Monitoring of Pesticide Residues in meat and Regulation issues on muscle and fat samples

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1 Monitoring of Pesticide Residues in meat and Regulation issues on muscle and fat samples Ralf Lippold, Björn Hardebusch Limassol, 24 Mai / Monitoring and Regulation

2 Monitoring of Pesticide Residues in meat and Regulation issues on muscle and fat samples Content Regulation Sampling Analyzing 2 2 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

3 Regulation 396/2005 Footnotes in Annex I 3 3 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

4 Meeting on 21 November 2011 in Freiburg 13 experts participated in the workshop: 7 participants from different NRLs for Pesticides in Food of Animal Origin and Commodities with High Fat Content One expert of EFSA Five scientists of the EURL-AO. Name Institution Country Christoph Czerwenka Austrian Agency for Health and Food Safety (AGES) Austria Arvid Fromberg National Food Institute Denmark Hans Mol RIKILT-Institute of Food Safety The Netherlands Patrizia Pelosi Istituto Superiore di Sanità (ISS) Italy Jan Rosmus State Veterinary Institute Praha Czech Republic Darinka Štajnbaher Public Health Institute of Maribor Slovenia Andrew Wyeth LGC Limited United Kingdom Bruno Dujardin EFSA Italy Karin Kypke EURL AO Germany Ralf Lippold EURL AO Germany Karin Malisch EURL AO Germany Biljana Trajkovska EURL AO Germany Walter Zachariae EURL AO Germany 4 4 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

5 General Questions - Is it necessary to have special rules for MRLs with asterisks (MRL set at LOD), or can they be treated like the others? - How is fat soluble defined? as in Reg 396/2005 (marked with F)? by log Pow (greater than 3)? - Milk / Milk products: Shouldn t the judgement of milk products be consistent with the judgement of the milk they are made of? Raw milk from cows: 4 % fat for calculation? what about milk of another animal origin than of cows? - Hen s Eggs: must hen s eggs be differentiated by fat content (< / > 10 %)? - Shall we keep the footnotes at all? or should all information be given in the table itself? - Shall we change the system of key-matrices? - Suggestions for Amendment of Annex I for Matrices of Animal Origin 5 5 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

6 Footnote - Milk and Milk Products old regulation, effective till March 2013 Where the pesticide and/or metabolites (included in the residue definition) is/are water soluble (log Pow less than 3) the MRL is expressed as mg/kg of milk and milk products. Where the pesticide and/or metabolite (included in the residue definition) is/are fat soluble (log Pow greater than or equal to Old 3) the MRL is expressed regulation as mg/kg of cow's milk and whole cream cow's milk. In determining the residues in raw cow's milk and whole cream cow's milk, a fat content of 4 % by weight should be taken as a basis. For raw milk and whole cream milk of another animal origin the residues are expressed on the basis of the fat. For the other foodstuffs listed with a fat content of less than 2 % by weight, the maximum level is taken as half that set for raw milk and whole cream milk, with a fat content of 2 % or more by weight, the maximum level is expressed in mg/kg of fat. In such cases, the maximum level is 25 times that set for raw milk and whole cream milk. The latter does not apply when the MRL is set at the LOD. 6 6 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

7 Milk and Milk Products Old Regulation, Scheme for Interpretation MRL = LOD MRL in mg/kg product Milk, cream, Butter, cheese, Log Pow < 3 MRL in mg/kg product Old regulation MRL LOD Log Pow 3 raw milk / whole cream milk Milk products Cow (4% fat w/w) Other animals Fat < 2% w/w Fat 2% w/w MRL in mg/kg product MRL in mg/kg product MRL= 0.5 MRL in mg/kg product MRL= 25 MRL in mg/kg fat 7 7 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

8 Footnote - Milk and Milk Products Actual regulation Footnote (7) of Commission Regulation (EU) No 212/2013: In all cases the MRL values are expressed as mg/kg of raw milk. Where the residue definition is marked as fat soluble (with F) the MRL is based on raw cow milk with a fat content of 4 % by weight; for raw milk of other species the MRL value shall be adjusted proportionally according to the fat content of the raw milk of that species. 8 8 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

9 Footnote - Milk and Milk Products Actual regulation Footnote (7) of Commission Regulation (EU) No 212/2013; Interpretation if residue definitions marked as fat soluble (with F): 9 9 / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

Eggs and Egg Products 10 10 / Monitoring /

10 Eggs and Egg Products / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

11 Footnote - Eggs and Egg Products old regulation, effective till March 2013 Where the pesticide and/or metabolites (included in the residue definition) is/are water soluble (log Pow less than 3) the MRL is expressed as mg/kg of shelled fresh eggs, for bird s eggs and egg Old regulation yolks; Where the pesticide/or metabolite (included in the residue definition) is/are fat soluble (log Pow greater than or equal to 3) the MRL is also expressed as mg/kg of shelled fresh eggs, for bird s eggs and egg yolks. However, for eggs and egg products with a fat content higher than 10 %, the maximum level is expressed in mg/kg fat. In this case, the maximum level is 10 times higher than the maximum level for fresh eggs. The latter does not apply when the MRL is set at the LOD / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

12 Eggs and Egg Products old regulation, effective till March 2013 MRL = LOD* MRL in mg/kg product Eggs, yolk, Egg Old products regulation Log Pow < 3 MRL in mg/kg product MRL LOD* Fat 10% MRL in mg/kg product Log Pow 3 Fat > 10% MRL = 10 MRL in mg/kg fat / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

13 Footnote - Eggs and Egg Products Actual regulation Footnote (8) of Commission Regulation (EU) No 212/2013: In all cases the MRL values are expressed as mg/kg of eggs. Where the residue definition is marked as fat soluble (with F) the MRL is based on hens eggs with a fat content of 10 % by weight; for eggs of other species the MRL value shall be adjusted proportionally according to the fat content of the eggs of that species, if the fat content is higher than 10 % by weight / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

14 Footnote (7) - Eggs and Egg Products Interpretation if residue definitions marked as fat soluble (with F): / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

15 Meat and Preparations of Meat / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

16 Footnote - Meat and Preparations of Meat old regulation, effective till March 2013 Where the pesticide and/or metabolites (included in the residue definition) is/are water soluble (log Pow less than 3) the MRL is expressed as mg/kg of meat (including fat), preparations of meat, offal and animal fats. Where the pesticide and/or metabolite Old regulation (included in the residue definition) is/are fat soluble (log Pow greater than or equal to 3) the MRL is expressed as mg/kg of fat contained in the meat, preparations of meat, offal and animal fats. In the case of foodstuffs with a fat content of 10 % or less by weight, the residue is related to the total weight of the boned foodstuff. In such cases, the maximum level is one-tenth of the value related to fat content, but must be no less than 0.01 mg/kg. The latter does not apply when the MRL is set at the LOD. 16 / Reg. 396/2005 Annex I Footnotes

17 Meat and Preparations of Meat old regulation, effective till March 2013 MRL = LOD* MRL in mg/kg product Meat/products Old regulation Log Pow < 3 MRL in mg/kg product MRL LOD* Fat > 10% MRL in mg/kg fat Log Pow 3 Fat 10% MRL = 0.1 MRL in mg/kg product, but not less than 0.01 mg/kg / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

18 Meat and Preparations of Meat old regulation, effective till March 2013 Processed or composite products included in the list of matrices caused problems In comparison to the list of matrices of plant origin or to regulations for veterinary medicine products (VMPs) : No processed or composite products are listed in annex I of Regulation (EC) No 396/2005 for food and feed of plant origin. No MRL values for processed or composite products are listed in Commission Regulation (EU) No 37/2010 (MRLs for VMPs) Conclusions for improvement: 1. Reduce the matrices listed for food of animal origin to the raw matrices 2. Processed or composite products are covered by article 20 of 396/ / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

19 Footnote Muscle and Fat Actual regulation Footnote for meat no longer required / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

20 Amendment of Annex I for Matrices of Animal Origin Actual regulation Footnote for meat no longer required Meat deleted in the annex of 396/ / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

21 Amendment of Annex I for Matrices of Animal Origin Actual regulation Advantages: Footnotes for fat soluble compounds would no longer be required MRLs for all tissues can be expressed on a whole product; Based on the logic of Article 20, separate MRLs for muscle and fat would allow the enforcement of any meat samples as they are all composed of muscle and fat; MRL values would have a better traceability as they would be derived directly from the livestock feeding studies; According to the experience of EFSA performing a consumer risk assessment would be simplified; A better comparability with the veterinary drug legislation would be obtained allowing a better inclusion of veterinary drug MRLs in pesticide risk assessment and legislation / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

22 Amendment of Annex I for Matrices of Animal Origin Actual regulation Disadvantage: Review of MRLs for fat soluble pesticides in meat > muscle required Time by time check of MRLs for fat soluble pesticides for muscle in combination with Article 12 reviews All Problems solved? Interpretation of the rules for the checking MRLs much clearer Confusion about sampling/analysing muscle meat fat / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

23 Pesticides analysis in practise Sampling according Commission Directive 2002/63/EC 23 / Monitoring and Regulation 23

24 Sampling according Commission Directive 2002/63/EC Table 3 (meat and poultry): minimum size of laboratory samples Part 1 (non fat soluble pesticides) Mammal meat 0,5 kg Part 2 (analysing fat soluble pesticides) 2.3 Mammal meat parts Either visible fat, trimmed from unit(s) 0,5 kg or whole unit(s) or portions of whole 2,0 kg unit(s), where fat is not trimmable 24 / Monitoring and Regulation 24

25 Applying the new legislation in practise Sampling according Commission Directive 2002/63/EC Tenderloin (beef) No trimmable fat Sample size 2.0 kg (if analysing fat soluble pesticides) 25 / Monitoring and Regulation 25

26 Applying the new legislation in practise Sampling according Commission Directive 2002/63/EC Beef meat trimmable fat Trim 0.5 kg fat (if analysing fat soluble pesticides) Sample size 2.0 kg (whole meat, if analysing fat soluble pesticides) 26 / Monitoring and Regulation 26

27 Applying the new legislation in practise Meat as laboratory sample possibilities for analysing 1. Trim the fat from the muscle and then analyse the fat. 2. Homogenize the whole sample and extract the fat. Analyse an aliquot of the fat. The result will be the amount of pesticide in fat. 27 / Monitoring and Regulation 27

28 Applying the new legislation in practise Meat as laboratory sample possibilities for analysing 3. Homogenize the whole sample and extract the fat. Use the extracted fat for analyzing; Determine the fat content of the sample; Calculate the amount of the pesticide in the fat. 4. Homogenize the whole sample and analyze it. Determine the fat content of the sample; Calculate the amount of the pesticide in the fat. 28 / Monitoring and Regulation 28

29 Applying the new legislation in practise Meat as laboratory sample possibilities for analysing Determination of the fat content. Apply a method validated for the determination of fat; Official methods for determining the fat content in meat and meat products might be the best choice. 29 / Monitoring and Regulation 29

30 Summary The new regulation removes confusions in interpretations of the footnotes. The suggestions by the core working group footnote were fully implemented in Regulation (EU) No 213/2013. For about 25 pesticides MRL values for muscle are actually higher than needed from former calculation on fat basis. In practise this is no real problem because the main amount of the fat soluble pesticides will be cut together with the trimmed fat. MRLs for muscle will be adjusted in line with the new approach when EFSA is reviewing MRLs on a regular basis. The size of a meat sample must be at least 2.0 kg if analyzing for residues of fat soluble pesticides The analyzes can be performed according the usual procedures of the laboratory 30 / Monitoring and Regulation 30

31 Final Thank you for your attention / Monitoring / Reg. 396/2005 and Regulation Annex I Footnotes

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