Notes there is no requirement for a business to write anything down, nor to monitor the controls. Enforcement or demonstration of compliance will be difficult. Suggests the clause needs strengthening to require documentation and ongoing monitoring of controls.
Editorial Note for Clauses 6 & 7 and also Clause 10
The reference to temperatures at or above 60ºC should be removed.
Clause 15
Suggests the addition of words to indicate general criteria for judging equivalence of ‘an equivalent manual’ in the definition of ‘Manual’
Clause 20
The Clause should be amended to refer to the ‘Export Control (Processed Food) Orders’.
Suggests strengthening the Clause with the addition of words to the effect that ‘the effectiveness of the controls should be scientifically validated’.
Implementation
Notes the potential for inconsistency of enforcement across the States.
