- 04 Jun
MRL’s – a new challenge for the food industry
As you may know, the Standing Committee on Food Chain and Animal Health (SCoFCAH) have been reviewing and tightening the Pesticide Regulations with the issuance of Maximum Residue Levels (MRLs) for two compounds following reported misuse of chemicals, after higher levels of chemical residues were reportedly found on some fruit by the German Authorities. The compounds are both Quaternary Ammonium Compounds (QAC), specifically Didecyldimethylammonium chloride (DDAC) & Benzalkonium chloride (BAC).
Chemicals, including DDAC and BAC, play a vital role in the management of our environments, particularly those where food is being manufactured, processed and prepared. Benzalkonium chloride (BAC) and Didecyldimethylammonium chloride (DDAC) are the primary biocides of choice, as they represent best in class of the biocides that are available for use. They are broad-spectrum biocides and allow for a lower quantity of the biocides to be present in solution for the performance required.
In July 2012, Bundesinstitut für Risikobewertung (BfR), the German federal institute for consumer protection and food safety, issued a statement finding no long- or short-term risk for any consumer group from the DDAC residue levels resulting from direct treatment of foods. After reviewing the statutory guideline, SCoFCAH agreed to adopt a higher temporary guideline of 0.5 mg/Kg for all food and feed of plant and animal origin. The proposal of 0.5 mg/Kg was judged to be safe for all consumer groups, though each member state retained the option to enforce the default position should they wish. Dietary risk assessment studies have observed a no effect level of QAC to 16mg/Kg.
Quality controls have been put in place by the Chemical Regulation Directorate in the UK to monitor the use of these chemicals throughout the foodchain, which has led to food manufacturers being identified as having MRLs higher than the temporary guidelines found on some of their foodstuffs.
Following a comprehensive review of all available monitoring data on residues of these substances in food commodities by EFSA, the EU Commission has now proposed an amendment to Regulation 396/2005 which would have the effect of setting a permanent MRL of 0.1 mg/kg for each of the commodities listed in the Regulation. The proposal was voted through at the June 2014 Standing Committee meeting The MRL of 0.5mg/kg continues to remain in force until 12th August 2015 when the lower statutory MRL of 0.1mg/kg takes effect.
Byotrol plc is working with industry including BACS, the Chilled Food Association, chemical suppliers of the active substances and other industry players. It is our position that the difference in food production in the UK as compared with the rest of Europe has not been fully considered in setting this statutory MRL of 0.1 mg/kg. As such we supported a paper sent by the HSE requesting a derogation of biocide MRL’s in UK food and will continue to lobby while further studies are carried out.
We feel it is therefore incumbent on the food industry to continue to risk assess the use of biocides within the production chain. Byotrol plc is supporting its customers by working with food manufacturing partners to determine at what level chemical residues are being captured within the food chain, allowing for a targeted approach for the management of chemical residues without compromised food safety.
Within this context however and recognising that food manufacturers have no choice at present but to comply with legislation, Byotrol plc is pleased to offer a QAC-free solution for food contact surfaces, QFS Sanitiser+, delivering its renowned residual protection whilst lobbying continues. Whilst manufacturers such as Byotrol plc are able to respond to legislation with new technologies, one cannot underestimate the financial impact on the UK economy at the cost of these legislative changes, nor ignore the question is an MRL for QAC only the first biocide to be targeted and if all are given such low MRLs, what will the implications be to food safety in the EU which has to be our primary priority.
Byotrol plc remains committed to ensuring we retain biocidal efficacy, optimised for food safety, whilst using very low levels of biocides.
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