Advisory Council on Food and Environmental Hygiene

Confirmed Minutes of the Seventeen Meeting
held at 2:30 p.m. on Monday, 22 September 2003
at Room 1007, 10/F, Citibank Tower, 3 Garden Road, Hong Kong


Professor YUEN Kwok-yung, JP (Chairman)
Mr CHAN Bing-woon, SBS, JP
Dr CHAN Hei-ling, Helen
Dr HO Dit-sang, John
Mr HUNG Hak-hip, Peter
Professor KWAN Hoi-shan
Mr KWOK Chun-wah, Jimmy, MH
Mr LAI Tat-sang, David, MH
Ms LAM Wai-ling, Leona, JP
Mrs LAM WONG Pik-har, Grace
Mr LEE Luen-wai, John
Dr LO King-shun

Dr the Hon LO Wing-lok, JP

Dr LUI Chiu-tong, Jacqueline
Mrs Carrie YAU Permanent Secretary for Health,Welfare and Food
Mr Thomas CHAN Director of Agriculture, Fisheries and Conservation
Mr Gregory LEUNG Director of Food and Environmental Hygiene
Miss Vivian KO (Secretary)

Absent with Apologies

Dr Anthony Edward JAMES

Dr P Y LAM Director of Health

In Attendance

Health, Welfare and Food Bureau

Mr Eddy CHAN Deputy Secretary for Health, Welfare and Food (Food and Environmental Hygiene)
Mr Edward LAW Principal Assistant Secretary for Health, Welfare and Food (Food and Environmental Hygiene) 2
Ms Priscilla TO Assistant Secretary for Health,
Welfare and Food (Food and
Environmental Hygiene) 1
Miss Cordelia LAM Assistant Secretary for Health,
Welfare and Food (Food and
Environmental Hygiene) 2
Mr Louis NG Senior Executive Officer (Food and
Environmental Hygiene)

Food and Environmental Hygiene Department

Dr S P MAK Deputy Director (Food & Public Health)
Ms Rhonda LO Acting Deputy Director
(Environmental Hygiene)
Dr Y Y HO Consultant (Community Medicine)
(Risk Assessment and Communication)
Dr Samuel YEUNG Senior Medical Officer (Risk Assessment)

Department of Health

Dr L Y TSE Consultant (Community Medicine)


Opening Remarks

                The Chairman welcomed Members to the meeting.

  Agenda Item 1: Confirmation of the Minutes of the Last Meeting

2.                             Members confirmed the minutes of the last meeting.

  Agenda Item 2 : Matters Arising from the Minutes of the Last Meeting

3.                             There was no matter arising.   

  Agenda Item 3: Discovery of Vibrio Cholerae in Retail Fish Stalls and the Quality of Fish Tank Water

4.                            The Chairman invited Mr Eddy CHAN to present the paper.

5.                             A Member opined that as Vibrio cholerae contamination could occur anywhere along the supply chain of live fish for food purposes, the Government should be cautious in determining which party would be liable for the contamination detected when amending the law to regulate live fish.

6.               A Member asked whether the Government could trace back the source of seawater in the recent incident of finding Vibrio cholerae O1 E1 Tor serotype Ogawa in a supermarket fish stall. In response, Mr Gregory LEUNG said that the concerned supermarket chain had already provided an investigation report to the Food and Environmental Hygiene Department (FEHD). According to the company, live fish was sourced from live fish wholesalers and transported to the company��s Ap Lei Chau distribution centre before being sent to individual fish stalls in the supermarket chain. The company used natural seawater for its distribution centre and synthetic seawater for the retail outlets. It claimed that contamination had occurred at the wholesale level. FEHD was still conducting a detailed investigation on the incident.

7.               The Member suggested that the Government could require live fish retailers and wholesalers to source seawater from registered suppliers. She also asked if the Government was planning to license the operation of live fish wholesalers. Mr Leung replied that the issue of possible contamination during transportation, storage and delivery could not be addressed by licensing seawater suppliers. FEHD was considering to require all live fish wholesalers and retailers to use synthetic seawater instead of natural seawater to keep live seafood. FEHD had conducted a survey in early September 2003, and the results showed that 70% of the restaurants with water tank containing live seafood and 50% of the retail outlets selling live seafood already used synthetic seawater. Although the trade claimed that the use of synthetic seawater would significantly increase their operational costs, the problem seemed not that significant. As regards live fish wholesalers, the Government planned to introduce a licensing scheme whereby the wholesalers would be required to install sanitary fitments, drainage and disinfection facilities in accordance with standards set by FEHD. The licensing scheme would apply to wholesale fish stalls managed by the Fish Marketing Organization as well as those outside its purview.

8.                 Another Member said that a filtration and disinfection system should also be installed even if synthetic seawater was used. He asked whether there were qualified contractors for inspecting filtration and disinfection facilities. Noting that time was needed for a filtration and disinfection system to kill all the germs in fish tank water, the Member said that seafood had to be kept under the system for an adequately long period of time before consumption. This might however affect the quality of the seafood.

9.                             Mr Leung concurred that it was important for seafood operators to properly install and operate their filtration and disinfection system. FEHD had issued detailed guidance notes to traders to apprise them of the proper procedures for four common disinfection methods and management practices that should be observed for better quality control of fish tank water. Briefing sessions were also conducted and relevant pamphlets distributed to seafood operators and suppliers of filtration and disinfection facilities.


10.                        Addressing a Member��s question on the source of Vibrio cholerae and another Member's question on the infectivity of the bacteria, Dr Y Y HO said that Vibrio cholerae was present in seawater contaminated with human faecal matters. However, the latest research indicated that even without such contamination, Vibrio cholerae could also be found in seawater as the bacteria could be natural habitants of seawater, particularly in estuarine waters. As regards infectivity, the infectious dose of Vibrio cholerae was 104 to 106 organisms and the presence of this pathogen of O1 and O139 types in fish tank water already constituted a breach of the law.

11.                        A Member said that the requirement to use synthetic seawater could not fully address the problem. He suggested that the problem should be controlled at source and consideration should be given to adopt HACCP-based food safety plan to safeguard food safety and the quality of seafood. Mr Leung agreed that the proposal to require the use of synthetic seawater could only reduce the risk. Any measures to regulate seafood at source would affect the existing modus operandi of the fishing industry. As a major proportion of the locally consumed seafood was caught outside Hong Kong waters, there would be problems in tracing the source.

12.                        In response to the Member��s query about the prevalence of Vibrio cholerae in Hong Kong waters, Dr Y Y HO said that it was not always easy to detect the bacteria even if they were present in seawater. The prevalence of the bacteria in local waters was unclear and further research would be required to understand the local situation.

13.                        Noting that the ultra-violet disinfection system was not functioning properly when the initial water sample was collected from the fish stall at Tokwawan Market on 20 August 2003, a Member asked whether such disinfection system broke down easily. Dr Y Y HO replied that UV radiation was one of the three most commonly used methods by the trade for disinfection of fish tank water. The other two were ozonation and cooper silver ionisation. These three types of systems, if properly installed and used, could produce the desired effects of disinfection. However, their efficacy could be undermined by the lack of regular maintenance or improper management practices. In response to two Members�� questions about the use of titanium oxide for disinfecting fish tank water, Dr Y Y HO said that this disinfection method was also used by the trade, but was not as common as the other three.

14.                        Addressing another Member��s concern about whether there was any surveillance of other bacteria and parasites in fish tank water, Dr Y Y HO said that the main focus was to test for Vibrio cholerae as the bacteria could cause major outbreaks.

15.                        A Member asked if there was any previous case of cholera outbreak caused by the contamination of fish tank water. He also asked if there was any surveillance of other contaminants in seafood and specific regulatory programme for the sale and consumption of sashimi. Dr L Y TSE said that there was one previous cholera outbreak associated with contaminated fish tank water. She pointed out that the best safeguard against cholera was to practise good personal, food and environmental hygiene, and cook seafood thoroughly before eating. Dr S P MAK added that FEHD had put in place a risk-based surveillance programme to collect samples of seafood along the supply chain. Under the programme, marine fish was tested for heavy metal contaminants and biotoxins whereas freshwater fish was tested for the presence of parasites and chemical residues. Ms Rhonda LO supplemented that there was special licensing control over food premises selling sashimi and shellfish to ensure the food safety and hygiene of these food products.

16.                        A Member said that he supported the proposal to require all live seafood retailers and wholesalers to use synthetic seawater to keep their live seafood. In response to his query about the cost discrepancy between using synthetic seawater and natural seawater, Ms Rhonda LO said that live seafood operators claimed that their cost of operation would double if synthetic seawater was used. Mr Leung added that the requirement to use synthetic seawater would inevitably increase the operational cost of those seafood operators who had all along extracted seawater from the sea at no cost. However, it was doubtful if the additional cost was really that significant.

17.                        Addressing the Member��s concern about the pollution in Victoria Harbour, Ms Rhonda LO said that FEHD erected warning signs at coastal areas where the seawater was heavily polluted and should not be extracted for keeping live seafood. FEHD also carried out blitz operations against any illegal extraction of seawater from these water zones for keeping live seafood for sale. Mr Leung supplemented that the enforcement actions, however, were not easy. FEHD had to establish that the seawater was actually used for keeping live seafood for sale in order to successfully put the case to court. It required FEHD staff to follow the whole sequence of activities from the extraction of polluted seawater to the discharge of seawater into a fish tank located in food premises.

18.                        A Member asked whether the two recent incidents of detecting Vibrio cholerae in fish tank water were alarming as compared with previous surveillance records. She said that while further control measures should be taken, it was also important to strike a balance to avoid causing unnecessary panic amongst the public if the media played up the incident. In response, Mr Leung said that the recent situation was not particularly alarming as compared with previous surveillance records. In fact, the two incidents were a reflection of the effective operation of the existing surveillance mechanism. However, given that Vibrio cholerae was highly infectious, the Government needed to put in place further measures to ensure the quality of seafood and fish tank water for the protection of food safety and public health.

19.                        A Member said that cholera organisms would be present in seawater when there was contamination by faecal matters. In addition, cholera organisms were also natural habitants of seawater where there was inter-crossing between rivers and the sea. With the increase in temperature, the amount of cholera organisms would increase. Cholera outbreak was an important public health incident as the disease was highly infectious. He supported the Government��s proposal to license the operation of live seafood wholesalers in order to ensure the quality of seawater used by wholesalers for keeping live seafood. However, as contamination might occur during transportation and delivery, Government should also license live seafood transporters.

20.                        Mr Eddy CHAN said that for the longer term, the Government would review the adequacy of existing legislative framework and regulatory measures with respect to surveillance, examination and sampling of seafood in the food distribution chain. As the regulation of seafood especially live fish involved complicated issues, the Government would carefully consider the matter and draw on international best practices as appropriate.             

Agenda Item 4 : Any Other Business

21.                        Mrs Yau said that the Health, Welfare and Food Bureau issued a publication ��Checklist of Measures to Combat SARS�� on 22 September 2003 and a copy of the publication was tabled for Members�� perusal. The Checklist outlined the preventive, surveillance and contingency measures at different levels that would be taken by the Government to combat SARS. The Severe Acute Respiratory Syndrome Expert Committee would publish its report in October 2003. The Government would study the recommendations made by the Expert Committee and incorporate them in the Checklist where appropriate. The Checklist would be updated in the light of the views received from the public and further experience gathered.

22.                        There being no other business, the meeting ended at about 5:00 p.m.



Advisory Council on Food and Environmental Hygiene

Health, Welfare and Food Bureau

October 2003