RUSSIAN VET SERVICE DELISTS 3 MORE

UNCLAS MOSCOW 000685

SENSITIVE
SIPDIS

USDA FAS FOR OCRA/KUYPERS, NENON; OSTA/BEAN,
HAXTON; ONA/TING, SALLYARDS
PASS FSIS DUTROW, HARRIES
PASS APHIS SNOWDON
STATE FOR EUR/RUS
STATE PASS USTR FOR CHATTIN, HAFNER, S MURPHY
BRUSSELS PASS APHIS/FERNANDEZ
VIENNA PASS APHIS/MITCHELL

E.O. 12958: N/A
TAGS: EAGR ETRD ECON WTO RS
SUBJECT: RUSSIAN VET SERVICE DELISTS 3 MORE
POULTRY FACILITIES

REF: A) HANSEN/DUTROW EMAIL 3/19/09

SENSITIVE BUT UNCLASSIFIED


1. (SBU) SUMMARY: The Russian Federal Veterinary
and Phytosanitary Surveillance Service (VPSS)
advised via official letter that 3 more U.S.
poultry facilities were delisted after tests
results ostensibly showed the presence of
antibiotics and pharmaceuticals in shipments to
Russia from those plants. The original scanned
copy of the letter and courtesy translation were
sent to FAS/FSIS on March 19, 2009 (REF A). An
informal embassy translation of the letter
follows. END SUMMARY.


2. (SBU) BEGIN TEXT:
Moscow, March 18, 2009
No. FS-NV-2/2236

Assistant Administrator
Office of International Affairs
USDA Food Safety and Inspection Service (FSIS)

Dear Dr. Jones:

The Federal Veterinary and Phytosanitary
Surveillance Service (VPSS) extends its regards
to the USDA Food Safety and Inspection Service
(FSIS) and informs you of the following:

During monitoring tests of the residues of
harmful and prohibited substances, antibiotic
doxycycline, oxytetracycline and coccidiostatic
nikarbazin were revealed in chicken leg quarters
exported from the United States to the Russian
Federation (Protocols 4515 and 4516 of February
26, 2009; Protocols 4425 and 4428 of February
26, 2009; Protocol 4429 of February 26, 2009).

The products were manufactured at U.S. poultry
establishments P-243, P-7264, and P-890
(veterinary certificates RFA-057227 of December
10, 2008; RFA-049680 of November 23, 2008; RFA-
057566 of October 31, 2008; RFA-035247 of
November 07, 2008).

This incident is in direct violation of the
requirements of the negotiated veterinary
certificate for the poultry and poultry by-
products exported to the Russian Federation from
the United States.

In this connection, VPSS informs you that
temporary restrictions will be imposed on the
exports of products from the above-mentioned U.S.
poultry establishments to the Russian Federation
as of March 27, 2009. VPSS requests that you
conduct an investigation of the above-mentioned
cases and take measures for preventing the
shipments of products to the Russian Federation
that do not comply with the requirements of the
Russian Federation and the negotiated veterinary
certificate. Once the investigation is
completed, please inform VPSS with the results of
and the preventing measures that FSIS will take
to stop these types of occurrences from taking
place in the future.

Mr. Jones, let me assure you of my highest
esteem.

Attachment: on 15 pages (not included in this
cable)

Deputy Head
N.A. Vlasov
END TEXT.


3. (SBU) Russia's veterinary service began
delisting dozens of EU pork packing plants (and
several U.S. pork plants) in 2008 for allegedly
exceeding minimum residue levels for antibiotics.
Russian MRL limits do not conform to
international standards and are so low they
approach the threshold of detection. Embassy and
other observers view these delistings as an
instance of pure protectionism, and an action
paralleling recent delistings of poultry plants
for food-borne pathogens such as Salmonella.
Carried to an extreme, these measures potentially
could shut down U.S. exports of pork to Russia.
Similar restrictions related to Salmonella may
soon threaten poultry meat trade as well.

--------------
A SANPIN PRIMER
--------------


4. (U) The mechanism apparently being used,
delisting for exceeding maximum permissible
residue levels of antibiotics, involves
application of Russia's Soviet-era Sanitary Rules
and Norms (SanPiN) that are significantly more
stringent than international standards set forth
in Codex Alimentarius. Russian official
requirements for MRLs of antibiotics are listed
in SanPiN section 2.3.2.1078-01. The current
document was approved by Gennadiy Onishchenko,
Chief Medical Officer of the Russian Federation
on June 11, 2001, but it contains the Soviet
Union's legacy norms. Clause 4.1, Chemical and
Biological Pollutants, states that meat and
poultry meat, fresh, chilled and frozen, should
meet the following indicators with regard to
antibiotics:

Laevomycetine - no more than 0.01 Unit per gram

Tetracycline group - no more than 0.01 Unit per
gram

Grisin - no more then 0.5 Unit per gram

Bacitracin - no more than 0.02 Unit per gram

Thus the MRL for tetracycline and oxytetracycline
is no more then 0.01 Unit per gram for fresh pork
and poultry.


5. (U) These units of measure ("units per gram")
are not the units found in either Codex
Alimentarius or in EU regulations. Russia uses a
completely different methodology, in compliance
with guidelines approved by the Ministry of
Public Health of the USSR in 1984. Tetracycline
is revealed in a product by measuring its ability
to inhibit growth of standard microorganisms (a
special strain of Bacillus cereus). The activity
is measured in Units. According to Russian
pharmaceutical manuals 1,000,000 Units equals 1
gram of good quality tetracycline.


6. (U) Most Russian laboratories use this
methodology, but a few labs, including the
residue-testing lab of the All-Russian Federal
Scientific-research Institute for Control,
Standardization and Certification of Veterinary
Preparations (VGNKI) are equipped with modern LC-
MS (Liquid Chromatography with Mass Spectrometry)
equipment, which allows detection of low levels
of tetracycline in samples measured by weight,
e.g., micrograms. In the case of detection of
antibiotics for the U.S. poultry plants mentioned
in the letter, the tests were obviously conducted
in VGNKI. COMMENT: Washington addressees should
be aware that Russia's current CVO, Dr. Nikolay
Vlasov, worked in that institute before joining


VPSS, so he knows well the specialists in the
institute and their abilities. END COMMENT.


7. (U) By applying a conversion factor, one can
calculate that the Russian MRL for tetracycline
group antibiotics in meat and poultry is equal to
10 micrograms per kg (or 20 times more stringent
than the international standard). It is also 10
times more stringent than the EU standard.


8. (U) The Russian MRL is in fact close to the
minimal threshold sensitivity of the
microbiological method recommended for Russian
veterinary laboratories. Russian specialists
believe that level to be almost zero from the
sanitary point of view and informally consider it
an unrealistic level in day-to-day practice.

--------------
COMMENTS
--------------


9. (SBU) The agreed veterinary certificate for
export of U.S. pork and poultry to Russia
stipulates, "Meat and meat by-products do not
contain harmful residues of the following
compounds: natural or synthetic estrogenic or
hormonal substances, thyreostatics, antibiotics
or tranquilizers." It is thus a question of what
constitutes a harmful residue - the Codex MRL, or
something lower. As one of our trade contacts
put it, it is hard to find any meat and poultry
in the U.S. (or in Russia) that does not contain
even minute antibiotic residues. Thus, an
unreasonably low threshold gives the Russian
government the protectionist tool it needs to
restrict U.S. meat and poultry exports to Russia.
BEYRLE