MINISTRY OF AGRICULTURE AND RURAL DEVELOPMENT
NATIONAL AGRO-FORESTRY-FISHERIES QUALITY ASSURANCE DEPARTMENT The Residues Monitoring Program for Certain Harmful Substances in aquaculture fish and products thereof in 2009 and Implementation Plan in 2010
RESULTS OF THE MONITORING PROGRAM FOR CERTAIN HARMFUL
The Program for control of residues in farmed fish has been implemented with allocated
budget and plan approved by the Ministry of Agriculture and Rural Development (by Decision No. 1543/QD-BNN-TC of 2 June 2009 approving estimated expenditure of National Target Program for Food Hygiene and Safety 2009). Relevant bodies carried out the Program in accordance with the regulations promulgated by the Decision No. 130/2008/QD-BNN of 31 December 2008 of the Ministry of Agriculture and Rural Development, procedures as described in the Manual for control of residues as well as relevant guidances published by the National Agro-Forestry-Fisheries Quality Assurance Department (NAFIQAD), which are also in compliance with EC regulations.
The Program was considered to be in line with EU requirements by the FVO inspection
team to Vietnam during 19-29 October 2009, reflecting effective controls of residues in aquaculture fish in Vietnam.
2. Monitored scope and species Participating provinces Aquaculture species monodon), white shrimp (Penaeus Vannamei), tilapia (Oreochromis spp)
monodon), white shrimp (Penaeus hypophthalmus), tilapia (Oreochromis monodon), white shrimp (Penaeus (Macrobrachium rosenbergii), white
(Scylla serrata), catfish (Pangasius hypophthalmus) Black
Catfish (Pangasius hypophthalmus),
tilapia (Oreochromis spp), black tiger
prawn (Macrobrachium rosenbergii) 36 provinces/cities 2.2. Sampled species
Under the Program 2009, samples have been taken at all stages of production chain:
from hatchery to commercial size farming stage. Certain samples of fishery veterinary drugs and feeds have also been taken for surveillance. Details of sampling at each stage and groups to be analysed are described in the Table 2.
Table 2: Sampled species Production stage Samples taken Testing parameters
Seller of veterinary drugs Veterinary drugs
- A1 group (Stilbens – salts and derivatives of stilbens): Diethylstilbestrol - A3 group (Steroids): Methyltestosterone - A6 group (prohibited antibiotics): Chloramphenicol (CAP), Nitrofurans (NTRs) - B1 group (Anti-bacteria substances): Groups of Tetracycline, Quinolones, Sulfonamide,
- B2a group (Anti worm substances, paracides): Trichlofon (Dipterex) - B3a group (Organochlorinated pesticides group): HCB, Lindane, Heptachlor, Aldrin,
- B3c group (heavy metals): Pb, Cd, Hg, As - B3d group (Toxic fungus): Aflatoxin - B3e Violet/Leucocrystal Violet.3. Sampling and testing 3.1. Sampling
- In 2009, the sampling was carried out by the local competent authorities in compliance with the plan approved by the Ministry of Agriculture and Rural Development (Decision No. 1543/QD-BNN-TC of 2 June 2009 approving estimated expenditure of National Target
Program for Food Hygiene and Safety 2009). However, following monthly reports on current aquaculture from local competent authorities, NAFIQAD Branches modified monthly sampling plan on types of sample, testing parameters and number of samples to be taken to be complaint with current situation in locals. Therefore, there was a slight difference between the Plan and the implementation.
Sampling activities carried out in 2009 in NAFIQAD Branches are showed in Table 3.
Table 3: Sampling activities Samples taken upon testing group/parameter NAFIQAD Samples Qui Trim Flo 58 57 1,439 1,222 270 51 53 1,410 1,184 258 Note: CAP - Chloramphenicol; NF - Nitrofurans; TC - Tetracyclines; Sul - Sulfonamides; Qui - Quinolones; Trim – Trimethoprim; Flo – Flofenicol; Hg - Mercury, Cd – Cadmium; Pb – Lead; As – Arsen; MG:Malachite Green/ Leucomalachite Green; CV - Crystal Violet/Leucocrytal Violet.
Within the Residues Monitoring Program 2009, total of 3,990 samples were
taken, in which 3,455 samples of aquaculture fish, 150 of veterinary drugs, 172 of feeds, 97 of hatchery water and 116 of fish raw materials taken at middlemen, completing 96,8% of the Plan.
The above table shows that sampling by NAFIQAD Branches is fairly in line
with the Plan. However, the implementation is still insignificantly different from the Plan because NAFIQAD Branches has amended sampling plan to fit actual farming (based on monthly monitoring reports).
The number of taken samples is actually lower than the planned due to the
impacts of storms and flood in the Central Vietnam; epidemic outbreak in some aquaculture areas causing death of fish species and no sampling; and changes of harvest time in some aquaculture sites (earlier harvest to avoid flood).
3.2 Testing results
Testing results for harmful substances residues in 2009 are showed in the
Table 4. Testing results Number of Number of testings unsatisfact Tested groups Tested substances Plan Imple. 1. Aquacultured fish A1. STILBENES A3. Steroids A6.CHLORAMPHENICOL A6.NITROFURANS Nitrofurantoin Furaltadone Furazolidone Nitrofurazone TETRACYCLINES B1. Other antibiotics Number of Number of testings unsatisfact Tested groups Tested substances Plan Imple. SULFONAMIDES QUINOLONES Flofenicol Trimethoprim B2a. Anti worm substances, parasiticides B3a. Organochlorinated pesticides group Number of Number of testings unsatisfact Tested groups Tested substances Plan Imple. B3c. Heavy metals B3d. Fungal toxin B3e. Dyes 2. Fishery raw materials at middleman A6. CHLORAMPHENICOL 3. Veterinary drugs A6. CHLORAMPHENICOL A6. NITROFURANS A6. CHLORAMPHENICOL A6. NITROFURANS B3d. MYCOTOXINS 5. Hatchery water A6. CHLORAMPHENICOL 3.2.1. For fish samples collected from aquaculture sites
- DiethylStilbestrol (group A1) residues were not detected in 51 analysis;
Methyltestosterone (group A3) were not detected in 53 analysis of tilapia and catfish samples. As last years, these results showed no abuse of hormones or growth stimulators in aquaculture industry in Vietnam.
- Prohibited antibiotics (Group A6): 05 samples of tra catfish among 887
analysis (0,56%) were detected with Chloramphenicol residues of 0,41 – 2,01 ppb; 03 samples of giant prawn and 04 samples of soft shell crab / 888 analysis (0,79%) with SEM of 0,27 – 7,59 ppb. This demonstrated that certain farms still abused prohibited antibiotics in aquaculture.
- Malachite Green was not detected in 340 analysis. Together with the MG
control results of recent years, this result reflects positive changes in farmers’ awareness about no MG abuse in fish disease prevention and cure. In 2009, Crystal Violet (Gentian violet) was added to group B3e, but it was not detected in aquaculture fish among 293 analysis.
- For restricted antibiotics (group B1):
+ None among 258 analysis was detected with Tetracycline.
+ 02 tra catfish and 01 black tiger shrimp among 697 analysis (0,43%) were
found with Sulfonamides exceeding the MRL.
+ 02 tra catfish and 01 black tiger shrimp among 702 analysis (0,43%) were
found with Quinolones exceeding the MRL.
+ 02 tra catfish / 108 analysis (1,85%) were detected with Trimethoprim of 56
+ None among 115 analysis was detected with Trimethoprim and none among
101 analysis was detected with Florfenicol.
All above mentioned results demonstrated that there is still antibiotics (groups of Quinolones, Sulfonamides) abuse for fishery disease treatment (according to Circular of the Minister of Agriculture and Rual development No. 15/2009/TT-BNN dated 17 March 2009 promulgating the list of drugs, chemicals, antibiotics banned/restricted to use), however violations have decreased in comparison with those in 2008. Therefore, it is required to strictly control the use of these groups in 2010.
- There was no detection of anti worm substances and parasiticides (B2a
- For environment contaminants: Among 184 analysis, there was no detection
of organochlorinated substances residues (Group B3a); among 181 analysis, none found with heavy metal residues (Group B3c).
- No Aflatoxin was detected in 140 analysis.
3.2.2. For fish samples collected at middlemen
Among 121 analysis, none was detected with Chloramphenicol residues. This
showed that the abuse of banned antibiotics in fishery preservating was effectively controlled.
3.2.3. For veterinary drugs, feed and hatchery water samples
- For veterinary drugs samples: all results of 147 analysis were satisfactory,
there was no detection of Chloramphenicol and Furazolidone residues in veterinary drugs samples.
- For feed samples: Chloramphenicol residues were not detected in any feed
samples; one among 160 analysis (0,6%) was detected with Furazolidone residues; 10 feed samples / 166 analysis were contaminated with Aflatoxin (B1) exceeding the MRL with the detection values from 10 ppb - 94,2 ppb. The above mentioned results demonstrated that feed preservation at some middlemen and farmers was not carried out well and in accordance with techniques, therefore Aflatoxin (B1) was formed in feed samples.
- For hatchery water samples: Analysis results showed that 2 hatchery water
samples / 97 analysis (2,06%) were found with Chloramphenicol residues of 0,03 ppb and 56,89 ppb. These results reflect that the Chloramphenicol abuse in breeding production stage has significantly decreased.
3.3. Actions taken against violations 3.3.1. For farmed fish a. Violations related to Chloramphenicol, SEM contaminations
- Requesting to suspend the harvesting in contaminated aquaculture sites, apply
- Requesting processors not to purchase raw materials from aquaculture sites
contaminated with chemical, banned antibiotics residues;
- Carrying out the investigation of contamination cause and intensifying the
sampling. When the results of intensified samples testing were satisfactory, the harvesting in relevant aquaculture sites was allowed;
- Intensifying the sampling in contaminated aquaculture farms/areas in the
- Strengthening propaganda on harmfulness of using banned chemicals and
b. Sulfonamides, Quinolones, Trimethoprim residues exceeding the MRLs
- Requesting to suspend the harvesting, apply relaying regime / surveillance;
- Until the antibiotics detection levels were under the MRLs, the relaying regime
was removed and the harvesting was allowed.
- Guiding farmers to comply with the withdrawal time of veterinary drugs prior
3.3.2. For Aflatoxin contaminated feeds
- Seizing and destroying contaminated feeds;
- Carrying out the investigation of contamination cause and intensifying the
inspection of storage conditions of feed traders.
- Strenghtening communications to feed traders on hygiene conditions in feed
3.3.3. For Furazolidone contaminated feeds
- Applying administrative sanctions against violations for middlemen providing
the above contaminated feeds and carrying out traceback, recalling feeds from middlemen.
- Carrying out the investigation of contamination cause and recommending food
business operators to comply with regulations on the use of banned chemicals, antibiotics in breed production and trade.
3.3.4. For hatchery water samples
- Carrying out the investigation of contamination cause. However, since shrimp
breeds in two hatchery basins, where contaminated water samples were taken, died because of white spot disease, the farmers let the hatchery water out.
- Carrying out the sampling for verification in other hatchery basins of
contaminated aquaculture site/hatchery, all results of samples testing were satisfactory.
- Strengthening propaganda on harmfulness of using banned chemicals and
antibiotics to farmers, recommending hatchery farmers to check composition of drugs indicated on the label before purchase and use, do not use drugs containing banned substances or substances with unknown origin.
PLAN FOR MONITORING CERTAIN HARMFUL SUBSTANCES
Based on monitoring results of 2009 and survey results on current aquaculture
status, the Monitoring plan 2010 has been set up as follows:
1. Species and subjects to be monitored:
a. Principles to identify species and subjects to be monitored:
- Aquacultured species having large production;
- Samples of raw materials at middlemen for verification the use of banned
chemicals, antibiotics in fishery preservating;
- Do not carry out sampling for veterinary drugs and aquatic feeds to verify
banned chemicals, antibiotics residues, this activity will be carried out by the specialized departments in charge of veterinary drugs and feeds.
b. In 2010, following species and subjects will be sampled:
- Giant prawn (Macrobrachium rosenbergii)
- Black Tiger Shrimps (Penaeus monodon)
- White shrimp (Penaeus vannamei)
- Tra Catfish (Pangasius hypophthalmus)
- Climbing perch (Anabas testudineus)
- Mudfish (Ophiocephalus striatus) 2. Parameters to be analyzed
Following EU guidelines on the control planning of chemicals and antibiotics
residues in aquaculture fish for third countries, results of previous years and feedback from importing markets and recommendations of EU inspection team in October 2009, testing groups in 2010 are designated as follows:
Table 5: Testing groups in 2010 Substrates Designated testing groups
- B3a: Organochlorinated pesticides, including
Lindan, HCB, Heptachlo, Aldrin, Diendrin, Endrin,
Substrates Designated testing groups
- A6: Chloramphenicol and Nitrofurans (AOZ (3-amino-2 oxazolidinone); AMOZ (3- amino - 5 morfolinomethyl-1,3 oxazolidin-one); AHD (1-aminohydantoin); SEM - Semicarbazide). - B1: Tetracylines (Chlotetracycline, Oxytetracycline, Tetracycline), Sulfonamides (Sulfadiazine, Sulfadimidine (Sulfamethazine), Sulfamethoxazole, Sulfadimethoxine, Sulfachlorpyridazine), Quinolones (Difloxacin, Sarafloxacine, Ciprofloxacine, Danofloxacine, Enrofloxacine, Flumequine, Oxolinic acid), Trimethoprim, Florfenicol
- B2a and Trifluralin: Trichlorfon (Dipterex), Praziquantel; Trifluralin. - B3a: Organochlorinated pesticides, including Lindan HCB, Heptachlo, Aldrin, Diendrin, Endrin, DDT, Chlodance - B3c: Pb, Hg, Cd - B3d: Aflatoxin - B3e: Malachite Green/Leuco Malachite Green; Crystal Violet/Leucocrytal Violet For farmed fish, it is required to carry out additional tests for: - A1: Diethylstillbestrol - A3: Methyltestosterone
3. Sampling plan
Samples are monitored for harmful substances residues throughout the
aquaculture, the sampling based upon production volume will be carried out as follows:
- For intensive farmed shrimps: 2,313 samples over 234,782 tons of products
(estimated), equivalent to the rate of 1/100 (sample/ton).
- For extensive farmed shrimps: this farming method is only applied in several
provinces with large water surface and mangroes forest for aquaculture; farmers localize big tidy areas (over 5 ha) and use natural breeds. With big aquaculture areas and low stocking density, the use of feeds and veterinary drugs for fish disease prevention in this case is not efficient. Therefore, farmers applying this aquaculture method never feed and treat the fish with veterinary drugs. For this reason, for extensive farmed shrimps, the sampling will be carried out to test for environmental contaminants (B3a, B3c) with a frequency of 1-2 samples/area/year at the time of commercial-sized products.
- For Tra catfish: 1,540 samples over 857,663 tons, equivalent to the rate of
1/550 (sample/ton). The low sampling rate is applied due to the super-intensive farming with a productivity of 300-500 ton/ha. For this reason, the proposed rate can assure the effective control of chemical and antibiotics residues on tra catfish.
Table 6: Sampling plan based upon productivity Tentative production in 2009 categorized by farming methods Farmed fish / Others Intensive Extensive production 1,148,085 1,150,251 4. Sampling plan upon testing groups
Based on monitoring results of 2009, the samling plan 2010 will focus on:
- Intensifying the sampling of farmed fish for CAP and NTRs.
- Intensifying to test farmed fish for Sulfonamides and Quinolones residues.
- Reducing number of follow-up samples for B3d, Tetracylines, Florfenicol, Trimethoprim.
- Additionally testing for Trifluralin together with Group B2a.
- Adding Praziquantel to the Group B2a - Anti worm substances, parasiticides.
- Reducing number of samples for Crystal Violet/Leucocrystal Violet (for which farmed fish designated to test, not shrimp/crab).
Sampling plan and groups and parameters to be analyzed are showed in Table 7Table 7: Sampling plan in 2010 Number of samples to be analysed upon testing groups No. Substrates B2a and Trifluralin B3a B3c B3d CAP NF TC Sul Qui Flor Trime Trich Prazi Triflu Tra catfish Climbing Snakehead Black tiger materials Hatchery 57 59 1,015 771 194 594 593 118 210 210 162 300 179 Note: CAP - Chloramphenicol; NF - Nitrofurans; TC - Tetracyclines; Sul - Sulfonamides; Qui - Quinolones; Trime – Trimethoprim; Flo – Flofenicol; Trich: Trichlofon; Prazi: Praziquantel; Triflu: Trifluralin; MG:Malachite Green/ Leucomalachite Green; CV: Gentian violet/ Crystal Violet/Leucocrytal Violet. 5. Sampling plan upon parameters (Annex 1)
The report of FVO inspection mission in Vietnam in October 2009 showed that
Vietnam residues monitoring program for certain harmful substance in aquaculture fish 2009 was set up and implemented in compliance with the Directive 96/23/EC of April 29, 1996 and other relevant documents.
The setting up of the Plan 2010 is based upon EC relevant legislation
documents/guidances (updated until October 16, 2009) on the establishment of the Program for control of residues in third countries, implementation results of the program 2009 as well as recommendations by FVO inspection mission carried out in October 2009. This Plan could be amended in accordance with monthly reports on aquaculture status, disease situation and use of veterinary drugs, chemicals and probiotics in aquaculture in Vietnam.
Cc: For the Director General Deputy Director General
- Competent authorities of EU member countries;
- Vietnam Embassies and Trade offices in EU member countries;
Tran Bich Nga Annex: RESIDUE MONITORING PLAN confirma Screening Group of substances Substance Matrices Confirmatory method B3a+B3c+B3d + B3e
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