Written by: Mallory Gaines | October 30, 2024
The use of veterinary drugs is generally a prominent topic in global discussions about food and agriculture, but it is particularly a focus for the Codex Committee on Residues of Veterinary Drugs in Food (CCRVDF). I recently had the opportunity to participate in a meeting on behalf of the animal feed industry, which addressed this important topic, working to ensure harmonization of global standards that could otherwise make it challenging to do business.
Typically, the CCRVDF assesses these veterinary drugs and establishes Maximum Residue Limits (MRLs) for specific animal species, so that they are safe for people who eat the animal protein and dairy foods. These MRLs play a crucial role in promoting food safety and harmonizing trade, which is the cornerstone of the Codex Alimentarius’s work.
Recently the CCRVDF shifted its focus from food to feed. The committee posed the question:
“What do we do when there is unavoidable and unintended carryover of a vet drug from feed to food?
Thankfully, “carry over” (i.e., when a veterinary drug is found in the tissue of an animal intended for food, but that drug is not approved for use in that species) is uncommon, but occasionally does exist. As the question states, it is often unavoidable and unintended by the manufacturer. Codex already has established guidelines for good animal feeding practices, and the United Nations Food and Agricultural Organization (FAO) has shared guidelines on how to implement the Codex text in practice. If the feed manufacturer is following the Codex and FAO guidelines, then any carryover is clearly unavoidable and unintended.
However, good manufacturing practices do not address the question above of how do we handle unavoidable and unintended carryover of a veterinary drug from feed to food?
In response, the CCRVDF sought to answer this question and adopted a guideline in setting “action levels” in food when carryover is present. CCRVDF agreed to define action levels as:
“a concentration of residue resulting from unintended and unavoidable carry-over in a feed of a veterinary drug (expressed in mg/kg or μg/kg on a fresh weight basis) in a non-target animal that is recommended by the Codex Alimentarius Commission to be recognized as acceptable in or on a food, above which action should be taken.”
The committee also unanimously agreed that carryover of this nature is not a human health concern and seeks to harmonize trade with an action level.
I attended the CCRVDF as a delegate of the International Feed Industry Federation (IFIF), which the American Feed Industry Association is a member of, representing the global feed industry. In this role, I made two interventions (which, in Codex-speak, means I raised points) on behalf of the industry. When the conversation shifted toward manufacturing practices, I reminded the committee that we had already established that carryover is unavoidable and unintended and as such, cannot be further “fixed,” as it is also not a food safety concern. This intervention helped guide the committee back to the task of how to set the action level. The other intervention again reminded the committee that carryover was not a human health concern.
Ultimately the CCRVDF will ask the Codex Commission, in November when it meets, to adopt the addition of “Criteria and Procedures for the Establishment of Action Levels for Residues of Veterinary Drugs in Food of Animal Origin Resulting from Unavoidable and Unintentional Veterinary Drug Carry-Over in Non-Target Animal Feed (p. 5)” into its procedural manual so that action levels can be set as needed.
Further, the committee is starting new work on a guide for governments on what to do when the action level is exceeded and/or when there is no action level, or one could not be set. This new work, titled, “A Guideline for Actions to be Taken by Competent Authorities Following the Detection of a Residue of a Veterinary Drug in a Non-Target Animal Commodity Associated with Unavoidable and Unintentional Carryover in Feed,” will commence as an electronic working group, chaired by Australia and co-chaired by the United States and Canada once adopted by the Codex Commission.
It was a busy Codex meeting for animal feed. The AFIA will remain diligent, ensuring U.S. animal feed producers are not hindered by Codex’s standards in international arenas by engaging with the U.S. Codex Office, IFIF and our fellow animal feed associations globally. Till next time at Codex- signing off!
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