Table to clause 20 specifies ‘primary production of bivalve molluscs’ as the activity for which a seafood business must implement a documented seafood safety management system. Notes that the DAR states that ‘..implementation of food safety programs for the post-harvest sector up to the beginning of the retail sector is proposed’.
States that if these two references are to be in agreement, then shucking of oysters (e.g. into half shells and bottled oyster meat), storage and delivery of processed oysters to retail would have to be considered as within the scope of ‘primary production of bivalve molluscs’. This would appear not to be consistent with the definition of the term primary production of seafood in Sec. 2(2). Comments that there is a need for a clear distinction between what is primary production and what is beyond that.
Supports the draft variation to the Code as detailed in Attachment 1.
Hopes that FSANZ will continue to be involved and take leadership during the implementation of the standard at state level and thereby ensure that the intended outcomes of having nationally consistent food safety standards are achieved.
