South America, we will see increasingly competitive markets for meat and a complex and evolving range of food safety issues that includes chemical residues. Rising consumer concerns in overseas markets about meat safety and political exploitation of these concerns by the domestic meat industry in importing countries is becoming more prevalent. As a result, the maintenance of market access is becoming progressively more difficult. The meat industry must maintain high standards of meat safety and chemical residue controls to retain consumer confidence or risk losing market share, here and overseas.

Satisfactorily addressing these issues requires a concerted and united effort from you here today, primary producers, the Australian meat industry, and the Commonwealth and State Governments. The challenge is to ensure that agricultural and meat production and inspection procedures arc updated to keep pace with 'best-practice' developments around the world, so that we retain our reputation as a the one of the world's premier meat exporters.

 


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