THE APA - WORKING TOGETHER TO PROTECT THE PUBLIC

QUALIFIED to PROTECT

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Science - friend or foe?

Science these days is such a familiar part of our lives that often the positive role that it plays fails to be recognised instead we occasionally hear of the mistakes that scientists make and the detrimental effects that can result as a consequence.

It is reassuring, therefore, to know that there are scientists working to protect us all by maintaining a constant surveillance of the food we eat, the water we drink, the air we breathe and the toys our children play with to ensure that they are safe and fit for their intended purpose.

Scientific Enforcement

Enforcement of the many laws that control the safety and quality of food, safety of consumer goods, pollution of the environment and potability of water is generally carried out by local authority officers such as Trading Standards and Environmental Health officers, often involving the taking of official samples.

Scientific testing and evaluation of these samples is crucial to determine the truth of a situation. In circumstances where chemical and related testing is appropriate the primary service is provided by special public protection scientists known as Public Analysts.

Deadly Insecticide

Estate residents alarmed at high dog mortality, had been unable to convince the authorities that there was risk to children or cruelty to animals.

Meat found on the estate and stomach contents from dead animals were submitted by the Tenants Association to the Public Analyst, who identified an insecticide known to attack the central nervous system and produce symptoms like those displayed by the dogs.

As a consequence the Tenants were able to involve the police, who used information relating to the specific poison to narrow the search, resulting in legal action against a resident on the estate.


Why Public Analysts?

The cornerstone of the Public Analyst Service is the very special qualification known as the Mastership in Chemical Analysis (MChemA), which is an award base on a rigorous combination of pre-entry assessments and a wide-ranging examination set at post Master of Science (MSc) level. The examination itself spans a full seven days in total and comprises both theory and practical papers.

It is sobering to note that it takes longer to qualify as a Public Analyst than to become a practising doctor of medicine!

A Personal Experience

The examination itself is a most demanding test - but it is only the final part of the assessment process that leads to the award of the Mastership in Chemical Analysis. A fundamental pre-entry requirement for the examination is the attestation that the candidate has attained the appropriate level of maturity, experience and proficiency by two approved referees (counsellors), the senior being an M.Chem.A. holder from outside the candidate's own place of employment, with the second normally being the candidate's own laboratory head.

In addition to this independent assessment which is spread over a period of at least two years, candidates must demonstrate by written record direct to the awarding body, the Royal Society of Chemistry, that the breadth and depth of their experience is adequate, before entry to various parts of the examination is accepted.

The examples detailed in this bulletin give an idea of the range of situations faced by Public Analysts and involvement with which, together with many thousands of other situations and samples, form an essential part of their training. Much of the Public Analyst's work is more routine in nature but every situation or sample still needs direct and individual attention, both at the analytical stage and in its interpretation and reporting.

Learning from Mistakes?

Three years ago, with his animals dropping like flies, a distressed farmer was desperate for help.

The Public Analyst (as Official Agricultural Analyst) identified the cause to be a feeding stuff containing toxic levels of lead. Indeed, such was the enormity of the contamination that a regional crisis was declared and the combined resources of several Public Analysts' laboratories became involved in tracing the source of the lead and the consequential contamination of dairy products intended for human consumption.

A single shipment of maize gluten in a uncleaned ship's hold that had formerly contained a lead based mineral was identified as the source. Undetected by the importer or feedstuff manufacturer the lead resulted in the destruction of livestock and livelihoods and would have posed a major threat to human health had action not been taken in time.

Was the importer to blame or the feed producer negligent? Were enforcement and surveillance sampling inadequate? These questions may be debatable, but luckily the contamination had not travelled far in the human food chain and the public at large were not affected directly. Constant vigilance should ensure this incident is not repeated.

Recently, in a tragi-comic parody of the situation, a Public Analyst found a faulty consignment of China clay to have been contaminated by residues of an animal feeding stuff ... via a dirty ship's hold.


 Meat ...or is it?

A food manufacturer introduced a new product containing ham and cheese and, on the advice of a large independent consulting laboratory (non-Public Analyst and without an M. Chem. A. holder) which had tested the product and examined the recipe, declared a minimum meat content of 50%.

A Public Analyst found the product to contain only 32% meat, less than two thirds of the claimed amount.

The consultant "expert" laboratory backed up the 50% claim by producing analytical "evidence" showing the meat content to be approaching 60%. However, scrutiny of the analytical results by the Public Analyst showed that the consultant had included the cheese in with the meat!

Examination of the recipe revealed the theoretical content of "ham" in the product to be fractionally under 50% - and the true meat content of the ham used was unknown. "Ham" can contain a significant proportion of added water and have a meat content as low as 70% - hence the true meat content of the actual product.

Not only had the consultant laboratory not attempted to differentiate between meat and cheese in its analysis, even going so far subsequently as to suggest that to do so was an analytical impossibility, but it had never questioned the composition of the ham used by the manufacturer.

Without proper knowledge of analytical techniques, food composition, and appropriate interpretation, analytical results may be worse than useless.

Masters of Analysis & its Application in Law

The M.Chem.A. holder has the highest qualification in applied analytical chemistry in the UK, together with proven understanding of the law and the use of scientific data in its enforcement

The examination itself is unique in testing interpretational and reporting ability as well as analytical capability, all to the standards required in a Court of Law. This includes such interpretation of both the law and information pertaining to the sample as is necessary to assess the most appropriate analysis required in any situation.

An assurance is thereby provided that the holder of the M.Chem.A. is fully qualified to perform such functions from receipt of sample to the presentation of appropriate conclusions in legal proceedings.

Accredited Competence

The statutory qualification for Public Analysts has its origins in the infancy of food law a century ago, when the importance of accrediting the competence of individuals empowered to undertake analysis and interpretation in relation to law enforcement work was recognised. The M.Chem.A. is the legal accreditation for Public Analysts.

The recently introduced system of laboratory accreditation provides assurance that testing and analysis are carried out according to documented procedures, but the interpretation of results is not covered, nor is the ability to react and adapt to different analytical and legislative needs, nor is laboratory accreditation alone any guarantee of the absolute quality of results.

The M.Chem.A. examination covers interpretation and reactive and adaptive ability as well as analytical competence, while external proficiency testing schemes such as the Ministry of Agriculture, Fisheries and Food's Food Analysis Performance Assessment Scheme ('FAPAS) provide a means of confirming that the quality of analytical results is adequate.

When these three elements are combined to give an accredited laboratory participating in proficiency testing schemes directed and overseen by an M.Chem.A. holder, the entire package becomes an accredited service from decision on appropriate analysis to reporting of a conclusion.


A Wider Experience

Public Analysts as members of their professional Association enjoy a close professional relationship with their peers and can tap freely into the vast resource of experience and knowledge of a hundred other Public Analysts.

This resource is supplemented by the legacy of experience and knowledge passed down by generations of forbears, dating back to the very origins of public protection science.

Harmonised Enforcement

In the interests of a "level playing field" for industry and effective protection for the public it is important that public protection laws should be enforced in an equitable manner in all areas.

Part of this equitable approach requires scientists in different areas to use methods of test and standards for enforcement that yield similar results and levels of control. Indeed, in terms of food control the European Union specifically requires official laboratories to use harmonised methods.

To this end the Association of Public Analysts via the Validated Enforcement Method Service has created a common stock of harmonised methods, and via its Guide levels for Food Quality initiative seeks to ensure that all Public Analysts are fully aware of the standards the Association's members collectively support

Contaminated Water "Superior"

A Restaurant refused to serve tap water, declaring that the bottled water offer was greatly superior.

The water was labelled in a similar manner to branded mineral waters, by microbiological examination and chemical analysis showed it to have a high bacterial count, together with yeasts, moulds and algae, and including high sodium.low hardness and high nitrate levels.

The Public Analyst deduced from the overall characteristics of the water that it was most probably tap water that had been softened and perhaps filtered before bottling.

Inspection of the restaurant revealed the water bottling plant hidden in a corner of the cellar, indeed comprising a water softener and a carbon filter that had not bee changed for at least two years.

The restaurant's "superior" water was actually tap water, the wholesomeness of which had been significantly reduced by their intervention.


In Total...

The Public Analyst is therefore much more than a mere chemist, however well qualified, but is the accumulation of his or her own extensive and proven personal experience and knowledge backed by those of a dynamic network of others.

Truly a friend to all concerned with the protection of the public, but a formidable foe to those who would put the public at risk.


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