Meat Notice 2018-05 - Establishment sourcing of stock to comply with importing country requirements for cadmium levels in offals

​​​NSFS reference: 12

Issue date: 05/11/2018​​

Date of effect: 15 November 2018

Review date: November 2020

Contact officers:

Dugald MacLachlan
Director Residues and Microbiology Policy
02 6272 3183

Angela Davies
Director Export Meat Program
02 6272 4237

Distribution categories

  • Central and regional office
  • Department on-plant officer(s)

Purpose

To reinforce and clarify the national requirements for the management of cadmium in liver and kidney produced in export registered cattle and sheep slaughter establishments. This notice supersedes meat notice 2018/04.

Scope

This notice applies to all export registered cattle and sheep slaughter establishments, including those where market access requires compliance with specific cadmium levels in liver and kidney offals. This notice provides for transition arrangements, see page 4.

Background 

The Department of Agriculture and Water Resources can only certify liver and kidney export where appropriate systems are in place to provide the department with confidence that relevant standards are being met. 

The department considers that for contaminants ubiquitous in the environment, management programs based on sourcing will be acceptable where the National Residue Survey (NRS) results show that the offal has historically met specified market requirements. Table 1 lists relevant standards for major markets for Australian liver and kidney. 

Table 1: Maximum levels for cadmium in liver and kidney

Country/regionMaximum Level (mg/kg)
 LiverKidney
Singapore0.20.2
Eurasian Economic Union: Armenia, Belarus, Kazakhstan, Kyrgyzstan, Russia0.31
EU and similar: China/Hong Kong, Egypt, EU, EU accession countries, Israel, Republic of Korea (ROK), Taiwan, Turkey, Vietnam

0.5

1

GCC members (Bahrain, Kuwait, Oman, Qatar, Kingdom of Saudi Arabia, United Arab Emirates)0.5 (frozen liver)Not set
Malaysia11
Australia*1.252.5
CodexNot setNot set

* In accordance with the Australian Standard for the Hygienic Production and Transportation of Meat and Meat Products for Human Consumption AS4696:2007 and the Australia New Zealand Food Standards Code. 

Standards in markets have been divided into three broad categories to assist establishments in managing residues: 

  • Eurasian Economic Union (liver 0.3 mg/kg, kidney 1 mg/kg);
  • EU and similar (liver 0.5 mg/kg, kidney 1 mg/kg); and
  • Australia (applies to all countries other than those that have maximum limits that are lower than Australia.  The Export Control (Meat and Meat Products) Orders 2005 require product for export complies with the Australia New Zealand Foods Standards Code).

In response to concerns expressed by importing countries about reliance on commercial sourcing programs developed by individual establishments, the Department of Agriculture and Water Resources and industry have implemented a national program. 

A number of options have been developed that can be used by an establishment to provide the department with the necessary confidence that product complies with the relevant standards. More than one option can be used, for example option 2 might be used for mature animals and option 1 for the rest.

  1. Disposition tables: Test results for cadmium in sheep and cattle liver from the NRS random monitoring program were used to develop state-based dispositions in order to provide confidence that the derived product complies with the relevant market standards (Appendix 1 and 2). When using this option, slaughter establishments are required to use the tables in Appendix 1 for cattle and Appendix 2 for sheep when making decisions about sourcing liver (as well as pluck where liver is included) and kidney where markets have identified maximum levels for cadmium in these offals. Where the table indicates the product is not suitable for “All other countries” the product is not suitable for human consumption.
  2. Production testing: Samples are collected from the slaughter floor or offal room from mature animals (1/500 sheep liver and kidney from ewe, wether or ram, 1/100 cattle kidney from cow, ox or bull) ensuring that tracing is maintained to the property of origin. Testing is on a test and hold basis. If all results for that tissue are less than the maximum level for that tissue in a market, the days production of that tissue is deemed acceptable for that market. If a sample is above the Australian standard, the relevant tissue (liver or kidney) from animals from that PIC are not suitable for human consumption. The product would remain eligible for use in pet food. The data will be analysed and used to further refine sourcing disposition tables. This NRS testing program will be open to nominating establishments until the required number of samples has been collected.
  3.  Alternative Procedure: Slaughter establishments that wish to use an alternative procedure (for example an establishment testing based program) to ensure liver and kidney meet relevant market standards, must apply for consideration of that procedure as outlined in the department’s Policy for approval of alternative procedures and new technologies in export registered meat establishments. This policy is found on the department’s website in ELMER 3. In their application the establishment must demonstrate that the alternative procedure delivers at least the same confidence that the product is compliant with market standards. For example, an establishment might wish to conduct lot testing.  Testing is on a test and hold basis. The department considers 10 individual cores or 10 individual liver or kidney samples, analysed separately (no aggregating/combining samples) would provide an appropriate level of confidence for compliance. A single result above the market maximum level would mean the consignment could not be certified for that market. A single level above the Australian standard would mean the consignment is not suitable for human consumption.

Establishments are responsible for the arrangement and funding of testing at a laboratory accredited by NATA for testing cadmium in offal. If conducting lot testing DO NOT use NRS consumables

Responsibilities

  1. Export-registered establishments: establishment management must:
    1. ensure the sourcing policy within their approved arrangement includes specific requirements for liver and kidney as set out in this notice
    2. where required, amend their approved arrangement to reflect changes to their sourcing policy
    3. Where establishments choose to develop and validate an alternative procedure for the sourcing of animals to produce product compliant with importing country requirements, the submission should be submitted in accordance with the “Approval of alternative procedures and new technologies”.
    4. Undertake testing of liver and kidney samples if the establishment elects to implement option 2 or 3 as described above.
    5. Retain the tested product and only release to commerce to an eligible market based on the test results and in accordance with the Maximum Levels for cadmium in table 1 above.
  2. Tier 2 establishments: Department of Agriculture and Water Resources On-Plant Veterinarian (OPV)
    1. Review any amendments to the establishment’s Approved Arrangement (AA) and recommend to the Area Technical Manager (ATM) for approval as appropriate.
    2. Verify that the company is complying with the requirements of this meat notice.
    3. Oversee the sample collection by company personnel.
    4. Where a detection has occurred above the Australian standard, notify the ATM and ensure that the establishment has taken the necessary measures to prevent the affected product from entering commerce as fit for human consumption.
  3. Tier 2 establishments: Department of Agriculture and Water Resources ATM
    1. Approve amendments to the establishment’s AA.
    2. Verify that the amended AA describe the necessary measures to prevent product with levels higher than the Australian standard from entering commerce as fit for human consumption. 
    3. Verify through audits, the establishment’s continued compliance with the requirements of this notice.
  4. State Regulatory Authority – Food
    1. As per the service level agreement with the department, audit Tier 1 establishments to assess compliance with the requirements of this notice.
    2. Notify the department through the Certification Integrity Unit (CIU) of any non-compliance with the requirement of this notice

Transition Arrangement Procedure

  1. Scope
    1. This procedure applies to all export-registered establishments not using Option 1 (disposition tables) and exporting kidneys and livers.
  2. Process
    1. Establishments will e-mail the department, via the Export Meat Operations email address, (exportmeatoperations@agriculture.gov.au) notifying of their intention to implement Option 2 and/or 3 by 15 November 2018.
    2. The Export Meat Program will acknowledge receipt of e-mails and advise the relevant Field Operations Manager/ Area Technical Manager (ATM) and the NRS.
    3. Establishments must submit their written application for alternate procedure (under Option 3) to the department through their ATM by 29 November 2018. This application must be in accordance with the department’s Policy for approval of alternative procedures and new technologies in export registered meat establishments.
    4. Amendments to the establishment AA, reflecting option 2 and/or 3, must be submitted to the department for approval through the ATM by 2 January 2019. This will enable the department to work with establishments towards assessing and approving proposed amendments.
    5. Implementation of Option 2 and/or 3 must be completed by 30 January 2019.

 

Angela Davies
Director
Export Meat Program

Appendix 1: State and age based disposition table for cattle kidney and liver to ensure confidence that exported product complies with relevant country standards for cadmium

State/ Milk teethYoung cattle (heifer/steerMature cattle (cow, ox, bull
TissueEurasian Economic UnionEU and similar †All other countriesEurasian Economic UnionEU and similar †All other countriesEurasian Economic UnionEU and similar †All other countries
Western Australia
Kidneyxx
xxxxxx
Liverx xx xx
South Australia
Kidneyxx xx xxx
Liver x xx
Victoria
Kidney xx xxx
Liver x
Tasmania
Kidney xx
Liver
New South Wales
Kidneyxx xxx
Liver x
Queensland
Kidney xx
Liver
All classes of cattle from the Northern Territory are expected to comply with importing country Cadmium residue level requirements

Key:
Indicates that animals in this category sourced from this state are most likely to provide offal (liver or kidney) with an acceptable cadmium level for this market.
x Indicates that animals in this category sourced from this state are most likely to provide offal (liver or kidney) with an unacceptable cadmium level for this market.
† EU and similar: China/Hong Kong, Egypt, EU, EU accession countries,  Israel, Republic of Korea (ROK), Taiwan, Turkey, Vietnam;  GCC members (Bahrain, Kuwait, Oman, Qatar, Kingdom of Saudi Arabia, United Arab Emirates) are considered to be “EU and similar” for exports of frozen liver. For exports of kidney GCC members are considered as “All other countries”.

Note: Singapore has set a limit of 0.2 mg/kg (Sale of Food Act) which is not captured in the above table. Other countries may have similar standards.

Appendix 2: State and age based disposition table for sheep kidney and liver to ensure confidence that exported product complies with relevant country standards for cadmium


State/  LambHoggetMature (ewe/wether/ram)
TissueEurasian Economic UnionEU and similar †All other countriesEurasian Economic UnionEU and similar †All other countriesEurasian Economic UnionEU and similar †All other countries
    Western Australia  
Kidney xxxxxx
Liver x xxxxxx
    South Australia  
Kidney xxxxxx
Liver x xx xxx
    Victoria  
Kidney xxxxxx
Liver x xxxxxx
    Tasmania  
Kidney xxx
Liver x x xx
    New South Wales  
Kidney xxx
     Western (NSW)*      
Liver
  Riverina Murray (NSW)*     
Liver x x
  Central West (NSW)*     
Liver x xx
  North West (NSW)*     
Liver x xxx
  South East (NSW)*     
Liver x xx
  North Coast (NSW)*     
Liver x xx
    Queensland  
Kidney xx
Liver x

Key
Indicates that animals in this category sourced from this state or region are most likely to provide offal (liver or kidney) with an acceptable cadmium level for this market.
x Indicates that animals in this category sourced from this state or region are most likely to provide offal (liver or kidney) with an unacceptable cadmium level for this market.
† EU and similar: China/Hong Kong, Egypt, EU, EU accession countries, Israel, Republic of Korea (ROK), Taiwan, Turkey, Vietnam;  GCC members Bahrain, Kuwait, Oman, Qatar, Kingdom of Saudi Arabia, United Arab Emirates) are considered to be “EU and similar” for exports of frozen liver. For exports of kidney GCC members are considered as “All other countries”.

Note:  Singapore has set a limit of 0.2 mg/kg (Sale of Food Act) which is not captured in the above table. Other countries may have similar standards.
* The following table gives the district codes for the various regions. In NSW the PIC comprises two letters followed by six numbers. The first two numbers are the district code, eg for the hypothetical PIC NG631111 the district code is 63, so the PIC is from the Murray Riverina region (see Appendix 3). To identify which region a PIC is located use the table at appendix 3.

Appendix 3 NSW sub-regions and district codes

Western

Murray RiverinaCentral West (includes Central Tablelands)Northwest (includes Northern Tablelands)Southeast

North Coast (includes Hunter & Greater Sydney)
PICs
District codes
03
05
07
09
13
31
39
58
60
61
01
18
20
29
30
32
34
42
44
54
55
63
04
10
11
14
16
17
22
24
27
38
40
43
02
25
33
41
45
50
51
56
59
06
08
15
23
62
75
12
21
26
28
35
36
37
46
48
52
53
64
​​​​
Last reviewed: 4 November 2019
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