Artigo Acesso aberto Revisado por pares

Reporting data on pesticide residues in food and feed according to Regulation (EC) No 396/2005 (2018 data collection)

2019; Wiley; Volume: 17; Issue: 4 Linguagem: Inglês

10.2903/j.efsa.2019.5655

ISSN

1831-4732

Autores

Maria Anastassiadou, Alba Brancato, Daniela Brocca, Luis Carrasco Cabrera, Lucien Ferreira, Luna Greco, Samira Jarrah, Aija Kazocina, Renata Leuschner, Alfonso Lostia, José Oriol Magrans, Paula Medina, Ileana Miron, Ragnor Pedersen, Marianna Raczyk, Hermine Reich, Silvia Ruocco, Angela Sacchi, Miguel Santos, Alois Stanek, José Tarazona, Anne Theobald, Alessia Verani,

Tópico(s)

Animal Ecology and Behavior Studies

Resumo

EFSA JournalVolume 17, Issue 4 e05655 GuidanceOpen Access Reporting data on pesticide residues in food and feed according to Regulation (EC) No 396/2005 (2018 data collection) European Food Safety Authority (EFSA), European Food Safety Authority (EFSA)Search for more papers by this authorMaria Anastassiadou, Maria AnastassiadouSearch for more papers by this authorAlba Brancato, Alba BrancatoSearch for more papers by this authorDaniela Brocca, Daniela BroccaSearch for more papers by this authorLuis Carrasco Cabrera, Luis Carrasco CabreraSearch for more papers by this authorLucien Ferreira, Lucien FerreiraSearch for more papers by this authorLuna Greco, Luna GrecoSearch for more papers by this authorSamira Jarrah, Samira JarrahSearch for more papers by this authorAija Kazocina, Aija KazocinaSearch for more papers by this authorRenata Leuschner, Renata LeuschnerSearch for more papers by this authorAlfonso Lostia, Alfonso LostiaSearch for more papers by this authorJose Oriol Magrans, Jose Oriol MagransSearch for more papers by this authorPaula Medina, Paula MedinaSearch for more papers by this authorIleana Miron, Ileana MironSearch for more papers by this authorRagnor Pedersen, Ragnor PedersenSearch for more papers by this authorMarianna Raczyk, Marianna RaczykSearch for more papers by this authorHermine Reich, Hermine ReichSearch for more papers by this authorSilvia Ruocco, Silvia RuoccoSearch for more papers by this authorAngela Sacchi, Angela SacchiSearch for more papers by this authorMiguel Santos, Miguel SantosSearch for more papers by this authorAlois Stanek, Alois StanekSearch for more papers by this authorJose Tarazona, Jose TarazonaSearch for more papers by this authorAnne Theobald, Anne TheobaldSearch for more papers by this authorAlessia Verani, Alessia VeraniSearch for more papers by this author European Food Safety Authority (EFSA), European Food Safety Authority (EFSA)Search for more papers by this authorMaria Anastassiadou, Maria AnastassiadouSearch for more papers by this authorAlba Brancato, Alba BrancatoSearch for more papers by this authorDaniela Brocca, Daniela BroccaSearch for more papers by this authorLuis Carrasco Cabrera, Luis Carrasco CabreraSearch for more papers by this authorLucien Ferreira, Lucien FerreiraSearch for more papers by this authorLuna Greco, Luna GrecoSearch for more papers by this authorSamira Jarrah, Samira JarrahSearch for more papers by this authorAija Kazocina, Aija KazocinaSearch for more papers by this authorRenata Leuschner, Renata LeuschnerSearch for more papers by this authorAlfonso Lostia, Alfonso LostiaSearch for more papers by this authorJose Oriol Magrans, Jose Oriol MagransSearch for more papers by this authorPaula Medina, Paula MedinaSearch for more papers by this authorIleana Miron, Ileana MironSearch for more papers by this authorRagnor Pedersen, Ragnor PedersenSearch for more papers by this authorMarianna Raczyk, Marianna RaczykSearch for more papers by this authorHermine Reich, Hermine ReichSearch for more papers by this authorSilvia Ruocco, Silvia RuoccoSearch for more papers by this authorAngela Sacchi, Angela SacchiSearch for more papers by this authorMiguel Santos, Miguel SantosSearch for more papers by this authorAlois Stanek, Alois StanekSearch for more papers by this authorJose Tarazona, Jose TarazonaSearch for more papers by this authorAnne Theobald, Anne TheobaldSearch for more papers by this authorAlessia Verani, Alessia VeraniSearch for more papers by this author First published: 11 April 2019 https://doi.org/10.2903/j.efsa.2019.5655 Correspondence: pesticides.mrl@efsa.europa.eu Requestor: EFSA Question number: EFSA-Q-2018-01038 Acknowledgements: EFSA wishes to thank the members of the Pesticide Monitoring Network of EFSA for the contributions to review this scientific output. Adopted: 8 March 2019 AboutSectionsPDF ToolsExport citationAdd to favoritesTrack citation ShareShare Give accessShare full text accessShare full-text accessPlease review our Terms and Conditions of Use and check box below to share full-text version of article.I have read and accept the Wiley Online Library Terms and Conditions of UseShareable LinkUse the link below to share a full-text version of this article with your friends and colleagues. Learn more.Copy URL Share a linkShare onFacebookTwitterLinkedInRedditWechat Abstract According to Regulation (EC) No 396/2005 on maximum residue levels of pesticides in or on food and feed, Member States have to monitor pesticide residue levels in food samples and submit the monitoring results to EFSA and the European Commission. The Standard Sample Description (SSD, version 1) is the data model used for reporting the data on analytical measurements of chemical substances occurring in food, feed and water to EFSA. This document is a consolidated version of the past four years' guidance defining the appropriate SSD codes to describe the samples and the analytical results and it gives directions for the reporting of the pesticide residues monitoring data starting with the data generated in 2018 onwards. These provisions take into account the experience of both the previous reporting seasons and the new legislation applicable in 2018. This EFSA Guidance will not be applicable for the 2019 data collection provided to EFSA in 2020. In 2020, all data on annual monitoring will be transmitted in SSD2 format only. Summary Regulation (EC) No 396/2005 on maximum residue levels (MRLs) of pesticides in or on food and feed of plant and animal origin requires that Member States carry out official controls on pesticide residues in food. The results of the analysis have to be submitted to the European Food Safety Authority (EFSA) and the European Commission. According to Article 32 of this Regulation, EFSA is responsible for drawing up a Report on Pesticide Residues on the basis of the monitoring results provided by the reporting countries. In 2009, the Standard Sample Description (SSD) for food and feed was developed which is a standardised data model for reporting of data on analytical measurements of chemical substances occurring in food, feed and water. The SSD contains the data elements describing characteristics of samples and analytical results, controlled terminologies and validation rules to ensure compatibility of data from different data providers. In the past years, the guidance document describing the SSD data elements and the data coding was progressively and thoroughly revised on a yearly basis; the present document is a consolidated version of the past four years' guidance defining the appropriate SSD codes to describe the samples and the analytical results and it gives directions for the reporting of the pesticide residues monitoring data starting with the data generated in 2018 onwards. The current document not only replaces the previous Guidance (EFSA, 2018), but also the ones published in 2017, 2016 and 2015 (EFSA, 2015a, 2016, 2017). In particular, the following data elements were updated: Country of origin of the product ('origCountry', Section 3.6): the XX code on unknown origin is sufficient; previous coding of unspecified European Economic Area (EEA) country (AA) or unspecified third country (XC) not proven to be of added value, were deleted. Product code ('prodCode', Section 3.13): new codes for food commodities in Part B of Annex I of Regulation (EC) No 396/2005 and its amendments (e.g. goji berries) were added. MatrixTool (Section 5.3.1): the content of the tables A, B, 'babyfood' and 'EUCP' was shortly described. Result LOQ (Section 5.12): the part of the summing of limit of quantification (LOQ) is updated based on the experience of the first year of implementation of the DG SANCO working document on the summing of the LOQs in case of complex residue definitions (European Commission, 2014). EU coordinated monitoring programme coding for the 2018 and 2019 data collection (Sections 7 and 8): new commodities were introduced based on the relevant European coordinated control programme (EUCP) Regulations. Food to be analysed according to Regulation (EC) No 669/2009 (Section 9): new commodities were introduced based on the relevant amendments of Regulation (EC) No 669/2009. The above changes were necessary for one or more of the following reasons: New parameter codes are included in the PARAM catalogue to reflect the changes in the legal residue definitions laid down in the EU pesticide MRL legislation and applicable in the reference monitoring year; some of the existing codes in the catalogue are no more reportable, as obsolete. New parameter codes are included in the PARAM catalogue for the single components of the Multicomponent legal residue definitions that are made up of more than one component. New parameter codes are included in the PARAM catalogue because new pesticides are analysed in the national laboratories and appropriate codes were not available in the previous version of the catalogue. Typos in the textual description of the PARAM codes have been identified and corrected. Existing PARAM codes which were previously set for the same substance in the framework of different food data collection domains were appropriately amended (e.g. overlapping substances in the pesticide residue and veterinary medicines areas). In Sections 3, 4 and 5 of the present document, all the single SSD data elements are described and an indication is provided whether they have to be mandatorily or voluntarily reported. For 2019, the reportability of these elements is the same set for the previous year, i.e. if a data element was mandatory for the 2017 data collection, it is still mandatory for the 2018 data collection. In addition, these sections give reference to the applicable SSD catalogues (where existing) and its restriction in use them, if and where applicable. Section 6 provides for additional guidance related to the pesticide monitoring coding for specific food/feed samples and/or substances, which are not fully covered by Regulation (EC) No 396/2005 on pesticide residues MRL (i.e. baby food, fish, feed, veterinary medicines residues, synergists and safeners). In Sections 7 and 8 of this document, EFSA provides an updated list of codes to describe the samples covered by the 2018 and 2019 EUCP ('prodCode', 'prodTreat', 'progLegalRef', 'progSampStrategy' and 'progType'); in Section 9, the appropriate coding of the samples tested in the context of the reinforced import controls under Regulation (EC) No 669/2009 and applicable for the 2018 control activities ('prodCode', 'prodTreat', 'progLegalRef', 'progSampStrategy' and 'progType') is provided. The updated rules for data validation are listed in a separate (Excel) document; they can be retrieved in the EFSA Document Management System1 (DMS) or directly in the Data Collection Framework (DCF) data loading platform.2 Finally, in Annex A – the template for the preparation of the 2018 National Summary Report is provided. 1 Introduction 1.1 Background According to Regulation (EC) No 396/20053 on maximum residue levels (MRL) of pesticides in or on food and feed of plant and animal origin, Member States have to carry out official controls on pesticide residues in food. The results of the analysis have to be submitted to EFSA and the European Commission. According to Article 32 of this Regulation, EFSA has to prepare for each calendar year a report on pesticide residues on the basis of the results provided by the reporting countries. The annual report shall provide the following information: An analysis of the results of the controls on pesticide residues provided by EU Member States and European Economic Area (EEA) countries; A statement of the possible reasons why the MRL were exceeded, together with any appropriate observations regarding risk management options; An analysis of chronic and acute risks to the health of consumers from pesticide residues; An assessment of consumer exposure to pesticide residues based on the information provided under first bullet point and any other relevant available information, including reports submitted under Directive 96/23/EC4; Recommendations should be elaborated regarding pesticides to be covered in future programmes. Since 2009 the Standard Sample Description (SSD) is the harmonised data model used for the reporting of chemical occurrence data (including pesticide residue monitoring data) to EFSA. The SSD contains in total 76 data elements describing characteristics of samples and analytical results, controlled terminologies and validation rules. For the pesticide monitoring data collection, out of the 76 SSD data elements 24 elements are to be reported on a mandatory basis (for four additional elements the data reporting is mandatory only under certain conditions). For the mandatory data elements, it is essential that reporting countries use a consistent approach for coding. Thus, clear guidance needs to be provided to the national competent authorities responsible for the data submission; only if these coding conventions are respected, EFSA can perform the analysis of the data from different data sources as required in Article 32 of Regulation (EC) No 396/2005. On a yearly basis, the EFSA Network on Pesticide Monitoring provides feedback on the experience with the use of the SSD data model. Based on this, on the observations made by EFSA during the data analysis of the previous year and on the basis of the new legislation relevant for control of pesticide residues in food,5,6 EFSA identified a number of issues where the guidance document prepared for the previous reporting of pesticide monitoring data (EFSA, 2018) should be amended. This document was revised in 2018 and is aimed at the coding and reporting the 2018 pesticide monitoring data. It should be noted that the changes introduced by this guidance are reflected in the EFSA supporting tool named 'MatrixTool'; this latter tool is meant to provide the data providers with additional assistance in the selection of the appropriate combination of the codes for the following SSD data elements: prodCode, paramCode and paramType. The MatrixTool is provided separately. Finally, on a yearly basis EFSA – in collaboration with the Network's members – reviews the SSD catalogues in view on the next pesticide monitoring data collection. The catalogue updates described in this document reflect the new legal requirements, e.g. the changes in the legal residue definitions under Regulation (EC) No 396/2005; comments and suggestions for improvement provided by the Network were also assessed and/or addressed in this document. EFSA frequently receives public access to documents requests from stakeholders concerning pesticide monitoring data submitted to EFSA in the context of Regulation (EC) No 396/2005.4 In its capacity as a European Union agency, documents held by EFSA (i.e. documents which it has produced or received from third parties, including Member States, all areas of its activity) are subject to Regulation (EC) No 1049/2001 on public access to documents (PAD Regulation)7 and to Regulation (EC) No 1367/2006 on public access to environmental information as per the interpretation of the European Union Courts.8 Consequently, data sets submitted to EFSA must be disclosed to any European Union (EU) citizen or any natural or legal person residing or having its registered office in a Member States who requests access to such information, subject to the exceptions to disclosure outlined in Article 4 of the PAD Regulation. These exceptions to disclosure, interpreted restrictively by the EU Courts, ensure the protection of legitimate interests such as, for example, the privacy and integrity of the individual and the commercial interests of natural or legal persons, including intellectual property, unless an overriding public interest exists. In the specific case of pesticide residues data, an overriding public interest in disclosure is normally considered to exist with respect to the protection of commercial interests. When submitting data to EFSA, Member States should be aware of the stringent transparency obligations by which EFSA is bound, in application of the legal framework referred to and the relevant case law interpreting the specific provisions concerned. This is particularly relevant if the data contain commercially sensitive information and/or personal data as defined in Article 3(1) of Regulation (EU) 2018/17259. Before transmitting data to EFSA, Member States should take into consideration the complex nature of the application of the relevant exceptions to disclosure and might consider facilitating this process by including only information which they consider may be made publicly accessible via access to documents' release. EFSA launched Member States consultations on the draft versions of this guidance document on 21/12/2018 and on 15/2/2019. No comments were received during the two rounds of consultations. The document was agreed by written procedure on 28/2/2019 by the EFSA Network on Pesticide Monitoring. 1.2 Terms of Reference EFSA shall update the guidance document prepared for the past data collections (EFSA, 2015a, 2016, 2017, 2018) describing the use of the SSD for coding the results of official controls performed in the course of 2018 by Member States and in accordance with the provisions of Article 29 and 30 of Regulation (EC) No 396/2005. The current update shall in particular provide instructions for reporting information in the SSD controlled terminology that changed compared to the previous guidance documents. The new legislation having an impact on the provisions on control of pesticide residues in food shall also be taken into account in this revised version of the guidance. In addition, the document shall provide unambiguous guidance for data elements where difficulties with inconsistent coding were identified in the past or where the information provided by the reporting countries did not allow EFSA to perform the analysis as required in Article 32 of Regulation (EC) No 396/2005; in these cases, specific examples on the correct food samples coding should be provided. To facilitate the work for the reporting countries concerning the 2018 data collection, the guidance document shall also provide the valid SSD codes for the reporting of the samples and results taken in the frame of the 2018 EU coordinated control programme. 2 Data model for reporting the monitoring pesticide residue data The SSD defines in total 76 data elements which are characterised by an element code, an element name and an element label. For each element, a specific format is defined, such as text fields with a permitted number of characters (e.g. xs.string (20) for text field with 20 characters) or numerical fields (e.g. xs.decimal 4,0 for a numerical field with 4 digits and no digits after the comma or xs.double). The following data elements of the SSD are numerical and typically reported with decimal figures: resLOD, resLOQ, resVal, resValRec, resValUncertSD, resValUncert, moistPerc, fatPerc and resLegalLimit. Considering that in XML language the comma (',') cannot be used as a decimal separator, the results for the mentioned data elements have to be formatted with a dot ('.') as decimal separator. In Table 1, the 76 data elements of the SSD data model are listed, including the element names, codes and labels. For a number of data elements, controlled terminology has been developed, i.e. a list of terms that can be used for reporting the values of the data element. These lists of controlled terminology are also referred to as 'catalogues' or 'dictionaries' or 'pick lists'. In the last column of Table 1, the relevance of the data elements for coding of pesticide residue data is reported (mandatory, optional or not reportable data elements): Mandatory data elements: elements that are needed to report essential information; if they are not reported, an automatic error message will be returned to the data provider and the related, incomplete record will not pass the data validation step. Mandatory under certain conditions data elements: a data element becomes mandatory if a certain code is selected for another data element (e.g. if the residue result reported was adjusted for recovery then the result recovery value data element (resValRec) becomes mandatory). Details are provided in the appropriate sections of the present Guidance. Optional data elements: elements that can be returned at the discretion of the data provider on voluntarily basis. Not reportable data elements: data elements with this status shall no longer be reported; they all refer to element used in the past to report free-text information. The not reportable data element shall be left blank for all the records coded and to be transmitted to EFSA. In case any text or value will be inputted in this data element, an error message will be returned to the data provider. In total, 24 data elements are mandatory for pesticide residue data; the majority of the remaining data elements are optional, meaning that they can be used to describe certain features of the samples or of the results, but this information is currently not or partially used for the data analysis performed by EFSA. Overall, only four SSD elements are 'not reportable' in the frame of the pesticide monitoring data collections. For 15 mandatory data elements, the controlled terminology also named 'catalogues' have to be used for coding. In addition, catalogues are available for a number of optional data elements. It is noted that as a general rule when an entry from a catalogue is selected, only the code is required. Any furthers descriptions reported in additional columns of the catalogue are not required. Finally, in general for each data element only one element value can be reported with the exception of the data element Action Taken (see Section 5.25) where multiple element values can be selected from the catalogue ACTION. The Excel file which contains the updated controlled terminologies (catalogues) and the corresponding codes relevant for the reference period 2018 is published separately. The individual data elements listed in Table 1 can be clustered in: Information describing the sample and the sampling procedure: data element code starts with the letter S (Section 3 of this document); Information on the laboratory that generated the analytical result: data element code starts with the letter L and O (Section 4 of this document); Information describing the analytical method/analytical results: data element code starts with the letter R (Section 5 of this document) and The result evaluation: data element code starts with the letter R (Section 5 of this document). The list of the sample related SSD data variables most frequently reported are the following ones:10,11 labSampCode, labSubSampCode, sampCountry, origCountry, origArea, origFishAreaCode, origFishAreaText, procCountry, procArea, prodCode, prodProdMeth, prodPack, prodTreat, sampY, sampM, sampD, progCode, progLegalRef, progSampStrategy, progType, sampMethod and sampPoint. It is important noticing that the SSD sample descriptors must be consistent for all records reported with the same 'Laboratory sample code' (labSampCode), (identical text/code for all records related to a certain labSampCode). For example, for a given food sample analysed and identified by a unique 'labSampCode' (sample identification number), the 'prodCode', and 'prodTreat' have to be consistently and exactly the same for each analytical result reported. In Sections 3, –5 of the present guidance, detailed instructions and examples are provided on the selection of the correct codes for these four groups of data elements. Section 6 provides additional information and examples for cases that are not fully covered by Regulation (EC) No 396/2005, such as the reporting of the analytical results for baby food, feed, fish and results for veterinary medicinal products, safeners and synergists. In order to make the document a useful reference for the daily work of data managers or experts working in the official control laboratories in national competent authorities responsible for the reporting of results to EFSA, the document contains cross-references and hyperlinks to related data elements which should facilitate to find relevant information in the document. EFSA developed a number of data validation rules for checking the compliance of the data coding with the rules described in this guidance document; the validation rules are meant to ensure a high level of data quality is achieved. Where applied by EFSA, the validation rules may return error or warning messages. In case an error message will be generated by the rule, the non-valid value selected for reporting/coding a certain data element will have to be corrected by the data provider; in case the validation of the data returns a warning message, the data transmitter may confirm to EFSA the value that generated a warning is correct (in this case, the data will be accepted in the EFSA data depository); optionally, the data provider will correct the mistake and re-submit the corrected data. The description of the business rules applicable to the pesticide residue data collection are reported in a separate (Excel) document. It should be noted that EFSA has developed a new version of the SSD (Standard Sample Description_ver. 2.0 or 'SSD2') (EFSA, 2013). While the first version of SSD was developed for reporting occurrence data of chemicals in food, SSD2 was intended to integrate also the reporting of other food domains such as to monitoring of zoonoses, zoonotic agents and antimicrobial resistance and results on environmental samples. However, for pesticides the original version of the SSD data model is still used by many countries. The reporting of the pesticide monitoring results in SSD2 is possible starting from the 2017 data in 2018. A separate working document should be consulted for the data coding in SSD2 format in 2019. From 2020 onwards, the reporting of the data on the monitoring of pesticide residues in SSD2 format will become mandatory and the present guidance on SSD will no longer be valid. This guidance document will replace some provisions of the EFSA Guidance Document 'Standard sample description for food and feed' (EFSA, 2010) in order to solve problems for data reporting and/or data analysis as this guidance document is no longer updated. The current document is complementary to the Guidance on the data exchange (EFSA, 2014) which is dealing with technical details regarding the data submission. Finally, considering that the data submitted in the framework of the pesticide monitoring will be transferred to the EFSA scientific data warehouse (DWH), the rules on data sharing should be born in mind (EFSA, 2015b). Table 1. Overview of the SSD data elements for the reporting of the pesticide residue monitoring data to EFSA and the related SSD catalogues, where existing Element code Element name Element label Data type SSD catalogue namea Relevance/status for pesticide residue data S.01 labSampCode Laboratory sample code xs:string (20) Mandatory S.02 labSubSampCode Laboratory subsample code xs:decimal (4,0) Optional S.03 lang Language xs:string (2) LANG Optional S.04 sampCountry Country of sampling xs:string (2) COUNTRY Mandatory S.05 sampArea Area of sampling xs:string(5) NUTS Optional S.06 origCountry Country of origin of the product xs:string (2) COUNTRY Mandatory S.07 origArea Area of origin of the product xs:string (5) NUTS Optional S.08 origFishAreaCode Area of origin for fisheries or aquaculture activities code xs:string (10) FAREA Optional S.09 origFishAreaText Area of origin for fisheries or aquaculture activities text xs:string (250) Optional S.10 procCountry Country of processing xs:string (2) COUNTRY Optional S.11 procArea Area of processing xs:string (5) NUTS Optional S.12 EFSAProdCode EFSA Product Code xs:string (250) FOODEX Optional S.13 prodCode Product code xs:string (20) MATRIX Mandatory S.14 prodText Product full text description xs:string (250) Mandatory (only under certain conditions) S.15 prodProdMeth Method of production xs:string (5) PRODMD Mandatory S.16 prodPack Packaging xs:string (5) PRODPAC Optional S.17 prodTreat Product treatment xs:string(5) PRODTR Mandatory S.18 prodBrandName Brand name xs:string(250) Optional S.19 prodManuf Manufacturer xs:string (250) Optional S.20 prodIngred Ingredients xs:string(250) Optional S.21 prodCom Product comment xs:string (250) Data element disabled for the pesticide residues data collection.Not to be used S.22 prodY Year of production xs:decimal (4,0) Optional S.23 prodM Month of production xs:decimal(2,0) Optional S.24 prodD Day of production xs:decimal (2,0) Optional S.25 expiryY Year of expiry xs:decimal (4,0) Optional S.26 expiryM Month of expiry xs:decimal(2,0) Optional S.27 expiryD Day of expiry xs:decimal (2,0) Optional S.28 sampY Year of sampling xs:decimal (4, 0) Mandatory S.29 sampM Month of sampling xs:decimal (2, 0) Mandatory S.30 sampD Day of sampling xs:decimal (2, 0) Mandatory S.31 progCode Sampling programme code xs:string (20) Optional S.32 progLegalRef Programme legal reference xs.string (100) Mandatory S.33 progSampStrategy Sampling strategy xs:string (5) SAMPSTR Mandatory S.34 progType Type of sampling program xs:string (5) SRCTYP Mandatory S.35 sampMethod Sampling method xs:string (5) SAMPMD Mandatory S.36 sampleNum Number of samples xs:integer Optional S.37 lotSize Lot size xs:double Optional S.38 lotSizeUnit Lot size unit xs:string (5) UNIT Optional S.39 sampPoint Sampling point xs:string (10

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