Maximum Residue Limits (MRLs) and Biocides
Article 19(1)(e) of the Biocidal Product Regulation (EU) No 528/2012 requires that Maximum Residue Limits, where appropriate, are established for active substances contained in a biocidal product.
MRLs are not safety levels.
The meaning of “where appropriate” has not been defined. There are concerns that these limits might be set in an inappropriate manner, at impractical levels and enforced at inappropriate tiers of the supply chain.
Food safety may be adversely affected. Biocides are used to control pathogens.
Food waste may be adversely affected. Biocides also control environmental bacteria which are linked to food spoilage. Premature food spoilage results in higher levels of food waste.
Leading a group of more than 15 other UK food and hygiene industry organisations (Food & Biocides Industry Group, or FBIG), we have developed a position statement, questions and answers, and Good practice approaches to the use of biocides for cleaning and disinfection.
Data are required on biocide residues in food and feed – use the CFA data collection proforma.
Coverage in Food Manufacture (6/4/16).
We are seeking:
1. Recognition by the EC that food safety and public health is of paramount concern. MRL considerations for biocidally active substances should be in tandem with consideration of the risks to safety from those pathogens the biocides are intended to control. In March 2017 the EC adopted a 3 year interim approach recognising this.
2. Impact and risk assessments should be commissioned to adequately consider all the concerns before any MRLs are set. MRLs should only be set for those operations and actives where risk assessment demonstrates that their use may exceed an acceptable margin of safety.
3. Careful consideration should be given to the workability of any regime to ensure that no size or type of business is set at a significant disadvantage in complying with this legislation.
4. Urgent clarification on the scope and means of enforcement of both the PPP (396/2005) and the BPR (528/2012) in the case of foodstuffs and biocidal actives which potentially fall under both regulations. It is clear that the means are not available to the foodservice industry and other sectors to ensure compliance with the PPP for components of composite foods which fall under the scope of Annex I of the PPP.
5. An exemption under the PPP to be applied to residues of biocidally active substances regulated under the BPR in prepared and composite foods.
6. The enforcement of disinfectants under the BPR is not conducted by analysing food for biocide residues since those residues may have arisen in prior stages of the food supply chain and not be attributable to the business under inspection.
7. The future efficacy requirements for various product types to be agreed by the member state Competent Authorities responsible for food hygiene substantially before the product authorisation process under the BPR commences.