Other implementation issues
One submission urged FSANZ to ensure that the national standard will not compromise regulatory measures already in place in NSW. As drafted, the proposed standard should not compromise the capacity of NSW to enforce their regulatory measures already in place.
One submission stated that is was imperative that FSANZ ensure that there is no duplication between this proposed standard and other standards already in existence or under preparation in South Australia. There are no existing standards in South Australia so there is no risk of duplication in this state.
Audits
Several submissions made mention of concerns around ensuring recognition of third party audits and a process for recognition of equivalence. Further, there were concerns voiced about the cost of audits.
The concerns raised in the submissions around this issue were communicated to ISC at their October 2004 meeting.
Currently, ASQAP is in place for export with audits being conducted by AQIS (or by States on behalf of AQIS). Further discussions are occurring between AQIS and the States/Territories in relation to the States recognising AQIS audits without the requirement for further separate State requirements to determine compliance with the domestic standard.
At the national level work is proceeding on the finalisation of food safety auditor competencies and ISC has commenced a body of work in relation to a national food safety auditor policy.
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