Dr. Roberto Minetti: “Any change in the legislation modifies behavior in the producers”
Minetti is member of the register Department of the National Service of health and agro-food quality (SENASA) in Buenos Aires, Argentina.
We interviewed Roberto Minetti, member of the register Department of the National Service of health and agro-food quality (SENASA) in Buenos Aires, Argentina. Dr. Minetti has been a member of the SENASA Veterinary team for 23 years. In this interview he tells us how this department works in his country, its peculiarities and how they cooperate with other countries to achieve harmonization of laws in animal nutrition. It also gives us a frame of reference on the situation that Argentina lives in terms of additives and feed.
How long have you been working in the SENASA Register department?
I have been in the register Department of the National Service of Health and food Quality (SENASA) for 23 years.
Have you always worked at SENASA?
No. Previously, I had worked as a veterinary doctor in the Bromatology field, for 15 years, and also as a veterinary doctor in the Small Animal Clinic, for 12 years, at the same time.
What positive aspects would you highlight from SENASA?
It has several positive aspects, since it covers a wide range of topics and there are many areas that work together to achieve a goal.
In my opinion, the most important thing, is its work on the controls of the safety, the health and the quality of the products of animal and vegetal origin, although in some areas it also covers products of laboratory synthesis, such as the vitamins and also the products of mineral origin.
All this is related to public health, because ultimately, everything that goes through the service will end indirectly in the final consumer, which we are ourselves.
By possessing the necessary tools for the beforementioned controls, SENASA has a very important function, because it enforces the animal and phytosanitary requirements to maintain the country’s health status at its highest possible levels.
What do you mean by health status?
The health status of each country is the level or state of health in which it is found, such as being free, or of insignificant risk as it is qualified internationally, of diseases such as BSE (bovine spongiform encephalomyelitis).
Fortunately, Argentina has a high health status, which makes foreign markets acquire our products. For them the fact that an official agency supports these products is very important, because they have particular requirements, that SENASA must verify that they are fulfilled.
In addition, these controls are extended to the products that are imported, mainly those that are of risk. And here again comes the concept of health status: Not only do we have to achieve the status, but also maintain it, so it is important to work on preventing pests or harmful products from entering the country.
As you can see, the control aspects are many and that’s why there are many areas involved in these controls: borders, laboratories, risk analysis, import and export, toxic waste analysis, product inspection, etc.
What difficulties have you faced during your career?
Generally, the difficulties for a professional arise at the beginning of the career, not only in SENASA, but also in any profession. But that is not a problem if you know how to handle it, i.e. at the beginning of the career, when there are unprecedented situations, the solution is to use the one who has more experience than you, which is usually the top hierarchical and ask for the solution for “such a problem.” Over the years it goes through different circumstances, which make one acquire “gymnastics”, to solve the issues that arise.
I imagine that the change in the laws affects the registration of the products and consequently the producers
Yes, any change in legislation modifies behavior in producers. That’s actually the intention. But changing a behavior for better is not bad.
The point is that each time a change is made, it is necessary to notify the producer (with a time of anticipation) and make the changes gradually, in order to give it a lapse of adaptation so as not to impair its operation.
At the XXXI International Symposium Biovet, held in Tarragona from 26 to 29 May 2018, you spoke of Feedlatina, what is this organization about?
Feedlatina is not an official organism, it is the association of the Animal Feeding industries of Latin America and the Caribbean. It deals, among other things, with improving trade between Latin American and Caribbean countries and led a project to improve the region’s trade exchange.
What is the importance of unifying the rules in Latin American territory?
Although the rules of the Latin American territory cannot be unified in its entirety, the idea is to harmonize the laws of the countries. This means recognizing similarities between the rules of each country, without changing them and, as a consequence, improving international trade.
What did the project accomplish?
It is a very ambitious project that managed to capture the harmonization of the different points of conflict between the public and the private sector.
Harmonizing means agreeing or approving the different concepts on the same topic that have the different countries. In other words, the objective is not for each country to change its rules, but for countries to accept some part of its regulation as similar or homologous to that of another country in the group. Because many times you talk about the same thing in other terms that seem different.
A joint technical committee was formed, consisting of representatives of the official part of the countries and the representatives of the industries.
The project developed several topics of common interest: harmonizing trade-related issues of products intended for animal nutrition; Physically assemble the official and private parties of the different countries in order to be known; To contribute to a levelling in the regulatory affairs of the constituent countries; Interact with international organizations and finally, show the commitment to continue these improvements in the future.
With respect to the first point (trade in products intended for animal nutrition), several objectives were achieved: the harmonization of free-sales certificates, the labelling of packaging and a glossary of terms for the region and others.
In relation to the second point (physically gathering the official and private parties), it was very important to know each other in the project, resulting in a fluid dialogue between the official agents and the representatives of the industry. In addition, to know firsthand the problems of the industry and the official limitations to modify regulations based on the problems posed.
In the third point (leveling in regulatory affairs), it sought to contribute to leveling the standards of requirements of countries by planning BPM courses (Good Manufacturing Practices) and HCCP (critical control points), backed by International organizations such as IICA (Inter-American Institute for Cooperation on Agriculture) and FAO (United Nations Food and Agriculture Organization). In this way a sanitary floor was achieved in all the countries, from which the animal feed can be prepared.
With respect to the fourth point (interacting with international organizations), international organizations such as FAO, OIE (World Organization for Animal Health), IICA and Codex (Codex Alimentarius) were contacted. These are important organizations to exchange knowledge and to carry out an international projection of the institution in order to achieve the support for a future continuity.
With respect to the fifth point (to show the commitment to continue with these improvements in the future), a project of continuity was carried out in the last meetings to continue working in an autonomous manner.
Do you think the project will continue?
Like any project, it has a beginning and an end. This was completed a few months ago and the results were sent to the authorities.
But the Feedlatina group’s Joint Technical Committee continues its work to initiate new projects.
A project ends and a new project should begin, that is the idea, since the subject of animal feed is not static, it is dynamic and evolves permanently.
Of course, you have to overcome issues that arise on the road as is the financing of projects, which is what is being worked on.
At the symposium, you talked about functional food for human nutrition and concluded that, with respect to probiotics, on a scientific level there are concepts to define what concepts are they referring to?
It’s basically a technical issue that I’m going to try to explain in the simplest possible way.
This principle it is valid not only for probiotics, but for all functional food in general.
When it comes to approving one of them, in the scientific field, it is going to have to demonstrate the merit of this functional food. In other words, it is not going to be able to classify a food as functional, if it does not promote any kind of merit beyond the nutritive one.
Punctually, with respect to probiotics, not all bacteria-based products can be called probiotics. To have a probiotic character they have to be the bacteria corresponding to the animal species to which it will benefit. And not only the genus of bacteria, but also the strain of the bacterium in question.
And once defined, if we get deeper, we must study whether that probiotic, which should act in the intestine, for example, has the ability to reach intact to the intestine overcoming the natural barriers of the organism that tend to destroy it.
Summarizing, and returning to the initial sentence: at the scientific level there are concepts to be defined in order to give you the classification that deserves the product.
How does the administration deal with the appearance of new types of products, as in this case?
As this new functional food, official organisms must legislate on the basis of that new food that did not exist before.
But first, before legislating, you have to study very well the products on which you are going to legislate. It is not easy to draft regulations on products that did not exist before.
And in this context, from the regulatory point of view, there are two important points: to legislate well and to legislate quickly.
Legislating well refers to not leaving gaps that lend themselves to misinterpretation or that the scope of the regulation is not understood. The concepts must be clear.
And with regard to fast legislation, refers to not take too long to do so because, in all this time that the issue is not legislated, there is gaps that leads to legal misinformation and could even confuse one issue with another because they are not clear the rules of the game.
How could the binomial administration-private company for the subject of records be improved?
By having regular meetings, between the official and the private parts. On the one hand, the private part through its representatives (Chambers of food producers) should expose their problems. On the other hand, the official part, should try to regulate the regulations, to solve those problems without hindering trade, but always, above all, protecting public health and maintaining health standards.
At the Symposium, has been also mentioned the tendency that currently exists in developed countries to use better quality food, what situation does Argentina live in at this moment?
In the countries with the greatest purchasing power, in terms of human nutrition, the demands of the market are increasing. Therefore, emphasis is placed on GMO-free foods (Genetically Modified Organisms), functional food, such as probiotics, prebiotics and others, gluten-free food, organic food, etc.
Of course, the production of these products raises the cost of processing and have greater access to them, which have greater purchasing power.
In general, each country has its strengths in certain topics. Nowadays with specializations, there is not a single country that does everything and everything well.
Regarding Argentina, the important thing is that it is not oblivious to these issues, we have full knowledge that the planet tends to it and we are one more link in the chain of production of this type of food. It is an agricultural-livestock country of excellence and has a fundamental role in the production of food not only for domestic consumption, but also for export. It has the capacity to produce food for 10 times more of its population. This is due to the geographical characteristics of the country that allow very large harvests and the obtaining of primary products in large quantities.
What challenges does the country have in terms of food?
In terms of production of animal feed, the steps to follow are those that point to excellence in production, such as the application of GMP (Good Manufacturing Practices) in all establishments and, a step further, establish HCCP (Critical Control Points) in them. All this must be carried out gradually and carried out step by step in time and form to allow a period of adaptation to the producers, in order not to produce a shock and therefore stagnation in the marketing.
And finally, what trend is currently following Argentine market in additives for animal nutrition?
Additives, not only in Argentina, but also in the world, are increasingly complex. This is due to the fact that science is developing more and more efficient products, with a lower degree of toxicity and with more precise indications of use. That is, they are more specific for each function.
Of course, there are still traditional additives that work perfectly and do not have consequences, because they are products that have been studied and have been in the market for many years.
But the general trend is to develop more synthetic products to lower costs, which is not bad, but they must have prior approval by the official sanitary agency competent in the material.