CASE NOTES

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Chemical Residues and Export Market Access

Emily Doyle, State Residues Coordinator, Biosecurity & Food Safety, NSW DPI

Posted Flock & Herd September 2021

Australian agricultural exports are complex and valuable industry, with predicted to be worth $46 billion in 2020-21 (ABARES 2021). Australia trades on its clean green image - and trading partners are watching.

The spectrum of importing country requirements for meat and meat products are as broad as the trading partners are numerous.

In the least, meat must be produced to the Australian (domestic standard), at its most arduous trading partners exert additional requirements at all ends of the spectrum - and regularly send auditors to appraise our system.

Residue testing is a mandatory requirement for any country exporting to USA, Canada, Mexico, European Union participants, Japan and Korea and many smaller trading partners.

Auditors interrogate records of residue testing, tracebacks and regulatory interventions to make an assumption and/or judgement about the robustness of the regulatory and quality assurance system.

Issues we might consider domestic, if published in the media can now become escalated to global relevance in a heartbeat should a sensitive trading partner pick up the virtual Aussie newspaper, usually part of their routine risk monitoring activities.

As districts veterinarians, it is important to keep chemical residues in your mind - as a differential diagnosis, a consequence of your actions and as a trade sensitivity.

Some History

Following the organochlorine (OC) crisis of the 80s, Australia has had many repeat encounters with a range of offending residues interrupting trade. Including, but not limited to:

• USA - sulphonamides 1990,
• Canada - penicillin 1991,
• Russia - trenbolone 2014 - that market is STILL closed to Australia, and
• 1994/5 - a new substance, Chlorofluazuron (CFZ) identified in residue testing at abattoir. Originating from 'cotton trash' grazing during severe drought throughout Queensland and most of New South Wales. The detection triggered a major international product recall, properties and cattle being quarantined throughout NSW and Queensland.

The US immediately ceased trading with Australian meat companies and Japan and Korea quickly followed. Large consignments of Australian meat were put on hold regardless of where in Australia it had been sourced. Slaughtering establishments were irrelevant, 'Australia Inc' was the source.

Overnight $100m surety had to be found to keep open trade with the US. After days and nights of deliberations and negotiation this was put in place, later to be reduced and some 18 months later removed but only after other protocols had been put in place and proven.

This was the beginning or expansion of many of export QA programs and systems we know today including:

• National Residue Survey (NRS) had been around since the 60s but took on a greater role,
• National Vendor Declarations,
• HACCP based QA programmes continued to evolvee.g. Cattlecare, now part of LPA.

The National Residue Survey (NRS)

The NRS was established by the Australian Government in the early 1960s following concerns about pesticide residues in exported meat.

Since then, the NRS has expanded to test other animal and plant products for residues of pesticides and veterinary medicines, as well as for other contaminants. NRS is vital part of the Australian system for managing the risk of chemical residues and environmental contaminants in Australian animal and plant products. The NRS supports Australia's primary producers and agricultural industries by confirming Australia's status as a producer of clean food and facilitating access to domestic and export markets.

Since 1993, participating industries have funded NRS residue monitoring programmes and associated activities via levies or direct payments. Exporters of animal products are required under Australian law to participate in a national residue management program and export industries, such as the red meat, pork and seafood industries, use the NRS to satisfy these obligations.

Other industries such as the grain, horticulture or non-exporting animal product industries use the NRS on a voluntary basis in order to demonstrate compliance with state food safety obligations and/or importing country requirements.

Participating industries also use respective NRS residue monitoring data in industry reports as a way of further demonstrating the integrity of their produce to customers.

The presence of chemical residues in food, particularly meat, has a high profile for consumers and dominates public health concerns about the regulation of food safety.

This, and concern about microbial contamination of meat remain the cornerstones of quality assurance systems that are being developed, implemented and audited, and have been put in place by the Australian meat industry to assure the customers of the high quality of Australian beef and sheep meats.

Except for environmental contaminants such as heavy metals, chemical residues in meat generally are from the misuse of chemicals and drugs or failure to observe the prescribed withholding periods (WHP) or export slaughter intervals (ESI) between the last treatment and slaughter.

In most cases failure to comply with prescribed withholding periods (WHP) or export slaughter intervals (ESI) is unintentional though the consequences to the meat industry can be catastrophic.

Residue monitoring has an important role to play in the overall strategy to minimise chemical residues in meat.

Random monitoring

Programmes are designed to estimate the occurrence of a residue(s) by using randomised sampling processes. NRS random residue monitoring data facilitates and underpins the demonstration of:

• compliance with requirements for domestic consumption,
• the certification of commodities for export (where required), and
• the setting or review of Australian Food Standards.

This underpinning helps participating industries to maintain access to important export markets and a competitive advantage in those markets.

Targeted monitoring

Targeted monitoring program run in conjunction with random sampling arrangements and are designed to obtain more focused information concerning known or potential residue problems. These programmes use specific sampling processes tailored to the area or participants of concern.

Traceback

Where appropriate, traceback information is forwarded to industry and government authorities for consideration. Traceback information may also be forwarded to the APVMA for consideration during its chemical review processes.

Where we fit in - Tracebacks

Australia relies on the NRS to generate and provide the evidence to support trade when audits occur and when issues occur. The NRS relies on jurisdictions to do the leg work of tracebacks on farm.

The responsible state or territory agency is required to investigate cases of laboratory detection of residues above the Australian Standard to establish the cause and provide advice to the producer to prevent recurrence. In more serious circumstances, regulatory action may also be taken.

The NRS uses jurisdictions' evidence to satisfy trading partners that our system works, and when issues do arise, they are managed satisfactorily.

Your expertise as the local veterinarian enables you to investigate and pass the local context, and professional lenses over a case to make a judgement about what has occurred and what now needs to be done to ensure that it doesn't happen again.

Tips for top notch tracebacks

What makes a good traceback? The report is the last step to enables the team at the NRS to explain a detection - its origins and why it is not a regular occurrence and why it won't happen again.

• Show the case has been investigated, gather evidence - to support what has occurred, and demonstrate that it is resolved -e.g. blood testing, feed testing, interviews with producers.
• Show you've gotten to the source of the problem and something has been done about it - producer discussion, legal instruments or ongoing monitoring. Regulatory action if that has occurred.
• Be timely - this also demonstrates our system and that we take detections seriously, sometimes trading partners are aware of the traceback or have requested it - timeliness even more critical.
• You are not alone - call the SRC for assistance - sometimes residue isues are bigger than one DV, one region or even one commodity and there are plenty of people to reach out to.
• Remember the NRS pays the states for these activities - make sure you bill them, and make their money work!