Dar seafood ppp standard

Recognition of equivalence

Notes that it is important that the PPPS for seafood is harmonised with other relevant standards and that a process for recognition of equivalence be implemented.

Notes that duplication of audits has the potential to add significant costs to the seafood business. Recognition of equivalence and the ability to demonstrate compliance with standards through a single audit system remains a high priority for industry. Welcomes the commitment of FSANZ to this process.
Cost Recovery

Remains concerned at the potential for unrealistic expectations of State Governments for cost recovery by their food safety regulators. Believes expectations may result in unnecessary requirements being implemented at State level as revenue raisers and may impede achievement of food safety outcomes. Recognises that this is a state jurisdictional issue, but believes that FSANZ has to be committed to resolve this or risk non-achievement of nationally consistent standards and the expected outcomes as detailed in the DAR.

Brett McCallum Executive Officer Pearl Producers Association

Welcomes the current recommendation in the DAR regarding the classification of pearl meat using solely the adductor muscle. Supports the definition of the high risk ‘bivalve mollusc’ class of product excluding pearl oysters where the only part of the product consumed is the adductor muscle. Notes that the Standards Development Committee for the PPPS decided that the definition of Shellfish by ASQAP was flawed, hence the correct definition in the PPPS based on the real level of risk. Notes that the only shellfish which have an elevated level of risk according to the FSANZ Risk Assessment are ‘whole’ bivalve molluscs harvested from unmanaged fisheries and eaten raw or lightly cooked. States that there is abundant literature showing that bivalve adductor muscle, such as pearl meat and scallops, are one of the safer forms of seafood. Notes that review on literature by Janet Howieson of WA Fisheries Dept previously forwarded (also see Submission #5). States that in over 50 years of corporate knowledge, there has not been any instance of food poisoning due to consumption of pearl adductor meat. Over 1000 people working in the industry in any given year. Notes that pearl farms are located in remote pristine wilderness areas with the watersheds surrounding the areas generally having no permanent populations and no point or diffuse sources of pollution. Notes that while there is little data available on potentially toxic algal species in tropical Australian waters, notes that a comprehensive survey of Darwin Harbour by Padovan (1991) found no toxin producing species. States that as a result of the lack of associated problems with the consumption of pearl meat, the industry has not seen the need to conduct any structured program to provide supporting documentation. The industry considers that this history and the position taken on scallop adductor muscle is compelling argument that pearl oyster adductor meat is a safe product. States that this position now supported by SDC for the PPPS. Notes differences in definition of bivalve shellfish between the draft PPPS (which exempts pearl oyster adductor muscle) and the ASQAP Operations Manual (includes pearl oyster adductor muscle). Notes that FSANZ Risk Assessment resulted in the exemption of the product in the definitions in the draft Seafood PPPS. States that a strong argument will be put to ASQAAC to change the definition in the ASQAP Operations Manual on the basis of FSANZ RA. Notes that as raised with Jenny during the Perth seminar, there is a process issue that PPA requests needs careful consideration in the finalisation of the draft PPPS. Should there be any consideration of a change to the exclusion of pearl oyster adductor muscle from the definition of high risk bivalve molluscs, the PPA would require the opportunity to consider the basis for any change and to formally comment or take action to further support the current draft. Analysis results for heavy metal analysis from pearl farms from 5 sites attached (same as for submission #5). All the values for heavy metals are below the maximum limits as outlined in the Code. States there be a need, the industry is prepared to undertake laboratory feeding experiments to quantify any accumulation of algal biotoxins in the adductor and viscera of pearl oysters. General outline of this testing as been developed (see attached to Submission #5).

John van den Beuken Programme Manager Carole Inkster Director, Food Standards New Zealand Food Safety Authority