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Page 1 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey 23 December 2008 Introduction On 3 November 2008 the New Zealand Food Safety Authority (NZFSA) released a public discussion document entitled: “Tutin in honey, NZFSA Public Discussion Paper; no. 09/08”. The discussion document provided information and sought feedback on a proposed new food Standard, the Food (Tutin in Honey) Standard 2008. This proposed Standard would introduce a maximum level in honey for the naturally occurring toxin tutin, along with a range of means by which one might demonstrate compliance. This summary covers the main issues raised by submitters. It also incorporates NZFSA’s response to the issues raised, including changes made to the Standard as initially proposed. Summary of proposed Standard as circulated for consultation The draft Standard circulated for consultation proposed maximum levels for tutin in New Zealand honey for export, and for domestic retail sale for human consumption. It also set out four options for demonstrating compliance with the maximum levels. The person required to demonstrate compliance was either the exporter, or the last person to package the honey before it was sold for retail for human consumption. The draft Standard also included a listing requirement for beekeepers. NZFSA set out a range of options in the discussion document as summarised below. Setting a safe limit for tutin in honey but taking no further action. Education through both NZFSA and Bee Products Standards Council (BPSC) channels. Removing hives by the end of December each year. Demonstrating the absence of tutu (Coriarea arborea) in a 5 kilometre radius of the hives. Producing evidence that hives are only in low risk areas defined as below an approximate latitude in the South Island, or above a particular altitude. Beekeepers developing a risk management programme (RMP) for primary processing under the Animal Products Act 1999. Testing for the presence of tutin by approved laboratories. Page 2 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Synopsis of the engagement and consultation process The discussion document was mailed to all registered beekeepers along with a copy of the proposed Standard and a letter that provided notification of public meeting times and locations. The consultation document, proposed Standard, and notification of public meeting times and locations were posted on the NZFSA website. Those members of the public who fell ill after eating contaminated honey during the Easter 2008 period were also notified about the consultation. Public meetings were held in Nelson, Hamilton, Auckland, Wanganui, Napier, Te Puke, Whangarei, and Blenheim. There were approximately 200 attendees. The closing date for submissions was 28 November 2008. Ninety-six submissions were received. NZFSA thanks the submitters for their comments. NZFSA recognises that November is a busy time for the bee products industry, and not ideal for consultation purposes. In NZFSA’s view, the level of response from the industry, at this busy time, indicated that there is a high level of interest in how best to address the problem posed by tutin in honey. Summary of changes made to the Standard Key changes made to the Standard after the consultation process include: • The Standard no longer applies to honey produced and harvested from 1 July to 31 December of any year. • A new option: confirming that the risk is managed under a food safety programme. • Another new option: weekly inspections of tutu from 1 January until harvest date if there are significant amounts of tutu in a 3km radius of beehives. • In place of a requirement to demonstrate that there are no tutu bushes in a 5km radius of one’s beehives, the requirement in option four is to demonstrate there is no significant amount of tutu bushes in a 3km radius of one’s beehives. • A new requirement to extract, blend and test honey once honeydew is found on tutu bushes in a 3km radius of beehives. • The limit for tutin in comb honey has been set at 0.1mg/kg. • It is no longer an option to test comb honey, as it was not possible to devise a cost-effective sampling plan that would consistently detect excessive levels of tutin in comb honey. • The tutin risk area in the South Island is limited to the Marlborough region only. Page 3 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Submitters Grouping of submitters Submitters have been grouped in this document according to the group to which they are affiliated. NZFSA acknowledges that this grouping is somewhat arbitrary; in some cases submitters did not indicate an affiliation, and some were assigned to the category to which they appeared most likely to belong. Affiliation Number Beekeeper 23 Hobbyist 25 Commercial operator 28 Honey Packer 3 Associations and Clubs 6 Victim of poisoning 3 Employees in the honey industry 3 General public 1 Ungrouped 5 List of submitters The submitters were: Aaron Fox A. B. Effendi A. H & M. A. Allen Alan & Ellen McArdle Allan & Barbara Pimm - Hikutaia Honey Ltd Andrew Beach / Jo Salisbury Andrew Cory & Tim Oliver - Niue Honey Co NZ Ltd Andrew Geddes Andrew & Pauline Stratford - LV Honey Co Ltd Andrew Whitehead Page 4 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Anna Swail Anne Hulme Annette Briggs Arataki Honey Ltd (Hawke’s Bay Division) - Ian Berry, John Walsh, Pam Flack, Rhys Flack Arataki Honey Ltd (Rotorua Division) - Russell Berry Barry Foster - Tawari Apiaries Ltd Blair Auckram Bob Douglas - Federated Farmers NZ Bryan Walford Carol Downer Carolann Murray Cindy Maddox C. T. Norton Darren Clifford D. J. Pons Dominicus Klaassen Donald McIntosh Don Bertram Dragos Mihaila Erwin Czutta - Epec Farm Fiona Black - Bees R Us Fiona O’Brien - Beeline Apiaries Frank Lindsay - Lindsay’s Apiaries Garry C. Goodwin Graeme Crosby Page 5 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Graham Cammell - Graham Cammell Ltd Graham & Lyn Pearson Howard Norton Ian Fielding I McPherson Jacob De Ruiter - Haewai Meadery & Wind Gardens James Gellen - Manawatu Beekeepers Club James Ward - Kintail Honey Ltd J. A. Wright - South Auckland Apiaries Ltd Jeanette Evans Joanne Katherine Whittle John Berry John Burnet Jo Scott Judith Lee Karen Perri Keith Deverall Keith Tomlinson - Aorere Apiaries Kerry F. McCurdy - Beez Thingz Kevin Gibbs Kevin Wallace Kim Kneijber Leroy Johnston Malcolm G. Marshall Margaret Tauri Page 6 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Mark Denize Marlborough Beekeepers Association - Darren Clifford, Will Trollope, Mike Taylor, James Jenkins, Mark Graham, Murray Bush, Robert Harper, Daniel Milne, Alistair Drew, Oliver Vercoe, Grant Josephs Maureen Maxwell - BeesOnline Ltd, Wild Forage Ltd, Auckland Beekeepers club, Whangarei Beekeepers Club & Executive Member National Beekeepers Association of NZ Moira Haddrell - Cambridge Bee Products Ltd Murray Bush - J. Bush & Sons Ltd NZ Honey Producers Cooperative Owen Watson Patrick T E Fox Pauline Foote Peter Beere Peter Berry Peter Biland - Franklin Beekeepers Club Peter Bray - Airborne Honey Ltd Peter & Frances Burt Rodney H McKenzie R. N. Farrer Robert William Neckelson Roger Bray - Central South Island Ward National Beekeepers Association R. Walker R. W. Butcher Silas Stedman Simon & Sarah Peacey - Wairua Apiaries Stephen Black - Bees-R-Us Page 7 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Steve Caughley Steve Lyttle - Honey Valley New Zealand Ltd Stewart Turner Stuart Smith Sue Tetley - Franklin Beekeepers Club Sue Walker - Honeyland NZ Ltd Tony & Jane Lorimer - Lorimer’s Honey, Hillcrest Apiaries Trevor Cullen - Ceracell Beekeeping Supplies Ltd Trevor Wright Vicky Alexander Wellington Beekeepers Assn Inc - John Burnet William Rodie - Bill Rodie Beekeeping Ltd W. P. W. Goldsmith Submissions and NZFSA responses A summary of the main issues raised in submissions and the NZFSA responses is provided below. Testing Twenty-eight submitters (including 12 hobbyists, 7 beekeepers, 6 commercial operators, 2 associations/clubs, and 1 honey packer) contended that the Standard would effectively impose a mandatory testing regime for honey, the unnecessarily high costs of which would encourage small beekeepers to operate “under the radar”. The suggestion was that packers and extractors would avoid product from small beekeepers, who would in turn be more likely to give away their honey or sell it without adequately managing tutin risk. NZFSA response: Given the amendments made, NZFSA is satisfied that the Standard will support responsible beekeeping practices. The main changes in this regard are to the period in which the Standard applies, and the addition of new option six (discussed below under Cost). Testing will now only be carried out on product from areas that have been identified as high risk because of the presence of honeydew on tutu bushes (or when a packer has concerns about the source from which they are purchasing honey). The Standard also requires tested product to be held subject to test results showing that the maximum tutin level has not been exceeded. Page 8 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Some submitters raised concerns about being required to test honey that had been produced in previous seasons. NZFSA response: The Standard has been amended to clarify that it will apply to honey produced or harvested (and the packing of honey produced or harvested) after 25 January 2009 and before 30 June 2009. The Standard also states that in subsequent years it will apply to honey produced or harvested between 1 January and 30 June (and the packing of honey that is produced or harvested between 1 January and 30 June). A submission from a major New Zealand company argued against the need to test large homogeneous batches of honey, on the basis that any tutin content will be sufficiently diluted to not pose a problem. This submission was supported by 13 others (including 6 commercial operators, 4 beekeepers, 1 hobbyist, 1 honey packer, and 1 association/club). NZFSA response: While tutin in large batches of honey will be diluted to some extent, dilution may not be sufficient to meet the 2.0mg/kg limit. NZFSA considers it is better to avoid harvesting honey when factors such as risk area, time of year, and weather conditions indicate that toxic honey will be likely to be produced. Two victims of poisoning submitted that the sale of comb honey should be banned. Three submitters (including 1 beekeeper, 1 commercial operator, and 1 association/club) argued that the Standard only needed to apply to comb honey. On the other hand, three submissions by employees in the honey industry expressed support for the checking procedures used by a comb honey producer. NZFSA response: NZFSA has formed the view that no sampling regime could adequately address the problem of tutin being concentrated in a section of comb honey. Therefore while the limit for extracted honey remains 2.0mg/kg, the limit for comb honey has been changed to 0.1mg/kg (based on the consequences of 2mg/kg being present in a portion of comb consumed by a child). This lower limit will only apply to comb honey for the purposes of ensuring that compliance action can be taken on contaminated product. Comb honey harvested once honeydew is present in an area will have to be extracted, blended, and tested. It cannot be sold as comb honey. Cost Forty-seven submitters (including 14 hobbyists, 13 commercial operators, 12 beekeepers, 2 honey packers, 2 associations/clubs, 1 victim of poisoning, and 3 with an unknown affiliation) contended that the combined costs imposed by the Standard would be too high, particularly for hobbyists. A further eight submitters (including 7 hobbyists and 1 beekeeper) argued that the costs were an unnecessary expense for those who were not selling or bartering their honey. Eight other submitters (including 3 beekeepers, 3 commercial operators, 1 hobbyist, and 1 with an unknown affiliation) felt that costs should be either subsidised or funded by sources other than industry. Page 9 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Twelve submitters (including 4 commercial operators, 3 hobbyists, 2 beekeepers, 1 honey packer, 1 association/club, and 1 with an unknown affiliation) objected to the lack of available laboratories to ensure competitive pricing for tests. NZFSA response: NZFSA is satisfied that the Standard as amended will have a very limited impact on business compliance costs for those honey producers who already take adequate precautions to ensure that the food they produce is safe. Now that the Standard does not apply to early season honey, beekeepers who harvest their honey by 31 December each year can avoid the costs of having to demonstrate compliance with one of the options set out in the Standard. NZFSA is of the view that most beekeepers who do need to demonstrate compliance with the Standard will make use of new option six. This option involves keeping written records of weekly inspections for the presence of honeydew from 1 January until the honey is harvested. This requirement is similar to that under the Animal Products (Human Consumption Specifications) 2004 that applies to export premises and already covers 80 percent of the honey produced in New Zealand by volume. It will be a particularly affordable and practical way for a small beekeeper to comply with the Standard. Approximately 2000 of the 2600 registered beekeepers in New Zealand have fewer than 20 hives, and it is likely that most of them live close to their hives. It should not be onerous or time-consuming for these beekeepers to keep such written records; the inspections could form part of their regular local travel. Many beekeepers with large numbers of hives have indicated to NZFSA that they already have systems in place to manage tutin risk. Where an inspection does detect honeydew, the potentially contaminated honey will not be able to be packed unless it has been tested for tutin. Affected comb honey will not be able to be packed for sale for human consumption or exported. Response to the problem A large number of submitters made comments on whether the proposed Standard was an appropriate response to the problem with tutin in honey. Thirteen submissions (including 5 commercial operators, 3 beekeepers, 2 hobbyists, 2 associations/clubs, and 1 victim of poisoning) specifically stated agreement with the need to produce safe honey products. Thirteen submissions (5 commercial operators, 3 hobbyists, 2 beekeepers, 2 victims of poisoning, and 1 association/club) stated support for setting a maximum tutin level in product. Very few submitters commented on the proposed maximum level itself. Notably the 3 victims of poisoning proposed a zero level for tutin in honey. NZFSA response: NZFSA is satisfied with the toxicological data set out in its discussion paper. It seems likely that very low levels of tutin contamination are widespread and may be largely unavoidable in many areas in late summer. To impose a “zero” limit for tutin in honey would be Page 10 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey likely to make beekeeping unviable in many parts of New Zealand, which would have an unnecessary negative impact on the pollination of flowering plants and industries reliant upon pollination. Internationally, limits for natural toxicants are often set using limited data as there tends to be a lack of chronic toxicological data available. Maximum levels are set on the basis that there is a need to protect public health, and can be revised as new data is gathered. Nineteen submitters (including 7 commercial operators, 4 hobbyists, 3 beekeepers, 2 with an unknown affiliation, 1 honey packer, 1 association/club, and 1 member of the general public) contended that the Standard was an excessive response to the problem. Thirteen submitters (including 4 commercial operators, 3 beekeepers, 3 hobbyists, 2 with an unknown affiliation, and 1 association/club) stated that there was no need for the Standard given beekeepers already have a responsibility to produce safe product. Twelve submitters (including 8 commercial operators, 3 beekeepers, and 1 association/club) commented that commercial operators were being made to pay for mistakes caused by hobbyists/small operators. NZFSA response: It is clear to NZFSA that few, if any, precautions to avoid tutin in honey have been taken by some operators. A more specific set of requirements to encourage effective risk management is required. Fourteen submitters (including 4 commercial operators, 3 beekeepers, 2 hobbyists, 2 with an unknown affiliation, 1 honey packer, 1 victim of poisoning, and 1 association/club) argued that the proposed Standard would not eliminate the risk. Several submitters and meeting attendees suggested that tutu should be declared a noxious weed. NZFSA response: NZFSA acknowledges that the Standard cannot eliminate the risk of poisonings, because compliance cannot be guaranteed. Should tutu or the passion vine hopper insect (Scolypopa australis) be eradicated, there would no longer be a need for the Standard. However, given that tutu is a native plant and is well established in many areas, it is extremely unlikely that eradication will be a realistic option. Risk definition Thirteen submitters (including 6 commercial operators, 3 beekeepers, 3 hobbyists, and 1 honey packer) stated that the boundaries and risk areas in the proposed Standard needed to be more tailored, to either include/exclude specific areas. Five submitters (including 2 commercial operators, 1 beekeeper, 1 honey packer, and 1 with an unknown affiliation) proposed that the lower North Island should be declared a low-risk area. NZFSA response: the lower North Island should not be considered a low-risk area, given the known presence of the passion vine hopper. However, on the basis of the data available, there appears little potential for a problem in the South Island outside Marlborough. Therefore the risk area for the South Island has been reduced to the Marlborough region. Page 11 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey Information available on the life cycle of the passion vine hopper supports the idea that honey produced by bees from spring until the end of December will not pose a risk. Therefore the Standard will apply only to honey produced by bees between 1 January and 30 June of any given year (except in 2009, when it will apply to honey produced after the date of the Standard’s commencement). This does not mean that honey contaminated with tutin can be sold if it has been harvested before this date. Honey with more than 2mg/kg of tutin would be likely to be in breach the general provisions of the Food Act 1981. Research A large number of submitters commented on the extent of the research done on the problem. Eleven submitters (including 4 commercial operators, 2 beekeepers, 2 hobbyists, 1 honey packer, 1 victim of poisoning, and 1 with an unknown affiliation) commented that insufficient research had been done into the extent of the problem with tutin in honey. Nine submitters (including 3 commercial operators, 2 beekeepers, 1 honey packer, and 1 victim of poisoning) stated that NZFSA’s 2008 Honey survey results were not representative or flawed in some way. Fourteen submitters (including 8 commercial operators, 2 hobbyists, 1 beekeeper, 1 association/club, 1 victim of poisoning, and 1 with an unknown affiliation) supported further research being done into the exact conditions that lead to the production of toxic honey (for example weather, passion vine hopper population, and high-risk locations). The most-suggested topic for further research, proposed by nine submitters (including 4 commercial operators, 2 beekeepers, 2 hobbyists, and 1 association/club), was the development of a fast, cheap “field” test for tutin. Random sampling in the marketplace was also proposed. NZFSA response: There are significant gaps in the data available, but NZFSA does not feel that this justifies further delay in addressing the matter. NZFSA’s 2008 survey was not intended to be representative; it was only undertaken to determine whether the risk of tutin in honey was limited to the area in which the poisoning had occurred. NZFSA intends to conduct a survey on the passion vine hopper over the 2009 summer period. The risk areas in the Standard could be further refined should more information become available on the distribution of the passion vine hopper population. Consultation process Twenty-six submitters (including 12 commercial operators, 6 beekeepers, 3 hobbyists, 2 associations/clubs, 2 with an unknown affiliation, and 1 victim of poisoning) contended that the process for developing the proposed Standard was too rushed. These submitters expressed concerns about matters such as the short notice given for the discussion meetings, the submission closing date, and the timing of the consultation period in the busiest part of the beekeeping season. Twelve submitters (including 6 commercial operators, 3 honey packers, 2 beekeepers, and 1 Page 12 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey hobbyist) felt that the proposed implementation date for the Standard of 1 January 2008 was too soon. In addition, six submitters (including 3 commercial operators, 1 victim of poisoning, 1 beekeeper, and 1 hobbyist) criticised the discussion paper for being too brief, biased and/or inaccurate. NZFSA response: The timing of the consultation process was inconvenient for industry, and a different period would have been selected if possible. NZFSA provided advance notification to the bee products industry of its intention to set a limit for tutin and/or its derivative hyenanchin once sufficient data was available. It became apparent that formal consultation could not begin until November 2008, due to the need to await the availability of the results of a toxicological assessment of hyenanchin. NZFSA notified the BPSC in advance about the likely timing and duration of the consultation period, and it was also signalled in the October issue of the Beekeeper magazine. Compliance options Twenty-one submitters (including 6 commercial operators, 5 beekeepers, 4 hobbyists, 3 associations/clubs, 1 honey packer, 1 victim of poisoning, and 1 with an unknown affiliation) contended that it would be impractical to demonstrate the absence of tutu bushes in a 5km radius of beehives. There were a range of reasons for this view, including that it was too great a distance, too onerous to provide evidence, and that almost no beekeeper in New Zealand could make use of this option. NZFSA response: Option four in the Standard no longer requires the demonstration of an absence of tutu. The concept of “significant” presence of tutu has been introduced instead. It is accepted that bees have a clear tendency to collect from regular sources of nectar, pollen, or honeydew. Also, it is generally accepted that bees only fly more than 3km for good sources of nectar. Therefore, if there is no significant amount of tutu in a 3km radius of hives, the area will not be considered a problem. A definition of “significant” for this purpose is provided in the guidance material on the Standard. Five submitters (including 3 commercial operators, 1 victim of poisoning, and 1 with an unknown affiliation) opposed using 1100 metres as a cutoff point for tutin risk. NZFSA response: Given the very high likelihood that no honey will be produced at this altitude, this provision has been removed from the Standard. Ten submitters (including 7 hobbyists, 2 commercial operators, and 1 beekeeper) commented that the Standard’s requirements were impractical for small commercial beekeepers and hobbyists. Four submitters (including 1 beekeeper, 1 hobbyist, 1 commercial operator, and 1 association/club) supported removing honey supers by the end of December. Eight submitters (including 4 Page 13 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey hobbyists, 2 commercial operators, 1 beekeeper, and 1 with an unknown affiliation) supported the removal of honey supers, with different dates set by region. NZFSA response: As noted above, the Standard no longer applies to honey produced or harvested (and the packing of honey that is produced or harvested) between 1 July and 31 December. The view was expressed at several public meetings that many beekeepers would be unwilling to reveal the exact location of their hives, as this information could be exploited by competitors. For clarification purposes a change has been made to the Standard so as to not require beekeepers to provide the exact details of hive locations to potential competitors. The Standard now states that beekeepers will need to maintain records necessary to enable the person that they are supplying to demonstrate compliance, and provide a written statement when requested to do so in respect of options four, five, and six. Eight submitters (including 3 hobbyists, 3 commercial operators, and 2 beekeepers) supported the monitoring of tutu plants as a means to manage tutin risk. NZFSA response: The same compliance options will be available for both extracted and comb honey, with the exception of testing which will only apply to extracted honey. New option three involves holding records confirming that the risk is managed under a Food Safety Programme (FSP). The records will need to confirm that the honey has been sourced from a processor that has undertaken either primary processing or apiary activities under an FSP. New option six is discussed at length under Cost. It involves weekly monitoring of tutu bushes for honeydew and keeping written records of inspections. NZFSA sees it as a particularly affordable and practical option for a small beekeeper to take to demonstrate compliance with the Standard. Listing Eighteen submissions (including 5 commercial operators, 4 beekeepers, 4 hobbyists, 3 associations/clubs, 1 honey packer, and 1 with an unknown affiliation) supported NZFSA having access to the existing apiary register under the Biosecurity Act 1993, rather than duplicating records by creating a new listing requirement. Two hobbyists disagreed with having a register of hives. NZFSA response: The listing requirement has been removed from the Standard, due to a desire not to pre-empt the discussion around the apiary register. Should a listing requirement prove necessary this could be added at a later date. Education Twenty-two submitters (including 7 commercial operators, 6 hobbyists, 3 beekeepers, 2 associations/clubs, 2 with an unknown affiliation, 1 victim of poisoning, and 1 honey packer) suggested that better education of beekeepers is required. Page 14 Summary of submissions received on NZFSA Public Discussion Document 09/08: Tutin in honey NZFSA response: NZFSA agrees that the bee products industry needs to be better educated about the risk of tutin in honey, and this will be a component of future communication with the sector. NZFSA is sending guidance material to all registered beekeepers along with copies of the new Standard to ensure that this information is widely disseminated. NZFSA understands that new beekeepers registering their hives, as required under the Biosecurity Act 1993, are now receiving education material on tutin risk. Next steps The Minister for Food Safety has agreed to issue the Food (Tutin in Honey) Standard 2008. The Standard will come into force on 25 January 2009. NZFSA is sending out a copy of the Standard along with a guidance document to all registered beekeepers. The guidance document will explain how to comply with the new Standard. The Minister requested the addition of a new clause in the Standard, which provides that NZFSA must begin a review of the operation of the Standard and its impacts within six months of the commencement of the Standard.
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