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ANIMAL FEED CONTROLS
PROGRAMME (2012-2014)
Background
The activities of the Department of Agriculture, Food and the Marine (DAFM) in the area of
animal feed controls is set out in the following documents:
1) Article 41 of Regulation (EC) No 882/2004 of the European Parliament, requires
Member States to transmit a single integrated Multi-Annual National Control Plan
(MANCP) concerning the implementation of their programmes. Feedingstuffs control
activities have been included in the MANCP.
2) Further, more detailed, information on the scope of feedingstuffs controls is set out
herewith in the Animal Feed Controls Programme 2012 – 2014.
3) Very specific details on the type, numbers and individual Feed Business Operators
subject to controls are set out in the Feedingstuffs Annual Inspection Programme
(FAIP). The information in this document is considered sensitive and is subject to
restricted access.
Animal Feed Controls – Programme (2012 – 2014) In Ireland, DAFM is the competent authority with responsibility for the negotiation,
transposition and enforcement of EU legislation in the feedingstuffs area. The Divisions of
DAFM centrally involved in this activity are the Feedingstuffs Division and the Crop Policy,
Production and Safety Division, collectively referred to as the Animal Feedingstuffs Control
Group.
Strategic Objectives for the Animal Feedingstuffs Control Group (AFCG)
To negotiate the most favourable EU policy in relation to feedingstuffs which enhance
food safety, and animal and crop production under Irish conditions;
To implement an efficient programme of inspections, sampling and analysis to ensure
that feedingstuffs do not endanger food safety or animal health, and to ensure that all
operators in the feed chain comply with statutory requirements concerning imports,
storage, manufacture, trade and use;
To ensure that all Feed Business Operators (FBOs) are registered in accordance with
relevant EU legislation and that these operators fulfil the obligations such registration
places on them;
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Areas of competence / scope of responsibility At central level the AFCG negotiate EU policy, transpose legislation, and establish a risk based
inspection programme for animal feed as well as administering, coordinating and implementing
that programme.
Reporting and communication channels
The organisational chart below outlines the organisation of the AFCG within the Department of
Agriculture, Food and the Marine.
Administration Inspection / controls
Control
The organisational chart below outlines the organisation of the AFCG in terms of human
resources available for the purpose of carrying out official controls:
Administration Inspections / sampling controls
Control
ANIMAL FEEDINGSTUFFS CONTROL GROUP
Chief Inspector
Feedingstuffs
Division Crop Policy, Production &
Safety Division
FOOD SAFETY AND PRODUCTION AGRICULTURAL
PAYMENTS
POLICY
ANIMAL FEEDINGSTUFFS CONTROL GROUP
2 Agricultural
Inspectors
Feedingstuffs
4 Assistant
Agricultural
Inspectors
Feedingstuffs
10 Supervisory Agricultural Officers
SAO
1 Area
Superintendent
1 District
Superintendent
1 Senior Inspector 1 Principal Officer
1 Assistant Principal
1 Higher Executive
Officer
5 Support staff
Feedingstuffs….
Division
Crop Policy, Production &
Safety Division
5 Support Staff
Deputy Chief Inspector
DEPARTMENT OF AGRICULTURE, FOOD and the MARINE
CORPORATE
DEVELOPMENT
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Feedingstuffs Division:
The Inspectorate staff at central level (1 Senior Inspector, 2 Agricultural inspectors, 4 Assistant
Agricultural Inspectors) are authorised under the various Regulations on feedingstuffs to carry
out designated functions, including the inspection of premises and the sampling of produce of
imported and domestic origin for analysis. Authorised Officers are empowered to inspect all
premises where feedingstuffs are manufactured, imported, stored or used, including use at farm
level, and to seize and detain products where they have reasonable grounds for believing that a
contravention of the feedingstuffs regulations has occurred.
The general responsibilities of the Agricultural Inspectorate staff include the following:
Participation at Commission and Council meetings relating to feedingstuffs issues;
Assist in the transposition of legislation;
Draw up the Feedingstuffs Annual Inspection Programme (FAIP);
Coordination and implementation of the FAIP;
Deal with infringements of the legislation;
Preparation of an annual report on the outcome of controls in the field of animal nutrition
and input to the MANCP annual report;
Carry out inspections at all stages of the production, storage, distribution and use of
animal feed;
Review the outcome of inspections & carry out/ coordinate the relevant follow up
actions;
Training of regional inspection staff;
Monitor developments in the industry;
Advise and liase with the industry on various issues.
At regional level the Authorised Officers carry out certain designated functions in line with those
pertaining to the Inspectorate staff at Central level. These include the routine inspection of
premises; sampling of imported feed materials along with materials of domestic origin for
analysis. Again, Authorised Officers at regional level are empowered to inspect all premises
where feedingstuffs are manufactured, imported, stored or used, and to seize and detain products
where they suspect that a contravention of the regulations has occurred.
Crop Policy, Production and Safety Division (CPSD)
All CPSD staff are centrally based. Certain staff in the Division (PO, APO, HEO and EO) are
authorised officers under the feedingstuff legislation and are empowered, inter alia, to direct the
CSSO to initiate legal proceedings against a non compliant FBO (following a recommendation
from the Feedingstuffs Division); to issue licences and Approval / Registration certificates to
FBOs; and to issue instructions to FBOs to undertake certain activities following the
identification of non compliance by Feedingstuffs Division.
The general responsibilities of the staff in the Division are:
Populate and maintain the FBO database;
Issue licences and Approval / Registration forms to FBOs as appropriate;
Prepare draft legislation for approval by Legal Services Division;
Prepare briefing material for Senior Management, Oireachtas; EU; or as requested;
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Address all political, ombudsman and FOI requests;
Maintain all records/files relating to feed policy and FBOs in an efficient manner;
Purchase and supply all equipment as required by the field officers;
Provide any additional administrative assistance as considered necessary by
Feedingstuffs Division.
Resources supporting official control actions o laboratory facilities:
The AFCG has access to appropriate laboratory support for its feedingstuffs analysis programme.
Details of the analyses carried out in the laboratories used are given below.
o other resources/infrastructure as applicable
The AFCG Headquarters is located at the DAFM offices at Backweston, Celbridge, Co. Kildare.
This building provides general office facilities, including storage of files. Feed samples are
sorted and securely stored at purpose built facilities at the nearby DAFM Variety Testing Station,
Backweston Co. Kildare.
At regional level, field staff and field supervisory staff, are located at Department local offices or
operate from their own home. In the case of the local offices there are general office and storage
facilities available. In the case of officers working from home arrangements are in place for the
officers to provide such facilities.
Officers carrying out inspections are supplied with appropriate protective clothing and footwear.
Buckets and scoops are provided for sample taking. Staff are trained in the correct use of this
equipment in taking samples of feed. Competency in the use of this equipment and in taking
samples is recorded in the officers training record.
The Feedingstuffs Division does not have specific testing or measuring equipment as all samples
for analysis are forwarded to a designated laboratory.
The Information Systems Division of the DAFM is responsible for the maintenance and security
of databases used by the AFCG. These databases include the FBO Register; the Inspection
database; the Imports database and the Sampling Results database.
Laboratories [other than national reference laboratories]:
Designation of laboratories The State Laboratory is the principal laboratory responsible for feedingstuffs analysis in Ireland.
In the case of all analyses other than for Salmonella testing and animal proteins (microscopic
testing), the State Laboratory undertakes the work and outsources only in the case of certain
analyses for which they themselves are not equipped to carry out. Samples of feedingstuffs are
submitted to one of the designated laboratories listed in Table 1.
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Table 1 Designated testing laboratories
Name
Address Denoted by
State Laboratory Backweston
Complex
Young's Cross
Celbridge Co.
Kildare
A
Feed Microscopy
Laboratory
Backweston
Complex
Young's Cross
Celbridge Co.
Kildare
B
Pesticide Control Service Backweston
Complex
Young's Cross
Celbridge Co.
Kildare
C
Central Veterinary
Research Laboratory
Backweston
Complex
Young's Cross
Celbridge Co.
Kildare
D
Irish Equine Centre Johnstown Naas Co.
Kildare
E
Sciantec Analytical
Services
Cawood North Yorkshire U.K. F
Premier Analytical
Services
Lincoln Road,
High
Wycombe
Bucks HP12
3QR
U.K. G
Eclipse Scientific Group Chatteris Cambridgeshire
PE16 6QZ
U.K. H
Eurofins Laboratories
WV6 8TQ
Wolverhampt
on
West Midlands U.K. I
Food and Enivonment
Research Agency (FERA)
Sand Hutton York Y041 1LZ U.K. J
Scientific Analysis
Laboratories
Cornbrook Manchester
M16 9FE
U.K. K
LTZ Augustenberg Germany L
RIKILT Wageningen The
Netherla
nds
M
National Veterinary
Research Institute
Department
of
Pharmacolo
gy and
Toxicology
57
Partyzantów
Avenue
24-100 Pulawy, Poland N
Details of the analyses carried out in the designated laboratories, the method reference and
tolerance applied to analytical results are given in Annex 1.
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The Irish Equine Centre, Johnstown, Naas Co. Kildare is the principal laboratory used by
DAFM to undertake microscopic analysis for the presence of products of animal origin in feed
materials and compound feeds.
Measures ensuring requirements applicable to official laboratories are met: Providing the competent authority agrees for the State Laboratory to employ the services of other
laboratories, then the managing staff in the State Laboratory confirm the current status of the
other laboratory’s quality system and its accreditation status for the tests required. Where no
accredited laboratory can be found, then the managing staff in the State Laboratory must be
satisfied with the quality system in use, the test method proposed and that satisfactory
performance in proficiency schemes is obtained.
The State Laboratory retains responsibility for all tests carried out in other laboratories provided
its managing staff have made the selection based on the criteria above. Where the competent
authority specifies a specific laboratory to carry out the analysis, then the State Laboratory will
relinquish responsibility for the work.
The control methods and techniques used and where and when applied
A feedingstuffs annual inspection programme (FAIP), is drawn up for animal feedingstuffs
controls. It includes the control activities undertaken to ensure compliance with the relevant
legislation. The programme includes inspection, sampling and analysis activities in relation to all
levels of the feed chain. In particular it covers the following broad areas:
General Food Law
Feed Hygiene
The circulation and use of feed materials
The marketing of compound feed
Additives for use in animal nutrition
Undesirable substances in animal feed
Feedingstuffs for particular nutritional purposes
Certain protein products used in animal nutrition
GMO in feed
Medicated feedingstuffs
Animal Health (as it relates to animal feed)
The programme is drawn up where appropriate in consultation with other relevant areas within
DAFM.
The day to day organisation and implementation of the control activities is driven by the FAIP
with each officer assigned to carry out the required tasks in his / her designated areas.
Management monitors routine control activities.
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Control priorities, resource allocation and how they relate to risk
categorisation The inspection programme runs from 1
st January to the 31
st December annually. The programme
contains information on the scope of the inspections and on the structure and systems of the
control activities. The programme is approved by the Senior Inspector in Feedingstuffs Division
as early as possible in the year of operation. The programme provides information on the
following:
Overview of the inspection activities and the staff involved
Scope and criteria for controls
Type and number of inspections
Type and number of samples
Type and number of analyses
Analysis methods, tolerances and designated testing laboratories
Risk assessment for determining control activities
When drawing up the Inspection Programme each year, a detailed risk assessment is carried out
to determine how resources should be used. Once this is determined, the number of inspections
and analysis completed for each operator within each segment of the industry is determined
using risk based criteria, which takes into account the following:
The outcome of previous inspections
Nature of risk to health or the environment associated with an operation or type of feed
Auto controls of the operator and history of compliance
Community coordinated controls
Information on controls in other member states or scientific findings.
Progress on the inspection programme is formally reviewed on a quarterly basis and
management makes adjustments in priorities and/or resources as required.
Scope and Criteria for Controls
EP and Council Regulation 1831/2003 (Additives in Feedingstuffs)
The surveillance programme will aim to ensure that feed additives used in animal feed are
authorised under Regulation 1831/2003 and that they are used only in accordance with the
conditions of the authorisation. During inspections the relevant labelling particulars of the
products will be examined on-site and where samples are drawn, the label will be attached to the
sampling form for verification purposes. Controls will be carried out at all stages of the feed
chain from manufacture of the additives to use at farm level. The analysis programme will focus
in particular on the following:
Use of trace elements in animal feed
Use of authorised and unauthorised medicinal additives (Commission Recommendation
2005/925/EC)
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Use of authorised additives at levels in excess of the maximum levels laid down.
Feed Additives and Medicines Commission Recommendation 2005/925/EC requires that member states examine the level of
Copper (Cu) and Zinc (Zn) in compound feed for pigs. In addition, cobalt and manganese levels
will be checked in sheep and poultry rations.
Commission Recommendation (2005/925/EC) also includes assessment of certain authorised and
unauthorised medicinal substances in animal nutrition. The analysis programme will focus on
the following:
1. Medicinal Substances authorised as Zootechnical Additives (Coccidioststs) for certain
species or categories only.
Substance Licenced for
medicinal use in:
Authorised as an additive
for:
Types of Feeds to be
targeted for
unauthorised use.
Decoquinate Calf and Lamb diets Chickens for fattening Adult cattle diets.
Diclazuril Ruminants
(administered orally
– dose)
As Clinacox: Chickens for
fattening, chickens for
laying, guinea fowl, rabbits,
turkeys for fattening.
Halofuginone Not a medicine in
Ireland.
Chickens for fattening and
turkeys for fattening
Lasalocid A sodium
Poultry As Avatec 15 %: Turkeys,
chickens for fattening,
chickens for laying.
Maduramicin ammonium alpha
Not a medicine in
Ireland.
As Cygro 1 % Chickens for
fattening, turkeys.
Monensin sodium Not a medicine in
Ireland.
Chickens for laying &
fattening, turkeys
Cattle
Narasin Not a medicine in
Ireland.
As Monteban: Chickens
for fattening,
Nicarbazin/Narasin Not a medicine in
Ireland.
As Maxiban G60: Chickens
for fattening
Robenidine hydrochloride
Not a medicine in
Ireland.
As Cycostat 66 G: Rabbits
for fattening, rabbits for
breeding, chickens for
fattening, turkeys,
Salinomycin sodium
Not a medicine in
Ireland.
Chickens for fattening,
chickens for laying,
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Semduramicin sodium
Not a medicine in
Ireland.
As Aviax 5 %: Chickens
for fattening
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2. Substances licenced as Medicines in Ireland but no longer authorised as feed additives
Substance Licenced for medicinal use
in:
Types of Feeds to be
targeted for unauthorised
use.
Tetracyclines (CTC) Non-ruminant bovines, pigs
and poultry.
Adult ruminant ration
Tylosin phosphate Pigs Random and Beef
2. Substances licenced as Medicines in Ireland but not authorised as feed additives
Substance Licenced for medicinal use
in:
Types of Feeds to be
targeted for unauthorised
use.
Sulphadiazine (only with
Trimethoprim)
Pigs, Chicken and Turkey Bovines
Pen V Pigs Bovines
Zinc Oxide Pigs Bovines
Amoxycillin (Stabox) Pigs Bovines
Tilmicosin Pigs Bovines
Flubendazole Pigs, Chicken Turkey Bovines
Trimethoprim (only with
Sulphadiazine)
Pigs, Chicken, Turkey Bovines
3. Substances Banned in Ireland - not licenced as medicines and no
longer authorised as feed additives
Substance Types of Feeds to be targeted for
unauthorised use.
Amprolium / ethopabate Calves and Pigs
Amprolium Calves and Pigs
Arprinocid Poultry
Avilamycin Piglet and finisher
Avoparcin Pigs, Poultry and Cattle
Carbadox Pig
Chlorampenicol All feeds – target fish feed
Dimetridazole (DMZ) Poultry (turkey) and game feed
Dinitolmid Poultry
Ethopabate Poultry
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Substance Types of Feeds to be targeted for
unauthorised use.
Halofuginone hydrobromide (Stenorol)
Poultry [Authorisation as an additive for
chickens for laying expired 30/09/09].
Ipronidazol Poultry (Turkeys)
Meticlorpindol (Clopidol) Poultry
Meticlorpindol/methylbenzoquate Poultry
Metronidazole Poultry
Nifursol Poultry
Olaquindox Pigs
Ronidazol Poultry (Turkeys)
Salinomycin – feed add or not. Pigs
Spiramycin Growing Pigs
Virginiamysin Growing Pigs and Sows
Zinc Bacitracin Growing pigs and poultry
The aim is to target those rations or situations where non-compliance may be suspected. In the
case of the banned feed additives, the programme will include analysis of home-mix rations.
The State Laboratory will continue to outsource the analyses for Flavophospholipol, Zinc
Bacitracin and Avoparcin. RIKILT Institute of Food Safety in the Netherlands have a
microbiological test available that is suitable for screening the above antibiotics, in addition to
Avilamycin, Tylosin and Virginiamycin.
The State Laboratory has validated an LC-MS/MS method that has the capability of detecting
medicinal substances in feed that are no longer authorized as feed additives as listed in Annex II
of Commission Recommendation 2005/925/EC (these include Avilamycin, Tylosin, Carbadox,
Virginiamycin, Spiramycin, Ethopabate, Dinitolmid, Ipronidazol, Metachlropindol (Clopidol),
Ronidazol and Olaquindox). Testing will be carried out for additional medicinal substances
which are are no longer authorised as feed additives.
Testing of medicinal substances which are authorised as feed additives will enable monitoring of
unavoidable carryover of coccidiostats in non-targeted feed as per Directive 2002/32/EC of the
European Parliament and of the Council as amended Commission Regulation (EU) No
574/2011 of 16 June 2011 and the undeclared use of such substances.
In the case of the authorised feed additives, the programme will mainly focus on the absence of
coccidiostats from broiler withdrawal diets both at manufacturing level and at farm level.
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The Feedingstuffs Division is responsibe for following up results which show coccidiostat levels
in excess of maximum permitted levels in animal products. The action taken will depend on
certain criteria, based upon the levels of the coccidiostat detected. An authorised officer of the
Feedingstuffs Division conducts a follow up on-farm inspection in these cases. The follow up
action takes place as soon as practically possible from the date of the notification of the positive
result. The inspection incorporates examination of the feeding system on the farm as follows:
Details of feedingstuffs delivered i.e. quantity, type, source and date of delivery and the
sale of birds from the unit are examined and verified.
Samples of feedingstuffs kept on the farm are taken for analysis as appropriate.
Advice is given to the farmer on proper management of feeding bins to ensure cross
contamination does not occur and to enable farmers ensure that withdrawal periods are
observed.
All details are recorded on an official inspection form.
In addition, an inspection of the mill which supplies the feed to the farm may be carried
out and withdrawal feed sampled for coccidiostat analysis.
Antibiotics in Dried Distillers Grains with Solubles (DDGS) from the USA
In the United States, virginamycin is added to fermentation tanks during ethanol production, to
reduce or eliminate competition between yeast and bacteria for glucose, in favor of yeast growth
which increases ethanol yield. Following an announcement, in 2010 by US authorities on the
status of virginiamycin in the bioethanol production, the European Commission stated that the
presences of virginiamycin in feed could not be tolerated. Member States were requested to
perform regular checks on DDGS. Two consignments of DDGS will be tested annually for
Virginamycin as part of the screen test for banned antibiotics.
Regulation (EC) No 767/2009 of the European Parliament and of the Council
of 13 July 2009 on the placing on the market and use of feed,.
Regulation (EC) No. 767/2009 amending European Parliament and Council Regulation (EC) No
1831/2003 and repealing Council Directive 79/373/EEC, Commission Directive 80/511/EEC,
Council Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and
Commission Decision 2004/217/EC entered into force on 01 September 2010.
Regulation (EC) No 767/2009 - Bioproteins
Regulation (EC) No 767 / 2009 repealed Directive 82/471/EC (bioproteins) and removed the
requirement for pre-market authorisation of bio-proteins. The majority of bioproteins are now
included in the Catalogue of Feed Materials. As in the case of all feed materials, bioproteins will
be subject to a risk assessment, and if the result is unfavourable, the material will be added to the
prohibited list in Annex III of the Regulation.
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With the repeal of Council Directive 82/471/EEC concerning bio-proteins, the existing
prohibition on the use of protein products obtained from Candida yeasts cultivated on n-alkanes
continues with its addition to the prohibited list in Chapter 1 of Annex III of Reg (EC) No
767/2009.
Regulation (EC) No. 767/2009 – Circulation and Use of Feed Materials
Article 16 of Reg (EC) No 767/2009 sets out specific mandatory labelling requirements for feed
materials. In accordance with Chapter 5 of the Regulation, a Catalogue of Feed Materials has
been created – Regulation (EU) No. 575/2011. The non-exhaustive Catalogue includes
information on the properties of feed materials, defines different processes and technical
expressions, and for certain feed materials specifies tolerances for the presence of processing
aids.
Up to two thirds of the non-forage feed materials used in feedingstuffs are imported, mainly from
3rd
countries. All consignments from 3rd
countries will be subject to identity checks (Customs
officials) and documentary checks (DAFM authorised officer) in line with Art 16 of Council
Regulation (EC) No. 882/2004. Importers are required to inform the Department prior to
importation of a consignment and this information is recorded on a database. The aim is to carry
out physical checks and sample imported consignments of feed materials from 3rd
Countries to
check for the presence of animal proteins. In the case of imports from 3rd
Countries and
shipments of EU sourced feed materials, the level of testing will be set out in the annual FAIP.
All feed materials put into circulation will be subject to random checks to ensure that the correct
descriptive name and the appropriate labelling particulars accompany each batch. The inspecting
officer will complete a report in respect of each inspection carried out at such premises.
The analysis programme will focus in particular on the statutory labelling requirements as laid
down in the Catalogue of Feed Materials and will be based on an annual risk assessment.
The number and type of imports in the preceding year is used to estimate the number of analyses
of the different feed materials that will be carried out in the current year.
When submitting samples for analysis, care will be taken to ensure that the level of analysis of
the various feed materials is distributed across all operators on a pro-rata basis with their levels
of imports.
Feed consignments will also be selected for documentary and physical/identity checks in
accordance with Commission Regulation (EC) No 669/2009. Currently groundnuts for (bird)
feed from certain third countries and feed additives and premixtures from India are subject to
controls under Reg (EC) No 669/2009. The feed types and source countries listed in the annex to
Regulation 669/2009 is subject to a quarterly review.
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By-products and surplus food as animal feed.
By-products of the food industry and surplus food are a small but significant source of animal
feed in Ireland. Controls are carried out to ensure the manufacture and supplies of these feeds are
in accordance with the feedingstuffs legislation and to ensure the safety of the feed.
Inspections at FBO’s which are under the control of Dairy Certification and Controls Division
(DCCD) are carried out by DCCD staff.
The selection of operators for inspection is based on risk analysis which will have regard to
among other factors, compliance history, type of feed material and the operators other activities.
By-Products of food and biofuel industries.
By-products are produced by food processors such as breweries (brewer’s grains) and industrial
processors such as biofuel manufacturers (rapeseed cake / meal). These FBO’s are classified as
“Suppliers of Feed Materials”. The Department continues to ensure that any operator producing
or supplying feed materials from food or industrial processing are registered and comply with
their obligation as feed business operators. Inspections will be carried out at food supplier’s
premises, brokers and at farm level. The selection of FBO’s for inspection is based on risk
analysis will have regard to among other factors, compliance history, type of feed material and
the operators other activities. The aim is to ensure that DAFM can identify any by-product that
may represent a potential hazard in animal feed.
Surplus food
Food processors may also supply surplus or non-conforming food as feed material. These FBO’s
are classified as “Suppliers of Feed Material”. A survey of food operators supplying surplus food
and byproducts as feed material commenced in spring 2011 in order to update the Department’s
information on the types and quantities of by-products and surplus food that are in use in animal
nutrition. This survey follows on from the review in 2009 following which DAFM assigned a
higher risk categorisation to these operators. DAFM has imposed an outright ban on the use of
retail returns as feed for food producing animals since 2009. Exceptions are made for bread
products taken back by the bakery and milk products taken back by the dairy and amalgamated
with their production surpluses. Food manufacturers that supply surplus food for use as feed are
selected for inspection on a risk basis.
The supply of food as feed material and the recycling of surplus food were again reviewed in
spring 2011. The review findings were endorsed by DAFM’s Management Advisory Committee
and the higher risk categorisations for food recyclers and suppliers of surplus food and by-
products and the ban on retail returns were maintained.
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Food Recyclers Since the Dioxin crisis of 2008, all Food re-cyclers are subject to increased controls. All food re-
cyclers are selected for one audit and at least two unannounced inspections.
Regulation (EC) No. 767/2009 – the marketing of compound feedingstuffs)
Establishments manufacturing compound feeds and premix/mineral mixtures are subject to
regular unannounced inspections and a report is completed in respect of each inspection. Where
samples are taken for analysis, the labelling particulars are attached to the sample report form.
During the inspection, particular attention is paid to the feed materials in stock, the additives
used and the labelling particulars of the compound feeds.
A number of inspections are carried out on farms with livestock to ensure that purchased
compound feed originates from establishments that are registered or approved under Council
Regulation (EC) 183/2005. The labelling details are examined during the inspection and samples
taken on a selective basis.
The analysis programme will focus in particular on compliance with the statutory labelling
requirements, as laid down in the annex to the Regulation.
Council Directive 2002/32/EC (on undesirable substances in animal nutrition)
The analyses of additives and feed materials will be targeted where possible on materials that are
considered to represent a potential risk. Particular emphasis will be placed on fulfilling the
requirements outlined in Commission Recommendation 576 of 2006 concerning mycotoxin
levels in feed materials and compound feed. The selection of samples for analysis is based on
risk analysis.
Following on from the Dioxin crisis of 2008, DAFM has increased dioxin testing, with particular
emphasis on surplus food products and any feed, including grain, which has been dried.
Targeted analysis for PCB and dioxins in the case of commercial (Grain / feed, incl food
recyclers) and indicator PCBs in the case of on-farm drying processes are given the highest risk
weighting (5). Where a screen test shows elevated levels of indicator PCB’s, a full confirmatory
test will be carried out for dioxins and PCBs. Any sample which exceeds the “action threshold”
is then subject to analysis for dioxins and PCBs by the confirmatory method. In 2012, Directive
2002/32/EC is amended to provide for the declaration and control of dioxins and PCBs by
reference to WHO-TEFs (Toxic Equivalency Factors) for human risk assessment based on the
conclusions of the World Health Organisation meeting in Stockholm, Sweden, 15-18 June 1997
(Van den Berg et al., (1998) Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs for
Humans and for Wildlife. Environmental Health Perspectives, 106(12), 775).
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Following a discussion on the manufacturing of feed material at the June 2009 SCFCAH Animal
Nutrition meeting, rapeseed cake as feed material will be targeted for testing for dioxins/PCB’s
and heavy metals.
Following on from the German dioxin incident in 2011 involving the contamination of feed oil,
plant oils and blends of oils supplied as feed material will be subject to increased testing from
2012 for dioxins and other undesirable substances in line with the amendment of Regulation
(EC) No 183/2005 (Reg 225/2012) to include new measures on the production, storage, transport
and controls of dioxin in oils, fats and their derivatives. These activities and feedingstuffs are
given the highest risk weighting (5)
Testing of feedingstuffs for certain undesirable substances such as hydrocyanic acid and free
gossypol is dependant on the import of the target feed materials – linseed by-products and
cottonseed by-products respectively. In the absence of imports, random samples will be tested.
Commission Regulation (Euratom) No 770/90 - maximum permitted levels
of radioactive contamination of feedingstuffs.
This Regulation sets the maximum permitted levels of radiactive contamination (caesium-134
and caesium-137) for feedingstuffs. The levels set are intended to contribute to the observance of
the maximum permitted levels for foodstuffs and the monitoring of contamination levels in
animal products destined for human consumption. The MPLs apply to feedingstuffs as ready for
consumption.
The Radiological Protection Institute of Ireland (RPII) is responsible for monitoring radiation
levels including levels in food. Each year DAFM samples native grain for testing by the RPII.
For 2012 and subsequent years, DAFM will sample native grains (cereals) which go directly in
to the human food chain – for brewing and milling. These samples will be tested for Caesium by
the RPII.
In addition, the RPII has identified certain countries from which feed imports in to Ireland should
be tested for Caesium. Samples of feed materials imported from Russia and Turkey will be sent
to the RPII for Caesium testing.
COMMISSION IMPLEMENTING REGULATION (EU) No 961/2011 of 27
September 2011 imposing special conditions governing the import of feed and
food originating in or consigned from Japan following the accident at the
Fukushima nuclear power station.
This Regulation sets the maximum permitted levels of radiactive contamination in feedingstuffs
i.e. caesium-134 and caesium-137 and the isotopes of iodine, notably I-131. In order to ensure
consistency with action levels currently applied in Japan, the maximum permitted level stated in
17
this Regulation replaces on a provisional basis the MPL for Cs-134 and Cs-137 laid down in
Commission Regulation (Euratom) No 770/90. This MPL laid down for isotopes of iodine in
feed on a provisional basis is the same as that for foodstuffs, pending an assessment of transfer
factors of iodine from feedingstuffs to food products. This Regulation applies until 31 October
2012 unless extended.
There were no feed imports from Japan in 2011.
Regulation (EC) No 767/2009 and Directive 2008/38/EC- feedingstuffs
intended for particular nutritional purposes.
Reg (EC) No 767/2009 repealed Council Directive 93/74/EEC. Control in this category includes
some products commonly referred to as “nutritional supplements”. Labels of feeds for particular
nutritional purposes i.e. dietetic feeds, will be checked for compliance, with particular attention
to the level of use of additives and the claims made concerning the purpose and efficacy of the
products. A limited number of samples will be taken for analysis.
Council Regulation (EC) 183/2005 (laying down requirements for feed
hygiene)
Each year a proportion of establishments approved or registered for the manufacture of
compound feed and approved for the manufacture of premixes/mineral mixtures will be formally
audited to ensure continued compliance with the conditions of approval/registration. These
audits will usually be prearranged in order to ensure that the appropriate personnel are present
during the inspection. An audit report will be completed in respect of each visit and any
deficiencies identified will be brought to the attention of the establishment.
Each of these operators is also subject to a number of unannounced visits based on a risk
assessment. During the course of routine inspections a number of key areas are examined:
Hygiene, Production, Quality Control, Storage, HACCP and traceability. Unannounced
inspections are also carried out at all other levels of the feed chain including at import, storage,
transport, retail, primary production and use on farm. The inspections aim to ensure that the feed
materials and compound feeds originate from registered or approved premises that feed is
handled in a hygienic manner and that adequate traceability exists.
All on-farm manufacturers of medicated feed that apply for new medicated feed licences or
renewal of an existing licence are audited by Feedingstuffs Division as part of the approval
process under S.I. 432 of 2009 as manufacturers of compound feed for own use, prior to the
processing of the application for a medicated feed licence.
A selection of primary producers are inspected based on risk criteria. Where appropriate, the
results of these inspections will be communicated to the Single Farm Payment unit for Cross
Compliance purposes (Council Regulation EC 73/2009).
18
Hauliers
A number of hauliers of feed will be inspected in 2012 and subsequent years to ensure that feed
are transported in a way that maintains traceability and prevents cross contamination. Some of
the inspections will take place at hauliers’ headquarters.
ABP Division is responsible for controls relating to the transport of ABP. Hauliers involved in
the transport of ABP and feedingstuffs (in separate trailers) are assigned a higher risk factor.
Feed Drying
Since the Dioxin crisis of 2008 there has been increased focus on the monitoring and control of
direct drying processes for feed drying.
Commercial grain drying establishments: Storers of native grain involved in drying and using
fuels other than natural gas will be inspected in 2012 and subsequent years. The inspections will
focus on HACCP and the fuel used in the drying process.
On-farm grain/feed dryers: The farms are selected by risk analysis. The on-farm audits will
focus on the fuel used in dryers, and the operation of the dryers.
In addition to commercial and on-farm direct drying operations, there are a number of FBOs
which have a direct drying process in their feed manufacturing activity. These FBO’s are
involved in the manufacture of feed grade lime and the manufacture of feedingstuffs from marine
materials e.g. seaweed meal. All such FBO’s will be subject to an audit in 2012 and subsequent
years.
Council Decision 999/2001/EC (concerning protection measures with regard
to TSEs and the feeding of animal protein)
The control measures will involve inspections of storage facilities for feed materials and
sampling and analysis of imported feed materials and compound feed. Inspections will also be
carried out at compound feed manufacturing premises, intermediary premises and on livestock
holdings. The number of inspections and sampling frequencies will be based on risk assessment
criteria in accordance with the requirements of Commission Recommendation 2005/925.
A number of importers and establishments have been licensed in accordance with Commission
Regulation (EC) 1292/2005 to import, use or feed fishmeal and blood products derived from
non-ruminants. Each importer is required to inform DAFM in advance of importation of a
consignment. Consignments from 3rd
countries may not be put into circulation until, where
selected for sampling, the results of testing for the presence of mammalian bone are reported.
19
The provision of the Regulations concerning dicalcium phosphate from defatted bones has been
availed of by one operator in respect of horse feed. This FBO is inspected annually. Importers of
dicalcium phosphate (mineral origin or otherwise) are required to provide documentary evidence
concerning the origin of the material and to pass this information on to their customers (e.g.
compound feed mills, premixtures and mineral mixture manufacturers).
The Department has a licensing system in place since 2001 to control the manufacture, storage,
movement and use of fishmeal and compound feeds containing fish meal.
There are seven storage facilities licensed by Animal Feed Control Group (AFCG). One
compound feed manufacturer who incorporates fishmeal into its feeds is licensed by AFCG and
is inspected annually by the Feedstuffs Division to ensure compliance with the conditions of
their fishmeal licence. A second manufacturer recently ceased operations.
The Animal Feed Control Group (Feedingstuffs Division and Crop Production and Safety
Division (CPSD)) is responsible for the licensing of pig and poultry farms to use fish meal, blood
products and blood meal (for fish feeding only) or CFS containing these ABPs. These
inspections are carried out by the Veterinary Inspectorate in the local DVO’s and the
administration is carried out by CPSD.
From 2012, The Sea Fisheries Protection Agency (SFPA) will be responsible for implementing
feed controls in manufacturing premises supplying fishmeal and fishoil as feed materials.
Veterinary Medicines Division licence fish farmers manufacturing medicated feed.
Directive 2003/99/EC - Salmonella
The salmonella-monitoring programme will focus particularly on protein sources of vegetable
origin.
At least one sample will be taken in each feed mill for salmonella analysis. Feed mills that were
found to be deficient on hygiene assessments carried out during the course of routine inspections
will have an additional sample taken in the following year. Where such problems were detected
on more than one inspection the mill in question will have two additional samples taken in the
following year. In addition to these risk assessments, all mills producing poultry feed will have
an additional sample taken for salmonella testing.
Bulk storage facilities at retail premises will be targeted for sampling, particularly where the
hygiene standards are considered to be poor. These samples will include both feed materials and
compound feed.
A random selection of grain stores used for the storage for native grain will also be sampled for
salmonella.
At least 6 times a year environmental dust samples (25g) will be taken from the
screening/crumbling/filtering areas or other areas as per the discretion of the sampler and a
20
finished feed sample (50g) from the bin/bagging area/silo or when the truck is being loaded. One
set of samples will be taken at each inspection by a feedingstuffs officer and the remaining will
be taken by a Veterinary Inspector from the District Veterinary Office.
Regulation 1829/ 2003 on genetically modified food and feed.
Control will focus mainly on imports of certain feed materials, in particular those originating in
third countries. Documentary checks will be carried out to ensure compliance with Regulation
(EC) 1830/2003 concerning the traceability and labelling of genetically modified organisms and
the traceability of food and feed products produced from genetically modified organisms.
Sampling and analysis will be targeted on whole grains and by-products of commercially
available feed materials considered at risk of the presence of genetically modified organisms i.e.
soyabean, oilseed rape, maize and cotton, i.e. imported feed materials, which are potentially
GMs but not labelled as GM. In addition, Targeted sampling and analysis may also be carried
out on particular consignments of feed materials identified as being at increased risk.
Council Directive 90/167/EEC (Medicated Feedingstuffs)
Only medicines licenced by the Irish Medicines Board may be used in Ireland. In accordance
with Directive 90/167/EEC, a licence is required to manufacture an intermediate product
(premixture/mineral mixture) or a compound feedingstuff containing a medicine. Inspections are
carried out at licensed premises and the documentation required under the regulations is
inspected. Inspections will be completed in conjunction with other inspections e.g. 2-4 times per
year for feed mills and once per year in the case of farm inspections for home mixers selected for
inspection. A standard report form is completed in respect of each inspection. Where samples are
taken for analysis, the labelling particulars will be attached to the sample identification form.
Samples of medicated feed will be tested for the level of active substance. Samples of feed
manufactured after medicated feed will also be tested to demonstrate the efficiency of flushing
procedures practised on the premises i.e. the absence of carryover. These samples will be drawn
at the point of manufacture (i.e. feed mill) in order to facilitate the testing of these samples
within the best before period for the feed i.e. two weeks in some cases. Imported medicated feed
will also be sampled for testing. Feed and premixtures will be tested for licenced medicinal
substances.
All registered home mixers which apply for new medicated feed licences or for the renewal of
existing licences will be inspected by Feedingstuffs Division for approval as manufacturers of
compound feed for own use, prior to the processing of the application for a medicated feed
licence by Veterinary Medicines Division.
European Communities (Animal By-products) Regulations 1069/2009
21
Regulation (EC) No 1069/2009 repealed Regulation (EC) 1774/2002 with effect from 01 March
2011.
Used Cooking Oil Council Decision 2003/320/EC prohibits the use of used cooking oil (UCO) in animal feed. In
order to ensure that this ban is maintained, operators engaged in the collection, treatment and/or
blending of UCO will be inspected. The source of oils used in the manufacture of compound
feed at mills or on-farm will be checked during inspections to confirm compliance with the ban
on the use of UCO in feed.
Dairy products as feed materials.
The Dairy Certification and Controls Division’s (DCCD) Inspectorate has responsibility for
DAFM’s dairy processing controls at certain establishments. The feedingstuffs controls in these
premises will be carried out by the DCCD in conjunction with Feedingstuffs Division. Feed
supplied by dairy premises may also be inspected and sampled at other feed business operators’
premises.
Presence of melamine in certain imports from China
Decision 2008/798/EC adopted emergency measures for control of milk-based products from
China contaminated with melamine, an industrial chemical found in plastics. The Decision had
subsequently been extended, to soya and soya oil products from China for both feed and food
(amended by Decision 2008/921/EC). As a result of the decrease in the incidents of melamine
contamination, Decision 2008/798/EC was replaced by Commission Regulation (EC) No
1135/2009, which reduced the intensity of physical checks from 100% to 20%.
In addition, random checks for melamine will be carried out on high protein feed materials (rice
gluten, wheat gluten and Corn gluten) from any source. In the case of direct imports from China,
importers are required to bear the costs of checks. For 2012 and subsequent years, at least 10
random samples will be taken – 8 feed materials and 2 compound feeds (subject to the number of
imports).
Commission Regulation (EC) No 669/2009 on increased level of official
controls on imports of certain feed and food of non-animal origin.
Regulation (EC) No 882/2004 on official food and feed controls provides for the drawing up of
specific rules to govern the importation, into the EU, of certain food and feed products, which
present additional risks to the food chain. These rules, and the specific food and feed products
involved, are set out in EU Commission Regulation 669/2009. The controls came into effect on
25th
January 2010.
The list of products (Annex I to the Commission Regulation) is reviewed on a quarterly basis
with products added or removed or the frequency of physical and identity checks changed.
Documentary checks will be carried out on all consignments of the listed products and
22
physical/identity, checks, including analysis, will be carried out at the frequency specified in
Annex I of the Regulation.
Dublin sea port is designated point of entry for all feeds listed in Annex I of Reg (EC) No
669/2009.
Regulation (EC) No 396/2005 of the European Parliament and of the Council
of 23 February 2005 on maximum residue levels of pesticides in or on food
and feed of plant and animal origin and amending Council Directive
91/414/EEC.
This Regulation establishes maximum residue levels (MRLs) for the control of pesticide residues
in feed and food. DAFM will forward thirty samples of native grains for residue analysis in
spring 2012 and subsequent years. These samples will be tested for plant protection substances
and their derivatives. The analytical service will be provided by the Department’s Pesticide
Control Laboratory.
Regulation (EC) No 767/2009 - materials whose circulation or use for animal
nutrition purposes is prohibited.
In accordance with Article 6.1, Annex III of Regulation (EC) No 767/2009 lists materials whose
circulation or use for animal nutrition purposes is prohibited. When depacking surplus food,
packaging and parts of packaging could contaminate the resulting feed material. To ensure
compliance with Article 6.1, feed materials derived from former foods will be tested for the
presence of prohibited materials. Compound feed which includes surplus food will also be tested.
23
Supervision and verification of planned arrangements including reporting
arrangements
- The control programme is subject to on-going supervision by staff at central level. As
indicated above, progress on the programme is formally reviewed on a quarterly basis.
- Three times yearly liaison meetings take place between DAFM and the State Laboratory to
plan the annual work programme and to review progress. In addition, an annual audit is
carried out in conjunction with the NRL (Animal Protein) at the Irish Equine Centre in
relation to microscopic testing.
- The principle findings from the annual inspection programme are included in the annual
reports of the MANCP submitted to EU Commission. In addition, under existing
feedingstuffs legislation, the outcome of certain controls is communicated bi-laterally to the
relevant Commission services. To this end a comprehensive annual report is prepared
covering all aspects of the previous year’s FAIP.
- On-going supervision of the inspecting officers is carried out according to an annual
schedule drawn up by the quality manager in consultation with the appropriate officers.
The schedule aims to ensure that each inspection officer is subject to at least one annual
supervisory visit by a superior officer for each inspection task over a three-year cycle.
Some inspection tasks may be the subject of more than one supervisory visit over the three-
year cycle depending on the perceived need for an additional supervisory visit covering any
particular inspection task (e.g. extra duties because of new legislation) or the outcome of
previous supervisory visits. Supervisory visits covering tasks additional to those indicated
in the annual supervisory schedule may be carried out at the discretion of the supervisory
inspecting officer.
- Supervisory visits will be prearranged with the inspecting officer and a supervisory
inspection report is completed and retained on the officers training file. A copy of the
Supervisory Inspection Report is given to the officer subject to the supervisory inspection.
The supervisory inspection report will indicate whether, in the opinion of the supervisory
officer, further formal training or a follow-up supervisory inspection is required in any
particular inspection task or group of tasks. The quality manager ensures that such training
or supervisory inspections are carried out as soon as possible.
Arrangements for the application of horizontal legislation across different
sectors/sub-sectors The AFCG works in close co-operation with other Divisions or agencies of the Department such
as;
TSE and Animal By Products Division;
ERAD (Veterinary Medicines)
Veterinary Public Health (Zoonoses and Salmonella controls)
Sea Fisheries Protection Agency
Specialist Farm Services, Environment & Evaluation Division
24
DAFM’s Veterinary Division, are responsible for animal related medicine, Salmonella and BSE
controls. In the case of animal feedingstuffs, the sampling and analysis programme for medicated
feed, salmonella in feed and in the case of BSE controls, the ‘Total Feed Ban’ is included in the
Feedingstuffs programme of work. Meetings are held on an ad hoc basis between the Divisions
to address issues as they arise. There is formal consultation each year prior to drawing up the
inspection programme for the year to ensure the requirements of these Veterinary areas are met
in the programme.
The Sea Fisheries Protection Agency has responsibility for the licensing and monitoring of
fishmeal manufacture in Ireland. All other aspects of enforcement of the derogations for feeding
protein of animal origin foreseen in the provisions laid down in Annex IV to Regulation (EC)
No. 999/2001 are the responsibility of the AFCG .
The Specialist Farm Services, Environment & Evaluation Division of DAFM remit includes the
area of environmental policy. Feedingstuffs Division undertakes monitoring of phosphorus levels
in feedingstuffs on behalf of this Division. Meetings are held on an ad hoc basis between the
Divisions to address issues as they arise.
How specific control plans or programmes required by community legislation
are integrated into the control systems for the relevant sectors or sub-sectors
as appropriate - The control plans in place are those specified or required under the relevant community
legislation relating to animal feedingstuffs.
- The annual inspection programme includes, where appropriate, inspections and analyses
undertaken in respect of Commission Recommendations on coordinated monitoring
programmes in the field of animal nutrition.
Measures to manage coordination between competent authorities with related
responsibilities: The AFCG also liaise with the following bodies as the need arise:
Food Safety Authority of Ireland (FSAI)
Environmental Protection Agency (EPA)
The Department of Health and Children
Customs
The FSAI are responsible for contaminants in food. Feedingstuff Division staff draw samples of
some bulk food grains such as wheat for milling, barley for brewing, oats for porridge oatlets on behalf
of FSAI and have them tested for Mycotoxins (specifically Aflatoxin and Ochratoxin A). This satisfies
FSAI’s requirements for controls to check out compliance with maximum levels laid down in Regulation
466/2001 for these contaminants in food. Meetings are held on an ad hoc basis between the FSAI
and DAFM to address issues as they arise.
25
The Department of Health and Children, the EPA and the FSAI are involved in implementing
legislation relating to GM in Ireland. There is ongoing communication between the AFCG and
these bodies on GM feed issues.
The AFCG liaise with the customs authorities to ensure identification and control of imported
feed. Importers are required to notify the Group in advance of importing animal feed. This pre-
notification system is highly effective in ensuring that the appropriate controls are carried out on
imports.
Measures to ensure efficient and effective cooperation both within and
between competent authorities
Within the CA
Feedingstuffs Division management monitor routine control activities. Progress on the FAIP is
formally reviewed on a quarterly basis.
Between CA’s
Meetings are held on an ad hoc basis between the relevant Competent Authorities to address
issues as they arise. There is consultation each year prior to drawing up the feedingstuffs
inspection programme for the year to ensure the requirements of all relevant areas are met in the
programme.
Measures to ensure all areas where coordination and cooperation are required both within
and between competent authorities are addressed
See previous points
Training arrangements
Identification of training needs
The training procedure is intended to include all aspects of both technical and administrative
duties with regard to conducting inspections concerning animal feed. Each year both technical
and administrative staff completes a role profile. As part of this exercise, officers identify their
training needs for the year ahead. These training requests are examined by the AFCG
management and the Staff Training and Development Unit of DAFM and where possible,
appropriate training is organised.
Implementing training plan(s)
Training and supervision of inspection staff is carried out at the following stages:
Induction (for new staff)
Supervised working period with experienced officers
Continuation training to keep pace with developing legislation and technology.
Supervision
26
A continuation training record is placed on the officers training file, together with details (agenda
and dates) of the training.
Administrative staff generally benefit from ‘on the job’ training as well as attending courses on
computer skills, legislation and effective writing organised by the Staff Training Unit.
Recording and evaluating training
All inspection staff training records are maintained on file at central level. Records are kept for
at least 5 years after an officer ceases to work in the Feedingstuffs Division. The success of
training provided is assessed during a supervisory inspection and is based on the capacity of the
Feedingstuffs Division to deliver on business plan commitments.
In general training needs are recorded for all staff in their Personal Development Plans and at
annual review meetings. Those plans are reviewed twice each year at which time training
provided is also assessed.
Contingency plans & mutual assistance
Sectors/subjects/areas where contingency plans are in place
Article 13 of Council Regulation (EC) 882/2004 on Official Controls performed to ensure the verification
of compliance with feed and food law, animal health and animal welfare rules, outlines that Member
States shall draw up operational contingency plans setting out measures to be implemented without delay
when feed and food is found to pose a serious risk to humans or animals either directly or through the
environment.
The AFCG has put in place a contingency plan for animal feed setting out the procedures to be
followed and the measures to be taken in the event of a serious contaminant being detected in
animal feed. Hazards requiring consideration and possible management may be identified
following the Department’s routine controls on animal feed or may be notified by an external
source, for example, through the EU Rapid Alert System for food and feed. The contingency
plan outlines the responsibilities of officers involved in any contamination incident.
Scope of each plan
The contingency plan is intended to cover the following activities in the field of animal nutrition:
Importation of animal feed
Storage of animal feed
Manufacture and/or processing of animal feed
Transport of animal feed
Manufacture of compound feed
Distribution of animal feed (wholesalers, retailers, etc)
Use of animal feed on farms
Final destination of contaminated animal feed
The contingency plan does not include measures to be taken following contamination of animal
products for human consumption, animal disease control or the environment as such actions
27
would be the responsibility of the Food Safety Authority of Ireland, Veterinary Division of
DAFM or the Environment Protection Agency.
Body responsible
Animal Feedingstuffs Control Group (AFCG), Department of Agriculture, Food and the Marine.
Arrangements for dissemination and training to ensure effective implementation
including simulation exercises
A co-ordination group made up of representatives from relevant Division’s within the
Department and also certain external agencies (FSAI) has been set up to provide technical advice
when required. The plan ensures a focussed approach to the handling of each incident and
allows for appropriate information exchange between all the relevant parties.
The contingency plan is reviewed and updated on a regular basis, for example, in the light of
changes in personnel or following improvements identified after incidents or simulation
exercises. In addition, the plan may be revised from time to time to incorporate harmonised rules
for contingency plans where such are developed by the Commission in conformity with
Regulation (EC) No 882/2004.
The contingency plan allows for simulation exercises where appropriate. It should be noted that
heretofore this has not been necessary as the contingency plan has been tested on a number of
occasions in ‘live’ situations.
Arrangements for mutual assistance:
The AFCG will provide the administrative assistance and cooperation in relation to animal feed
controls referred to in Articles 34 – 39 of Regulation 882/2004 where appropriate.
Arrangement for audit of competent authorities
Internal audit
For the purposes of meeting the legislative requirements of Regulation (EC) No. 882/2004, the
DAFM Internal Audit Unit (IAU) conducts, as part of its functions, internal audits on the
effectiveness and suitability of official controls performed by DAFM personnel in a number of
Agricultural Inspectorate Divisions, including The AFCG. The IAU derives its authority from
the top management within DAFM.
The IAU puts in place an annual programme of internal audits to be carried out by an internal
audit team who are independent from the functions being audited. The objective of IAU audits in
relation to feedingstuffs is to ensure that the implementation of the official controls for the
feedingstuffs inspection programme is compliant with and achieving the objectives of the
relevant EU legislation. All major aspects of implementation of DAFM’s feedingstuffs
inspection programme are fully reviewed at an appropriate risk-based frequency over a period
not exceeding five years. The conduct of audits takes account of the guidelines provided by the
28
European Commission laying down the criteria for the conduct of audits under Regulation (EC)
No. 882/2004 (Commission Decision 2006/677/EC).
Measures ensuring that competent authorities take appropriate measures in the light of
results of these audits
The IAU makes the results of these audits available to the Heads of Division within the AFCG.
Where findings and recommendations outlined in the audit report indicate the need for
corrective, preventive or improvement action as applicable, the IAU will propose that such
actions be undertaken by management by a specific agreed date. The completion and
effectiveness of such actions will be verified as part of a subsequent audit to be carried out by the
IAU.
The implementation of audit recommendations is the responsibility of line management within
the AFCG. Where a serious feed safety issue is discovered during an audit, this evidence will
immediately be brought to the attention of senior management in the Group.
Measures ensuring that these audits are subject to independent scrutiny and are carried
out in a transparent manner
In order to preserve its independence, the IAU does not engage in the functions of the AFCG
thereby ensuring the provision of impartial advice to management.
The audit arrangements of the IAU functions relating to Agricultural Inspectorate controls are
overseen by an Audit Monitoring Body composed of two experts from outside DAFM. One of
the functions of the Audit Monitoring Body is to provide advice to the IAU through independent
scrutiny of the audit reports. The Audit Monitoring Body is independent in the performance of its
functions. The Body and its members are appointed by top management within DAFM.
A number of audit body practices are in place to provide transparency to the audit process for
relevant stakeholders. These include access to documented audit body procedures, consultation
on planning of the audit programme and audit plans, circulation of the audit programme,
opportunity to provide a management response on draft audit reports, distribution of the final
audit report.
External Audits
The IAU will cooperate with the FVO in any external audits, which this body may undertake.
Measures to ensure compliance with the operational criteria of Regulation
(EC) No. 882/2004.
Impartiality, quality and consistency of controls
The AFCG management are committed to ensure that all staff have the appropriate qualifications
and training to carry out the duties assigned to them. The aim is to ensure that inspection staff
has the necessary skills and competence to carry out inspections. In addition, on-going
29
supervision ensures that inspections continue to be carried out in a competent and uniform
manner by inspection staff. Administrative staff are encouraged to attend appropriate training
courses.
Staff are free from conflict of interest
All staff working for DAFM complete a declaration and registration of interests form each year
stating whether or not they have any conflict of interest when completing their duties e.g., where
family members could benefit from decisions taken by an officer in the course of their work. It is
the responsibility of the Heads of Divisions to draw up procedures to deal with any potential
conflict of interests that are brought to light.
Adequate laboratory capacity
Each year DAFM meet with the State Laboratory in January to outline their analytical
requirements for the year. A further 2 meetings are held annually to monitor progress and to
inform the laboratory of any additional analytical requirements. DAFM meet with other
laboratories on an ad hoc basis. Following these meetings, management in the relevant
laboratory is aware of the analytical requirements of the group.
Sufficient number of suitably qualified & experienced staff
The Heads of the Divisions within the AFCG identify any areas where additional inspectorate or
administrative staff are required and informs the Deputy/ Chief Inspector. Personnel Division is
responsible for the allocation of staff. Appropriate training programmes are arranged for new
staff.
Adequate facilities & equipment
The system in place for review of business plans (twice yearly) includes a review of the
resources, including laboratory facilities and equipment available.
Documented procedures are available The procedures manual for the Group details all relevant procedures
Adequate legal powers
The Group, in consultation with Legal Services Division, ensure that all necessary legal powers
are in place to ensure that staff can carry out the necessary controls.
Food & Feed business operators co-operate with staff performing official controls
Since 1973 all EU legislation on feedingstuffs has been given effect under the European
Communities Act, 1972, a legal instrument specifically enacted to give effect to the Treaties
governing the European Communities and to enable the introduction of regulations giving effect
to EC legislation.
Legal procedures are in place to ensure that staff has access to premises and documentation kept
by feed business operators so as to enable them to accomplish their tasks properly. Authorised
officers are also empowered to seize and detain where they have reasonable grounds for
believing that a contravention of the feedingstuffs legislation has occurred.
30
There is provision under the various regulations on feedingstuffs for specific control measures at
national level and penalties in the event of breaches. Under legislation where the activity is the
subject of a Licence or the issue of an Approval / Registration status, such Licences or
Approval’s / Registrations can be withdrawn by the Minister of Agriculture, Food and the
Marine in the case of non-conformity with requirements. Financial penalties can only be applied
following a successful prosecution in Court.
Records are maintained
All inspection visits are documented and the records are maintained on the Inspection System for
Animal Feed (ISPAF) system. All samples of feed taken and all laboratory sample results are
recorded in ‘Feed Main’, an Access database. In both cases, these records are maintained
indefinitely.
Review and adjustment of the plan
Each year, Feedingstuffs Division draws up a feedingstuffs annual inspection programme
(FAIP). The result of controls from the previous one or more years is taken into account before
finalising the programme. In addition, relevant EU Rapid Alert System for Food and Feed
(RASFF) notifications throughout the previous year and any Commission Recommendations are
taken into account.
Following on from this process a formal review of the animal feedingstuffs section of the single
integrated multi-annual national control plan will be undertaken and it will be adjusted where
necessary. Where adjustments are made then the revised plan will apply to the next period of its
operation. The Commission and other interested parties will be informed of adjustments made as
appropriate.
31
ANALYSIS METHODS, TOLERANCES AND LABORATORIES – 2012 -2014
Part 1: Proximates, Sugar, Starch,Amino Acids and Ash Insoluble in HCl
Laboratory Analysis Screening Accredi
ted
(Y/N)
LOQ Non-compliant samples Accredit
ed (Y/N)
LOQ Tolerance
(Ref if
available)
A Crude Protein Singly:-DUMAS
method using a LECO
nitrogen/protein
analyser.
(In house method based
on EN ISO 16634-
1:2008)
Y In duplicate by
DUMAS method
(In house method based on EN
ISO 16634-1:2008)
Y Reg EU
No
939/2010
A Crude Oils and Fats Singly:-NIR spectroscopy Y In duplicate:- (Commission
Directive 152/2009 Annex III, H)
Y Reg EU
No
939/2010
A Crude Fibre Singly:-NIR spectroscopy Y In duplicate:-Commission (Directive
152/2009, Annex III, I)
Y Reg EU
No
939/201
0
A Crude Ash Singly:-Gravimetric
method using a
Microwave Furnace
Y In duplicate:- (based on Commission
Directive 152/2009, Annex III, M)
Y Reg EU
No
939/201
0
A Moisture Singly:- (Commission
Directive 152/2009 Annex
III, A)
Y In duplicate:-(Commission Directive
152/2009 Annex III, A)
Y Reg EU
No
939/201
0
A Ash Insoluble in HCl Singly:-
(Commission Directive
Y In duplicate:-
(Commission Directive 152/2009,
Y Reg EU
33
152/2009, Annex III, N) Annex III, N) No
939/201
0 H Starch* See table 7 I Sugar* See table 7 H Lysine* See table 7 H Methionine* See table 7
Part 2: Macro and Trace Elements
Laboratory Analysis
Method reference Accredited (Y/N) LOQ Tolerance
(Ref if available)
A Calcium ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ:
41 mg/kg (organic) 482 mg/kg (inorganic)
Reg EU No
939/2010
A Phosphorus
ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ:
1 mg/kg (organic)
359 mg/kg (inorganic)
Reg EU No 939/2010
A Sodium ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ: 96 mg/kg (organic)
224 mg/kg (inorganic)
Reg EU No 939/2010
A Magnesium ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ: 39 mg/kg (organic)
482 mg/kg (inorganic)
Reg EU No 939/2010
Potassium Not tested
A Cobalt Inorganic Feed only: ICPOES using microwave
digestion sample preparation (based on CEN/TS
15621:2007)
Organic Feed : ICPMS using microwave digestion
sample preparation
Y
N
LOQ: 12 mg/kg (inorganic)
Reg EU No 939/2010
34
A Copper ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ 13 mg/kg (organic)
21 mg/kg (inorganic) Reg EU No 939/2010
I Iodine* See table 7
A Iron ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ 49 mg/kg (organic)
35 mg/kg (inorganic) Reg EU No 939/2010
A Manganese ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ 7 mg/kg (organic)
17 mg/kg (inorganic Reg EU No 939/2010
A Selenium ICPMS using microwave digestion sample
preparation
N LOQ: 0.27 mg/kg (inorganic
feed
Reg EU No 939/2010
A Zinc ICPOES using microwave digestion sample
preparation (based on CEN/TS 15621:2007)
Y (inorganic feed) LOQ 25 mg/kg (organic &
inorganic) Reg EU No 939/2010
I Vitamin A* See table 7
I Vitamin D* See table 7
I Vitamin E* See table 7
Part 3: Heavy Metals Feed materials
Laboratory Analysis
Method reference Accredited (Y/N) LOQ Tolerance
(Ref if available)
A Arsenic ICPMS using microwave digestion sample preparation
Y (inorganic
feed)
LOQ: 0.02 mg/kg (inorganic
feed
A Cadmium ICPMS using microwave digestion sample preparation
Y (inorganic
feed)
LOQ: 0.03 mg/kg (inorganic
feed
A Lead ICPMS using microwave digestion sample preparation
Y (inorganic
feed)
LOQ: 0.7mg/kg (inorganic feed
A Mercury ICPMS using microwave digestion sample preparation
N
LOQ: 0.08mg/kg
35
Part 4: Zootechnical / Medicinal Additives: authorised
Laboratory Analysis
(in
feedingstuffs)
Method reference Accredited (Y/N) LOQ Tolerance
(Ref if available)
A Nicarbazin
(therapeutic) In House HPLC method with DAD, based on EN
15782:2009
Y 3 mg/kg Reg EU No 939/2010
A Ionophores:
Monensin,
Salinomycin,
Narasin
(therapeutic)
HPLC with post column derivitization
In house method based on EN ISO 14183:
Y Mon: 0.6 mg/kg
Nar: 1.5 mg/kg
Sal: 1.5 mg/kg
Reg EU No 939/2010
A CTC
(medicated
levels)
In duplicate by HPLC
(in-house method)
N 5 mg/kg
A SDZ
(medicated
levels)
In duplicate by HPLC
(in-house method)
N 10 mg/kg
A Decoquinate
(therapeutic)
HPLC (based onFprEN 16162:2011) N 0.5 mg/kg Reg EU No 939/2010
A Lasalocid Commission Directive 152/2009, Annex IV, G N 10 mg/kg Reg EU No 939/2010
Part 5: Zootechnical / Medicinal Additives: banned
This table outlines the analytes carried out by State Laboratory to confirm presence or absence in a feed sample. The method used is
an in-house method using LCMS/MS. The samples will be screened by single analysis. Where banned additive is found DAFF will be
immediately alerted and the sample will be subjected to repeat confirmatory analysis in duplicate.
Analyte Analyte
Reporting limit
Dimetridazole Avilamycin 0.1 mg/kg for all
36
Ronidazole Tylosin analytes
Metronidazole Virginiamycin
Ipronidazole
Dinitolimide
Ethopabate
Carbadox
Clopidol
Chlorampenicol
Part 6: Implementing Commission Directive 2009/8/EC: monitoring maximum levels of unavoidable carry-over of
coccidiostats in non-target feed
This table outlines the analytes carried out by State Laboratory to confirm presence or absence and quantify in a feed sample. The
method used is an in-house method using LCMS/MS. The sample will be screened by single analysis. Where a non-compliant has
been found, the sample will be subjected to repeat confirmatory analysis in duplicate.
Analyte LOQ (mg/kg)
Halofuginone 0.015
Robenidine 0.350
Nicarbazin 0.250
Diclazuril 0.005
Decoquinate 0.200
Semduramicin 0.125
Lasalocid 0.675
Salinomycin 0.350
Monensin 0.675
Narasin 0.350
Maduramicin 0.025
Part 7: Analyses out sourced
37
Due to insufficient resources and the small numbers of samples involved, these analyses will continue to be sub-contracted.
Analyte Subcontract
Laboratory
Accredited
(Y/N)
Lysine H Y
Methionine H Y
Penicillin V F N
Fluorine I Y
Flubendazole N
Iodine I Y
Sugar I Y
Starch (Polarimetric) F
Y
Theobromine F N
Vitamin A, D, E I Y
Amoxycillin K
Y
Tilmicosin I Y
Melamine Eurofins (Germany) Y
Flavophosppholipol
/Zinc
Bacitracin/Avoparcin
M Y
Table 8: Dioxins and PCBs.
Analysis
Laborator
y
Method
reference
Method reference Tolerance (reference if available) LOD
(mg/kg)
38
Dioxins A/J/K Reg
152/2009
High Resolution Gas
Chromatography/High
Resolution Mass
Spectrometry
Maximum content values given in Commission Directive 2006/13/EC
for undesirable substances in animal feed as regards dioxins and
dioxin-like PCBs
0.05 ng/kg
(per
congener)
Dioxin-like PCBs
(Non-ortho PCBs(1)
Mono-ortho PCBs(2)
)
A/J/K Reg
152/2009
High Resolution Gas
Chromatography/High
Resolution Mass
Spectrometry
Maximum content values given in Commission Directive 2006/13/EC
for undesirable substances in animal feed as regards dioxins and
dioxin-like PCBs
0.05 ng/kg(1)
10ng/kg(2)
(per
congener)
Screening for
Dioxins/PCB
A Reg
152/2009
DR CALUX screen
method
Maximum content values given in Commission Directive 2006/13/EC
for undesirable substances in animal feed as regards dioxins and
dioxin-like PCBs
Total BEQ: ≥
0.15ng/kg
(Matrix
dependent)
LOQ
Table 9: Other Undesirable Substances and Products
Analysis
Laborator
y
Method
reference
Method reference Tolerance (reference if available) LOD
(mg/kg)
Undesirable substances – no tolerance permitted for undesirable substances, MPLs set in Directive 2002/32/EC
Mycotoxins
Aflatoxin B1 A High Performance
Liquid Chromatography
with Immunoaffinity
clean-up
Directive 2002/32/EC
0.0005 LOQ
Ochratoxin A High Performance
Liquid Chromatography
with Immunoaffinity
clean-up
Commission Recommendation 2006/576/EC
0.001 LOQ
Fumonisins G High Performance
Liquid Chromatography
with Immunoaffinity
clean-up
Commission Recommendation 2006/576/EC 0.020 LOQ
39
ZEA G High Performance
Liquid Chromatography
with Immunoaffinity
clean-up
Commission Recommendation 2006/576/EC 0.006 LOQ
DON, T2, HT2,
Nivalenol
G GC/MS(Trichothecene
Analysis)
Commission Recommendation 2006/576/EC 0.010 LOQ
Hydrocyanic acid A
Free gossypol A Reg
152/2009
Theobromine H High Performance
Liquid Chromatography
Directive 2002/32/EC 1.0
Volatile mustard oil A Directive 2002/32/EC
Vinylthiooxazolidone
(Vinyloxazolidine
thione)
A Directive 2002/32/EC
Botanical impurities
Apricot
Prunus armeniaca L.
B Microscopic
Bitter almond Prunus
dulcis (Mill.) D.A.
Webb var. amara (DC.)
Focke
(= Prunus amygdalus
Batsch var. amara
(DC.) Focke)
B Microscopic
Unhusked beech mast
Fagus silvatica L.
B Microscopic
Camelina
Camelina sativa (L.)
Crantz
B Microscopic
40
Rye Ergot (Claviceps
purpure)
A LC/MS Directive 2002/32/EC 0.005
Weed seeds and
unground and
uncrushed fruit
containing alkaloids,
glucosides or other
toxic substances
separately or in
combination including:
(a) Lolium temulentum
L.,
(b) Lolium remotum
Schrank.,
(c) Datura stramonium
L.
A Directive 2002/32/EC
Castor oil plant
(Recinus communis)
C Directive 2002/32/EC
Crotalaria spp. C Directive 2002/32/EC
Regulation 1135/2009
Melamine Maximum Permitted level 2,5 mg/kg
Pesticides
Aldrin singly or
combined with dieldrin
C Directive 2002/32/EC
Dieldrin expressed as
dieldrin
C Directive 2002/32/EC
Campheclor
(Toxaphene)
C Directive 2002/32/EC
41
Chlordane (sum of cis-
and trans- isomers and
of oxychlordane,
expressed as chlordane)
C Directive 2002/32/EC
DDT (sum of DDT-,
TDE- and DDE-
isomers, expressed as
DDT)
C Directive 2002/32/EC
Endosulfan (sum of
and isomers and
of endosulfan sulphate
expressed as
endosulfan)
C Directive 2002/32/EC
Endrin (sum of endrin
and of -keto-endrin,
expressed as endrin)
C Directive 2002/32/EC
Heptachlor (sum of
heptachlor and of
heptachlorepoxide,
expressed as
heptachlor)
C Directive 2002/32/EC
Hexachlorobenzene
(HCB)
C Directive 2002/32/EC
Hexachlorocyclohexane
(HCH)
C Directive 2002/32/EC
-isomer C Directive 2002/32/EC
-isomer C Directive 2002/32/EC
-isomer C Directive 2002/32/EC
Microbiological
42
Salmonella D ISO/FDIS 6579 No tolerance permitted one
organism in
25 grams
Directive 99/29
Meat and bone meal B/E Microscopic* No tolerance permitted Fishmeal B/E Microscopic* No tolerance permitted
Regulation 1829/2003
Presence of GMO’s J Qualitative and Real
Time PCR
Thresholds as per legislation (Regulations (EC) No. 1829/2003
and 1830/2003).
Dependent on
Matrix and on
ingredient
level –
typically less
than 0.01 %
per sample
Level of GMO’s J Real Time PCR