CHAPTER 3

REPORT ON THE IMPORTATION OF COOKED CHICKEN MEAT INTO AUSTRALIA

CHAPTER 3

SCIENTIFIC BASIS FOR THE PROTOCOL

Overview

Industry concerns
AQIS response to industry concerns Committee's conclusions

Overview

3.1 As noted in Chapter 2, AQIS has determined time and temperature parameters for cooking chicken meat in order to inactivate avian viruses such as Newcastle disease (ND) and Infectious Bursal disease (IBD). AQIS based this protocol on Dr Dennis Alexander's study of IBD. Mr Paul Hickey advised the Committee that AQIS selected this study as a basis for development of quarantine protocols because it represented a more conservative approach to inactivating viruses using heat than some other studies.(1)

3.2 AQIS argued that IBD can be used as a standard for heat treatment of other viruses because of its considerable resistance to heat treatment. IBD is recognised as being more resistant to heat treatment than ND or other pathogens such as salmonella bacteria.

3.3 Mr Hickey advised the Committee that there is broad agreement in the scientific community concerning the scientific work underpinning this protocol. Mr Hickey told the Committee that the following persons and organisations have collectively agreed to AQIS's scientific and technical parameters:

3.4 Dr Sarah Kahn reinforced Mr Hickey's comments and advised the Committee that:

Industry concerns

3.5 Without exception, all witnesses agreed that the work done by Dr Dennis Alexander on the thermal inactivation of IBD was sound and highly professional. However, several witnesses questioned the validity of a number of the conclusions that AQIS had drawn on the basis of Alexander's work.

3.6 Industry has encountered considerable difficulty in challenging AQIS's conclusions about the adequacy of the science that underpins the cooking protocol. Mr Tim Luckhurst explained the difficulty the industry faced:

3.7 Mr Luckhurst maintained that if a procedure cannot be scientifically proven to be unsafe, AQIS assumes that it is safe.

3.8 The areas that industry disagrees with AQIS about the science underpinning AQIS's conclusions fall into the following categories:

3.9 The Committee also received evidence from Mr Bob Baldwin MP, Member for Paterson, who raised concerns about AQIS's use of Dr Alexander's study. Mr Baldwin argued that AQIS had misused Alexander's test results and tabled a letter he had received from Dr Alexander concerning AQIS's use of his study.(5)The letter is attached at Appendix 6.

Lack of data about ND

3.10 Dr Margaret MacKenzie, General Manager, Technical Services, Inghams Enterprises, told the Committee that AQIS based its entire quarantine assessment on the work of Dr Dennis Alexander and that "Alexander himself totally disagrees with the way AQIS has used his information". She said that AQIS had extrapolated Alexander's findings concerning the inactivation of IBD and that "you cannot do that".(6)

3.11 Dr MacKenzie argued that much more work has to be done on the thermostability of ND strains. She told the Committee that there are many different strains of ND and IBD, but only a small number had been tested for thermostability:

3.12 Dr MacKenzie pointed out that the mild strain of ND that is present in Australia is "very heat resistant" and would survive heating at 56C for nine hours. She emphasised that the characteristics of the other strains of ND were unknown:

3.13 In correspondence following the public hearing process, Dr MacKenzie advised the Committee that virulent strains of IDB have "decimated" the poultry industry in some parts of Thailand and have also been present in some parts of the USA. She said that no research has been done on the thermal inactivation of these strains.(9)

3.14 Mr Luckhurst concluded that it was misleading for AQIS to draw general conclusions about the effectiveness of a cooking process on the basis of an experiment conducted with one strain of IBD:

Protective effect of different heating media

3.15 Industry representatives also argued that Alexander's test results may not give an accurate indication about how ND virus would be affected by heating in chicken meat. Dr MacKenzie explained that there is very little information available concerning the ability of Newcastle disease virus (NDV) to survive heating in chicken meat. She noted that for example, if the cooking takes place in a high fat medium, the viruses and bacteria are much more protected.

3.16 Dr MacKenzie submitted that it is not valid to draw wider conclusions about results obtained in one test medium and that work should be done on the characteristics of the virus when heated in chicken meat. She contended that:

3.18Dr Paul Gilchrist, a consultant for the Australian Chicken Growers Association, supported Dr MacKenzie's comments. He told the Committee that Dr Dennis Alexander's work is a "good standard laboratory procedure." However, he considered AQIS's use of Alexander's work was based on two questionable assumptions:

3.18 Dr Gilchrist told the Committee that it was difficult to persuade people that such assumptions were valid:

Alexander's view of AQIS's use of his test results

3.19 In his letter to Mr Baldwin, MP, Dr Alexander advised that he had problems with AQIS's interpretation of his data in two areas. Firstly, he expressed concerns about the extrapolation of data to temperatures that had not been tested. Secondly, the probability of survival of virus after heat treatment depends on the starting infectivity level. He said that this could confound stating specific times for particular temperatures if not taken into account when defining acceptable treatment processes.

3.20 Alexander confirmed Dr MacKenzie's assertions that no tests had been done on heat inactivation of ND in chicken meat and that ND may be present in the muscles and organs of infected birds:

3.21 However, much of Dr Alexander's letter supported AQIS's views. He confirmed that IBD is a very heat resistant virus and noted that when conducting his experiments, he was surprised at just how heat resistant this virus proved to be.

3.22 He advised that comparisons between heat resistance of IBD and ND are difficult as "parallel experiments under identical conditions are not available". However, he said that a "rough guide" could be obtained from an experiment conducted on liquid whole egg in his laboratory. This experiment demonstrated that ND virus lost infectivity more rapidly and at lower temperatures than IBD when compared to the results he had obtained with IBD.

3.23 Dr Alexander acknowledged that different testing media (egg instead of homogenised bursae) could have affected the results obtained. However, he considered that these would have to be "extremely different in severity" to have produced such significant differences in heat resistance between the two viruses. He concluded that:

3.24 Alexander considered that laboratory test results could be extrapolated for wider use. However, he cautioned that:

AQIS response to industry concerns

3.25 Mr Hickey strongly refuted suggestions that the cooking protocol AQIS had proposed is based on inadequate science. He said that AQIS had not relied solely on Dr Alexander's test results but has also considered eight studies on the thermal inactivation of NDV and five studies on IBD virus early in the risk analysis process. He asserted that AQIS had adopted this study because it was more conservative than other studies in the literature. Accordingly, AQIS decided to use Alexander's data as a basis for development of quarantine protocols on the basis of that conservatism.(17)

3.26 Mr Hickey tabled AQIS's 1991 discussion paper which contained the comparative studies conducted on the two viruses. Tables 1 and 2 below summarise the results of these studies.

Table 1: Summary of results of thermal inactivation studies of

Newcastle disease virus

                                                                
 REFERENCE                        RESULTS             


Farinas (1930)                   Inactivated between 50C and   
                                 55C for 30 minutes            

Bushness  and Erwin (1950)      Inactivated between:            
                                58C - 64C for 30 minutes      
                                67C for 5 minutes              

Foster and Thompson             4 strains, inactivated          
                                70C for 40-50 seconds          
                                65C for 80-90 seconds          
                                60C for 6-7 minutes            
                                55C for 60-80 minutes          

Digioia et al (1970)            99% loss of infectivity at      
                                43.3C                          
                                for 75 minutes                  

Thacore and Younger (1971)      Inactivated at 55C after       
                                 10 minutes                     

Estola (1974)                   Finnish strain survived 56c    
                                for 270 minutes                 

Lomniczi (1975)                 24 strains, most survived 50C  
                                for 60 minutes                  

Ideris et al (1990)             V4 strain, survived 56C        
                                for 9 hours                     


Source: AQIS discussion paper, The importation of fresh frozen

and cooked chicken meat and products from USA, Denmark,

Thailand and New Zealand, p. 12.

Table 2: Summary of results of thermal inactivation studies of

Infectious Bursal disease virus

                                                                
REFERENCE                                   RESULTS             


Landgraf et al  (1967)          Survived 60C for 30 minutes    
                                 Inactivated 70C for 30        
                                minutes                         

Cho and Edgar (1969)            Survived:                       
                                60C for 90 minutes             
                                25C for 21 days                
                                -20C for 3 years               

Fahey (1988)                    Survived 72C for 10 minutes    
                                Inactivated 82C for 30         
                                minutes                         
                                (Virus in tissue culture        
                                fluids)                         

Digioia et al (1970)            99% loss of infectivity at      
                                43.3C                          
                                for 75 minutes                  

MacKenzie and Spradbrow         Inactivated at:                 
(1988)                          75C for 5 minutes              
                                80C for 1 and 5 minutes        
                                85C for 1 and 5 minutes        
                                (virus in meat nugget mixture)  

Alexander (1988)                To reduce to a probability of   
                                0.1, that an infectious virus   
                                remained, heat at:              
                                70C for 50 minutes             
                                80C for 8.8 minutes            

                                To reduce to probability of     
                                .001 heat at:                   
                                70C for 90 minutes             
                                80C for 14.4 minutes           

                                (Virus in bursa homogenate)     


Source: AQIS discussion paper, The importation of fresh frozen

and cooked chicken meat and products from USA, Denmark,

Thailand and New Zealand, p. 13.

3.27 Mr Hickey assured the Committee that AQIS's proposed cooking protocol was far more stringent than suggested as being required by any of the research studies examined. For example, MacKenzie's 1988 study reported IBVD as being killed in chicken nugget meat after one to five minutes at 80C, whereas AQIS's proposal calls for processing at this temperature for 15 minutes, that is, three times as long.

3.28 Mr Hickey attacked Dr MacKenzie's statements about the effectiveness of the heat treatment process. He said the Dr MacKenzie used the results of her research to support an application by Ingams to export cooked chicken nuggets and chicken smallgoods to New Zealand and suggested that Dr MacKenzie's concerns lacked consistency with her own research:

3.29 Mr Hickey dismissed Dr MacKenzie's concerns about possible heat resistant strains of NDV:

Use of IBD as a reference organism

3.30 Mr Hickey advised the Committee that AQIS's decision to use IBD as a reference organism was a valid approach confirmed by published data. He noted the advice from Dr Alexander which stated that:

Lack of data about ND

3.31 Mr Hickey advised that there have not been specific studies on the inactivation of NDV in chicken meat. (21)However, he considered that it is not necessary to commission such research:

Protective effect of different heating media

3.32 Mr Hickey asserted that AQIS had reviewed scientific literature on heat inactivation of NDV and has taken any protective effects fully into and determining the effectiveness of the proposed quarantine treatments. He further noted that Dr Alexander's letter to Mr Baldwin indicated that he (Alexander) doubted whether chicken nugget would differ significantly from the homogenised bursae in terms of its protective effects on viruses.

3.33 The BRS study also refutes the suggestion that the use by Alexander of bursal homogenate was an invalid method of testing thermostability. The BRS noted that:

Alexander's concerns

3.34 As noted in the preceding paragraphs, Alexander expressed two reservations about AQIS's use of his data:

Extrapolation of data

3.35 Mr Hickey refuted suggestions that AQIS had improperly extrapolated Alexander's data to untested temperatures. He noted that the BRS report had made similar comments. However, AQIS had used "internationally accepted methods for calculating thermal processing standards."(24)

Probability of survival of virus and starting infectivity level

3.36 Mr Hickey said that the levels of virus used by Dr Alexander in his study were very high compared to the likely levels to be found in a vaccinated, clinically healthy but nonetheless infected chicken. BRS advice provided to AQIS confirms this assertion.(25)

3.37 The BRS report suggests that Alexander conducted his experiment using considerably higher concentrations of virus than would be found in either chickens infected with the virus or in meat contaminated with the virus after processing. He explained that the amount of virus in the material Alexander tested was:

3.38 Mr Hickey indicated that the Australian Animal Health Laboratory had provided AQIS with further information which was consistent with that of the BRS, advising that properly vaccinated birds secrete less virus.(27)

Committee's conclusions

3.39 The Committee, as non-scientists, do not consider that it is appropriate or wise to arbitrate on the issue of whether the science underpinning AQIS's proposal is sound.

3.40 AQIS has put forward a considerable amount of evidence supporting the view that its science is sound. Reputable scientific opinions including those of most of the state veterinary authorities, the Australian Animal Health Laboratory, the Bureau of Resource Sciences and Dr Dennis Alexander, a renowned international virologist support AQIS's view.

3.41 The Committee notes that Dr Alexander qualified his support with a warning about the need for care when adapting scientific findings to a commercial situation:

3.42 Equally, however, scientists within the Australian poultry industry have raised areas of doubt about some of the assumptions AQIS has made. The Committee is reluctant to dismiss these concerns lightly.

3.43 The major areas of doubt appear to be a lack of specific knowledge about the behaviour of Newcastle disease virus in chicken meat and the characteristics of different strains of both IBD and ND. While considerable scientific opinion supports AQIS's assumptions that ND is more susceptible to heat treatment than IBD, it is likely that this will remain as a point of contention unless AQIS produces incontrovertible evidence.

3.44 The Committee recommends that AQIS commission tests of the thermal inactivation of Newcastle disease virus and infectious bursal disease virus in chicken meat products. This study should be conducted in conditions that are as close as possible to commercial processing conditions.

3.45 The Committee further recommends that AQIS collaborate with industry in the design of this experiment so that there can be no further disputation about the validity of the science underlying the protocols.

Chapter 4

ENDNOTES

  1. Evidence, 13th September 1996, p. 204.
  2. Evidence, 20th September 1996, p. 24.
  3. Evidence, 28th August 1996, p. 21.
  4. Evidence, 13th September 1996, p. 136.
  5. Evidence, 13 September 1996, pp 170-3.
  6. Evidence, 13th September 1996, p. 129.
  7. Evidence, 13th September 1996, p. 135.
  8. Evidence, 13th September 1996, p. 129.
  9. Correspondence, MacKenzie, 23 October 1996
  10. Evidence, 13th September 1996, p. 136.
  11. Evidence, 13th September 1996, p. 137.
  12. Evidence, 13th September 1996, p. 137.
  13. Evidence, 13th September 1996, p. 161.
  14. Evidence, 13th September 1996, p. 172.
  15. Evidence, 13th September 1996, p. 171.
  16. Evidence, 13th September 1996, p. 171.
  17. Evidence, 30 September 1996, p. 214.
  18. Evidence, 30th September 1996, p. 219.
  19. Evidence, 30th September 1996, p. 219.
  20. Evidence, 30th September 1996, p. 215.
  21. Evidence, 30th September 1996, p. 232.
  22. Evidence, 30th September 1996, p. 218.
  23. AQIS position paper, op. cit., p.22.
  24. Evidence, 30 September 1996, p. 214.
  25. Evidence, 30 September 1996, p. 216-7.
  26. Gard, op. cit., p.11.
  27. Evidence, 30th September 1996, p. 217.
  28. Evidence, 13th September 1996, p. 171.