Stakeholder meeting on animal feed issues held on 18 July 2008

Food Standards Agency – Animal Feed Unit (AFU)
Keith Millar (Head of AFU) – Chairman
Tim Franck
Stephanie Cossom
Ron Cheesman
Mandy Jumnoodoo
Joseph Nicholas
Ned Mazhar

Food Standards Agency – other
Chris Edwards (Regulation and Consultation Branch)
Gerard Smyth (Northern Ireland)
Stewart Herd (Scotland)
Kerys James-Palmer (Wales)
Delyth Murray-Lines (Wales)

Other Government departments
Stephen Nixon (Department for Agriculture and Rural Development, Northern Ireland)
John Conway (Department for Environment, Food and Rural Affairs)
Roy Smith (Department for Environment, Food and Rural Affairs)
Annie Green (Veterinary Medicines Directorate)

External stakeholders
John Allen (Agricultural Industries Confederation)
Judith Nelson (Agricultural Industries Confederation)
Ruth Evans (Brewing, Food and Beverage Industry Suppliers Association)
Robin Crawshaw (Brewing, Food and Beverage Industry Suppliers Association)
Harry Evans (British Association of Feed Supplements and Additive
Manufacturers)
Chris Gordon (British Equestrian Trade Association)
Claire Williams (British Equestrian Trade Association)
Ed Komorowski (Dairy UK)
Bob Pass (Diageo Global Supply)
Alison Bannister (East Renfrewshire Council)
Keneth Chinyama (Food and Drink Federation)
Karen Percival (Food and Drink Federation)
Paul Allen (Foodaware)
David Halligan (Grain and Feed Trade Association)
Michael Richardson (Grain and Feed Trade Association)
Richard Scales (Hampshire County Council Trading Standards)
David Maxwell (Moypark Northern Ireland)
Hannah Moule (National Farmers Union)
Jim Farquharson (National Association of Agricultural Contractors)
Adrian Riley (National Association of Agricultural Contractors)
Marzena Young (Perth & Kinross Council)
Michael Bellingham (Pet Food Manufacturers’ Association)
Monika Prenner (Pet Food Manufacturers’ Association)
Tony Andrews (Responsible Use of Medicines in Agriculture Alliance)
Graham Fletcher (Seed Crushers and Oil Processors Association)
Keith Ball (Soil Association)

1.1 The Chairman outlined the agenda for the meeting and explained domestic arrangements. Stakeholders were advised that a note of the meeting will be sent to the attendees and it will be published on the website of the Food Standards Agency.

1.2 Apologies for absence were received from Yvette Layzell (ABC Food Safety), Edwin Snow (ACAF), Alison Taylor (Food Standards Agency, Scotland), Stephen Wyllie (Department for Environment, Food and Rural Affairs) and Lyn Insall (Food and Drink Federation).

Guidelines for assessment of feed additives

2.1 AFU said that a new set of feed additive guidelines had been agreed in December 2007 and published in the Official Journal as Commission Regulation 429/2008. These provide detailed advice on what needs to be included in a new application under EC Regulation 1831/2003 on additives for use in animal nutrition. They also contain advice in respect of renewed authorisations under Article 10 of the Regulation for those additives previously authorised under Directive 70/524/EC of 23 November 1970 (concerning additives in feeding stuffs) and 82/471/ECC of 30 June 1982 (concerning certain products used in animal nutrition), and for silage agents.

2.2 AFU also advised that it had received a document, shortly before the meeting, from the European Food Safety Authority (EFSA) setting out its priority list for dossier consideration, with safety as the main criterion. It was proposed that the substances should be divided into different groups in order to improve efficiency and facilitate administrative handling. The high priority groups are silage agents, additives not reviewed by EFSA and substances which bio-accumulate. It was proposed lower priority should be given to recently authorised additives. AFU will send the document to stakeholders in due course.

• Action: AFU to send details of EFSA’s proposals on the re-evaluation of feed additives to stakeholders.

Re-authorisation of additives under EC Regulation 1831/2003 on additives for use in animal nutrition

2.3 For these feed additives to be used and sold after November 2010, an application (according to the guidelines contained in EC Regulation 429/2008) needs to be submitted by this time. It is expected that, as up to 2,000 dossiers might be submitted, there could be a bottle-neck in the assessment system.

2.4 BAFSAM raised concerns about the volume of additive dossiers that EFSA will need to process within the specified timeframe and that many 'generic' additives may not be re-authorised. In addition, BAFSAM stated that the EU Feed Additives and Premixtures Association (FEFANA) were aware of these implications and had advised feed additive companies to submit relevant dossiers to EFSA as soon as possible.

2.5 Within FEFANA a consortia had been established with regard to the preparation of dossiers for 'generic' additives. AIC said that it also had concerns about the potential loss of generic technological additives and had advised its members to consider submitting dossiers as soon as possible. It also sought clarification on the membership of the FEFANA consortia. AFU suggested hosting a meeting with FEFANA, BAFSAM, AIC, PFMA and other interested parties (e.g. VMD) to discuss these issues further, in the coming months.

• Action: AFU to arrange a meeting with interested parties on the re-authorisation of feed additives.

2.6 AFU informed the meeting that the European Commission plans to distribute a letter to interested parties reminding them of the need for re-authorisation applications to be submitted by November 2010. AFU will also write to relevant stakeholders regarding this issue.

• Action: AFU to write to relevant stakeholders in relation to the re-authorisation of additives under EC Regulation 1831/2003.

Trace elements in animal feed

2.7 AFU said that it was expected that EFSA would conduct a review of trace elements in the medium term, possibly to coincide with the re-assessment of Article 10 of EC Regulation 1831/2003 (i.e. the revision of guidelines for the authorisation of feed additives)

The use of coccidiostats and histomonostats in animal feed

2.8 VMD stated that the Commission had produced a report for the European Parliament and Council concerning a decision on whether coccidiostats and histomonostats should continue to be classified as feed additives. The report concluded that this classification should be retained and therefore did not propose any changes to the legislation. The Commission believes that the current system provides a high level of safety for consumers and adequately protects animal health and welfare and the environment while providing a fair framework within which operators can do business. However, the Commission will continue to monitor the development of new substances and techniques for the prevention of the relevant diseases. The report, discussed by the CVOs on 4 July, will be sent to the European Parliament and the Council for discussion and a considered view.

2.9 VMD had been advised by the UK permanent representative in Brussels that it was unlikely that the conclusions of the report would change, even if the European Parliament and Council view was not entirely in agreement. In light of this, VMD said it would not be carrying out a formal twelve week consultation on the report but would circulate it to interested parties for: (a) information; and (b) an opportunity to comment within a six week period.

• Action: VMD to send interested parties the Commission’s report on coccidiostats and histomonostats.

2.10 AFU said that the report had been sent to members of the Advisory Committee of Animal Feedingstuffs (ACAF) who agreed with the proposed continued classification of coccidiostats and histomonostats as feed additives.

Coccidiostats in feed for non-target species

3.1 VMD reported that the Commission had been discussing the setting of tolerances for the unavoidable carry-over of coccidiostats into feeds for non- target species. This had been the subject of ongoing discussions within the Standing Committee on the Food Chain and Animal Health (SCoFCAH), which would be considering a draft Regulation later that day. VMD had written to the Commission in January 2008 to outline the UK position, which is to keep levels as low as possible. VMD wished to maintain the system which had been developed in the UK, whereby the carry-over of tolerances are kept below 1%.

Recent amendments to Directive 2002/32/EC on undesirable substances in animal feed

3.2 AFU advised that recently adopted amendments to Directive 2002/32/EC had still to be published in the Official Journal. The adopted measure is broadly deregulatory as it removes restrictions on certain 'botanical' impurities (including Camelina sativa); increases the maximum permitted level (MPL) for fluorine in marine crustaceans; and rationalises the way that limits are expressed for certain banned pesticides (e.g. DDT). AFU added that it would expect to carry out a period of public consultation on draft Regulations to transpose the measure in due course. It is expected that further amendments to be made to MPLs in Annex I of Directive 2002/32/EC are likely in late 2008 or early 2009.

Update on negotiations

4.1 AFU set out the background to the proposed Regulation which is intended to replace four Directives (Directive 79/373/EC on the marketing of compound feed; Directive 82/471/EC concerning certain products used in animal nutrition; Directive 93/74/EC on feeding stuffs for particular nutritional purposes; and Directive 96/25/EC on the circulation of feed materials) with one directly applicable Regulation. Another aim is to decrease administrative burdens for industry by modernising and simplifying the legislation.

4.2 Since the draft proposal was published in April 2008, AFU had undertaken a six week public consultation to invite stakeholder comments on a set of specific questions. It had also liaised with government officials across Whitehall on the formulation of UK negotiating lines on the proposal. In May 2008 an Explanatory Memorandum and Partial Impact Assessment had been sent to the House of Commons and House of Lords scrutiny committees. It was expected that an updated Impact Assessment, including figures on the likely benefits and costs, would be submitted in autumn 2008.

4.3 Since April 2008 there have also been three Council Working Groups meetings to discuss the proposal (two under the Slovenian Presidency and one under the French Presidency). To date, the negotiations had reached Article 26 of the proposal. The next Council Working Group meetings are scheduled for: 29-30 July 2008, 4 September and 25-26 September 2008. On 14 July 2008, the Agricultural Committee of the European Parliament met to discuss the proposal and is expected to vote on it on 10 September 2008, followed by a plenary vote in 17-20 November 2008.

4.4 DARD sought clarification on the timing of the European Parliament elections and asked about the potential impact this could have on the negotiations. AFU said it would keep stakeholders informed of developments.

4.5 GAFTA expressed concern about the definition of 'batch' in the draft text. It said that it might not be possible for the definition to be applied to bulk consignments and batches of different origins and different types. AFU said that it had raised these concerns in Brussels and the revised text might cover this point. BETA said that it accepted the proposed definition of 'food-producing animals' on pragmatic grounds because it meant that horses would not be defined as pets.

4.6 Most Member States were in favour of the repeal of percentage ingredient declarations. AFU advised that percentage ingredient declarations are not a requirement of food law and the repeal is in line with the Commission’s aim of reducing administrative burdens. AIC said that it supported both the proposed repeal and the provision to withhold formulation information in response to customer requests if this would compromise the feed industry’s intellectual property rights. The NFU agreed with this and added that generally farmers did not require detailed product information. Hampshire County Council and DARD said that they considered percentage ingredient declarations as creating difficulties from an enforcement perspective.

4.7 Member State views were divided on the proposal’s provisions on the labelling of feed additives. AIC said it would prefer the status quo, which requires the declaration only of certain additives subject to a MPL, to be maintained as detailed information on feed additives was not generally required by purchasers. PFMA said that recent market research it had carried out showed that most pet food purchasers did not favour detailed information on additives. It suggested that it would be preferable if such information could be made available to pet food purchasers on request.

4.8 The Soil Association enquired whether percentage levels of non-organic feed in organic feed would be required on the labels of feed materials. If it was a mandatory requirement that the presence of all additives had to be declared, then this might expose the inadvertent use of unauthorised substances. AFU said that there was existing legislation on additives for feed use (i.e. EC Regulation 1831/2003) and legislation on organic feed. It added that while it thought it would be unlikely that proposal would conflict with existing organic feed legislation, clarification will be sought. However, AFU confirmed that the proposal specifically excluded GM feed materials and medicated feeds.

• Action: AFU to seek clarification from the Commission that organic feed legislation will remain outside the scope of the proposal.

4.9 BFBI said that it wanted the status quo maintained for analytical declarations for feed with a moisture content of over 50%. The existing legislation (Article 6.3(b) of Directive 96/25/EC) contains a derogation - feeds derived from agro-industrial processes and with a moisture content greater than 50% do not have to be labelled with information concerning weight, protein and certain other particulars. This point had been raised in Council Working Group and a considered response from the Commission was awaited. AFU had also made a series of other editorial amendments to the draft text with regard to analytical tolerance levels but the Commission had advised that no changes were to be made at this stage. Nevertheless the Commission had promised to circulate a paper on this issue. Diageo Global Supply said that some of the proposed declarations for tolerance levels could cause financial difficulties for feed manufacturers because many of the tolerance levels in Annex III of the proposal might not be scientifically attainable. AFU requested that BFBI and Diageo Global Supply furnish it with further details of their concerns on this issue. AIC said that it had recently made comments on Annex III and discussed these with Commission officials.

• Action: Diageo Global Supply and BFBI to furnish AFU with details of their concerns in relation to Annex III of the draft proposal.

4.10 BAFSAM informed the meeting that it had been working with FEFANA to develop a code of practice in relation to voluntary labelling declarations, especially those concerning premixtures and complementary feeds. AFU said it would be meeting FEFANA to discuss this. BETA, AIC and DARD expressed concern over the inclusion of logos and pictures on feed labels, which they considered could lead to feed manufacturers having to label the percentage inclusion of the ingredient depicted even though no specific claim for its presence was made.

Microbiological criteria including national codes of practice for control of salmonella

5.1 AFU said that EFSA’s Panel on Biological Hazards had very recently delivered its scientific opinion on 'Microbiological Risk Assessment in feedingstuffs for food-producing animals for both public health and animal health' earlier in the month. This stated that in order to ensure production of safe feed, the application of HACCP principles (as specified in the EC Feed Hygiene 183/2005) and good manufacturing practices was necessary. See the Opinion on the Commission website. AFU said it would consult stakeholders for their views on the Opinion.

5.2 It was noted that Defra was currently working with AFU and AIC on producing voluntary codes of practice on the control of salmonella (which would cover feed materials and feed additives). AIC said that this involved the revision of long-standing codes, originally produced by the Ministry of Agriculture, Fisheries and Food, which covered feed materials and feed additives; transport and storage; and, the production of finished feed. The finalised codes of practice will take into account the provisions of the EC Feed Hygiene Regulation; current zoonosis knowledge; and the requirements in various relevant assurance schemes. AIC added that it will share the texts on feed additives with BAFSAM prior to Defra launching a public consultation on the codes of practice, which is expected to commence in the coming months. Defra clarified that the finalised codes of practice will be available as booklets and it would be giving a presentation on this to an ACAF meeting in September 2008. The codes will be available in booklet form and will be publicised to the feed industry by means of an article in a forthcoming issue of 'Feed Compounder' magazine.

• Action: AIC to share texts on feed additives, with reference to the codes of practice for control of salmonella, with BAFSAM prior to public consultation on the codes.

• Action: The Food Standards Agency to consult interested parties on EFSA’s opinion on microbiological criteria.

5.3 Diageo Global Supply said it had provided input to four of the codes. However, it raised concerns about some of the methods employed in the setting of the microbiological criteria, especially with regard to cost effectiveness.

EC developments (i.e. financial guarantees, Community guides, and lists of non-EU countries)

5.4 AFU reminded the meeting that in August 2007 the Commission had published a report to the European Parliament and the Council on the feasibility of financial guarantees in the feed sector (Ref: COM (2007) 469). The report concluded that it was 'technically feasible' for there to be a requirement for feed businesses to have financial guarantees (e.g. insurance) and invited debate on this issue. However, there had been no developments regarding this and it was explained that, since the publication of the report, the legislative context had changed considerably. It was not clear whether the system for financial guarantees would have applied to farmers.

5.5 In accordance with Article 20 of Regulation 183/2005, three Community guides put forward by EU trade associations to assist feed businesses to comply with the requirements of the Regulation had been adopted. These guides covered feed materials, feed additives and pet food, respectively. The NFU said that it was awaiting feedback from COPA-COGECA (the European organisations representing farmers and farming co-operatives) on the national guide to good on-farm feeding practice that it had submitted as a basis for a Community guide.

5.6 AFU reported that there had not been any recent developments concerning the Commission’s proposed list of third country establishments which would be permitted to export feed products to the EU.

Reduction of administrative burdens

5.7 The Regulation and Consultation Branch (RCB) of the Agency, who have lead responsibility in the area of administrative burden reduction, provided the meeting with an update. It said that it was interested in hearing from stakeholders on the costs of the burden imposed by the record-keeping requirements of Regulation 183/2005, and whether stakeholders had ideas on reducing administrative burdens resulting from the Regulation. AFU reinforced this point and asked stakeholders to consider whether they thought the Regulation contained any requirements already fulfilled by businesses through their membership of assurance schemes or compliance with other existing pieces of legislation.

5.8 RCB advised stakeholders that it was important for it to receive figures and estimated costs from industry, which it hoped it could use when working with the Agency’s economists on the reduction of administrative burdens, and to inform negotiations in Brussels.

• Action: Stakeholders to provide figures on the costs of administrative burdens imposed by the Feed Hygiene Regulation and other relevant legislation.

Animal Feed Law Enforcement Liaison Group (and National Ports Panel)

6.1 AFU provided background on the Animal Feed Law Enforcement Liaison Group (AFLELG). AFLELG was created in 2005 following recommendations from ACAF and the European Commission’s Food and Veterinary Office (FVO), which encouraged greater consistency and co-ordination between UK enforcement authorities. The Group comprises representatives from UK enforcement bodies and government departments with an interest in animal feed law, including members from Defra, VMD, the Animal Medicines Inspectorate (AMI), the Animal Health Institute (AHI), the Local Authorities Co-ordinators of Regulatory Services (LACORS) and DARD. It meets twice a year to discuss enforcement related issues, to identify common problems and agree to a consistent and co-ordinated approach to feed law enforcement. The Agency hosts meetings of the Group and provides the Chair and secretariat. See minutes of the meetings.

6.2 The Chairman gave special thanks to the AFLELG Secretariat and DARD for arranging the last AFLELG meeting so efficiently and stressed the important role the Group played in exchanging views on topical enforcement issues and ensuring consistency of approach throughout the UK.

6.3 DARD said that it found AFLELG to be an extremely effective body and said it appreciated the flow of information, managed by the Group, in relation to emergency planning. Hampshire County Council said that it found AFLELG to be a useful organisation in establishing the responsibilities of enforcement bodies. Perth and Kinross Council acknowledged AFLELG as well and said that in Scotland an enforcement group, the Scottish Food Enforcement Liaison Committee (SFLC), carried out similar work. The Chairman explained that while SFLC played an important role it was necessary to ensure that there was consistency in approach among enforcement bodies in England, Scotland, Wales and Northern Ireland, hence the establishment and continuous important UK-wide role for AFLELG. He re-iterated this point by pointing out that an FVO mission on UK feed law enforcement was expected in 2009.

6.4 AFU explained that AFLELG has been working on several memoranda of understanding between its various member organisations. So far, the Group has established memoranda of understanding between LACORS and VMD, and was working on a similar agreement between the AHI and LACORS, on feed hygiene enforcement. Discussions have also started on the co-ordination of import controls on animal feed and are being pursued via the National and Feed Ports Panel (NAFPP) which held its inaugural meeting in January 2008. NAFPP mainly comprises UK enforcement officers and is a sub-group of AFLELG. The Chairman encouraged attendees to consider joining if they are based in an area where there is a port.

6.5 NAFFP has proposed that feed law enforcement is incorporated into the Agency’s Guidance and Regulatory Advice on Import Legislation (GRAIL) web-based database which can be found at food.gov.uk/grail. It is anticipated that this initiative will help local authority officers have better access to the law relating to import controls on feed.

Imported feed controls

6.6 AFU said the Agency had undertaken a considerable amount of work in relation to the list of 'high risk' products of non-animal origin (non-POAO) covered by Article 15(5) of EC Regulation 882/2004 on Official Food and Feed Controls. The Agency had been establishing a framework to bring arrangements for non-POAO more into line with those for POAO. This specifies that importers must pre-notify the relevant authorities of the arrival of such consignments and present these at specific points that have been designated specially to deal with them. The Agency had drawn up a list of 'high risk' products and had launched a public consultation on this.

6.7 Hampshire County Council enquired whether imports of 'high risk' non-POAO products would only be allowed through designated ports. AFU said that this was likely but could not yet be confirmed. It was expected that the earliest date for implementation of the measure would be early 2009.

Update on feed incidents

6.8 AFU reminded stakeholders of Commission Decision 2008/352/EC of 29 April 2008, which imposes special conditions on guar gum originating in or consigned from India due to the risk of contamination by pentachlorophenol (PCP) and dioxins, which came into force on 5 May 2008. This requires that consignments of guar gum originating in or consigned from India, or compound feedingstuffs and foodstuffs which contain at least 10% guar gum originating in or consigned from India, be prohibited from being first placed on the market unless they are accompanied by an original certificate of analysis.

6.9 In addition, stakeholders were reminded about the emergency measure adopted by the Commission, which applied from 15 April 2008, to make sure that rice and rice products imported from China do not contain unauthorised genetically modified (GM) rice known as 'Bt63'. Local authorities had been asked to liaise with businesses in their area that may have sold affected products. It was noted that although both measures mainly concerned food, there was some potential for these food materials to be used as feed.

6.10 A brief background history was given of the recent incident concerning animal material in wheat feed for ruminants, which had resulted from the diversion of material intended for use as biofuels into the feed chain. Animal Health, an agency of Defra with responsibility for the enforcement of Transmissable Spongiform Encephalopathy (TSE) feed law, had recently completed its investigations into this incident. An extensive tracing exercise had been carried out to establish the distribution of the feed material. It was established that this material was very low risk and present at very low levels. A total of 815 feed samples were collected and tested, of which 13 proved positive for low level contamination.

6.11 At the Agency’s request, tests had also been carried out which had eliminated any possibility of other types of contamination. Defra, on behalf of Animal Health, thanked AIC for providing key information on the contamination which had originated in Sweden. AIC requested a formal review meeting with Animal Health to discuss the lessons learned from the work done on this incident. Defra agreed to pursue this and it was decided that it would be prudent for AFU and NFU to also attend. DARD queried whether it would be possible for enforcement bodies to be formally advised on any review which had been carried out on the incident. AFU agreed to include this item on the agenda of the next AFLELG meeting.

• Action: Defra (Animal Health) to consider organising a formal review of the wheat feed contamination incident, involving AIC, NFU and AFU.

• Action: AFU to include an item on the outcome of the investigations of the wheat feed contamination incident in the next AFLELG meeting on 16 September 2008.

6.12 AFU said that work on the wheat feed contamination incident provided a successful example of interdepartmental co-operation. It added that it would be writing to biofuel companies, in liaison with LACORS, to advise them of their responsibilities as feed businesses operators under the EC Feed Hygiene Regulation (183/2005).

• Action: AFU to write to biofuel companies to advise them of their responsibilities as feed businesses operators under the EC Feed Hygiene Regulation (183/2005).

6.13 On a related issue, PFMA raised concerns about the proposed revision of the categories groups of risk materials in EC Regulation 1774/2002 laying down health rules concerning animal by-products not intended for human consumption. It queried whether the relaxation of existing rules could lead to co-products from the bio-fuels industry being used in pet food. Defra replied that no relaxation of controls was planned for categories 1 and 2 of the Regulation and there would be a public consultation on the issue soon.

EC developments

7.1 AFU reminded stakeholders that last year a Commission (DG Agri) report on 'asynchronous authorisations' of GM products stated that the EU takes a minimum of 2.5 years to authorise new GM plant materials, while the average time taken in the USA was 15 months.

7.2 It was noted that another factor creating trading difficulties was the difficulty involved in reaching agreement on low level presence of unauthorised varieties of GM lines. In recent months this issue has been widely discussed at Commission level and in September 2008 there will be a SCoFCAH meeting to discuss the Commission’s proposed 'technical solution' (i.e. a suggested de facto threshold for the low level presence of non-authorised GMOs). However, it was unknown at the present time whether the 'technical solution' would cover both feed and food.

7.3 GAFTA said that it was important that the issue of 'asynchronous authorisations' is resolved soon, as the EU is heavily dependent upon the importation of vegetable protein for livestock feed (e.g. in the last year about 16 million tonnes of soya meal alone had been imported into the EU). AIC said that it shared similar concerns and in recent years there had been feed shortages as a result of GM products (such as Herculex) not being authorised in the EU. It was highlighted that, although EFSA had issued an Opinion on Herculex in 2007, the total cost to the European feed industry of it not being authorised was about £4.5 million.

7.4 Moypark commented that a potential impact of the ongoing EU bans on imports containing certain GM varieties would be that the UK could lose a substantial amount of trade to expanding markets in third countries (such as China and India). It considered that the UK has significantly less influence in world markets than hitherto, so the perceived preferences of UK consumers (whether to embrace or reject GM technology) now count for less.

7.5 The Soil Association said that the problems were caused by commodity exporters, who made no effort to separate GM from non-GM crops. It was concerned by the feed industry’s attempts to speed up the GM authorisation process, because a considerable proportion of the general public were still not in favour of GM products entering the food chain. It reiterated that it was necessary for relevant controls to be maintained due to the prevailing negative public opinion of GM products, and added that it thought the 'sticking point' for the Commission’s proposed technical solution would be the threshold of detection.

8.1 BFBI provided detailed background information on the use of co-products from biofuel production, which it was argued were similar to existing co-products from the brewing and distilling industries. However, it was also argued that expansion of UK biofuel capacity could result in the development of crops with altered starch or oil content which would in turn lead to changes in the nutritional profiles of the co-products, rendering them less suitable for feed use.

8.2 Diageo Global Supply said that potable ethanol production is usually subject to strict restrictions that limit the scope for production changes. Conversely, the production of bioethanol may not be subject to such constraints but it is considered that within this area there are additional hazards that may require control. The safety of bioethanol and other biofuel co-products could be ensured through: (a) an adequate risk assessment; and (b) compliance with the EC Feed Hygiene Regulation (183/2005). It was stated that assurance schemes like FEMAS play a crucial role in relation to this.

8.3 Recent experiences indicated that the most significant hazards which require control included raw materials (e.g. aflatoxin and fusarium toxins); the GM status of processing aids (e.g. antimicrobials used in fermentation, antifoams, boiler treatment chemicals, flocculants used in co-product processing); fermentation micro-organisms; combustion gases in any drying processes (dioxins and PAHs may be a problem with certain fuels); preservatives used in moist/ liquid co-products; and, spoilage of moist co-products giving rise to mould and/or bacterial toxins. In addition, it was noted that glycerol produced in the process may be contaminated with methanol.

8.4 AFU said that it would bring some of the issues discussed to ACAF’s attention. It also reported that a position paper on biofuels had been published on ACAF’s website. See the paper on biofuels on the ACAF website.

• Action: AFU to bring the matters discussed above to ACAF’s attention.

Fishmeal and meat and bonemeal issues

9.1 Defra provided a brief explanation of the TSE road map process which, since 2005, has been examining BSE controls and the possible relaxation of some of those controls. In May 2008 a proposal to permit the use of fishmeal in feed for young ruminants had been discussed in favourable terms, although it is considered unlikely that there will be a return to use of fishmeal in feed for adult ruminants. In addition, in July 2008 the Commission proposed that the tolerance levels for bone fragments in tubers should be extended to all vegetable crops. Both proposals are likely to be submitted for a vote in SCoFCAH in September 2008.

9.2 BFBI commented that it did not consider the feeding of fishmeal to ruminants as an ethical problem but it was noted that the European Parliament disagrees with this.

ACAF issues

9.3 So far in 2008 there have been two ACAF meetings. The first was held on 5 March and the second was an out-of-town meeting which was held in Belfast on 3 June. The next ACAF meeting will be on 24 September 2008 in Aviation House and will include: a presentation on codes of practice on salmonella; an oral update on negotiations on the proposed EC Regulation on the Marketing and Use of Feed; a presentation on the work of the Farm and Animal Welfare Council and its implications for the animal feed sector; and discussion by the Committee on its Forward Work Programme, including horizon scanning. Another ACAF meeting is scheduled for 3 December 2008. Attendees were reminded that minutes of ACAF meetings can be found on the ACAF website (see the ACAF website); and, as all of the Committee’s meeting are held in open session, anyone could attend an ACAF meeting by informing the secretariat in advance.

Codex

9.4 AFU reported that the Codex Alimentarius Commission (CAC) met between 30 June and 3 July 2008. In that meeting CAC discussed future work of the Task Force on Animal Feeding. CAC agreed to postpone a decision on future work on animal feeding until its 32nd session, to be held between 29 June and 4 July 2009. In order to facilitate discussion it was agreed that an electronic working group, hosted by Denmark and co-chaired by Mexico would be established to prepare: (a) a proposal for the scope and terms of reference of future work in animal feeding; and (b) a proposal as to suitable mechanisms for Codex to carry out this work. AFU said that once it has received the relevant papers it will pass on the relevant details to stakeholders for information.

• Action: AFU to provide stakeholders with details of future work to be undertaken by Codex on animal feeding in due course.

Other issues

9.5 Foodaware advised that the Agency (the organisation’s only funder) had withdrawn its funding and therefore that it would be dissolved at the end of July 2008. Foodaware gave special thanks to the Agency and AFU for inviting it to various events, in particular the ACAF meetings. The Chairman paid tribute to Foodaware and thanked its delegate, Mr. Paul Allen, for attending and actively contributing in events hosted by AFU in the past.