Geoff Raven
Manager Food Safety Program
Primary Industries and Resources SA
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In considering the DAR, the Department of Primary Industries & Resources SA consulted with the Department of Health. Both agencies support the attached submission.
General Recommendations: South Australia supports:
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mandatory requirements for bivalve molluscs;
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the gazettal, as a voluntary standard, of the requirements for the remaining seafood businesses; and
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the splitting of the requirements for shellfish businesses between standards 3.2.1 and 4.2.1 and the imposition of food safety programs (standard 3.2.1) on shellfish food businesses up to the back door of retail premises.
Discussion:
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SA agrees with the assessment of bivalve molluscs in uncontrolled waters as a potentially high public health risk and supports the application of draft standard 4.2.1 to bivalve molluscs.
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SA does not have intensively farmed or contaminated estuarine harvest waters for prawns and as such does not see a public health need for mandatory requirements for prawn harvesting in SA. Notes that most harvesting of prawns in SA is covered by AQIS systems.
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SA supports the assessment of finfish as medium risk for ciguatera toxin, mercury and arsenic, but notes that draft standard 4.2.1 does not address these risks as they are managed by alternate strategies.
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SA acknowledges the potential risk to abalone and roe-off scallops from algal biotins, but notes that abalone and roe-off scallops are excluded from the relevant risk management tool i.e. application of Division 3 in 4.2.1. SA supports the exclusion but notes that if further data indicates an increased risk this may need to be reassessed.
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Notes that the risk assessment did not identify any high or medium risks for primary seafood production, beyond bivalve molluscs, that would be mitigated in SA by application of draft standard 4.2.1.
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SA contends that the contribution from poor handling and primary risks in primary seafood production, apart from estuarine/farmed prawns and bivalve molluscs and ciguatera toxin, is a minor contributor to food-borne illness and that post-harvest cross-contamination and poor handling is by far the major contributor.
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States that if the food-borne illness risk from the low risk sectors in primary seafood production is significant, then so too will be the costs to correct them. However, if there are minimal public health issues with primary seafood production than the implementation and compliance costs will be relatively low, but then the rationale for imposing the standard is also limited.
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On the basis of a limited positive benefit cost ration, the SA government does not support the mandating of hygiene requirements for primary seafood production apart for bivalve molluscs.
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SA will reassess its position if data is presented that supports the contention that the poor handling of primary seafood production, excluding shellfish, makes a significant contribution to food borne illness.
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Notes that there are indirect benefits for industry in implementing 4.2.1 eg improved consumer perception and improved shell-life, that may improve the benefit-cost ratio. As such, if primary seafood production sectors believe that the benefits outweigh the costs and support implementation of the standards, then SA would not oppose implementation of 4.2.1 for non-shellfish primary seafood production.
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DPIR South Australia provided specific comments on the draft standard. These are detailed below:
Defining the split between standards 3.2.1 and 4.2.1
The split between applications of 4.2.1 and 3.2.1 needs to be based on, and consistent with , the definition of ‘primary food production’ in the current Food Act and then be consistent with the definition of ‘primary production of seafood’ in standard 4.2.1.
Currently the words in clause 15 of 4.2.1 mean that bivalve molluscs are extended beyond the definition of ‘primary production of seafood’. They also conflict with the words ‘primary production of bivalve molluscs’ under the table in clause 20. The additional words also seem to be superfluous for applying the clauses relevant to bivalve molluscs under 4.2.1
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Suggests the definition of bivalve molluscs under clause 15 has the following words removed, ‘… either shucked or in the shell, fresh or frozen, ….., or processed….’.
The current words in the table to paragraph 2(2)(b) in 3.2.1 extend the application of 3.2.1 to the production of bivalve molluscs, as ‘handling’ includes production. As the intent is to now have 3.2.1 and 4.2.1 sit alongside each other then this table needs to be amended to exclude the primary production of bivalve molluscs from standard 3.2.1.
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Suggests the words be added: ‘other than the primary production of bivalve molluscs’ after ‘handling of bivalve molluscs’ in the table.
Frozen Seafood
Suggests that the following words could be removed as the remaining words adequately convey the intent:
frozen seafood remove ‘…has been changed into a different state by the reduction in temperature and…’.
It is unclear why there is a need to have a definition for ‘frozen seafood’, ‘thermal centre of seafood’ and ‘thawing’. In general, unless there has been penetration of a seafood animal, microbiological contamination will not occur in the centre of the animal and hence the need to ensure a specific temperature is achieved at the core of an animal would not seem to help in significantly reducing any public health risk. Enforcement would also be an issue as an inspector would need to probe into the centre of an animal to verify compliance with the standards. Appropriate chilling soon after capture or harvest would seem to be sufficient.
suggests the definitions for ‘frozen seafood’, ‘thermal centre of seafood’ and ‘thawing’ be removed.
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