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Minutes of the Molluscan Shellfish Safety Committee - 7 November 2024

Location: Online 

Attendees: 

  • FSAI: David Lyons, Una Walton 
  • SFPA: Niall O'Rahelly, Aileen O’Sullivan, Marc Shorten
  • MI: Bill Dore, Conor Duffy, Sinead Keaveney, Felix Sproll, Patrick Costello
  • IFA: Finian O’Sullivan
  • BIM: Vicky Lyons
  • EPA: Liam Ó Súilleabháin (LÓS)
  • Industry: Patrick Murphy, Dean Murphy, Tristan Hugh-Jones (THJ), Kian Louet-Feisser (KLF), Diarmuid Kelly (DK)
  • Uisce Éireann: Sarah Casey 

Apologies:

  • Patricia Daly, Teresa Morrissey, Gary McCoy, Dave Clarke, Joanne Gaffney, Pat Mulloy, Joanne Gaffney, Ciaran McGonigle, Susan Coughlan

1. Minutes and matters arising from the last meeting (17.08.2024)

The following points were discussed:

Management of Agricultural Slurry Spreading and Classification 

  • FO’S raised concerns about managing agricultural slurry spreading and the impact of high rainfall on water contaminants. These events can cause spikes that may not accurately represent typical bay conditions.
  • DL reiterated that there is an opportunity to make submissions during the classification process. These submissions can present linked environmental events that may collectively impact results. DL stressed the importance of timely submissions as soon as such events are observed.
  • DM highlighted that while individual rainfall events may not justify exclusion, cumulative events could significantly affect contaminant levels.
  • DL acknowledged the challenges of reevaluating historical data and suggested investigating rainfall parameters, especially given increasing rainfall trends.
  • AOS emphasised the importance of documenting elevated results through the SFPA’s report form, where SFPA follows up on elevated results. This documentation is critical for the annual classification process.

Action: A report on rainfall data and its impact on classification will be prepared for the next meeting, with potential adjustments to parameters. UPDATE: A verbal update on legislative options for managing rainfall events  was discussed at the meeting on 06.03.25 with a written update to be provided.

DL also noted that all measures align with the Community Guide to Good Practice to stand up to future audits by the Commission.

Differentiating Human and Animal Pollution Sources

  • FO’S requested testing to differentiate between human and animal contaminants, particularly in areas near sewage treatment plants.
  • DL acknowledged the challenges, explaining that past attempts to interpret legislation constructively, though well-intentioned, led to compliance issues and findings during audits. He emphasised the importance of adhering strictly to the legislation to avoid similar outcomes.
  • BD noted that while source attribution testing is technically possible, it is expensive. In general, when the MI sees a high result, they usually have a good idea of the source.

Water Quality and Pollutant Sources

  • DK raised concerns about the statutory roles of those responsible for managing water entering the bays, particularly pollution from agricultural and urban sources.
  • DK recommended catchment-level monitoring instead of focusing solely on shellfish sites.
  • KLF expressed frustration with Uisce Éireann's lack of prioritisation for areas with high norovirus levels due to legislative gaps.
  • DM questioned why Ireland does not permit exporting Class B shellfish, unlike other EU countries. DL explained that reclassification practices differ across Member States, noting Ireland does not reclassify. He highlighted that other Member States may perceive Ireland's small production areas as an advantage.
  • LOS outlined EPA responsibilities, including licensing urban wastewater discharges and overseeing agricultural inspection plans.
  • LOS clarified that urban wastewater discharge licenses include broad conditions, such as prohibiting discharges that cause environmental pollution. If a pollution incident is reported or evidence of non-compliance is found, the EPA will investigate under the terms of the license. Public complaints should first be directed to the facility operator, such as Uisce Éireann's, for prompt resolution.
  • LOS emphasised that overflow discharges should not cause environmental pollution. The EPA can take enforcement action without relying on specific parameters listed in a license.
  • DK raised concerns about cases where specific parameters are not included in licenses, allowing operators to act within the license limits despite potential issues. DK suggested reviewing these parameters to ensure adequate coverage. LOS clarified that while parameters vary across licenses depending on discharge location and environmental sensitivity, the overarching rule is that discharges should not cause pollution. Although there is no simple test for norovirus currently, this does not preclude the EPA from taking enforcement action to prevent pollution in protected areas.
  • AOS noted that other Member States are exploring different legislative approaches and suggested revisiting the matter in future discussions.

Action:  LÓS to provide additional EPA contact information and how to make a complaint 

UPDATE: LÓS provided the links below on how to make a complaint to Uisce Éireann or the EPA regarding wastewater discharges and shellfish water quality noting the quickest way to address an environmental issue is to contact the person/ business believed to be causing the problem. They may be unaware of the issue or its effects and might be willing to resolve it.

Action: AOS will review and share relevant legislation and include it on the agenda for the December meeting.

UPDATE: Relevant legislation has been shared with the meeting minutes.

Update on Castletownbere Phytoplankton Laboratory Analyst

Following the campaign in August, the MI have now recruited a person for this role. 

2. Standing Items

2a.Upda te on Shellfish Monitoring Coordination (SFPA)

Marc Shorten introduced himself as the new Shellfish Monitoring Manager and provided a Q3 2024 update:

  • Sampling Activity: SFPOs collected 1188 microbiological samples in 2024 to the end of Quarter 3 (September 30th) as part of the Microbiological Monitoring of Bivalve Mollusc Production Areas.
  • Out-of-Range Results: To the end of Quarter 3 of 2024, there were 46 (3.87%) samples collected which gave out-of-range results
  • Annex B: A summary of the out-of-range or elevated results for January to September 2024 is provided in Annex B.

DM queried if the out-of-range results are increasing or decreasing over the last three years.

Action: Provide a three-year analysis of out-of-range results for trend identification 
UPDATE: Results included with minutes. 

2b Toxicity Summary Report including Production Area Closures (MI)

PC presented the MI toxicity report (refer to attached document).

  • No site closures due to toxicity in 2024.
  • Six-year trend analysis shows a significant reduction in Diarrhetic Shellfish Poisoning (DSP) toxins since their peak in 2020.Since then, toxin concentrations have steadily decreased over the last 1–2 years, showing a downward trend.

3. Microbiology and Virology 

3a. Norovirus Outbreak in June 2024 Presentation 

  • SK provided an overview of a norovirus outbreak involving 34 confirmed cases linked to oysters, with contamination attributed to rainfall, sewage overflows, and the GII.17 genotype.
  • No sample was available from the implicated batch; however, a subsequent batch harvested one week later tested positive for norovirus at 407 copies per gram.
  • SK emphasised the importance of retaining frozen samples for future outbreak investigations.

Action: A comprehensive report on the outbreak is being finalised and will be shared publicly through MSSC channels.UPDATE: Norovirus report shared with the MSSC on 28.02.2025

SK provided an update on the Oyster Packers testing programme:

  • Data from October 2017 to January 2024 shows seasonal contamination peaking from October to March, with lower levels during summer. However, the summer of 2024 experienced unusually high contamination levels, reaching peaks comparable to winter months (e.g., 1,400 copies per gram in June).
  • A significant shift was observed from the previously dominant GII.4 genotype to GII.17 during the 2023–2024 winter, responsible for 70% of clinical outbreaks.
  • Pandemic intervention measures temporarily reduced norovirus levels in both the community and marine environments. These levels have since returned to pre-pandemic trends.

The following points on Norovirus were discussed:

  • DL advised that the norovirus guidance on the FSAI website is under review to reflect recent learnings. Further updates will be provided.
  • THJ highlighted challenges faced by shellfish producers in assessing risk levels from genome copy counts and expressed concern over the term "routine sewage overflows," emphasising that such overflows should occur only in extreme circumstances.
  • KLF emphasised that overflows should not cause pollution and highlighted the inadequacy of Ireland's wastewater infrastructure. He called for regulatory support for practical solutions to mitigate the effects of wastewater, noting successful systems in the marine industry. He noted that producers are often penalised for pollution they did not cause.
  • DM queried whether routine sewage overflow data comes from Uisce Éireann and whether such overflows are considered system failures. He pointed out a clear link between routine sewage overflows and contamination levels, adding that farmers are under immense pressure to produce safe food, yet overflows remain out of their control.
  • LOS clarified that stormwater overflows are designed to discharge during wet weather to prevent system overload. However, these discharges must meet specific criteria to avoid causing pollution or breaching water quality standards. A multi-year program is underway to assess and upgrade overflows, with monitoring being critical for understanding their frequency and impact.
  • FO’S raised questions about the Urban Wastewater Directive and whether prioritisation is given to critical aquaculture areas. He asked if the Bathing Water Directive takes precedence over food-producing areas and emphasised the need to prioritise such areas in treatment plans.
  • DL reminded attendees about Uisce Éireann stakeholder engagement process, which allows stakeholders to participate in the development of capital investment programs. Engaging directly with Uisce Éireann is the most effective way to influence their decisions.

Action: The Norovirus information on the FSAI website to be reviewed. 

LOS provided the following points:

  • Uisce Éireann capital investment programs span many years, with the EPA playing a consultative role but not being the sole decision-maker.
  • Stakeholders, including shellfish growers, are encouraged to provide input into these programs.
  • The EPA has developed a priority area list for the Urban Wastewater Report, though impacts on shellfish waters are not yet a criterion for prioritisation.
  • Frequent overflow events, especially during dry or minimally wet conditions, indicate network or treatment system overloading, which must be addressed.

PM suggested forming a subgroup to address challenges collaboratively and effectively. DL acknowledged the proposal and suggested presenting it to the main group for consideration, noting that group submissions carry more weight.

3b. PREVIR Research Project (MI)

SK presented an EU project aiming to develop an early-warning tool for predicting enteric viruses like norovirus, which could guide decision-making.

3c. Norovirus Carlingford

  • KLF presented slides on norovirus prevalence in classified production areas (October 2017 to January 2024). He stressed that norovirus is solely human-sourced and highlighted persistent water quality concerns since the 2010 product recall.
  • It was proposed exploring a sub-committee to engage with the EPA and other organisations responsible for ensuring good quality discharges.
  • Importance of coordinated approaches among producers for advocacy was highlighted.
  • Concerns about sharing individual data due to commercial sensitivity were discussed. Aggregated data could be shared with Uisce Éireann and the EPA to inform decision-making.

4. AOB

MS provided some updates:

  • Sanitary Survey programs are ongoing on a risk basis, with approximately 10 surveys planned for the next round.

Action: NO’R to share link to Sanitary Survey Webpage

UPDATE: There is a link on the SFPA Sanitary Surveys webpage for anyone in the industry who wishes to apply for their aquaculture site to be prioritised for a sanitary survey: https://www.sfpa.ie/Search/resource/2963

  • Awareness of busy season approaching – delays in samples can be problematic so it was stressed to producers to get samples in on time.
  • ALS lab’s withdrawal from service provision was discussed, with CLS potentially stepping in to cover the gap.
  • The latest draft of the COP revisions is expected in December, with a rollout planned for early 2025.

Concerns were raised about the lack of resources for retesting samples with unusual results. BD stressed that effort is put into lab quality control and that unusual results may not always indicate errors.