3 General seafood safety management One submission suggested it would be difficult for regulators to verify Clause 3, and also difficult for small businesses to follow. It was suggested the clause be removed, with it being replaced by a policy statement in the preamble to the statement. Another submission also suggested that the words ‘and document’ be inserted in the standard after the words ‘systematically examine’.
This would, in essence, mandate a de-facto food safety program and this is not the intent of the standard for the low and medium risk products covered by the General Provisions (however, it may be one way that implementation could achieve these outcomes).
It is suggested that the editorial note be amended to state that the measures listed are not exhaustive (the words ‘should include’ have been added) and that the meaning of the word ‘control’ be defined in the Definitions.
