This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Health & Consumers Directorate

This presentation expresses exclusively the author’s personal opinions and does

not, in any case, bind the European Commission

Health & Consumers Directorate General

Update on contaminants legislationAdvisory group on fish

and Aquaculture23 March 2010



Contents

Issues of relevance for fish and fishery products

PCBs and dioxinsHeavy metals (cadmium, arsenic, lead)Polycyclic aromatic hydrocarbons (PAH)



PCBs and dioxinsSetting levels for non-dioxin like PCBs in food

sum of 6 indicator PCBs (PCB 28, 52, 101, 138,153,180) level under discussions for fish: 75 ng/g fresh weight separate level for eel, river fish (?), exemption Baltic fish (?) Consultation stakeholders July 2009.



PCBs and dioxinsReviewing levels of dioxins and dioxin-like PCBs

TEF 1998 TEF 2005 levels TEF 2005 currently under discussion: For dioxins (PCDD/F) alone

fish: 3 pg/g fresh weight Eel: 3,5 pg/g fresh weightMarine oil: 1,75 pg/g fat

For the sum of dioxins and dioxin-like PCBs Fish: 6 pg/g fresh weight Eel: 10 pg/g fresh weightMarine oil: 6/7,5 pg/g fat



PCBs and dioxins

Simultaneously, discussions are ongoing for dioxins and PCBs in feed sector (fish meal, fish oil and fish feed)

setting levels for non dioxin-like PCBs reviewing existing maximum levels by using TEF 2005 values



Heavy metals Cadmium

EFSA opinion adopted January 2009Follow up discussions ongoing within Expert Committee of Member States

Arsenic: EFSA opinion adopted October 2009Follow up discussion to start soon

Lead: EFSA opinion adopted March 2010, not yet published



Cadmium- EFSA conclusionsTolerable Weekly Intake (TWI) of 2.5 µg/kg bodyweight (previously: 7 µg/kg b.w.)Vegetarians, children, smokers and people living in highly contaminated areas may exceed the TWI by about 2-fold. Cadmium exposure should be reduced



Follow up on EFSA Opinion - Cadmium

Review of current MLs in the light of EFSA opinion – still at initial stageFish and seafood not major contributors to exposure (mainly vegetables and cereals)But fish/seafood to be considered within the review, e.g. list of exemptions of default limit of 0.05 mg/kg (14 species)

Cadmium- Fishery products- Data needs IFish species Data needs-

priorities

Bonito (sarda sarda) ++

Common two banded seabream (Diplodus vulgaris)

++

Eel (anguila anguilla) ++

Grey mullet (Mugil labrosus labrosus)

++

Horse mackerel (Trachurus species)

++

Cadmium- Fishery products- Data needs IIFish species Data needs-

priorities

Louvar (Luvarus mperialis) ++

Mackerel (Scomber species) ++

Sardine (Sardina pilachardus) +

Sardinops (Sardinops species) ++

Wedge sole (Dicologoglossa cuneata)

++



Cadmium- Fishery products-Data needs IIIFish species Data needs-

priorities

Bullet tuna (Auxis spp.) +

Anchovy (Engraulis spp.) +/-

Swordfish (Xiphias gladius) +/-

Tuna (Thunnus, Euthynnus spp., Katsuwonus pelamis)

-

Arsenic – EFSA conclusionsInorganic arsenic is the most toxic form. Organic forms less toxic, but data on toxicity and occurrence lackingJECFA PTWI of 15 µg/kg b.w. for inorganic arsenic no longer appropriate. Margin of exposure approach (MOE) was used.Estimated dietary exposures for inorganic arsenic for average and high adult consumers is within the range of the benchmark dose (BMDL01 values); therefore there is little or no margin of exposureExposure for children can be 2-3 fold that of adults



Arsenic – EFSA conclusionsMain conclusion: Dietary exposure to inorganic arsenic should be reduced.Total arsenic levels in fish and seafood are high, but the relative proportion of inorganic arsenic in fish is small and tends to decrease as total arsenic increasesFixed values for inorganic arsenic in fish were assumed (0.03 mg/kg in fish and 0.1 mg/kg in seafood)



Arsenic – Follow up

Questions to be discussed in Expert group:

Need for MLs on arsenic?If so, on basis of total or inorganic As?For which food groups?Need for improvement of analytical methods and enhance laboratory performance?

Lead – EFSA ConclusionsOpinion adopted on 19 March 2010Publication expected for end of April 2010



PAH – EFSA conclusionsBenzo(a)pyrene alone is not a suitable indicator for the occurrence of PAH in foodA system of PAH4 or PAH8 would be more appropriate, with PAH8 not providing much added value compared to PAH4Highest contributors to human exposure: cereals& cereal products, seafood, vegetablesMargin of exposure for average consumers of low concern; for high consumers close to or less than 10,000 potential concern



Review of PAH MLsBenzo(a)pyrene MLs will be maintained but reviewed with new occurrence dataSum ML for PAH4 will be introduced (benzo(a)pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene)Review of analytical performance criteria (Regulation (EC) No. 333/2007): current proposal is to use the performance criteria for BaP



Specific issues on PAH in fish/seafood

Sprats in oil: request from Latvia for higher than current ML Smoked meat and fish, bivalve molluscs: are lower than current MLs possible/appropriate?Fresh and smoked bivalves: confirm that no difference in PAH levelsCrustaceans, cephalopods other than smoked

Need to maintain ML? No data and apparently low levels Do they metabolise PAH as fresh fish does (therefore low levels expected?)



Data needs for PAH

Smoked spratsCrustaceans, cephalopods other than smokedBivalve molluscs, smoked and not smoked



Contacts

[email protected]@ec.europa.eu

Thank you for your attention!

Documents

This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Health & Consumers Directorate