Division 3 – State Shellfish Control Authority
The State Shellfish Control Authority (SSCA) is an effective term in the ASQAP Manual. However there may be difficulty with using SSCA, as defined, as a legal entity in legislation. Particularly where the legal authority is split between agencies and/or legislation.
Suggests the term ‘SSCA’ is replaced by the term ‘appropriate authority’ or ‘controlling authority’.
Seafood Management Systems
This clause is in division 3 that is specific for bivalve molluscs. As such it should specifically refer to primary production of bivalve molluscs and the table removed.
However, the clause and table are obviously structured for future flexibility so that, if agreed, seafood management systems can be applied to another category of seafood business. In this case, clause 20 should be shifted out of division 3 and be placed after clause 15, i.e. in the general seafood businesses section of the standard.
