ANIMAL FEED CONTROLS - Minister for Agriculture, Food and ... · The State Laboratory retains...

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:


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:


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).

16

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.

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


Y (inorganic feed) LOQ:

1 mg/kg (organic)

359 mg/kg (inorganic)

Reg EU No 939/2010

A Sodium ICPOES using microwave digestion sample


Y (inorganic feed) LOQ: 96 mg/kg (organic)


Reg EU No 939/2010

A Magnesium ICPOES using microwave digestion sample


Y (inorganic feed) LOQ: 39 mg/kg (organic)


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


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



35 mg/kg (inorganic) Reg EU No 939/2010

A Manganese ICPOES using microwave digestion sample



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


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


(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)


(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



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



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


with Immunoaffinity

clean-up

Commission Recommendation 2006/576/EC

0.001 LOQ

Fumonisins G High Performance


with Immunoaffinity

clean-up

Commission Recommendation 2006/576/EC 0.020 LOQ

39

ZEA G High Performance


with Immunoaffinity

clean-up


DON, T2, HT2,

Nivalenol

G GC/MS(Trichothecene

Analysis)


Hydrocyanic acid A

Free gossypol A Reg

152/2009

Theobromine H High Performance


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


Dieldrin expressed as

dieldrin


Campheclor

(Toxaphene)


41

Chlordane (sum of cis-

and trans- isomers and

of oxychlordane,

expressed as chlordane)


DDT (sum of DDT-,

TDE- and DDE-

isomers, expressed as

DDT)


Endosulfan (sum of

and isomers and

of endosulfan sulphate

expressed as

endosulfan)


Endrin (sum of endrin

and of -keto-endrin,

expressed as endrin)


Heptachlor (sum of

heptachlor and of

heptachlorepoxide,

expressed as

heptachlor)


Hexachlorobenzene

(HCB)


Hexachlorocyclohexane

(HCH)


-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

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