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From: TSS ()
Subject: Mexico - Control of residues and contaminants in live animals and animal products, including controls on veterinary medicinal products ( BSE?)
Date: March 1, 2006 at 7:47 pm PST

Greetings,


ALL one has to do is read between the lines, and one might come to the conclusion that the BSE Protocols, surveillance, and feed ban also have some 'serious shortcomings'. only God will ever know though. ...TSS

Food and Veterinary Office - Inspection reports
MX Mexico - Control of residues and contaminants in live animals and animal products, including controls on veterinary medicinal products


snip...

5.4.3.2. In feed mills (medicated pre-mixes and medicated feedingstuffs)

Feed mills and on-farm mixers manufacturing medicated feed must be authorised by
SAGARPA Central level. The authorisation is unlimited in time, but must be
updated when changes occur. The CA informed the mission team that there are
currently 365 such establishments authorised. All establishments are required to
have a SAGARPA approved veterinarian employed and the approval of the
veterinarian is renewed every 2 years. The supervision of feed mills for medicated
feedingstuffs, and farms with on-farm mixing of medicated feed is delegated to the
SAGARPA State Offices. The SAGARPA Verification Programme will include
random checks on feed mills.
The mission team noted that:

> in the feed mill visited, growth promoting additives, medicated premixes and
coccidiostats were used routinely. Feed was produced for cattle, pigs, poultry,
shrimps and pets in two lines. No checks for homogeneity, stability,
recovery/content or cross contamination of feedingstuffs were carried out.
There is no system in place to prevent finishing feed to be manufactured directly
after a batch containing additives or medicated premixes;

> in the feed mill visited, several medicated feedingstuffs were marketed in sacks
with the concentration and types of added antibiotics listed on a separate label
stitched to the sack. However, several of the antibiotic combinations marketed
were not listed in the SAGARPA registration document and none of the labels
comprised SAGARPA registration numbers;

> the pig farm visited regularly produced feed with growth promoters and
therapeutic doses of VMPs (carbadox, ractopamine, tyiosin, florfenicol) for the
finishing period. Flushing was used between batches but no checks were made
for cross contamination or recovery;

s> the feed mill visited by the mission team had been inspected by the State Office
once during the last five years while the pig farm with on-farm mixing facility
for medicated feed visited had never been inspected;

> NOM-012-ZOO-1993 requires quality control, including quantitative analysis of
active substances in feedingstuffs. Such analyses were performed by the feed
mill delivering medicated feedingstuffs to the pig farm visited. However, the
feed mill visited only analysed the nutritional components in produced
feedingstuffs. In the inspection protocol from 2003 this fact had been noted as
an observation. The CCA informed the mission team on the spot that additional
analyses were not compulsory for feed mills.

5.4.3.3. On veterinary practitioners and farms

The SAGARPA State Offices are responsible for the controls of veterinary
practitioners and farms and no federal legislation or guidelines have been issued.
Veterinary practices for food producing animals are usually combined with a
pharmacy and thus inspected as pharmacies. The SAGARPA Verification
Programme will include random checks on veterinary practitioners. All poultry and
pig farms are required to have a SAGARPA approved veterinarian employed. This
approved veterinarian signs the animal movement certificates when animals are sent
to slaughter. Movement certificates for other species, e.g. horses, are signed by a
veterinarian of the State Committee (comprising farmers, food producers, federal
state and state government). Animal health inspections for export are conducted by
SAGARPA staff, while health inspections for control programs are conducted by

15

the approved veterinarians on the farms (pigs and poultry) or the Committee
veterinarians (other species). These inspections are coordinated by SENASICA and
include a description of disease problems and medicines used on farm.
The mission team noted that:

> there is no legal requirement for inspections of VMP usage in veterinary
practices or farms;

> there is no legal requirement for farmers to keep treatment records, thus
inspection of VMP usage on farm is based on verbal information from the
fanner or on voluntary farm records 7;

> health certificates for slaughter in TIF slaughterhouses are not required to
contain information or guarantees by the farmer or the approved veterinarian
regarding banned substances or the respect of withdrawal times for VMP;

> in two States visited apiaries were regularly inspected and comprehensive check
lists, including VMP usage, were used.

6. CONCLUSIONS

6.1. LEGISLATION

(1) Hormonal substances and beta-agonists for growth promotion (except
diethylstilbestrol and clenbuterol) are not legally prohibited for use as growth
promoters in food producing animals. In the absence of a split production
system the CCA does not meet Community requirements for the export of
fresh meat (currently only horse meat) to the EU.

(2) Whilst there is a legal basis for the control of residues and contaminants in
tissues of cattle, equidae, pigs and sheep, the absence of national legislation
for residues control of other commodities (e.g. milk, shrimps, eggs and
honey) and the absence of corresponding MRLs militates against effective
implementation of the NRCP, in particular the assessment of analysis results
and execution of follow-up actions.

(3) Several national MRLs and MLs for meat and animal tissues exceed those
fixed in EU legislation; this could result in situations where export
consignments would not meet Community requirements.

6.2. NATIONAL RESIDUE CONTROL PLAN

(1) The general layout of the NRCP and the range of commodities tested are in
line with Community requirements. However, many relevant substances
including EU-banned VMPs are not tested for and a limited number of
substances are tested within certain therapeutic categories. Given the
number of VMPs authorised, the current structure of the plan reduces the
possibility of detecting the potential misuse of numerous VMPs and to
guarantee that export consignments meet Community requirements.

(2) The random selection and number of samples taken in accordance with the
guidelines of the Codex Alimentarius can allow the estimated prevalence rate

7 In their response to the draft report the Mexican CA stilted that in the specific case of aquaculture,
farms must keep a register of the use and application of antibiotics, which will be checked during
the inspections by CONAPESCA.

16

snip...

(2) A prescription system laid down in national legislation in 2004 is still not
implemented. Together with the lack of a requirement for medicinal records
on farms, these factors undermine effective controls on VMPs at retail and
farm level.

(3) The authorisation and use of VMPs containing pharmacologically active
substances which are either banned or are not authorised for use in food
producing animals in the EL) is of concern, considering the absence of some
national MRLs, restricted analytical capabilities and lack of an effective
VMP control system. Cumulatively these factors may result in the presence
of undesirable residues in exported commodities and weaken CA guarantees
on the residue status of exported consignments. It is doubtful that the
relevant requirements of Community food law9 can be met.

6.5. OVERALL CONCLUSION

This first ever residues mission to Mexico revealed serious shortcomings in the
application of residues and veterinary medicines controls, in respect of commodities
currently exported to the EU or which are planned to be exported. In particular, the
authorisation and use of hormones and beta-agonists for growth promotion in the
absence of any 'split system' for EU exports means that Mexico does not comply
with Community requirements concerning the export of meat from potentially
treated animals. In addition, the fact that many veterinary medicines which are
banned for use in food producing animals in the EU are authorised and are freely
available in Mexico, raises concerns on the residue status of several commodities
exported to the EU. This is exacerbated by weak controls on the use of veterinary
medicines, failure to implement the nationally legally required prescription system,
the absence of any obligation to maintain medicinal treatment records on farm and
the fact that there is no laboratory capability at present to test for residues of most of
these substances. Given this situation and shortcomings in the current structure and
implementation of the national residue control plan, the residue control system in
Mexico can not be judged to offer equivalent guarantees to those required under
Community legislation.

7. CLOSING MEETING

A closing meeting was held on 15 September 2005 with representatives of the CA.
At this meeting, the inspection team presented the main findings and preliminary
conclusions of the mission. The CCA did not express major disagreement.

8. RECOMMENDATIONS

The competent authorities were invited to provide details of the actions taken and
planned, including deadlines for their completion ('action plan'), aimed at addressing
the recommendations set out below, within 25 working days of receipt of a draft of
this mission report.

(1) Ensure that consignments of meat and meat products exported to the EU are
not derived from animals which have been treated with hormonal growth
promoters or beta-agonists for growth promotion.

9 Article 11 of Regulation (EC) No 178/2002.

18


snip...

http://europa.eu.int/comm/food/fvo/act_getPDF.cfm?PDF_ID=5018


EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of Mexico
Last updated: 08 September 2004
Adopted July 2004 (Question N° EFSA-Q-2003-083)

Report
Summary
Summary of the Scientific Report

The European Food Safety Authority and its Scientific Expert Working Group on the Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR) were asked by the European Commission (EC) to provide an up-to-date scientific report on the GBR in Mexico, i.e. the likelihood of the presence of one or more cattle being infected with BSE, pre-clinically as well as clinically, in Mexico. This scientific report addresses the GBR of Mexico as assessed in 2004 based on data covering the period 1980-2003.

The BSE agent was probably imported into Mexico and could have reached domestic cattle. These cattle imported could have been rendered and therefore led to an internal challenge in the mid to late 1990s. It is possible that imported meat and bone meal (MBM) into Mexico reached domestic cattle and leads to an internal challenge around 1993.

It is likely that BSE infectivity entered processing at the time of imported ‘at - risk’ MBM (1993) and at the time of slaughter of imported live ‘at - risk’ cattle (mid to late 1990s). The high level of external challenge is maintained throughout the reference period, and the system has not been made stable. Thus it is likely that BSE infectivity was recycled and propagated from approximately 1993. The risk has since grown consistently due to a maintained internal and external challenge and lack of a stable system.

EFSA concludes that the current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The GBR is likely to increase due to continued internal and external challenge, coupled with a very unstable system.



Publication date: 20 August 2004


http://www.efsa.eu.int/science/tse_assessments/gbr_assessments/565_en.html


http://www.efsa.eu.int/science/tse_assessments/gbr_assessments/565/sr04_biohaz02_mexico_report_summary_en1.pdf


http://www.efsa.eu.int/science/tse_assessments/gbr_assessments/565/sr04_biohaz02_mexico_report_v2_en1.pdf

TSS




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