SUBMISSION TO PARLIAMENTARY PRIMARY PRODUCTION SELECT COMMITTEE MANUKA DEFINITION

Transcription

1 JOHN HILL SUBMISSION TO PARLIAMENTARY PRIMARY PRODUCTION SELECT COMMITTEE 15 TH FEBRUARY 2018

2 INDEX PAGE PURPOSE 2 SUMMARY 2-3 APPENDIX A Process - Gathering of Data 4-5 APPENDIX B Analytical Assessment of MPI 1516 Nectar Data 6-7 Outcome of this Regional Variation 7-8 Source of Data 9 APPENDIX C MPI Criteria for identifying manuka honey 10 APPENDIX D Response to Submissions on MPI s proposed definition for mānuka honey MPI Information Paper No: 2017/14 John Hill V1 Page 1 of 12

3 Purpose The purpose of this paper is to show that the MPI Manuka Honey Science Team has not followed a process that has a level of transparency and accuracy to develop a Robust science-based criteria for identifying mānuka honey that could be used to provide product assurances and demonstrate product authenticity in a regulatory context. Science and characterising mānuka honey Current and future science to support a definition MPI Technical Paper No: 2014/23. Summary The science process followed by MPI appears to be flawed in the collection and analysis of sample data and does not meet the : MPI Requirements for Identifying Manuka Honey. A summary of Manuka Honey Science Programme MPI Technical Paper No: 2017/28 1. Honey sourced from suppliers cannot be traced back to the areas nectar samples were sourced. Therefore there is no link to say what chemical attributes, and at what levels transfer from the manuka nectar to the conversion in the hive to manuka honey (Refer Appendix A) 2. The MPI Monofloral definition requires 5mg/kg of 2'-Methoxyacetophenone. The nectar data shows 17% of the nectar data would fail the definition although direct from the plant. 70% of these failures were in the 5 regions with the lowest levels of 2'-Methoxyacetophenone(Refer Appendix B) 3. There is large regional variation in the levels of 2'-Methoxyacetophenone. Of the 12 regions, the lowest 3 regions have an average of 12 mg/l of 2'-Methoxyacetophenone, the 3 highest regions have an average of 95mg/L of 2'-Methoxyacetophenone(Refer Appendix B) 4. Stability. The chemical has been not been proved as stable over any length of time. I. The MPI Science paper says Stability of the chemical attributes All chemical attributes were examined in laboratory controlled conditions for their stability over time (500 days) and under different temperatures (4 C, 20 C and 35 C). Six mānuka honey samples were tested. This information is incorrect as the 6 manuka samples were incubated for 68 days only as disclosed in their Manuka Honey Science Datasets Incubation Details.Stability was only completed for the 1415 Nectar set which was regionally incomplete II. In public submission 1 on stability of manuka honey stored for 811 days MPI states that a decrease of 2'-Methoxyacetophenone of 15.5% at 20oC and 7.9% at 27oC was not statistically significant but a decrease of Leptosperin of 4.7% was significantly significant III. In public submission 2 on stability of manuka honey stored at 37oC for 444 days MPI states that a decrease of 2'-Methoxyacetophenone of 8.2% was not statistically significant. (Refer Appendix C) MPI have no proof of stability after 68 days. Peer reviewed industry papers show a chemical compound with high volatility over 1 and 2 years. The life of a manuka honey product from harvesting to final sale can be more than 5 years. More independent scientific study is required. 5. Likelihood of fraud and adulteration It is not possible for the combination of attributes chosen to be defensible against fraud as all the chemical compounds are readily available off the shelf for an economical price. John Hill V1 Page 2 of 12

4 6. No peer reviews on the MPI Science have been published or disclosed by MPI, other than on the statistical cart model for the 1 st definition released. An Official Information Request has been lodged for this information, but has not been disclosed by MPI as at 15 th February. Their response date has been exceeded and a complaint has been made to the Ombudsman. The Science is not robust, the process followed is not auditable, the outcome is not fit for purpose, the science does not meet the Robust science-based criteria for identifying mānuka honey that could be used to provide product assurances and demonstrate product authenticity in a regulatory context. This chemical marker 2'-Methoxyacetophenone although unique to Leptsopermum Scoparium and the other chemical markers used to define manuka honey need an urgent review by independent science experts, along with review of MPI Science processes and procedures. John Hill V1 Page 3 of 12

5 Appendix A Process - Gathering of Data The Scope of MPI Manuka Honey Science program was to identify what was manuka honey to demonstrate product authenticity I. MPI gathered and tested 115 samples of nectar direct from manuka (Leptospermum Scoparium) plants nationally in 2015/16 from 12 New Zealand regions. The purpose of this was to find chemical markers which were unique to this plant variety. The regions have not been disclosed by MPI in any publication, so they are numbered 1 to 12. An Official Information Act request has been lodged to disclose the actual regions I.I In 2014/15 MPI gathered 42 samples but this was from only 7 regions. As there can be no direct comparison of data sets 2014/15 has been omitted as it is not truly representative of NZ regions where manuka is grown. However MPI used the /15 Nectar sample data as the basis for the MPI Science Program attributes per MPI Technical Paper 2017/28 Pg 26 Table A. Assessment of the results of statistical analysis of attribute levels in plant and honey samples from 2014/15 season. Attributes shaded in grey were included in the classification modelling approach in stage 3 The logical next step should be to obtain pure manuka honey to verify the conversion from nectar to honey by the honey bee. The process would be achieved by following the following steps. 1. Assess the area the nectar samples were sourced, is any other crop flowering at the same time? If Yes move to an area where only manuka nectar is flowering, if No Step 2 2. Place clean, honey free beehives in the area that the nectar was taken from when the flowering was taking place. This would allow the bees to gather the nectar from that area and turn it into honey in the hive. 3. Gather the honey crop before any other crop flowers 4. Test the honey gathered 5. Match to the nectar samples to compete the chain of evidence. 6. Assess the attributes The manuka honey from each hive could then be directly related to the area the nectar was gathered from and a compete scientific analysis completed to prove the actual levels of chemical markers and pollen gathered in the honey This process was not undertaken, so no direct traceability to the actual plant Leptospermum Scoparium was achieved. Honey samples including manuka were obtained by requesting samples from beekeepers from the different regional area as follows. 660 samples were supplied, including 273 that were seen by the sample suppliers as manuka monofloral. The handling and sampling techniques for these could not be verified. 82% of these manuka samples were from 5 regions so cannot be seen as representative of the manuka harvesting and gathering from the 12 regions of NZ. John Hill V1 Page 4 of 12

6 Region Total Samples submitted TOTAL MANUKA MONO AND MULTI Multi Manuka Man John Hill V1 Page 5 of 12

7 Appendix B Analytical Assessment of MPI 1516 Nectar Data At a level of 5mg/kg of 2'-Methoxyacetophenone in the nectar samples 17% of all manuka nectar samples, would fail to be classed as Manuka Monofloral although direct from the Manuka plant MPI have ignored the regionality in the sample sets where the highest level in one region is 370mg/ ll against the highest level in another region being 31 mg/ ll. The conversion rates of 2'-Methoxyacetophenone from nectar to honey is unknown, the rate could vary but the highest level seen in the MPI Honey data sets is 67 against the nectar highest level of 370 which could suggest a change ratio of 5.5. This would mean that beekeepers in the 3 regions with a 2'- Methoxyacetophenone level in the nectar below 40/ ll may find it difficult to pass the new definition Monofloral Manuka definition Details of Analysis MPI Nectar 1516 There were 115 samples of Leptospermum Scoparium nectar collected and analysed by MPI Failure rate against new MPI Science Definition of 5mg/kg of 2'-Methoxyacetophenone From the sample set 20 had levels less than 5 mg/ll which would automatically fail the new MPI Definition requiring a minimum of 5mg/kg Failure rate on samples collected of 17.4% The ratio of conversion of the nectar to the honey in the hive is not known, therefore I am unable to calculate any additional failure rate for the new standard from this data. Regionality From Table 1 note the following on regional differences in 2'-Methoxyacetophenone Average per region ranges from 10.4 mg/l in region 3 to mg/l in region 12 The lowest level is.1 mg/l in area 5 but region 12 has a lowest level of 31 mg/l The highest level is 370mg/L in region 9 The lowest median region 3 The highest median region 12 Table 1 MPI NECTAR DATA '-Methoxyacetophenone mg/ll Region Code Sample Quantity Average Low High Median Total John Hill V1 Page 6 of 12

8 Table 2 demonstrates the difference of levels of 2'-Methoxyacetophenone mg/l between the 3 lowest average regions and 3 highest average regions Regions with Lowest mg/l of 2-MAP Nectar v Regions with Highest mg/l of 2-MAP Nectar Region 3,11,8 have an average level of 11.8 v Region 7,9,12 have an average level of 95 Region 3,11,8 have an average low of.7 v Region 7,9,12 average low of 12.8 Region 3,11,8and 8 have an average high of 36.3 v Region 7,9,12 have an average high of 283 Region 3,11,8 and 8 have an average median of 7.4 v Region 7,9,12 have an average median of 46.7 Table 2 MPI NECTAR DATA '-Methoxyacetophenone mg/ll Region Code Sample Quantity Average Low High Median Average Lowest Average highest Outcome of this Regional Variation 1. Reduced value to some regional beekeepers/packers for their product which fail to meet MPI Monofloral definition. Manuka honeys that fail the Manuka Monofloral definition 5mg/kg of 2'-Methoxyacetophenone would require blending with honey from high 2'-Methoxyacetophenone areas to bring value back and allow export. This would create a win for the major packers who source from various areas, and take away the ability of some regional packers to create a distinct geographical pack. Examples of this seen in MPI Honey Cart are I. Region 11 which has the 2 nd lowest levels of 2'-Methoxyacetophenone had 75 samples of manuka honey submitted to the MPI Honey Cart. 42 of these samples would have been classed as high strength manuka under the grading system used for the last 20 years. Of these 42 samples 9 failed in a range of 10NPA to 12 NPA =21% of high strength manuka samples II. Region 8 which has the 3 rd lowest levels of 2MAP had 34 samples of manuka honey submitted to the MPI Honey Cart 16 of these would have been classed as high strength manuka under the grading system used for the last 20 years. Of these 16 samples 6 failed in a range of 8.5NPA to 20 NPA =37.5% of high strength manuka samples John Hill V1 Page 7 of 12

9 2. The now legalised OPPORTUNITY to blend almost any honey to meet the MPI Multifloral Definition As an example I have used the MPI Honey Cart. Any honey that did not pass the MPI multifloral definition has been blended back with other honey. Table 3 then shows of the 660 samples of honey submitted 219 are manuka monofloral and the balance (441)could be blended into manuka multifloral honey. Details of the 310 Honeys that were not manuka at all are in Table 3A Table 3 MPI HONEY CART BLENDS Honey Type Identified by Qty Honey Type under MPI Definition Qty honey supplier Mānuka or mānuka blend 350 Mānuka Monofloral 214 Mānuka Multifloral 84 Other 52 Other Honeys(Details in 310 Mānuka Monofloral 5 Table 3A) Mānuka Multifloral 51 Other 254 Total NZ Honey Submitted Blend together the above honeys other than Manuka Monofloral Mānuka Multifloral 84 Other 51 Mānuka Multifloral 52 Other 254 Outcome under MPI definition Mānuka Multifloral 441 Final Total Mānuka Monofloral 219 Mānuka Multifloral 441 Total Honeys from MPI Cart defined as Mānuka under MPI Science Definition of /12/2017 Table 3A Honey Type Submitted Qty Other Honeys blackcurrant 1 borage 1 bush blend 28 cabbage tree 1 chestnut 1 clover & blend 76 honeydew 15 kamahi 22 kanuka 30 lavender 2 macadamia 1 multifloral 65 pohutukawa 7 radish 1 rata 5 rewarewa 6 tawari 23 thyme 14 towai 1 Tussock grassland 3 vipers bugloss 3 willow honeydew 4 Total 310 John Hill V1 Page 8 of 12

10 Source of Data This data was obtained from MPI Manuka Science Programme Data Sets Final authored by Claire MacDonald of MPI on John Hill V1 Page 9 of 12

11 APPENDIX C MPI Criteria for identifying mānuka honey A summary of Manuka Honey Science Programme MPI Technical Paper No: 2017/28 6. Selecting the attributes Pg 7 The Science Programme began by focusing on identifying and determining the potential usefulness of selected attributes to distinguish mānuka honey from other honey types. The critical importance of demonstrating the relationship to the source plant: Are the attributes linked to nectar and pollen of L. scoparium? These are the biological materials a bee transfers to a hive. Are the attributes only found in the mānuka plant Yes Levels found in honey: Yes Do the levels of the attributes enable separation of different honey types? Several factors were considered when assessing the suitability of the attributes. Yes Ease of detection and quantification: Are there suitable laboratory test methods that could be developed and validated to detect and quantify the target attributes? Stability of attributes: Are the attributes influenced by different temperatures over time? Regional and seasonal variation: Are the levels of the attributes consistent or different across regions of New Zealand and seasons? Likelihood of fraud and adulteration: Is it possible for the combination of attributes to be defensible against fraud? Stability of the chemical attributes All chemical attributes were examined in laboratory controlled conditions for their stability over time (500 days) and under different temperatures (4 C, 20 C and 35 C). Six mānuka honey samples were tested. Yes Yes Yes wide variations across different regions of NZ. No all 4 chemical markers can be bought off the shelf Incorrect Manuka was done for 68 days John Hill V1 Page 10 of 12

12 APPENDIX D Response to Submissions on MPI s proposed definition for mānuka honey MPI Information Paper No: 2017/ Submission 1 The data were from 7 honey samples stored at 20 C and 27 C and tested at four/five time points over 811 days. The rationale for the selection of storing at 27 C is not clear, but this temperature was not studied in the MPI science programme. This temperature is not high enough as storage temperatures of honey during harvest, post-harvest, processing and transit to point of sale will be higher. Although the honey is unlikely to be stored for long periods at high temperatures (>30 C), this could influence the concentration of the markers in the honey. MPI reports the following results and observations: 2 -MAP Marker Leptosperin Analysis by submitter in submission 1 decrease by 17% per annum when stored at 20 C decrease by 12% per annum when stored at 27 C decrease of 4.4% per annum when stored at 20 C. decrease of 4.3% per annum when stored at 27 C. Analysis by MPI of data in submission 1 Decrease by 15.5% per annum when stored at 20 C, but not statistically significant. Decrease by 7.9% per annum when stored at 27 C, but not statistically significant. decrease of 4.6% per annum when stored at 20 C. decrease of 4.7% per annum when stored at 27 C. MPI Summary comments Data more complex than other markers indicating a straight line trend is inappropriate. MPI contends from its own analysis of the data presented in the submission that 2 -MAP is stable over time. Both estimates (4.6% and 4.7%) are close to the submitter s suggested threshold of lack of stability at 5% Submission 2 For this submission, 10 samples were stored at 37 o C and sampled at four time points up to 444 days. MPI reports the following results and observations: Marker Analysis by submitter in submission 2 Analysis by MPI of data in submission 2 MPI Summary comments John Hill V1 Page 11 of 12

13 2 -MAP Leptosperin decrease by 20% over 444 days Decrease of 0.1% over 444 days, but not statistically significant. Decrease by 8.2% per annum, but not statistically significant. Increase of 0.65% per annum, but not statistically significant. Data more complex than other markers indicating a straight line trend is inappropriate. MPI analysis of results differs from that in the submission as the original analysis does not account for the substantial variability in the data set. MPI contends from its own analysis of the data presented in the submission that 2 -MAP is stable over time. MPI analysis of the data presented in the submission agrees with finding by the submitter. However, a small increase rather than a decrease in concentration was observed. John Hill V1 Page 12 of 12