Table 1: Summary of issues raised and FSANZ response Issue Raised by response Support P1027 and the use of an evidence based risk assessment process in developing the approach. Producers Australia National Working on Grain Protection CropLife Australia Queensland Department of Agriculture and Fisheries and Department of Health Safe Food Production Queensland Australian and Wine Authority Victorian Departments of Health and Human Services, and Economic Development, Jobs, Transport and Resources Noted. FSANZ is committed to the use of internationally recognised scientific methodologies based on the best available scientific evidence in its risk assessment approaches. The P1027 approach reflects that commitment. Commends for its initiative in developing this approach. Australian Grape and Wine Authority Noted. The approach is a practical and balanced way to manage low level inadvertent chemical residues in food commodities; provides marketing advantages for food imports and domestic food trade, relief from the application of ‘zero tolerance’ and gives certainty and national consistency for the food industry and regulators. It is consistent with the approach pursued in various international wine trade forums. Grain Producers Australia National Working Party on Grain Protection Food and Beverages Importers Association Queensland Department of Agriculture and Fisheries and Department of Health Victorian Department Economic Development, Jobs, Transport and Resources Australian Grape and Wine Authority Noted. The establishment of All other foods except animal food commodities MRLs using the P1027 approach, prevents the application of ‘zero tolerance’ to low level inadvertent agvet residues in food commodities assessed as safe, and prevents the violation of the Code by such foods. As stated in the 2nd call for submissions assessment summary (April 2016), an important principle underlying the approach is national consistency for regulators and the food industry. Support the All foods except trial Food and Beverages Noted
animal food commodities MRLs established for the 19 chemicals used to the approach as the levels are assessed as not posing health concerns to consumers. The approach allows control of use regulators to take actions required to improve chemical use practices food producers. Importers Association Safe Food Production Queensland (Safe Food) Australian Food and Grocery Council Victorian Departments of Health and Human Services, and Economic Development, Jobs, Transport and Resources Queensland Department of Health The approach is not appropriate for highly toxic chemicals and those not permitted for use in primary food production. Queensland Department of Health Agree. The technical paper that accompanied the 2nd CFS assessment summary showed the use of a robust risk assessment process including dietary exposure assessment for the Australian population for each agvet chemical. For an All other foods except animal food commodities MRL to be considered the agvet chemicals must already be listed in Schedule 20. To further ensure that the established All foods except animal food commodities MRLs do not pose any public health and safety concerns, niche chemicals, vertebrate poisons and chemicals listed only in Schedule 7 of the Poisons Standard (the SUSMP), were excluded. Support FSANZ’s decision not to adopt the Default MRL approach which does not address the increasing sensitivity of analytical methods to detect low level agvet chemical residues in food commodities. Safe Food Production Queensland CropLife Australia The P1027 approach overcomes the limitations of the Default MRL model, recognises the potential for increased detection of low levels of agvet chemicals with advances in analytical technology, and complies with the Ministerial Policy Guideline on the Regulation of Residues of Agricultural and Veterinary Chemicals in Food. The approach adopted as a result ensures that for each agvet chemical, the residue level permitted has been assessed, does not exceed the relevant health based guidance value and does not pose public health and safety concerns to consumers. Propose use of a provisional or complementary Default MRL for all the agvet chemicals in the Code until All other foods except Australia Australian Grape and Wine Authority Producers Australia Disagree. The aim of the Proposal and the approach developed does not for the use of interim Default MRLs.