Account of the outbreak
Fish sold to a processor
Five fishing vessels were listed on the statement of the certified catch certificate included in the RASFF report 29. The size of three of the five vessels was either 26/6m or 26/4m (length/beam) while two vessels could not be identified based on the name of the ships provided on the catch certificate or using information available on ‘global fishing watch’ 34. The three identifiable vessels sail under the flag of India and operate out of the Southwestern tip of India (i.e., FAO 51). The available fishing history of the three vessels occurred mainly within the exclusive economic zone of India, fishing between 70–76° W and 5.5–18° N. On May 8th 2017, the 5 fishing vessels unloaded a ‘quantity’ (i.e., 2995, 3000, 3000, 2950, and 2960 kgs, for vessels 1–5, respectively) of fish labeled as Lutjanus sp. to a processing plant in the port city of Kochi, located within the state of Kerala, India. The ‘verified weight landed’ mentioned on the original European Community Catch Certificate listed for ‘Frozen Red Snapper Steak Slice 3 cm thickness 1/3 pieces per kg. 800grs bag X 10/Carton – 8kg. Lutjanus sp., for vessels 1–5 was 1414, 1407, 1407, 1384, and 1388 kgs, respectively.
Processor submitted samples for CTX analysis
The fish underwent final packaging at the processor and was given a lot number 629/2017-08 (also referred to as lot number 85205 − 2217 in the RASFF report). A 1.5 kg portion of the 7,000 kg packaged lot was subsampled by the Central Institute of Fisheries Technology (India Council of Agricultural Research) in Kerala, India for CTX analysis only. Between July 5th and 18th 2017, the testing facility performed the Mouse Bioassay on the subsample according to IOC Manuals and guides No. 33, CH.08 1995, UNESCO 35. Accordingly, a test certificate (included in the RASFF report) was issued on July 18th 2017 regarding the sample submitted under the name ‘Frozen Red Snapper Steak Slice (Lutjanus bohar)’ and following the test results, part D of the document remarks “The samples tested for Ciguatera was found absent”. The certificate goes on to state that "the results stated above relate only to the items tested”, and no additional supporting documents or data were provided. The following day, July 19th 2017 the Export Inspection Council (Ministry of Commerce and Industry, Government of India) issued a “health certificate for imports of fishery products intended for human consumption” with reference number EIA/KOC/2017-18/02374 and the local competent authority on the document was listed as the Export Inspection Agency, Kochi.
Processor applied for export
A European Catch Certificate (Issued by the Competent Authority of India) was provided and a copy was included in the RASFF report, declaring the fishing vessels as being under the ‘Marine Fishing (regulation) act of Kerala, India’ (i.e., fish were harvested within the state of Kerala, including territorial waters along the coastline of the state) and fulfilling the requirements in Article 6 of EC regulation No. 1010/2009 regarding a system to prevent, deter and eliminate illegal, unreported and unregulated fishing. The included health certificate states the region of origin of the fish was FAO zone 51 (Western Indian Ocean). The date of shipment from the exporter was July 27th 2017. On August 1st 2017, the state authority validated the marine product for export to Antwerp, Belgium. The description of the shipped product was 7,000 kg of ‘Frozen Red Snapper Steak Slice 3cm thickness 1/3 pieces per kg. 800grs bag X 10/Carton – 8kg. Lutjanus sp.’
Arrival and distribution of lots
The port of Antwerp, Belgium provided a bill of landing which listed: ‘portion; 7000 kgs (875 cartons) of frozen red snapper steak. Temperature maintained at -21°C’. Sur Yon, France was listed as the destination for the imported product. No information was available regarding the product distribution until a bill of sale by the Wholesaler which sold ‘679 (quantity)’ reported at 5928 kgs on January 29th 2019. From this point, a distribution list was provided with a product distribution beginning on February 6th 2019 and continuing until the April 24th 2020. A total of 341 cartons (each 8 kg) from lot 85205 − 2217 was distributed to 86 individual businesses in 63 postal codes, among nine EU countries and the United Kingdom. Distribution information regarding the other 534 cartons was not available. The original ‘best before date’ listed on the package was May 7th 2019. This date of expiration on this frozen product was extended until January 13th 2020 within the EU.
Outbreak report
The Netherlands Food and Consumer Product Safety Authority reported that five people within one household in the Netherlands consumed ‘Red Snapper steak (Lutjanus bohar)’ on May 14th 2020 (approximately 3 years after the fish were landed). A diagnosis of CP was provided by a healthcare professional, the consumers experienced gastro-enteritis after three hours and neurological symptoms were reportedly long-lasting (+ 21 days). Within the household, one original sealed bag (800 g tissue) was available for ciguatoxin analysis. This was not the package consumed, but was from the same batch and was purchased at the same time by the consumers. The sample was analyzed for CTXs by the Wageningen Food Safety Research Institute on July 14th 2020 using a two-tiered CTX analysis approach, consisting of a cell-based assay followed by LC-MS/MS (details provided below).
Traceback information
The fish product was exported from Thoppumpady which is located within the city limits of Koch, belonging to the state of Kerala, India (red square, Fig. 1). May 7th 2019 was listed as the product's original ‘best before’ date, this was extended to January 2020. The importer country was listed as the Netherlands and a wholesaler was identified from France. The fish lot was distributed to other countries including Austria, Belgium, Finland, France, Germany, Italy, Luxembourg, Netherlands, Sweden, Switzerland, and the United Kingdom. The product was listed as destroyed after the passing of the best before date in Austria. In Finland, all product was sold before the notification. In Germany most product was not located, after being contacted some companies stated they do not carry the product in question, while some companies had been informed about the facts (e.g., outbreak, recall, and product information) by the company, while others stated they had no information about the facts of the case at the time of the investigation. In Italy, three kgs of the product remained in commerce and were scheduled for removal and disposal by an authorized company. In Luxembourg, all product was sold before the alert was registered. In the Netherlands, besides the original outbreak alert investigation, the remaining product was removed after the original expiration date (May 7th 2019). In Sweden all product was sold before the notification, however, a sign was displayed informing customers about whom to contact regarding the fish (no additional information was provided explaining if any callbacks occurred). In Switzerland the company listed as the recipient was no longer active at the time of the investigation, therefore tracing of the products was not possible. No additional information was provided from Belgium, France, or the United Kingdom.
DNA barcoding
DNA barcoding was performed to confirm the correct labeling of the species from the product lot implicated in the CP outbreak in the Netherlands. Therefore, the Cytb region was sequenced from two independent samples. The datasets generated and analysed during the current study are available in the NCBI repository, under the following accession number (ON759307, ON759308, ON759311, and ON759312). Sequence alignment confirmed that the analyzed samples were correctly labelled and belong to the species L. bohar. All sequenced samples had a base pair identity of 99%.
Toxin analysis by Neuro-2a cytotoxicity assay
Within this study, from the same lot as the CP outbreak, two sealed bags containing a total of seven pieces of fish were analysed at the BfR using the N2a cytotoxicity assay and all samples were determined to be positive for CTX-like toxicity (Table 1). All samples exhibited cytotoxicity only in the ouabain and veratridine pre-treated cells (OV+), confirming the sodium channel-specific mode of action resulting from the presence of CTX-like compounds contained in the sample extract (Fig. 2). The composite toxicity among all samples ranged from 0.79–5.39 ng CTX3C equivalent (eq.) per g wet tissue eq. (Table 1). Total toxin content among fish pieces ranged from 79.4–986 ng CTX3C eq. Based on the toxin content of each piece of fish, each bag recovered for testing contained a total of 1,965 and 1,690 ng CTX3C eq., respectively. Yasumoto 44 proposed a total CTX1B intake of 70 ng as a recommended limit for human health seafood consumption safety. Based on this recommendation these bags contained sufficient concentrations of CTXs to intoxicate multiple people. A bag of fish was also recovered at the home of the CP patients and was analyzed for CTXs using the N2a-cytotoxicity assay by the Food Safety Research Group at the University of Wageningen in the Netherlands. The Netherlands Food and Consumer Product Safety Authority reported that the samples were suspected to contain CTXs at levels above the US FDA guidance limit of 0.01 µg CTX1B eq. per kg and provided an analytical report for further details. Therefore, the CP outbreak and subsequent testing of related material combined with the results of this study demonstrate that multiple bags of fish portions from this lot contained CTXs which are not allowed in fishery products sold in the EU.
Table 1
Sample description by weight and composite toxin quantification. The sample tissue extract's toxicity was determined from the effective concentration for reducing cell survival by 50% as compared with the standards CTX1B and CTX3C. Results are presented in ng of CTX equivalents per g of wet tissue as well as the total ng of CTX3C or CTX1B equivalent contained in each sample.
Sample
|
|
1
|
2
|
3
|
4
|
5
|
6
|
7
|
CTX1B
|
CTX3C
|
mg TE mL− 1
|
0.60
(± 0.04)
|
0.28
(± 0.03)
|
1.43
(± 0.03)
|
1.89
(± 0.13)
|
0.76
(± 0.08)
|
0.49
(± 0.19)
|
0.79
(± 0.21)
|
-
|
-
|
CTX3C eq.
|
2.49
(± 0.17)
|
5.39
(± 0.58)
|
1.05
(± 0.02)
|
0.79
(± 0.05)
|
1.98
(± 0.21)
|
3.05
(± 1.19)
|
1.90
(± 0.51)
|
-
|
1.50
|
CTX1B eq.
|
3.14
(± 0.21)
|
6.78
(± 0.73)
|
1.32
(± 0.03)
|
1.00
(± 0.07)
|
2.50
(± 0.26)
|
3.84
(± 1.50)
|
2.40
(± 0.65)
|
1.89
|
-
|
Weight (g)
|
305
|
183
|
133
|
100
|
112
|
280
|
323
|
-
|
-
|
Total toxin
per fish piece
|
|
|
|
|
|
|
|
|
ng CTX3C eq.
|
760
(± 50.6)
|
986
(± 106)
|
140
(± 2.94)
|
79.4
(± 5.48)
|
222
(± 23.3)
|
854
(± 333)
|
614
(± 166)
|
|
ng CTX1B eq.
|
958
(± 63.8)
|
1,241
(± 132)
|
176
(± 3.70)
|
100
(± 6.90)
|
280
(± 29.4)
|
1,075
(± 419)
|
774
(± 209)
|
|
Toxin identification by UHPLC-MS/MS
Sample extracts analyzed by LC-MS/MS revealed the presence of several putative CTX congeners such as 2,3,51-trihydroxyCTX3C, 2,3-dihydroxyCTX3C, 2-hydroxyCTX3C or M-seco-CTX3C (Fig. 3). Excluding 2,3,51-trihydroxyCTX3C, congeners generally consisted of two peaks eluting with retention times < 1 min apart. The first peak is ascribed to the 49-epimer of the respective compound. Peak annotation was performed according to the m/z, the retention time (based on previously published elution profiles), and the fragmentation of the ammonium adducts (right column in Fig. 3) (additional details provided in Spielmeyer, et al. 25).
The bag of fish recovered from the home of the CP patients was analyzed by the Food Safety Research Group at the University of Wageningen for brevetoxins using LC-MS/MS. Brevetoxins are ithyotoxic neurotoxins that can accumulate in fish and this test allowed them to exclude the possibility of a different marine biotoxin with a similar mode of action causing the observed effect in the N2a-MTT assay 45. The results of the analysis showed the samples were negative for the presence of brevetoxins, however, the analysis report stated that CTXs could not be detected or confirmed, according to information provided in the analysis report included in the RASFF summary.
Catch region CP association
CP has a demonstrated association with geographic regions and species 6,9,13. Samples of the species L. bohar were considered ‘CTX positive’ by the mouse bioassay from two geographic areas (Kerala and Karnataka) up to 400 km apart within the wider region of southwestern India, providing precedent for CTX-like toxicity in this species and region (Fig. 1) 42,43. The southwestern region of India reported its first CP outbreak in 2015, with L. bohar being confirmed in subsequent CP incidences 40,41. Specifically, in Mangalore (upper outbreak circle overlapping with an environmental sample on the border region of Karnataka and Kerala, Fig. 1), a major CP outbreak was reported in 2016 affecting 200 people. Seventy-five percent of the affected individuals were hospitalized with severe symptomology (neurological and gastrointestinal) and ten percent required extended hospitalization due to the severity of the cardiovascular symptoms experienced. Samples collected and tested from that large outbreak were investigated using the receptor binding assay and found to contain CTX-like activity equivalent to 1.10, 1.36, and 2.61 ng CTX3C eq. per g tissue for muscle, intestine, and liver tissue types, respectively 23. LC-MS/MS investigations into the material suggested the Caribbean and Indian Ocean CTXs as the responsible ciguatoxin(s) 6,23. The samples tested in this study were comparatively toxic and ranged from 0.79–5.39 ng CTX3C eq. per g wet tissue eq. Suggesting the removal of this CTX contaminated material from the commercial market by the responsible authority in Germany, following the RASFF alert, could be described as a preventative action, as several CP intoxications like those reported in the 2016 outbreak in India with similar toxin concentrations may have been avoided.
In 2017 a CP outbreak in the United Kingdom was reported and involved 1230 kg of frozen red snapper fillet which was a product from FAO area 51 (Indian Ocean). Subsequent testing on 24% of the lot revealed that all samples were positive for CTX-like toxicity by the N2a-assay and the samples contained CTXs with chromatographic peaks attributed to potential C/I-CTXs 46. In contrast to I-CTXs, which remain structurally un-resolved and therefore complex to detect in outbreaks involving I-CTXs, no C/I-CTXs were detected in the samples from this study but rather several compounds in the CTX3C-group. The presence of CTX3C-group compounds may provide a CTX profile which could be further confirmed in other L. bohar from the Indian Ocean region, particularly in events where CTX-like toxicity was observed and CTXs remain unresolved. CTX3C-group toxins have been described in L. bohar caught in the Pacific Ocean in FAO 61 47 and 71 20. L. bohar was attributed to a CP outbreak in Germany in 2015 and described to contain 51-hydroxy CTX3C, the sample was purportedly a product of catch region FAO 51 (the western Indian Ocean) 18. For another outbreak in Germany in 2012 involving L. bohar and L. argentimaculatus from FAO 57 (the eastern Indian Ocean) detection of CTX1B and 2,3-dihydroxyCTX3C were reported, however, no additional data was provided regarding which species contained the reported toxins 18. L. bohar from the bank's fishery to the north of the Republic of Mauritius was reported to contain I-CTXs, this area is also part of FAO 51, but is located in the fishing territory’s extreme southwestern portion 48. The fishing vessels listed in this study were small (26 m length boats) and localized to the southwestern coastal region of India and therefore unlikely to have traveled over 4000 nautical miles round trip to fish in the Mauritius region. As of 2018, southwestern India has considered the existence of ciguatera as ‘rare’ but has nonetheless implemented monitoring fish for CTXs 49. Southwestern India is a major marine fishing region, contributing to approximately 30% of India’s total fisheries landings by weight (1.08 million tonnes) in 2019. Snappers as a category accounted for 10,246 tonnes of the 3.56 million tonnes of seafood landed throughout India in 2019 50. Therefore, the identification of CTXs in this species is of commercial importance and with potential CP ramifications for the wider regional fishery.
Follow-up actions from the EU
Follow-up actions and investigations by the competent authorities of the European Commission noted that the Export Inspection Council of India initiated actions against the establishment per the Executive instructions in force and the establishment was placed on “internal alert” on August 3rd 2020, stating that the export of red snapper to the EU was suspended until further order. The Export Inspection Council dispatched for a site examination observed that all red snapper (Lutjanus bohar) exported by the establishment weighed more than 5 kg and that available literature indicates an increased CP risk in fish over 2 kg. Accordingly, Oshiro, et al. 51 reported that 11.9% of L. bohar in Okinawa, Japan (region of highest CP rates in Japan) were CTX positive and no CTXs were detected among L. bohar weighing under 4 kg, providing precedent for the 5 kg weight restriction. The investigation concluded that the establishment's “own check system” of a species related to a hazard failed to identify and address the issue and failed to implement a raw material traceability system to help track the problem. Therefore, the Council concluded that because the establishment's traceback was insufficient and their product self-check did not work, these controls failed to prevent the distribution of fish containing CTXs to the destination. Currently, The European Commission has no responsibility for the export suspension of L. bohar from India and no additional information has been provided by the authorities in India regarding this outbreak (personal communication with the Directorate-General for Health and Food Safety March 29th, 2022).
CTX3C profile occurring in the Indian Ocean
This is the first complete description of multiple samples of L. bohar which were sourced from the Indian Ocean region and found to contain CTX3C-group compounds. Beyond the two mentions from the article by Friedemann 18 no descriptions of any CTX3C-group compounds originating in the Indian Ocean have been reported. Whether this is the first instance of a known CTX profile now reaching food web stability in a novel region, the FAO catch region was falsified (unlikely due to the certified catch record), or whether this profile has existed in the region as an undetermined CTX profile in seafood before this description requires further elucidation. The first description of CTX3C outside the Pacific occurred in the Atlantic, reported by Otero, et al. 52 followed by Silva, et al. 53, however, since these initial reports the CTX3C-group has not been described in the Atlantic region in any CTX analysis report. The Gambierdiscus complex including the species G. polynesiensis has been recently described in the northern Indian Ocean but remains undescribed for CTXs 54,55. Cultures of G. polynesiensis from the Pacific Ocean have been demonstrated to produce CTX3C-group congeners (CTX3C/B, 2-hydroxyCTX3C, M-seco-CTX3C, CTX4A/B, and M-seco-CTX4A/B) 56–59. Therefore, if this cosmopolitan species can produce the same suite of CTXs as those originating from the Pacific Ocean, then the CTX3C-group toxins identified in this study could originate from G. polynesiensis. Among the four groups of CTXs currently described only I-CTXs and the CTX3C-group have no specific regulation on toxin content guidance levels. Results presented here demonstrate that CTX3C-group congeners can be present at concentrations capable of causing CP without the presence of an additional CTX congener group and should be elevated to a CTX group of monitoring importance regarding suspected CP outbreaks.