Factors to Consider in Decision Making Given Variability and Uncertainty in Microbiological Risk Assessment: A Governmental Perspective

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IAFP European Symposium, 11-13 May 2016, Athens, Greece Factors to Consider in Decision Making Given Variability and Uncertainty in Microbiological Risk Assessment: A Governmental Perspective Paul Cook Science, Evidence & Research Division Paul.Cook@foodstandards.gsi.gov.uk

Outline of presentation The Food Standards Agency Approach to risk Uncertainty in risk analysis Legislation and guidance Three examples - eggs, burgers, antimicrobial resistance Looking ahead - developments that will impact on variability and uncertainty in MRA

Food Standards Agency: who we are? History Set up in April 2000 as a government department run by an independent board acting in the public interest. Food Standards Scotland from April 2015 Purpose To protect consumers by improving the safety of food and by giving honest, clear information. Food is safe Responsibilities Food and feed safety; risk assessment, management and communication Values consumer first/ open and transparent/ science & evidence based Facts Budget: 150m/ Staff: 1,500 (1,000 in meat plants)

STRATEGIC OUTCOMES Food is safe Food is what it says it is Consumers can make informed choices about what to eat Consumers have access to an affordable healthy diet, now and in the future

What do we mean by safe? The Government does not set out to achieve zero risk, but to reduce risk to a level which should be acceptable to the reasonable consumer Lord Phillips, The BSE Enquiry report, October 2000

Known pathogens: bacteria cause the majority of foodborne illness in the UK Estimate 500K cases/year known pathogens and 1M cases/year overall Foodborne illness caused by known pathogens, by pathogen type Numbers for UK, 2014. Data source: FSA Foodborne Disease Estimation Model.

Tackling Campylobacter in poultry

Vulnerable groups Increasing life expectancies and low rate of fertility in the UK are contributing to an ageing population ONS Population Projections 2013

FSA Approach to Risk Assess using best scientific advice and acknowledge uncertainties: reassess in the light of new evidence Manage: consistent, proportionate; not claim to eliminate risk Communicate: consultation, openness, honesty, role of the media

Perspective and scale of risk assessment - industry and government VTEC O157 Food Water Person-to-Person Animal contact Dairy Meat Fresh produce Milk Cheese Cream Process A Process B Process C Company A Company B Company C

Risk Assessment top down approach Use epidemiological data to define the scale and impact attributing to source (animals, food(s) etc.) Qualitative/quantitative depending on resources (time, data) Hazard(s) Non food Food A Food B Food C

Risk Assessment bottomup approach Qualitative or quantitative depending on resources (time and data availability) May sometimes be feasible to compare/combine approaches Risk Characterisation Hazard Characterisation Exposure Assessment Hazard Identification

Settings, timing and outputs for food safety MRA in the UK Setting Timescale Output type Food hazards and incidents Expert groups, ACMSF Strategic research Hours to weeks Weeks to years Months to years Qualitative or Semi-quantitative Qualitative or semi quantitative Semi-quantitative or Quantitative

Examples of factors that impact on uncertainty in risk analysis Risk Assessment No or limited data Data alignment Spatial Temporal Specificity Consumer behaviour Precision Time Risk Management Point(s) of application Impact Consumer behaviour Tolerability of risk Economic Political Displacement Time

Examples of factors that impact on uncertainty in risk analysis Risk Assessment No or limited data Data alignment Spatial Temporal Specificity Consumer behaviour Precision Time Risk Management Point(s) of application Impact Consumer behaviour Tolerability of risk Economic Political Displacement Time

Qualitative categories for expressing uncertainty in relation to qualitative risk estimates EFSA (2006)

Uncertainty in EFSA Scientific Assessments EFSA s Scientific Committee developing guidance in this area Toolbox of approaches to analysing scientific uncertainties Qualitative and quantitative approaches Flexibility to account for time constraints, new areas where data may be limited as well as established issues. Public consultation June September 2015 Revised draft Guidance published in March 2016 http://www.efsa.europa.eu/en/supporting/pub/1011e Publication anticipated at end of 2017 - currently being trialed by EFSA scientific committees

Legislation and Guidance Legislation Microbiological criteria EC 2073/2005 Based on risk assessment EC 178/2002 Guidance Time/temperatures e.g. 70 o C for 2 minutes Vacuum/modified atmosphere packed foods Advice to vulnerable groups on runny eggs Boil beansprouts for 15 sec

Salmonella and eggs

https://www.food.gov.uk/committee/acmsf/news-updates/news/2016/14899/fsa-launches-consultation-on-eggs-report

Prevalence of target Salmonella serovars in laying flocks detected during National Control Plan sampling in the main egg producing Member States (2011-2014) Source: EFSA and ECDC, The European Union summary report on trends and sources of zoonoses, zoonotic agents and food-borne outbreaks (2011 2014)

Salmonella outbreaks in humans linked to eggs/egg products, England & Wales 26 outbreaks in 2009-14 with confirmed or suspected link to eggs/egg products. 5 with potential link to UK eggs (4 chicken, 1 duck) none linked to UK Lion code eggs in last 7 years 9 outbreaks definitively linked to non-uk eggs 3 outbreaks linked to non-uk pasteurised egg products (caterers/bodybuilders) Several investigations unable to identify a specific source. Source:http://www.food.gov.uk/sites/default/files/consultation/pack/acmsf-egg-report.pdf

No. references retrieved Growth in the peer reviewed literature 1993-2015 To what extent does increasing knowledge help to reduce uncertainty and clarify variability? Source: PubMed accessed 8/5/16

Rare Burgers

Serving of rare burgers in catering Sept 15 FSA board approved serving of rare burgers in catering Source control QMRA modelling the impact of interventions in burger production Time/temperatures to achieve a 4 log reduction in STEC Epidemiological indicators that would prompt revisiting the issue Development of a framework for risky foods

A risk assessment model for Escherichia coli O157:H7 in ground beef and beef cuts in Canada: Evaluating the effects of interventions Use of QMRA model to assess the efficacy of intervention measures on the production chain singularly and in combinations Average probability of illness per serving ranged from no intervention (1.78 x10-4 ) to most effective combination (6.7 x 10-7 ) Used systematic reviews and meta-analyses to critically assess the results of intervention studies Source: Smith et al (2013), Food Control 29:364-381

QMRA for burger production chain* UK QMRA model adapted to focus on catering rather than the home Reviewed available interventions, feasibility, data sources To examine outputs under different cooking scenarios intended to deliver a 4 log reduction Look at the extent and sources of uncertainty and variability Review by ACMSF previous work on safe cooking of burgers *Kosmider et al. (2009). Attribution of Human VTEC O157 Infection from Meat Products: A Quantitative Risk Assessment Approach. Risk Analysis 30: 753-765.

log D (log min) ACMSF Report on Safe Cooking of Burgers 4.0 All data 3.0 This study's model (z = 6.0 C ) 95% upper limit (Student) 99% upper limit (Student) 2.0 ACMSF recommendation (z = 7.4 C ) 1.0 0.0-1.0-2.0 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 80 Temperature ( C) Source: ACMSF 2007

Antimicrobial resistance

The evolving threat of antimicrobial resistance WHO report Chapter 4: Reducing the use of antibiotics in animal husbandry More information is needed on the prevalence of AMR in bacteria of animal origin and its impact on human health, on the quantity of antibiotics used for different indications and on the classes of antibiotics used. Risk assessments and risk management are impeded by a lack of data and/or inability to access available data CODEX has produced guidelines for risk analysis of foodborne antimicrobial resistance CAC/GL77-2011 http://whqlibdoc.who.int/publications/2012/9789241503181_eng.pdf

AMR - Plasmid-mediated colistin resistance (mcr-1 gene) Nov 2015 Plasmid-mediated colistin resistance reported from E.coli in pigs, raw meat and human infections in China. Resistance previously thought to be chromosomal Now becoming an antibiotic of last resort for certain infections in human medicine Animal and Plant Health Agency find mcr-1 gene in E.coli in UK pigs. Public Health England screened WGS archive of 24,000 bacterial isolates for mcr-1 gene (24 hours) found 12 Salmonella and 3 E.coli isolates with mcr-1 Denmark (DTU) reported 6 positives from screening ~3000 WGS

AMR - Plasmid-mediated colistin resistance (mcr-1 gene) In China 0.7-1.4% of inpatient isolates of E.coli and Klebsiella pneumoniae with the mcr-1 gene - much lower than in animals (21%) or pork, chicken (15%). Frequency of the mcr-1 gene in clinical isolates in the UK much lower Qualitative assessment that the direct and indirect risk was very low - medium to high uncertainty - supported by ACMSF Jan 16 - screening of E.coli from retail meat for the mcr-1 gene as an add on to EU antimicrobial resistance monitoring - more data needed! mcr-1 gene now reported from many countries

Looking ahead implications for variability and uncertainty in risk assessment Whole genome sequencing what impact will this have on defining a hazard? Impact on other areas of risk assessment? Implications for previous MRAs? Wider adoption of systematic reviews and metaanalysis Better alignment of data to inform/support MRA rather than using what is available Consistency in the approach to assessing and communicating uncertainty and variability

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