Risk Management issues
One submission stated that the risk of a seafood safety accident happening at all should be clearly explained to the consumer in a manner that promotes the health benefits of eating seafood.
FSANZ released the Seafood Draft Assessment Report with a press release that emphasised the benefits of eating seafood and with a focus on protecting public health and safety.
One submission noted that the proposal deals principally with the high risk seafood and questioned what FSANZ proposes to do with medium risk seafood.
Division 2 of the proposed standard - General Seafood Safety Requirements - addresses the requirements for all seafood (low, medium and high risk).
One submission called for mandatory food safety program for anyone producing hot or cold smoked seafood, together with mandatory instructions.
The DAR assessed hot smoked seafood as medium risk and therefore there were no requirements for specific provisions. Cold smoked products were assessed as high risk but in terms of the impact of Listeria monocytogenes in susceptible population groups. Current risk management strategies include requirements in Chapters 1 and 3 of the Code and a pamphlet on Listeria that provides specific advice to the susceptible groups. The implementation of specific food safety programs would need to be justified by a positive benefit-cost ratio – a policy principle agreed to by the Ministerial Council on Food Regulation in their discussions on the management of food safety in Australia.
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