Dar seafood ppp standard

Division 3 Clause 20 – Specific seafood safety management systems

This provision should relate to any and all activities or species that must be covered by the Standard and as such it should be in a Division 4 rather than in Division 3 which specifically only covers bivalve molluscs and so is superfluous in this division. The table should be part of defining the extent that there is a regulated need for a standard e.g. high risk foods or processes.

Phil Pond General Manager Safe Food Production QLD	The Standard will need to expand the definition of Primary Production to include processing. Suggests that the definition in Section 11 of Food Production (Safety) Act 200 which in part includes the following: ‘the dismembering, filleting, peeling or shucking of seafood or added brine to seafood and the boiling of crustaceans’. This could be achieved by amendments to the editorial note. The opening para will also need to pick up on it. This will give consistency across the jurisdictions and allow for processing. The definition of oysters needs to include spat. The State Shellfish Control Authority (SSCA) will need to be reworded, as QLD does not have such a body and this does impose a new agency on QLD.
Graham Short Chief Executive Officer Western Australian Fishing Industry Council Inc. (WAFIC)	Calls for a National Fish Names List and big fines for fish substitution to be included in the Primary Production Standard for Seafood. Calls for the mandatory labelling of imported seafood at the point of sale. Calls for the recognition of third party audits against the Standard. Calls for the risk assessment to be completely reassessed to include the risk of a seafood safety incident happening at all.
Department of Agriculture, Fisheries and Forestry (Richard Souness/Tom Black)	Endorses a national regulatory approach with consistency across jurisdiction to the management of seafood safety. Notes that the interpretive guide and standard may have been better developed at the same time. Comments that it is difficult to assess whether the clauses are adequate for export requirements. Notes that bivalve molluscs produced under this standard will not be eligible for export. Export Issues Concerned that a standard that does not mandate the requirements for ASQAP will lead to significant downgrading of the requirements that are now in place. Highlights the fact that all products for export are processed in accordance with a documented food safety plan and are subject to performance-based audits. Imports The standard is not clear what the intention is in relation to imports. Is of the view that an Australian standard is just that and cannot be mandated in other countries.