Presentation of David Eisenberg
of Micro-Tracers,Inc. (San Francisco) at AOAC Forum on Methods for Analysis of
Antibiotics and Drugs in Feeds- Los Angeles 22 September 2002
The Use of Colored Iron Particles in Determining
Cross Contamination of Medicated Feeds at Feedmills and Feed Premix Plants
This topic is of current interest largely because the
European Union and other major world markets are developing new food and feed
regulations that are much more aggressive than what have existed in the past.
The European Union now requires that all feedmills
whether they mix drugs in feeds or not must be registered with their national
governments. Further, they must also have data validating the adequacy of their
mixing and of their control of contamination at their feedmills and premix
plants.
The issue of medicated feed contamination into
non-medicated feeds is not new. In 1976, the USFDA requested the Animal Health
Institute (AHI) and the American Feed Industry Association (AFIA) (then American
Feed Manufacturers Association) to submit recommended "Action Levels"
that could be met by industry. These were to be the maximum levels of drugs in
nonmedicated feeds that would be considered acceptable or alternately the
minimums that would lead to FDA enforcement actions. This AHI and AFIA did
submit recommendations but opposed any action by the FDA on the matter and
because of this opposition and also because the issues are complex, more than 25
years later no Action Levels exist and the FDA probably will not progress in the
matter for at least a few more years.
Why is it important to minimize
cross-contamination of drugs into non-medicated feeds? Such residues at high
levels (i.e. 20% of formulated levels) may be toxic such as Nicarbazin reaching
breeder feeds, salinomycin reaching adult turkey feeds. or monensin reaching
horse feeds. Such residues at trace levels into "finisher" feeds, the
last feeds fed animals prior to slaughter, may lead to illegal residues of the
drugs in the tissue of the treated animals, poultry or seafood. Past problems
with sulfamethazine in pork and current problems with chloramphenicol in seafood
would be examples. A related concern would be the issue of ruminant by-product
reaching ruminant feeds where it could lead to transmission of BSE (mad cow
disease).
How is the industry currently testing to confirm
manufacturing procedures are designed to minimize cross-contamination?
Some manufacturers are testing for specific drugs formulated in their feeds, and
using such results to establish procedures applicable to all drugs used at the
feedmill.
Many
drug assays are accurate and precise in detecting drug residues in meat and
poultry as these are relatively simple matrices to work with. Formula feeds,
however, often contain large numbers of ingredients that can make analysis for
drugs at very low levels difficult or in some cases effectively impossible. It
is possible to test for cross contamination of drugs into non-medicated feed
when the drug is formulated at a very high level in the medicated feed or better
the premix and when the drug has a good assay at relatively low levels.
Page 2
Determining Cross Contamination of Medicated Feeds
Another approach is to mix simple, easy to detect tracers
most often colored iron particles into a medicated feed or premix and to
determine the tracer rather than the drug, at least as a screening procedure.
Currently, this approach is being actively investigated by TNO (Dutch Research
Institute), Tecaliman (French Research Institute) and others, primarily in
Europe.
Micro-Tracers,Inc. (San Francisco) recently participated in such a Study as
described below:
Study of Cross-Contamination of Coccicor Premix 2.5% Amprolium at Feedmill/Premix
Plant: Formulation of Tracers Into Medicated Premix:
Two tracers, red colored iron
particles with a count of 25,000/gram (micron size 150-300) and fine blue
"lake" colored iron powder (micron size 50-150) were formulated at
1-kilo each per 2,000-lbs. into one 2-ton batch of Coccicor 2.5% Amprolium
Premix.
Sampling: Medicated Premix and
Three Following Batches of Premix (pelleted) Supposed to Contain No Drug
(or tracer).
From Coccicor 2.5% Amprolium Premix
One sample at each of five locations: #1. Mixer, #2.
Conveyer (after Discharge of Mixer), #3. Elevator (at top of feedmill above
pelletmill), #4. Cooler (after pelleting) and #5. Packer (pellets at truck
loading).
From each of the following three Batches of Premix
Five samples from each of three locations: #1. Mixer, #2. Conveyer and #3.
Elevator.
The three Batches of Premix were then commingled and additional samples were
taken
Five samples from each of the following: #4. Cooler and #5. Packer.
A total of 60 samples were taken, five of the Coccicor
2.5% Amprolium Premix and fifty-five of following premixes not formulated with
the drug.
Analysis of Samples:
All samples were analyzed for the red colored iron
particles and for the fine blue "lake" iron powder. The tracers were
isolated from the premix by magnetic separation using a "Rotary
Detector" (1) equipped with a special "rare earth" magnet.
Page 3
Determining Cross Contamination of Medicated Feeds
After isolating the tracers from the premix, the red
tracer was demagnetized, sprinkled onto a large filter paper, sprayed with a
mist of 50% ethanol with 0.5% ammonium hydroxide, the paper dried and the
resulting red colored spots counted. The blue color was diffuse, not countable.
A second sub-sample was also
analyzed, isolating the two tracers from the premix via magnetic separation.
Instead of developing colored spots on a filter paper, the magnetic material was
brushed into a centrifuge tube, diluted with 1 % sodium carbonate solution,
shaken on an "auto" shaker for ten minutes, and the two colors read on
a spectrophotometer.
To maximize sensitivity of the
tracer methods, four gram samples of the Coccicor 2.5% Amprolium Premix were
analyzed while 200 grams of all non-medicated samples were analyzed.
Twenty samples were analyzed chemically for Amprolium. These samples were chosen only after all tracer analyses had been completed. Samples were not chosen for chemical analysis at random but rather because they were thought interesting.
Tracer Results
Sample Weight Analyzed Red Count Color Absorbance
|
Coccicor
Mixer Sample-
4 gms. |
121 |
0.28 |
0.42 |
||||||
|
Conveyer- |
102 |
0.21 |
0.32 |
||||||
|
Top
of Elevator- |
85 |
0.14 |
0.25 |
||||||
|
Cooler-pellets- |
98 |
0.28 |
0.26 |
||||||
|
Packer-pellets- |
92 |
0.24 |
0.28 |
||||||
|
Coccicor-Average
of Samples |
100 |
0.23 |
0.31 |
||||||
|
Batch
#1 Following Mixer-Avg. five samples-
200 gms |
21 |
0.062 |
0.091 |
||||||
|
Mixer Sample #I -
46 |
20 |
0.075 |
0.110 |
||||||
|
Conveyer-Avg.
five samples- 200 gins |
395 |
0.597 |
0.675 |
||||||
|
Conveyer Sample #1-
66 |
985 |
2.67** |
1.8** |
||||||
|
Top of Elevator-Avg. five
samples-200 gms |
144 |
0.381 |
0.380 |
||||||
|
Top of Elevator Sample #1- 44
|
73 |
0.468 |
0.450 |
||||||
|
|
|
Absorbance Red Count |
Blue
Absorbance Nil |
|
|||||
|
|
Batch #2 Following Mixer-Avg.
five samples-
200 gms |
0.4 |
Nil |
|
|||||
|
|
Mixer Sample #I - |
1 |
Nil |
0.005 |
|
||||
|
|
Conveyer-Avg.
five samples-
200 gms |
47.4 |
0.105 |
0.143 |
|
||||
|
|
Conveyer
Sample #1-
46 |
104 |
0.212 |
0.255 |
|
||||
|
|
Top of Elevator-Avg. five samples-200 gms |
37 |
0.083 |
0.081 |
|
||||
|
|
Top
of Elevator Sample #1-
66 |
24 |
0.090 |
0.120 |
|
||||
|
|
Batch #3 Following Mixer-Avg.
five samples-
200 gms |
1.2 |
Nil |
0.008 |
|
||||
|
|
Mixer
Sample #I -
66 |
0 |
Nil |
Nil |
|
||||
|
|
Conveyer-Avg.
five samples-
200 gms |
19.4 |
0.037 |
0.058 |
|
||||
|
|
Conveyer Sample #1- |
64 |
59 |
0.122 |
0.220 |
|
|||
|
|
Top of Elevator-Avg. five samples-200 gms |
5.8 |
Nil |
0.009 |
|
||||
|
|
Top of Elevator Sample #1- |
44 |
7 |
Nil |
0.008 |
|
|||
|
|
Batches #1, 2 and 3 combined (Pellets) Cooler-Avg five samples- |
200 gms |
36.6 |
0.065 |
0.045 |
|
|||
|
|
Cooler Sample #1- |
64 |
35 |
0.060 |
0.031 |
|
|||
|
|
Packer-Avg. five samples- |
200 gms |
50.8 |
0.059 |
0.045 |
|
|||
|
|
Packer Sample #1- |
44 |
105 |
0.100 |
0.058 |
|
|||
* tracers retrieved from premix samples using Micro-Tracers,Inc.
Rotary Detector laboratory magnetic separator. For color readings, diluted to 15
ml in 1% sodium carbonate solution and read at 525nm and at 630 nm, the
wavelength maxima for FD&C Red#3 (erythrosine) and FD&C Blue#1
(Brilliant Blue FCF).
** for this sample only, for color reading tracer was
diluted in 100 ml of 1% sodium carbonate solution with results calculated and
reported to a 15 ml dilution basis.
Page 5
Determining Cross Contamination of Medicated Feeds
The five samples taken from the Coccicor 2.5% Amprolium
Premix yielded tracer "recoveries" as follows when compared to results
for analysis of the pure tracers:
|
|
Red Particle Count-Color |
Blue
Color |
|
|
Mixer- |
110% |
90% |
109% |
|
Conveyer- |
93% |
68% |
84% |
|
Top of Elevator- |
77% |
45% |
65% |
|
Cooler (pellets)- |
89% |
90% |
69% |
|
Packer (pellets)- |
84% |
76% |
73% |
|
Average: |
91% |
74% |
80% |
Chemical assay results for
Coccicor Amprolium 2.5% Amprolium Premix.
|
|
Amprolium |
Recovery
as Compared With Specification |
|
Mixer- |
2.02% |
80% |
|
Conveyer- |
2.24% |
90% |
|
Top of Elevator- |
2.14% |
86% |
|
Cooler-pellets- |
2.17% |
87% |
|
Packer-pellets- |
1.79% |
72% |
|
Average: |
2.07% |
83% |
Cross Contamination of the
Coccicor 2.5% Amprolium premix (average for 5 samples unless otherwise noted)
into following premix production was as follows:
|
|
Red Particle Count- Color |
Blue
Color |
|
|||||||
|
Batch #1- Mixer |
0.38%* |
0.40%* |
0.48%* |
|
||||||
|
Conveyer |
7.2% |
3.8% |
3.6% |
|
||||||
|
Conveyer Sample #1 |
17.9% |
17.2% |
9.5% |
|
||||||
|
Top of Elevator |
2.6% |
2.5% |
2.0% |
|
||||||
|
Batch #2- Mixer |
0.01% |
Nil |
Nil |
|
||||||
|
Conveyer |
0.86% |
0.68% |
0.75% |
|
||||||
|
Conveyer Sample #1 |
1.89% |
1.37% |
1.34% |
|
||||||
|
Top of Elevator |
0.67% |
0.53% |
0.43% |
|
||||||
|
Batch #3- Mixer |
0.02% |
Nil |
Nil |
|
||||||
|
Conveyer |
0.35% |
0.24% |
0.30% |
|
||||||
|
Top of Elevator |
0.11% |
Nil |
Nil |
|
||||||
|
Page 6 Sample |
Determining Cross Contamination of Medicated
Feeds |
|
||||||||
|
|
Red Particle Count-Color |
Blue
Color |
|
|||||||
|
Batches
#1,2 and 3 Combined (pellets) |
|
|
|
|
||||||
|
Cooler Cooler Sample #1 Packer Packer
Sample #1 |
0.67%
0.42% 0.64%
0.38% 0.92%
0.38% 1.90%
0.65% |
0.24% 0.16% 0.24% 0.30% |
|
|
||||||
|
*
All values are percentage of originally formulated tracer not adjusted for
recovery. The chemical assay data for twenty samples can be
compared with the tracer estimates of amprolium with results as follows: |
|
|||||||||
|
|
Red
Tracer |
Blue
Tracer Color 22,500 |
|
|||||||
|
Coccicor-2.5%
Batch #1 |
|
|
||||||||
|
Mixer
#1- |
370 |
90 |
120 |
180 |
|
|||||
|
Conveyer
#1- |
4,170 |
4,480 |
4,310 |
2,370 |
|
|||||
|
Conveyer
#2- |
1,410 |
1,260 |
1,110 |
1,120 |
|
|||||
|
Top
of Elevator #1- |
730 |
790 |
750 |
590 |
|
|||||
|
Top of Elevator #5- |
600 |
480 |
390 |
380 |
|
|||||
|
Batch #2 Mixer #1 - |
150 |
Nil |
Nil |
Nil |
|
|||||
|
Conveyer
#1 - |
660 |
470 |
340 |
340 |
|
|||||
|
Conveyer
#2- |
170 |
130 |
160 |
290 |
|
|||||
|
Top
of Elevator #1- |
160 |
110 |
150 |
160 |
|
|||||
|
Top
of Elevator #5- |
170 |
260 |
270 |
150 |
|
|||||
Page 7
Determining Cross Contamination of Medicated Feeds
Sample
Chemical Assay
Red Tracer-Count-Color
Blue Tracer Color
ppm
ppm
ppm
ppm
Batch #3
Mixer #I -
150
Nil
Nil
Nil
Conveyer #1-
520
270
200
290
Conveyer #2-
180
70
30
40
Batches #1, 2 and 3 combined
Packer
#1-
260
480
160
80
Packer #2-
210
220
70
50
Sample Calculations:
1. Red Colored Iron Particles-
Particle Counts
Tracer specification (and estimated count): 25,000/gram
Formulated at 1-kilo per 2,000-lbs. of Coccicor 2.5% Amprolium premix (all 2-ton
batches) Estimated particles added to premix per 2,000-lbs: 25,000 X 1,000 grams
= 25,000,000. Estimated particles per four (4) gram subsample of premix:
25,000,000 divided by 2,000-lbs. divided by 454 grams X Four (4) grams = 110
particles
Actual count from Coccicor
premix sample taken from Mixer: 121 (from 4 grams) Estimated Tracer Recovery:
110% of formulated.
Estimated Amprolium: 110% X 25,000pp, specification of premix = 27,500 ppm
(tracer estimate could be made more accurate by analyzing a larger sample and
counting more particles)
2. Particulate Red Iron Particles- Color Readings
Absorbance found from 0.0044 grams of tracer (the amount
formulated per 4 grams of Coccicor premix) diluted in 15m1 of 1% sodium
carbonate in water solution = 00.309
Absorbance found from tracer
from 4 grams of Coccicor premix- Mixer sample = 0.280. Estimated Tracer
Recovery: 90.3%
Estimated Amprolium: 90.3% X 25,000 ppm specification = 22,500 ppm
Absorbance found from tracer
recovered from 200 grams of followup Batch #1 Conveyer #1 sample, tracer diluted
in 100 ml of 7% sodium carbonate in water solution = 0.400, adjusted to dilution
in 15ml = 0.400 X 6.67 = 2.70 divided by 4/200 = 0.540
Estimated Tracer Recovery = 17.5%
Estimated Amprolium: 25,000 pp, X 17.5% = 4,380 ppm
Page
8
Determining Cross Contamination of Medicated Feeds
Linear regressions of this
limited data yielded equations and correlation coefficients as follows:
Chemical amprolium assays with red particle counts:
Y = 220.9 +.892, correlation coefficient 0.986
Chemical amprolium assays with red color readings:
Y = 534.6 +.985 X, correlation coefficient 0.950
Chemical amprolium assays with blue color readings:
Y = 491.3 +.970 X, correlation coefficient 0.973
Conclusions:
#1. The three tracer procedures- red particle counts, red
and blue color readings yielded data that reflected the presence of the coded
drug adequately to at least be used to screen samples for the much more
expensive chemical analysis.
#2. It appeared that through sequencing (no flushes were
employed) cross contamination of the drug into non-medicated following feed was
kept at 1% or less based on the average tracer results of final product at
loadout. This low result was achieved, however, by blending three batches of
following product together. If the immediately following batch had been kept
isolated through the mill, cross contamination into the packed product would
have probably been between 2.% and 3.5%.
#3. In testing for cross
contamination at feedmills and premix plants it is critical one know and
understand the flow of materials through the plant. This will allow generating
meaningful information as to where and when contamination is occurring so that
properly engineered solutions may be tried.
#4. It is also important to know
the physical properties of the medicated premix being studied, as powdered
products most likely contaminate more than granulated ones though this was not
evidenced by the data generated in this Study.
#5. Contamination is usually concentrated in the
first sample taken from following production. It also would increase as product
flows through a manufacturing plant, though in this case the highest average
levels of contamination occurred from samples taken at a conveyer exiting the
surge bin.
Page 9
Determining Cross Contamination of Medicated Feeds
#6. Surprisingly, the red particulate tracer yielded
decent colorimetric readings even from pelleted feed.
#7. Interpretation of the data requires consistency.
Should cross contamination results be compared with the specified level of the
drug or with the amount of drug found in the formulated batch based on chemical
assay of it.
#8. Approximately 20 hours of
laboratory time was required to generate the one-hundred and eighty tracer
results generated and the value of the tracers consumed was less than $100. The
cost of validating cross contamination procedures at feedmills would seem
trivial though the engineering costs involved in solving problems found could be
very great.