Minutes of the Animal Feed Law Enforcement Liaison Group meeting: 14 March 2008

Attendees
Keith Millar – FSA HQ (Chairman)
Cheesman - FSA HQ (Secretary)
Ola Fawehinmi - HMRC
Tim Franck – FSA HQ
Mercy Adebisi – FSA HQ (Minute taker)
Allyson Allman - FSA HQ
Alison Taylor – FSA Scotland
Gerard Smyth – FSA NI
Debbie Sharpe – FSA NI
Anthony Higgins – FSA NI
Les Bailey – LACORS
John Badley - HMRC
Janis McDonald - VMD
John Millward - VMD
Dave Harris - AH
Stephen Nixon – DARD NI
Ciaran Cunningham – DARD NI
Helen Garry – DARD NI
Francis Meehan – DARD NI

Agenda item 1 – Welcome and Introductions
1. Morris McAllister (Director of FSA Northern Ireland) welcomed AFLELG members and observers to the Food Standards Agency Northern Ireland. He acknowledged AFLELG’s efforts in promoting a joined up approach amongst feed law regulators and enforcers and also in maintaining consistency in feed law enforcement across the UK. The Chair responded on the behalf of AFLELG and thanked Morris McAllister and other colleagues from FSA Northern Ireland for hosting the sixth meeting of AFLELG.

2. The Chair welcomed members and observers and introduced to the Group those who were attending their first AFLELG meeting – Alison Taylor (FSA Scotland); Debbie Sharpe (FSA Northern Ireland); Anthony Higgins (FSA Northern Ireland); John Badley (HM Revenue and Customs); Ciaran Cunningham (Department of Agriculture and Rural Development Northern Ireland, DARD); Helen Garry (DARD); and Francis Meehan (DARD). The main aim of the meeting was to discuss developments since the last meeting held in September 2007 and also to exchange information on topical feed law enforcement issues. The Chair encouraged everyone to contribute to the meeting which would be minuted and a copy placed on the Agency’s website once finalised.

Agenda item 2 – Apologies for Absence
3. Apologies for absence had been received from: Jacqui Angus (FSA Scotland); Kirsten Dunbar (FSA NI); Jayne Griffiths (FSA Wales); Lindsay Horth (FSA Wales); Roy Smith (Defra); Jonathan Davies (LACORS); and Jon Averns (Association of Port Health Authorities, APHA).

Agenda item 3 – Draft minutes of AFLELG meeting held on 17 September 2007 (MIN/07/02)
Adoption of draft minutes

4. Ron Cheesman invited comments on the draft minutes of the last AFLELG meeting. It was agreed to make two minor drafting amendments.
Action: Secretariat

5. Members were content with the revised minutes which were agreed and formally adopted.

Outstanding issues and matters arising
6. Ron Cheesman summarised matters arising. There were 27 action points from the last meeting most of which had been completed. The remaining action points were currently ongoing and these include:

• The European Commission was yet to convene another working group meeting on sampling procedures. The Agency’s Animal Feed Unit had liaised with the European Commission about this matter but a date is yet to be set
• Ron Cheesman plans to visit Rotterdam with colleagues from DARDNI to view sampling from bulk consignments and use ideas/knowledge gained in drawing up a UK line on sampling procedures prior to the next Commission working group meeting on sampling issues Action: Ron Cheesman/DARD
• DARD had developed its Standing Operating Procedures which will be finalised soon. It was agreed that the Group should be updated on developments Action: Stephen Nixon

Agenda item 4 – Food and Veterinary Office (FVO) Missions
7. The Chair introduced this agenda item. He reported on a recent General Review Mission to the UK by the European Commission FVO (Reference 7713/2008) that took place 3–7 March 2008. This was a follow-up visit to a similar FVO mission conducted in October 2006. The Chair referred to the presentation that he gave on the UK’s control systems on feedingstuffs and animal nutrition, to update FVO officials on developments. The FVO team confirmed that there was no further action required from UK officials responsible for feedingstuffs and animal nutrition controls.

8. The Chair invited comments from members that were present at the recent FVO meeting. Ron Cheesman indicated that the joined-up approach demonstrated by UK regulators and enforcers by forming the AFLELG and also the National Animal Feed Ports Panel proved extremely useful in convincing the FVO that UK competent authorities were working together in order to enforce feed law.

9. The Chair thanked AFLELG members that had contributed to the success of the FVO visit. Copies of the Chair’s presentation; the FVO’s Country Profile document and the FVO closing meeting powerpoint slides were distributed to members and observers at the meeting.

Agenda item 5 – Feed hygiene
Feed hygiene enforcement training courses
10. Ron Cheesman reported on the nine two-day courses on feed hygiene enforcement requirements that were delivered throughout Great Britain between September 2007 and March 2008. The courses had been primarily targeted at local authority officers, 500 of whom had been trained in the past two years. An introductory training course on HACCP, tailored to help officers gain knowledge and understanding on HACCP principles, had also been developed and delivered to 120 officers. There was clear evidence that feed law enforcement officers were enforcing the legislation in line with the training they had received. See the FSA feed hygiene training course timetable.

11. The Chair extended invitations to officials present at the meeting to attend any of the future training courses as a means of developing their knowledge of enforcement issues. Dave Harris and Alison Taylor indicated that they had both attended some of the training sessions and had found them extremely useful. Les Bailey added that enforcement officers had benefited immensely from the training sessions provided. Ron Cheesman mentioned that he was currently liaising with Regional Groups to establish their training needs for the coming financial year. He added that a training course aimed at officers authorised to inspect feed manufacturers was currently being developed. He hoped this would include references to the involvement of AMI in this area of work and be consistent with the approach taken by AMI during their inspections. John Millward and Ron Cheesman agreed to liaise on this matter.
Action: Ron Cheesman/John Milward

Implementation issues
12. Tim Franck referred to the requirement in EC Regulation 183/2005 on feed hygiene (Article 18.3) which requires certain feed businesses to make a declaration that they comply with the conditions of the Feed Hygiene Regulation by 1 January 2008. Although this was partly an administrative procedure it helped raise feed business awareness of the requirements of the Feed Hygiene Regulation. The Agency had publicised this exercise on its website and written to local authorities about this issue on 7 December 2007. See a copy of the letter.

13. Alison Taylor wondered whether there was a deadline for submission of compliance statements by feed business operators (FBOs). Tim Franck said that local authorities should continue to accept statements of compliance from FBOs but should turn their attention to assessing compliance by FBOs with the feed hygiene requirements and not chasing FBOs for statements of compliance. He thanked FSA Scotland colleagues for the publicity exercises that they had conducted on this subject, which had included a series of industry seminars. Stephen Nixon confirmed that DARD NI had also conducted similar publicity exercises by producing feed hygiene leaflets to raise awareness of the introduction of the Feed Hygiene Regulation in Northern Ireland. Gerard Smyth added that FSA NI will be undertaking more feed hygiene publicity exercises at the 2008 Balmoral Agricultural Show taking place at King’s Hall Complex, Belfast from 16–18 May. FSA NI aims to target the smaller feed businesses at the show.

Microbiological criteria
14. EC Regulation 183/2005 on feed hygiene requires feed businesses to comply with specific microbiological criteria. Tim Franck reported that the European Commission had asked the European Food Safety Authority (EFSA) for its opinion. EFSA’s opinion is expected before the end of the year. There are currently no microbiological criteria for feed set out in the Regulation.

National guidance for feed businesses
15. EC Regulation 183/2005 envisages that national guides to good practice, developed by industry can be adopted. Tim Franck indicated that the codes will be widely consulted on. Views from AFLELG and other UK Agricultural Departments will also be sought. The Chair emphasised that it would be useful for the Codes to be agreed across the UK and also recognised at Brussels. He invited FSA colleagues from Scotland, Wales and Northern Ireland to be involved in this work area. The Chair asked Tim Franck to update AFLELG on developments.
Action: Tim Franck

Financial Guarantees
16. Tim Franck updated AFLELG on developments as regards the European Commission’s proposals for feed businesses to have financial guarantees. The Commission’s original proposal would have required feed businesses to have financial guarantees (e.g. insurance) to cover the costs of the withdrawal and possible disposal of feed (and associated livestock and livestock products) from the market in the event of a feed safety incident. The provision was subsequently amended and required the Commission to submit a report to the European Parliament (EP) and the Council of Ministers on the feasibility of a system of financial guarantees. The Commission published its report in August 2007 and this states that a system of financial guarantees is not readily available but technically feasible subject to a number of conditions, not least the costs involved. The Commission intended to carry out a public debate on this issue, over the next two years.

17. Tim Franck reported that the Agency’s Animal Feed Unit had liaised with the Association of British Insurers (ABI) about this matter and ABI had drawn up a position paper confirming that the Commission’s report was flawed and contained many technical inaccuracies. A copy of the paper was distributed to the Group. The Agency’s Animal Feed Unit will continue to update AFLELG of developments.
Action: Tim Franck

Records of cash sales records
18. Dave Harris sought clarification on this subject following an on-farm feed incident that occurred in November 2007, involving goat feed which had been contaminated with mammalian bone meal. It was not possible to trace some of the sheep and goat keepers who had bought this feed as they were unrecorded cash sales. He indicated that if it had been possible to trace animals that had access to the feed, Animal Health could have conducted a risk assessment with a view to killing affected animals or ensuring that they do not enter the food chain. Dave Harris, supported by John Millward referred to the Agency’s earlier view on this subject which was that cash sales do not need to be recorded by persons keeping farmed animals for their own use or as pets. If a similar incident occurred, tracing of animals that Animal Health may want to keep out of the food chain would still be an issue and did not fit in with the traceability objective of the Feed Hygiene Regulation.

19. Tim Franck indicated that the requirement to record all sales to feed businesses is reflected in the Feed Hygiene Regulation (183/2005). He clarified that the Agency’s opinion on this issue was based on the premise that certain non-businesses activities were exempt from the scope of the Feed Hygiene Regulation. Tim Franck said that the Agency had also liaised with industry (AIC) on a similar issue. The Chair asked Animal Health, AMI and DARD NI to liaise with each other about this matter so that everyone had clarity on what the legislation requires and update AFLELG accordingly at the September 2008 meeting. He concluded that the Agency’s Animal Feed Unit will also raise this point with the European Commission at the next meeting of Feed Hygiene Working Group.
Action: Dave Harris/John Millward/Stephen Nixon/Tim Franck

Agenda item 6 – Updates on standing operating procedures/Code of Practice
FSA – Proposed Feed Law Enforcement Practice Guidance
20. Ron Cheesman stated that the proposed Feed Law Enforcement Practice Guidance document, which supplemented the Feed Law Enforcement Code of Practice, had been subject to a public consultation exercise which had ended on 14 March 2008. The Agency’s Animal Feed Unit will finalise the draft Practice Guidance and publish it later in 2008. Views from the National Animal Feed Ports Panel and also those of the LACORS Feed and Fertiliser Focus Group would be particularly welcomed before the draft document is amended. Les Bailey said that LACORS will forward its comments to the Agency shortly. Initial comments received suggested that enforcement officers found the draft Practice Guidance useful. See the consultation package.

Veterinary Medicines Directorate/AMI
21. John Millward referred to the Animal Medicines Inspectors’ Standard Operating Procedures which had now been finalised. Ron Cheesman said that the document appeared to be a very useful document which met the relevant recommendation in the Advisory Committee on Animal Feedingstuffs (ACAF) Review of Feed Law Enforcement. It included references to joint working with local authorities and also material on inspections which might be usefully included in the training of local authority officers. John Millward indicated that VMD would be happy for the document to be used by local authorities if they found it helpful.

DARD
22. Stephen Nixon indicated that DARD was still developing its guidance document.

Animal Health
23. Dave Harris reported that Animal Health was developing its Operation Manual. He said that the proposed memorandum of understanding between Animal Health and LACORS would be incorporated into Animal Health guidance material.

24. The Chair asked DARD and Animal Health to update AFLELG on developments and share the documents when they became available.
Action: Stephen Nixon and Dave Harris

Agenda item 7 – EC developments
Update from Defra/Animal Health on EU feed ban/meat and bone meal (MBM)/use of fishmeal
25. The Chair referred to the update note that Roy Smith had provided. Further information on EU developments on the BSE-related feed ban, specifically relating to feeding fishmeal to young ruminants, is at Annex 1.

26. It was agreed that Defra should keep AFLELG updated on fishmeal controls.
Action: Roy Smith

Coccidiostats (VMD)
27. Janis McDonald provided background information on the requirement for the Commission to produce a report on the use and regulation of prophylactic coccidiostats and histomonostats with a view to phasing them out as feed additives by 2012, for those who had not attended previous meetings.

28. Janis McDonald reported that because the data requirements, assessment and controls of feed additives were equivalent to those for veterinary medicinal products, Defra intended to write to the Commission informing them that the UK supported the retention of the regulation and use of prophylactic coccidiostats and histomonostats under the feed additive legislation. This would be with the proviso that the UK would review its position once it has seen, and consulted stakeholders on, the report the Commission is drafting, together with any accompanying legislative proposals. The draft letter is currently with the FSA for clearance. The Commission has yet to produce the report, but it is expected shortly.

29. It was agreed that VMD would keep AFLELG informed of developments.
Action: Janis McDonald (VMD)

Update on Commission review of EC feed marketing and use legislation
30. The Chair reported that the European Commission recently issued a proposal to simplify the existing legislation on the marketing and use of animal feed. The European Commission has issued press releases on its proposal which can be accessed from the following links:

• First press release
• Second press release

31. The Chair said he would keep AFLELG members updated on developments.
Action: Keith Millar

Draft Commission Regulation on sampling of feedingstuff
32. Ron Cheesman reported that the European Commission was preparing a draft Regulation on sampling of feedingstuff and methods of analysis which will consolidate existing Directives on these matters. The final draft was discussed in Brussels recently and will be published soon. In light of concerns raised by the UK and other Member States the Commission had undertaken to review the sampling methods set out in the draft Regulation in due course as it was recognised there were problems with their application to bulk consignments.

Agenda item 8 – Import controls
Update on respective activities
33. The Chair introduced this subject and invited comments from AFLELG members.

Update on formation of National Animal Feed Port Panel (NAFPP)
34. Les Bailey reported that the inaugural meeting of the NAFPP had taken place at the offices of LACORS on 30 January 2008. The Panel comprises representatives of UK enforcement bodies and government departments (including, FSA, HMRC, LACORS, APHA, Animal Health, DARD NI and local authorities) with an interest in imported animal feed controls. Issues discussed included: liaison arrangements between feed law enforcement authorities/bodies; imports controls; FSA funding for imported feed sampling; training sessions on import controls; and sampling from bulk consignments of imported feed. The Panel also discussed its administrative arrangements. The Panel will meet four times a year to discuss imported feed controls and related issues. Jon Averns from the Association of Port Health Authorities has agreed to serve as the Chair. The position of Secretary remains unfilled.

35. On the behalf of AFLELG the Chair expressed appreciation to Jon Averns (in his absence) for agreeing to serve as the Chair of the Panel. As regards a secretariat for the Panel, the Chair said that the Agency’s Animal Feed Unit would provide a note-taker for future meetings, to draft action points agreed at meetings, which would subsequently be published on the Agency’s website together with the minutes of AFLEG meetings. In addition, the Chair advised members that the Panel had suggested it should become a sub-group of AFLELG. AFLELG members were content with this suggestion. It was agreed that Ron Cheesman should update Jon Averns on the Group’s discussions, and that Ron Cheesman and Jon Averns should keep AFLELG updated on developments.
Action: Jon Averns/Ron Cheesman

36. The Chair invited comments from AFLELG members who were at the inaugural meeting of the Panel. Stephen Nixon supported by Ola Fawehinmi indicated that he found the meeting most useful. John Millward expressed interest in serving as a Panel member on behalf of VMD, and this was endorsed by AFLELG. It was agreed that Ron Cheesman would pass this request onto the Chair of the Panel.
Action: Ron Cheesman

Grant for sampling and surveillance of imported feed in 2008/09
37. Ron Cheesman reported that the Agency had written to local authorities in January 2008 inviting them to bid for monies to support their analyses of imported feed. See copy of the letter. The Agency’s Animal Feed Unit has been working with the Agency’s Imported Food Division on this subject. Bids received from local authorities were being considered and local authorities would be notified in due course of the Agency’s decision on the bids. Ron Cheesman will update AFLELG on developments.
Action Ron Cheesman

38. John Badley updated AFLELG on latest developments at HMRC. A new body known as the UK Border Agency is likely to be formed soon. The Chair asked John Badley to make a presentation to enlighten AFLELG members on proposed changes at HMRC at the next AFLELG meeting.
Action: John Badley

Agenda item 9 – EC Regulation 882/2004 on Official Food and Feed Controls (OFFC)
Guidance on Enforcement Priorities for Animal Feed Law
39. Mercy Adebisi reported on this subject. As indicated in paragraph 6.12 of the National Control Plan (NCP), the Agency’s Animal Feed Unit had prepared draft guidance material on enforcement priorities for feed authorities in Great Britain for financial year 2008/2009. Similar guidance material will be issued by FSA Northern Ireland to DARD. Information contained in the guidance material was gleaned from data submitted to the Agency by local authorities for the 2006 inspection return; information on feed incidents notified under the European Commission’s Rapid Alert System for Food and Feed (RASFF) for 2007, UK on-farm feed incidents; European Commission Recommendations and other EC measures introduced in 2007.

40. The Agency’s Animal Feed Unit has recently circulated the guidance material to local authorities and will forward a copy to AFLELG members shortly.
Action: Secretariat

Reporting against the National Control Plan
41. Ron Cheesman updated AFLELG on developments. The Food Standards Agency in liaison with the UK agriculture departments introduced the National Control Plan (NCP) in 2006, in accordance with requirements contained in EC Regulation 882/2204 on official controls. The NCP had since been updated twice. UK enforcement authorities/bodies will be reporting their monitoring activities via the NCP to the European Commission by the end of June 2008. A questionnaire has been circulated by the Agency’s OFFC team to those Government departments affected to facilitate the drawing up of the report.

Agenda item 10 – RASFF/Feed incidents
42. The Chair reported that there had not been any major feed incidents since the last meeting of AFLELG. Dave Harris said that there was a minor feed incident that involved dog biscuits which had been fed to pigs. Stephen Nixon updated the Group on the outcome of the melamine incident which had occurred in Northern Ireland in 2007.

Agenda item 11 – GM issues
Approval procedures for GM line products
43. The Chair explained that delays in approving new GM lines (typically in excess of two years) which the European Food Safety Authority had deemed to be safe were causing the UK feed industry concerns due to the interruption and restriction of feed supplies from non EU countries. The Agency’s Animal Feed Unit was lobbying the Commission and other interested parties to resolve this matter.

Unauthorised 'Bt 63' genetically modified organism (GMO) rice and rice products from China
44. The Chair reported that the Agency had written to enforcement authorities and other stakeholders to inform them that the emergency measures controlling the import of rice products from the US, which have been in place since 2006, have been amended. From now on each consignment of US rice must be certified free from the unauthorised GM rice, according to the same test method that is used by enforcement authorities in the EU. At the same time, the need for duplicate sampling and testing of every consignment at the point of entry to the EU has been removed. Further information can be accessed from the Agency’s website at the following links:

• Letter to enforcement authorities
• News item from March 2008

The Chair circulated to AFLELG members the European Commission’s press release on this subject.

45. The Chair said that he will continue to update AFLELG on GM issues.
Action: The Chair

Agenda item 12 – Memoranda of Understanding (MoU) between UK Feed Law Enforcement Agencies
Update on bilateral MoUs
46. Ron Cheesman introduced this subject and invited comments from AFLELG members on proposed bilateral MoUs.

LACORS and VMD (AMI)
47. John Millward supported by Les Bailey confirmed that the MoU between LACORS and VMD had been agreed. They acknowledged that the MoU had improved liaison arrangements between both organisations. LACORS and VMD were content for a copy of the MoU to be placed on the Agency’s website. Other AFLELG members were also content for their respective bilateral MoUs to be placed on the Agency’s website when agreed.

LACORS and Animal Health
48. Les Bailey and Dave Harris reported that they had held a meeting in February 2008 and discussed the proposed MoU between LACORS and Animal Health. Both organisations are now fully aware of their respective roles and a good working relationship exists between them. A draft MoU is being drafted and would be agreed by June 2008. The Chair asked LACORS and Animal Health to keep AFLELG informed of developments.
Action: Les Bailey/Dave Harris

49. Dave Harris suggested that Animal Health and AMI could also explore the possibility of developing an MoU between them once the proposed MoU between LACORS and Animal Health has been agreed.
Action: Dave Harris/John Millward

LACORS and DARD NI
50. As regards exchange of information between LACORS and DARD NI, Stephen Nixon and Les Bailey will liaise with each other and update AFLELG accordingly.
Action: Stephen Nixon/Les Bailey

LACORS and AIC
51. Les Bailey confirmed that a draft Statement of Intent had been prepared between LACORS and AIC. As regards frequency and extent of inspections to monitor compliance with animal feed legislation, the industry is keen to involve local authorities with their assurance schemes. John Millward said that depending on the outcome of the liaison between LACORS and AIC, VMD (AMI) might explore the possibility of developing similar liaison arrangements with AIC. It was agreed that Les Bailey should keep AFLELG informed of developments.
Action: Les Bailey

LACORS and APHA
52. Les Bailey reported that LACORS and APHA were currently working together to draft and agree an MoU that would apply to feed and food. This work would be pursued through the National Animal Feed Ports Panel. LACORS and APHA will keep AFLELG updated on developments.
Action: Les Bailey and Jon Averns

Agenda item 13 – Advisory Committee on Animal Feedingstuffs (ACAF) Issues
53. The Chair introduced this subject pointing out that ACAF advises on the safety and use of animal feeds and feeding practices, with particular emphasis on protecting human health, and with reference to new technical developments. Further information on ACAF can be accessed at: acaf.food.gov.uk

Update on ACAF Review of Feed Law Enforcement
54. Mercy Adebisi said that the Agency’s Animal Feed Unit updated ACAF (at its 41st meeting held on 5 March 2008) on progress in completing the Agency’s Action Plan in response to the recommendations contained in the ACAF Review of Feed Law Enforcement. The Committee was pleased with the progress made on implementing its recommendations to improve co-ordination of feed law enforcement. Ron Cheesman elaborated further on the recommendations and actions that the Agency had taken.

55. The Chair thanked Ron Cheesman and his team for their efforts. It was agreed that the Secretariat should circulate a copy of the updated Agency Action Plan (ACAF paper 08/03) to AFLELG member.
Action: Secretariat

Agenda item 14 – Any other business
2007/08 study of dioxins, PCBs and mycotoxins in feed
56. On the behalf of Ray Smith of the Agency’s Animal Feed Unit, Mercy Adebisi reported that the Agency had made £120,000 available to UK feed law enforcement authorities/bodies to allow them to undertake additional analysis of feed for dioxins, PCBs, and mycotoxins during 2007/8.

57. 114 samples of feed and feed products were analysed for dioxins/PCBs. No samples exceeded the respective maximum levels or actions values. 109 samples were analysed for the presence of certain mycotoxins. No samples were found to exceed the maximum level for Aflatoxin B1, or guidance values for Deoxynivenalol, Zearalenone, Ochratoxin A and Fumonisin B1 + B2. The data for both parts of this work will be passed on to the European Commission to add to the pool of data currently available to help aid future risk assessment and risk management activities.

58. The Chair asked Ray Smith (in his absence) to forward an executive summary report of the 2007/08 UK study to AFLELG members and also to give an indication of when compiled data would be sent to the European Commission. [Ray Smith subsequently informed the Secretariat that dioxins data has already been sent to the Commission while data on mycotoxins would be sent by the end of April 2008].
Action: Ray Smith

AFLELG contact list
59. The Secretariat agreed to circulate an updated contact list to AFLELG members.
Action: Secretariat

Agenda item 15 – Date of next meeting
60. In closing the meeting, the Chair said that the seventh meeting of AFLELG would take place on 16 September 2008 at FSA Headquarters, Aviation House, London.

61.Gerard Smyth and Debbie Sharpe thanked AFLELG members for coming to Belfast for the meeting.

Feeding fishmeal to young ruminants proposal

• This proposal was discussed at a TSE Working Group on 10 March 2008.
• The proposal relates to the use of fishmeal for the 'production of milk replacers, distributed in dry form and administered after dilution in a given quantity of liquid, intended for the feeding of young farmed animals of the ruminant species as a supplement to or substitute for, post-colostral milk before weaning is complete'.
• Discussion focussed mainly on the proposed requirement for farmers feeding such products to notify the competent authority.
• The Commission intends to put proposal to the Standing Committee for opinion in April 2008.
• approximately 50% of Member States (MS) indicated support for the proposal. Only 1 MS indicated oppositon. Others had no final position.
• If supported by qualified majority in April, the proposal will have to go for a 3 month scrutiny process by European Parliament/Council, accompanied by the experts' report on the nutritional needs of young ruminants, before it can be adopted.

Prospects for introducing a tolerance principle for trace fishmeal

• This is still looking like a longer term prospect. This is unfortunate, as a tolerance would enable shared equipment to be used to produce feed containing fishmeal and ruminant feed, instead of the current strict physical separation currently required.
• Preliminary results of the latest inter laboratory study indicate that the revised quantitative method remains unreliable (for tolerance).
• The revised method included (i) a counting grid; and (ii) a new calculation. But there was significant variability in the preliminary results which meant that the method could not be validated.
• CRL-AP (Community Reference Laboratory - Animal Proteins) will carry out further analyses and present a report at its next workshop for National Reference laboratories on 15 -17 April 2008. It will look further at variability due to calculation of the 'd value' (an estimate of relative levels of scale and bone in particular types of fishmeal) and sample preparation.
• Whether the above development with classical microscopy is capable of delivering a validated estimation method seems questionable. Near Infra-Red Microscopy (NIRM) holds more promise for a future quantitative test as it is automated and computer analysed. SAFEED-PAP, the Community-funded test development project, is looking at NIRM - but this is unlikely to show results before 2009.