Dar seafood ppp standard

Seafood for Disposal

As primary seafood production businesses are the primary (first) businesses in the food chain they are unable to return seafood products to a supplier.

Suggests clause 9(1)(b) ‘returned to its supplier’ be removed.
Seafood Receipt

This clause was relevant when the standard was likely to extend beyond primary production, i.e. when product would be received by a seafood business up the food chain. However now that the standard only applies to seafood primary production there are no (second) businesses that will receive seafood products. There could be packing or grading operations but they will be part of the same seafood business.

Suggests clause 10 be deleted.
Recall

SA supports the recall provisions in clause 11 for bivalve molluscs as there are significant risks that may lead to recall of product. However believes there are no other high risks identified in the risk assessment that would be expected to lead to a recall by the operator. Difficult to envisage a situation where a fisher would know their product has become dangerous to the public and order retailers, wholesalers and processors to return or dispose of the product. As such, the requirement for a documented recall system means that an operator without the paperwork commits an offence. This imposition is significant with limited or no public health benefit.

Believes, however, there may be situations where seafood becomes contaminated through the chain and having a mechanism to trace the product back would aid in establishing the potential source of the contamination.
Suggests clause 11 becomes ‘a seafood business must have in place a system for ensuring the traceability of their products.’

suggests the current clause 11 be moved to Division 3 and be made specific for bivalve molluscs.