Identification of Potential Non-Scientific Risks The development and implementation of good regulation can be influenced by a range of factors outside the potential hazards to the food supply that are evaluated in the scientific risk assessment. This broader set of risks typically includes factors such as community perceptions, political implications, regional implications and industry issues. In developing options for the regulation of the primary production and processing of seafood, FSANZ discussed this issue with State and Territory regulators, a consumer representative, and various members of the seafood industry. Such consultation assisted FSANZ to identify a range of non-scientific risks that, potentially, could affect the development and implementation of regulation for the seafood industry.
Consumer perceptions of seafood are ambivalent and pose a potential risk to the acceptance by consumers of any improvements to safety that new regulation may offer. A study of consumer attitudes revealed that, while consumers believe that seafood has some nutritional benefits, they lack sound knowledge about seafood products and are uncertain about the safety and possible contamination of seafood63. Furthermore, the study revealed that the correct labelling of fish was very important for 70% of consumers surveyed in Perth, and 73% of those surveyed in Sydney. Communication with consumers during the process of developing new regulation will continue to be important to foster greater consumer confidence.
Industry is concerned that implementation of any new regulation may bring with it large compliance costs, either through excessive regulation that is disproportionate to manage the hazards or through excessive government charges. Such concern, if not addressed, could result in a low level of compliance with new regulation and a lower level of benefit to the Australian community.
This concern can be addressed through a transparent process that demonstrates to all parties how the proposed regulatory measures relate to the scientific risk and provides benchmarks for industry to gauge the likely level of government charges.
The seafood industry contains a high proportion of small businesses, dispersed along rural and some remote coastlines, which potentially can make the implementation of any new regulation very difficult. Many regional communities are highly dependent on the continuing viability of their local seafood industry and may be resistant to change. These factors can be taken into account in the process of developing a new regulation, through a transparent process that demonstrates minimum effective regulation, and also the benefits to industry of consistently maintaining good hygiene and safety practices.
The staged approach to implementing food safety regulations in the NSW seafood industry indicates that regional dispersion of the industry need not be a barrier to the successful introduction of new regulations.
A further risk involves the potential for uneven implementation of a new regulation by the States and Territories. While each jurisdiction has responsibility to determine its priorities for enforcement, and the level of resourcing for its enforcement and auditing activities, there is nonetheless the issue that similar seafood activities anywhere in Australia should be subject to similar regulatory requirements.
The consequence of uneven implementation would be to reduce the credibility of the new regulation amongst industry, which would then be sceptical of its claims to be ‘nationally consistent’ and may doubt its other benefits. This risk can be addressed by clarity in the description of the new regulation, the provision of a comprehensive Interpretive Guide, and coordination between the jurisdictions in their implementation and enforcement of the Standard.