Believes that with regard to the other areas of the seafood production sector, the proposed standard should be gazetted as a voluntary code, with the application of standard 4.2.1 being applied to the back door of a retail premise for bivalve molluscs.
States that individual jurisdictions have implemented State-based regulations and systems funded largely by industry to promote safe food processes by producers, or are considering some form of legislative mechanisms to capture those areas of primary food production that are considered to present the greatest risks to consumers.
States that the Code proposed should provide a framework which individual jurisdictions may draw on to strengthen identified weaknesses in food safety at a specific food production sector level, or where an industry sector chooses to obtain the market benefits of being associated with a regulated standard.
Preferred option is Option 2, but with the capacity for other species or sectors to be included within a schedule to the Standard where there is subsequent agreement to cover high risk products or for those sectors seeking a mandatory framework at a national level.
Believes that the Standard should be provided otherwise as a code of practice that can be adopted on a jurisdiction by jurisdiction basis within State-based legislative frameworks.
Option 3 is not preferred as this would oblige each State to mandate food safety programs for all primary producers of food safety and this would be inconsistent with the underlying principle of support for managing only high risk areas and the option for industry to adopt voluntary codes of practice for food safety.
Option 1 is not considered to have any merit.
Specific comments on the provisions within draft 4.2.1 as follows:
