Below is a list of issues currently under discussion at Codex and other international forums that are relevant to the Australian Seafood Industry. SafeFish welcomes any technical advice, comments, or input around these issues.
Issues under discussion at Codex
Issues under discussion at other International standard setting forums
Methylmercury – Maximum levels and associated sampling plans
In July 2018, Codex Alimentarius Commission (CAC) adopted maximum levels (MLs) for methylmercury in Tuna (1.2 mg/kg), Alfonsino (1.5 mg/kg), Marlin (1.7 mg/kg) and Shark (1.6 mg/kg). Maximum levels were set based on the ALARA (as low as reasonably achievable) principle. No consensus could be reached on setting an appropriate ML for methylmercury in Swordfish. In December 2022, CAC adopted MLs for methylmercury in Orange Roughy (0.8 mg/kg) and Pink Cusk Eel (1.0 mg/kg). The Codex Committee on Contaminants in Foods (CCCF) has agreed to discontinue the development of MLs for methylmercury in all other fish species due to low levels of methylmercury or insufficient data. CCCF continues to progress sampling plans for methylmercury and in May 2022 agreed that the recommendations for the sampling plans would be considered by CCCF in 2024.
Throughout the development of this work, SafeFish assisted in the upload of some methylmercury and total mercury data from Australian to the GEMS/Food database, and prepared formal technical submissions providing comments on the discussion paper produced by the EWGs to Codex Australia in December 2019, February 2020, September 2020 and March 2021. SafeFish has also continued to advocate that prior to any MLs being established the contaminant needs to be present in amounts that are significant for total exposure and that sampling plans, if developed, should be practical and feasible whilst ensuring food safety using a risk-benefit based approach.
The FAO/WHO will also be convening an expert meeting to consider updating the 2010 report on the risks and benefits of fish consumption and as part of this would consider if there is sufficient evidence to support how selenium-mercury complexes impact toxicity. The FAO-WHO Expert Consultation is planned for 9th to 13th October 2023.
Canned Sardines – Proposal to include Sardinella lemuru in list of approved species
In 2020 the Codex Alimentarius Commission proposed to evaluate if the Standard for Canned Sardines and Sardine-Type Products (CXS 94-1981) could be amended to include the fish species S. lemuru (Bali sardinella) in the list of Sardinella species. Codex Committee on Fish and Fishery Products (CCFFP) has been reactivated to work in accordance with the Procedure for the Inclusion of Additional Species in Codex Standards for Fish and Fishery Product. It was anticipated that the work would be finished by 1stOctober 2022 with the next CCFFP meeting tentatively scheduled to take place in early 2023.
Calanus oil – Inclusion in fish oil standard
A proposal for Calanus oil (derived from Calanus finmarchicus) to be listed as a named fish oil in Standard for Fish Oils (CXS 329-2017) is under consideration by the Codex Committee on Fats and Oils (CCFO). The main lipid class in Calanus oil is wax ester. The proposal to include Calanus oil as a named fish oil will reduce trade impediments and help governments in assessing the quality and the barriers and/or rejection of the product at the trade borders and help manufacturers and traders documenting product authenticity and traceability. It is anticipated that the proposal could be adopted in 2025.
More information on the proposal is available by contacting the SafeFish Secretariat at email@example.com
Diflubenzuron – MRL in Salmon
In December 2021, the Codex Alimentarius Commission (CAC) adopted a maximum residue limit (MRL) for diflubenzuron in salmon at 10 μg/kg in muscle plus skin in natural proportions. This proposed MRL was agreed to by the Codex Committee on Residues of Veterinary Drugs in Foods (CCRVDF) and follows a recent JECFA (Joint FAO/WHO Expert Committee on Food Additives) recommendation. FSANZ currently has a temporary MRL for diflubenzuron in fish muscle of 2 μg/kg.
Extrapolation of MRLs for Veterinary Drugs in Finfish
In December 2021, the Codex Alimentarius Commission (CAC) adopted the approach for the extrapolation of maximum residue limits for veterinary drugs to one or more species. In February 2023, the Codex Committee on Residues of Veterinary Drugs in Foods (CCRVDF) agreed to the proposed extrapolation of
- a MRL of 30 μg/kg of deltamethrin (an insecticide) in muscle of salmon to muscle of all finfish
- a MRL of 500 μg/kg of flumequine (an antibiotic) in muscle of trout to muscle of all finfish
The proposed extrapolations are subject to adoption by CAC in November 2023.
Ciguatera –FAO/WHO Expert Meeting and potential establishment of a Code of Practice
On 19th-23rd November 2018, the Food and Agriculture Organization of the United Nations (FAO) and World Health Organization (WHO) held an expert meeting to develop scientific advice in response to a request from the Codex Committee on Contaminants in Foods (CCCF). In particular, the requested scientific advice to FAO/WHO entailed a full evaluation of known ciguatoxins (toxicological assessment and exposure assessment), including geographic distribution and rate of illness; congeners; methods of detection; and based on this, guidance for the development of risk management options. A copy of the report is available at https://apps.who.int/iris/handle/10665/332640.
The Expert Meeting concluded that although there are many gaps in the available information about ciguatera poisoning; there are some needs that require urgent attention regarding both risk management and research. The main needs for risk management were the definition of clear protocols to avoid the risk of consuming toxic seafood, mainly by local people and tourists, but also consumers purchasing imported seafood from certain areas. This included a well-defined information and outreach programme, and a clear identification of the geographic distribution of fisheries resources and causative organisms, as well as CTXs presence and concentration in different tissues and anatomic parts of the affected fisheries resources. The main research needs referred to detection methods, and the need to have a stable supply programme of analytical standards.
In February 2023, CCCF released a discussion paper that proposes to develop a Code of Practice for the prevention or reduction of ciguatera poisoning. The discussion paper makes note of the many knowledge gaps that remain in regard to analytical methods, human toxicology, monitoring and surveillance programs, climate change, and international cooperativity. The discussion paper was circulated to key stakeholders and SafeFish provided a submission to Codex Australia. The discussion paper will be discussed during the next CCCF meeting to be held in April 2023.
Pathogenic Vibrio species in seafood – Revision of Guidelines
In December 2022, the Codex Committee on Food Hygiene (CCFH) agreed to establish an EWG, subject to approval of the Commission, to revise the guidelines to control pathogenic vibrio species in seafood. Key issues relevant to the control of V. parahaemolyticus and V. vulnificus which could be taken into consideration in the new work as follows:
- updated microbiological monitoring methods including molecular-based approaches;
- latest data on new pathogenic strains, their geographical spread and clinical incidence;
- detection and characterization of Vibrio species;
- novel methods including remote sensing-based techniques, satellite imagery and whole genome sequencing which would facilitate predicting periods of elevated risk and better control the viruses; and
- practical interventions, including pre-harvest interventions (e.g. relaying at harvest such as reduced cooling times), and post-harvest treatments (e.g. high-pressure processing, freezing and pasteurization), contributing to the reduction of risks of vibriosis associated with the consumption of seafood.
More information on the proposal is available by contacting the SafeFish Secretariat at firstname.lastname@example.org.
Viruses in Foods – Revision of Guidelines
In December 2022, the Codex Committee on Food Hygiene (CCFH) agreed to request JEMRA for scientific advice on the following five areas concerning viruses in foods, with a priority on items 1, 3, and 4.
- An up-to-date review of the foodborne viruses and relevant food commodities of highest public health concern.
- A review of the scientific evidence on prevention and intervention measures and the efficacy of interventions in the food continuum.
- A review of the analytical methods for relevant enteric viruses in food commodities.
- A review of scientific evidence on the potential utility of viral indicators or other indicators of contamination.
- A review of the various risk assessment models with a view towards constructing more applicable models for wide use among member countries, including a simplified risk calculator.
Listeria monocytogenes – Revision of Guidelines
In December 2022 the Codex Committee on Food Hygiene (CCFH) agreed to consider the possible revision of the Guidelines on the Application of General Principles of Food Hygiene to the Control of Listeria monocytogenes in Foods (CXG 61-2007). This follows an JEMRA Expert Meeting on microbiological risk assessment of Listeria monocytogenes in foods that was held 24-28 October 2022. Summary report available at https://www.fao.org/food-safety/news/news-details/en/c/1618932/. JEMRA has also recently released a meeting report from 2020 that considers Listeria monocytogenes in ready-to-eat (RTE) foods: attribution, characterization and monitoring (report available at https://www.fao.org/documents/card/en/c/cc2400en).
Safe Use and Reuse of Water in Food Production – New Guidelines under development
In December 2022, the Codex Committee on Food Hygiene (CCFH) agreed to forward the draft guidelines for the general section and an annex on fresh produce to the Codex Alimentarius Commission (CAC) for adoption. CCFH also agreed to establish an EWG to further develop the annex on fishery products.
In March 2023 the Joint FAO/WHO Expert Meetings on Microbiological Risk Assessment (JEMRA) released its report for determining appropriate and fit-for-purpose microbiological criteria for water sourcing, use and reuse in fish and fishery products from primary production to retail. A copy of the report Is available at https://www.who.int/publications/i/item/9789240066281.
Microplastics – Assessing human exposure and implications for human health (FAO/WHO)
In 2022 the FAO released a report titled Microplastics in Food Commodities: A Food Safety Review on Human Exposure Through Dietary Sources. The report outlines the existing literature on the occurrence of microplastics and their associated contaminants in foods. It estimates the dietary exposure of consumers to these materials, highlights some knowledge gaps with respect to their relevance to public health, and offers some recommendations for future work on microplastic particles to support food safety governance. A copy of the report is available at https://www.fao.org/documents/card/en?details=cc2392en%2f.
In August 2022 the WHO released a report titled Dietary and inhalation exposure to nano- and microplastic particles and potential implications for human health. A copy of the report is available at https://www.who.int/publications/i/item/9789240054608. The report considered the exposure from the environment, including exposure via food, water and air. The WHO assessed the risks to human health from exposure to microplastic particles from the environment, and identified research needs and defined the scope of future work needed on microplastic particles to address current uncertainties.
Climate change: Current and anticipated food safety issues (FAO)
In April 2020 FAO released a report titled “Climate change: Unpacking the burden on food safety”.
The purpose of the report was to identify and attempt to quantify some current and anticipated food safety issues that are associated with climate change. The food safety hazards considered in the publication are foodborne pathogens and parasites, harmful algal blooms, pesticides, mycotoxins and heavy metals with emphasis on methylmercury. There is also a section on the benefits of forward-looking approaches such as horizon scanning and foresight, that include microplastics and novel food production systems. The report is available from https://www.fao.org/documents/card/es/c/ca8185en/
Seaweed safety (FAO/WHO)
In 2022 FAO and WHO released a report identifying food safety hazards (microbiological, chemical and physical) linked to the consumption of seaweed and aquatic plants. This report is an output from an Expert Meeting held 28-29 October 2021. A copy of the report is available at https://www.who.int/publications/i/item/9789240058538.