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More about the National Residue Survey
Purpose
Clients and stakeholders
Objectives
Residues, health and trade
NRS legislation
Operating environment
Projects
Laboratory performance evaluation and proficiency testing
Funding
Analytical arrangements
Analytical costs
Purpose
The National Residue Survey (NRS) is an operational unit of the Food and Product Safety and Integrity Branch of the Product Integrity, Animal and Plant Health Division within the Australian Government Department of Agriculture, Fisheries and Forestry (DAFF). NRS is located in Canberra, and was established in the early 1960s as the Australian Government response to growing concerns about pesticide residues in major meat exporting markets. Since 1993, the imposition of various industry levies has meant that the range of commodities tested in 2007–2008 covers 25 animal-derived products (meat, honey, egg and fish) and 25 plant commodities including five horticultural products.
The primary purpose of NRS is to facilitate key export and domestic market access for participating industries by:
- providing residue testing services that are technically sound, risk-based and structured to meet market requirements, within a specified budget
- providing scientific and policy advice on residues and contaminants to the Australian government and industry
- underpinning participating industries’ quality assurance projects
- providing support to industry and government in settling matters concerning residue-related trade incidents
- maintaining a database of residue test results for the use of participating industries, when legally acceptable.
Clients and stakeholders
The key clients and stakeholders of NRS are:
- participating industries and the rural and regional communities associated with them
- Australian Government ministers
- Australian, state and territory government authorities
- trading partners, and
- the general community.
Industry leaders and decision-makers are involved in NRS planning and operation through the National Residue Survey Advisory Panel.
Objectives
NRS residue monitoring is part of an overall Australian Government strategy to minimise chemical residues and environmental contaminants in food. NRS can also assist in identifying potential problems including failure to comply with good agricultural practice, and can indicate where follow-up action is required to maintain Australia’s reputation as a supplier of produce that meets domestic and international market requirements.
NRS residue monitoring underpins the export and domestic marketing initiatives of participating industries and thus enhances the value of Australian agricultural industries, and maintains consumer confidence by providing:
- independent, authoritative and scientifically-based evidence supporting the chemical residue and contaminant status of the products covered by NRS residue monitoring activities
- scientific advice on residues and contaminants and contributing to the management of residue-related issues.
Residues, health and trade
In agriculture, the term ‘residue’ is generally used to describe a small amount of a chemical or its breakdown products which remain in or on a product. In the context of food safety concerns, the term ‘residue’ can also include environmental contaminants such as metals, or chemicals such as mycotoxins. These may be present in food either through natural circumstances or as a consequence of industrial or agricultural activities.
Conventional agricultural systems depend extensively on the use of a wide range of agricultural and veterinary (agvet) chemicals. Current analytical technology can detect such chemicals at very low concentrations. It is therefore to be expected that a wide range of chemicals will be detected in agricultural products and, in fact, in all products of the natural environment.
In these circumstances, the detection of a residue is not a matter of concern except when the use of the relevant chemical is unauthorised or its concentration is greater than a limit set in either the context of trade (domestic, export and import) or human health. In reality, human health is rarely an issue since Australian Standards for residues are set at levels necessary to meet health concerns or acceptable daily intake levels.
Food standards take into account residue levels that are normally likely to occur (environmental contaminants), and the amount that should not be exceeded if good agricultural practice has been followed (agvet chemicals). The average daily intake is normally established at a level 100 times lower than the ‘No Observable Effect Level’, so residue standards have a large built-in safety factor. However, climate, geography, pests, diseases and products vary from country to country, and therefore differing limits may be set for particular residues in certain products in other countries.
The general purposes of residue monitoring are to:
- provide an estimate of the occurrence of residues in products (based on sampling procedures and statistical probabilities)
- confirm (or otherwise) that residues in products are below set limits, and
- alert responsible government authorities and industry if and when limits are exceeded so that corrective action can be taken.
National Residue Survey legislation
The National Residue Survey Administration Act 1992 and 17 individual imposition Acts were enacted in December 1992 and came into effect on 1 July 1993. The National Residue Survey Administration Act was amended in 1994 to include animal feed and fibre products. To meet industry needs and the requirements of the Financial Management and Accountability Act 1997, further administrative changes were made in 1998 to combine the 17 individual imposition Acts into the National Residue Survey (Excise) Levy Act 1998 and the National Residue Survey (Customs) Levy Act 1998.
NRS has a legal obligation to present an annual report to government and industry, under the National Residue Survey Administration Act 1992. NRS results are reported regularly to participating industries and relevant government authorities. State and territory government authorities are immediately notified when Australian residue standards are contravened, so that they can investigate and take preventative action.
Operating environment
The World Trade Organisation Agreement on Sanitary and Phytosanitary Measures (WTO SPS Agreement) came into effect in 1995 following conclusion of the Uruguay round of multilateral trade negotiations. Implemented by member countries, it provides measures to safeguard the health and lives of humans, animals and plants, and allows for scientific scrutiny. The WTO SPS Agreement also requires such standards to be based, as far as possible, on international standards which in the case of residues are the standards set by the international Codex Alimentarius Commission. Measures that provide a high level of protection must be scientifically justifiable and not be a disguised restriction of trade.
This important change to the trading environment for Australian agricultural industries focused attention on the need for residue standards to be scientifically based and for data from residue testing programs (such as those conducted by NRS) to be capable of withstanding scientific scrutiny. NRS is accredited by the National Association of Testing Authorities as a proficiency testing provider, and requires all contract laboratories taking part in residue analysis to implement comprehensive intra-laboratory regimes in addition to their normal quality assurance procedures.
Some countries that import Australian meat products require a Government residue monitoring program in the country of origin, as a condition of entry for certain products. These countries include the United States of America and the European Union, both of which audit the operations and results of NRS random residue monitoring surveys. Canada, Mexico, Japan and Korea have conditions of entry similar to the United States. The European Union has specific requirements for fisheries and aquaculture products. Most countries require that imported food commodities are certified as complying with agreed chemical residues limits. The Australian Quarantine Inspection Service (AQIS) certifies meat products on the basis of NRS monitoring surveys.
Australian domestic meat processing facilities are required to comply with an appropriate Australian Standard such as theAustralian Standard for Hygienic Production and Transportation of Meat and Meat products for Human Consumption: AS 4696-2002. Compliance with the Standard is a condition of the license for processing meat from livestock, poultry, ratites (ostrich and emu) and game sold on the domestic market. Participation in NRS monitoring surveys is a necessary part of conforming to the appropriate Australian Standard.
The results from NRS residue testing facilitate certification of commodities for export (when this is required) and compliance with requirements for domestic consumption. NRS random monitoring projects assist participating industries to maintain long-term access to, and competitive advantage in, important markets. They also support agricultural and food promotions in new and potential markets and serve as yardsticks against which industry-operated quality assurance schemes can be validated.
Projects
NRS projects involve random, targeted and compliance monitoring of commodities, and laboratory performance evaluation.
Random monitoring
Projects are designed to estimate the occurrence of a residue (or residues) in a commodity, by a randomised sampling process
Targeted monitoring
Projects are designed to obtain more focused information about a known or potential residue problem, by a targeted (non-random) sampling process.
Compliance testing
Projects are part of regulatory control measures designed to prevent the normal marketing of products with a known contamination risk.
Residue prevention
Projects are designed to prevent or minimise the risks of unacceptable residues to public health and trade.
Consignment testing
Projects are designed to meet specific requirements of client industries for market access support (eg products where each consignment must be sampled prior to export).
Laboratory performance evaluation and proficiency testing
NRS supplies externally-funded laboratory performance evaluation and proficiency testing services in support of participating industries.
Chemical–commodity selection
Chemical–commodity combinations for analysis are selected on the basis of risk profiles and are determined by NRS in consultation with industries, on the basis of risk evaluations. Those combinations of the highest concern are considered for inclusion in NRS monitoring surveys. In conducting risk evaluations, the main factors considered are:
- the registered use of a particular chemical
- the likelihood of residue occurrence
- the extent of use, usage pattern and incentives for misuse
- the persistence of a chemical in the environment, animals and crops
- the extent to which the residue has been monitored in the past and the results of that monitoring
- the availability of suitable analytical methods, testing capacity and laboratory proficiency testing arrangements
- specific overseas requirements and perceptions of the residue as a possible public health hazard.
Sample numbers are determined through discussions with relevant industries, taking into account statistical probability requirements, costs and the demands of trading partners.
Concentrations of any agvet residues or environmental contaminants detected in samples are assessed against Australian Standards that are expressed as maximum residue limits (MRLs) for residues and maximum levels (ML) for contaminants. Residues and contaminants are classified as being ‘present’ if their concentration is greater than the limit of reporting (LOR) that is typically between 10% and 20% of the relevant MRL or ML.
Funding
Since legislation was enabled in 1992, NRS has operated under full cost-recovery. NRS is largely funded by industry, with projects being funded in several ways:
- direct funding via industry levies, and interest earned on the short-term investment of industry funds held in industry equalisation accounts (IEAs)
- direct payments from industries - for example, projects undertaken under contract
- payments from laboratories for participation in proficiency testing
- payments from external clients for provision of proficiency testing services.
NRS is also funded through the community service obligation appropriation of the Australian Government for activities related to national and international residue control.
Use of industry funds
The NRS Special Account was established under the National Residue Survey Administration Act 1992 (the Act). Payments from this Special Account may be spent in monitoring and reporting the level of residues and environmental contaminants, tracing and determining the sources and causes of those contaminants and preventing such residues and contaminants.
NRS is accountable to parliament as well as to participating industries because of the legislative base for its funding and operation. Section 8 (1) (a) (iv) of the Act allows for the conduct of related activity (which is not specifically defined) which also must be agreed to by the relevant peak industry body. Criteria for access to funds under this section are set out in the section concerning funding.
Funds in the NRS Special Account are held in separate Industry Equalisation Accounts or IEAs (cost centres), and as such are not used to cross-subsidise between participating industries.
Cost recovery
The basic policy underlying cost recovery is that expenses must not exceed revenue received. It is not a function of the NRS Special Account to generate a profit or sustain a loss, or to subsidise the activities of a particular industry or the Government, nor can industry programs be subsidised from government appropriations.
Analytical arrangements
NRS contracts laboratory services through a competitive tender process conducted in accordance with Australian Government guidelines. Some contracts are held by government laboratories while others are held by private sector laboratories. Contracts run through a two-year cycle, with the current cycle (three years) having started on 1 July 2008 and running until 30 June 2011.
NRS is an accredited proficiency testing provider, and carries out proficiency testing of laboratories to evaluate their relative performance and their competence to undertake specific chemical analyses. This ensures the validity of residue testing results.
The main criteria in selecting laboratories are technical proficiency, capacity to deliver services in a timely manner, satisfactory performance in ongoing NRS proficiency testing and value for money. Laboratory accreditation by NATA is required, as is accreditation for a particular test when (as generally occurs) circumstances permit.
Analytical costs
The costs of analyses vary, depending on the characteristics of the chemical involved and the tissue or substance in which it is to be measured. In general, chemicals such as hormones are more expensive to analyse than pesticide chemicals (eg. organochlorines) and, generally, analyses involving plant material are significantly more expensive than those involving material of animal origin.