Canadian Audit of the Mexican Shellfish Sanitation Program Final Audit Report - 2016
7. Conclusion and recommendations
Overall, the MSSP is delivered by a highly qualified professional team in a comprehensive manner. There are many examples where the program is delivered beyond the expected minimum requirements. The most notable are:
- the amount of samples collected to support the delivery of the program.
- the logistics involved in monitoring large and sometimes remote growing areas including delivery of the samples to laboratories within prescribed timelines.
There are a few recommendations noted here, which if addressed, will bring the MSSP to a level which will meet Canadian shellfish import requirements.
Growing area classification
- The Prohibited classification needs to be applied in accordance with the MSSP Technical Guide around sewage treatment discharge points and points of public health significance.
- Expand on some of the more pertinent elements required in the sanitary reports and indicate actions that were taken when bacteriological, or physical-chemical limits were exceeded.
- COFEPRIS review the statistical standard for classification of areas under the Adverse Pollution Sampling strategy described in the MSSP Technical Guide and how this would better align with the CSSP/NSSP requirements
- COFEPRIS apply more consistent and timely closures of growing areas that have been subjected to unusual weather events such as tropical storms, hurricanes and /or flooding.
Marine biotoxins
- The MSSP consistently implement the sampling procedures outlined in the Work Instruction for Sanitary Control of Shellfish Exposed to Harmful Algal Bloom and in the contingency plan for marine biotoxins. This includes taking phytoplankton samples as scheduled and responding to reported results accordingly.
On board waste containment
- The MSSP examine the issue of on-board human waste containment to determine overall roles and responsibilities as well as a current status of industry compliance with MSSP requirements.
Laboratory
- The MSSP complete in-house validation studies to verify performance of Scotia Rapid Test for ASP in the Baja California laboratory. Furthermore, a surveillance program to detect false negative results generated from the use of this kit must be implemented until a review of in-house validation data demonstrates whether an ongoing surveillance program is necessary.
- The MSSP implement an LC-MS/MS method to determine the prevalence and risk associated with lipophilic shellfish toxins documented to occur in Mexico but not included in the DSP rapid test.
- The MSSP maintain traceability of analysts conducting each laboratory method to ensure training records support work completed by individual laboratory analysts.
General
- The MSSP technical guide, technical annexes, patrol policy, and laboratory QA documents be implemented as written or updated to reflect procedures that are implemented but not documented.
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