What should be the scope of the proposed seafood Standard?
- Should cover the entire seafood industry.
- Should have consistency between definitions in the PP&PS and the SSA / ASIC standard, and an agreed process to change these.
- Outcomes based, not prescriptive.
- Outcomes focussed and based on food safety risk.
- Refer to, but not duplicate, other Chapters.
- Review Code as it does not allow health claims for omega 3 oil content.
- All foods should come under the standard not just foods for human consumption.
- Must apply equally to local and imported produce.
- Should apply to all seafood produced or traded in Australia, including imports and exports.
- Should not consider policy and regulatory issues other than food safety, and should not consider jurisdictional issues.
- Recognise and reference Australian Fish Names List.
- Don’t incorporate fish names.
- Exclude quality attributes and production methodologies.
- If the onus is on the supplier to source safe product, don’t need to heavily regulate primary production.
- Only regulate where significant risks and the benefits outweigh the costs.
- Standard should allow for voluntary codes of practice for GHP.
- Should simply apply Chapter 3 to primary production and processing, thus removing the need for a specific seafood standard.
- Difficult to legislate marketing names, but if done then should include Tasmanian Atlantic salmon and ocean trout.
- Self regulation is preferable to government regulation – use the SSA guidelines on GMP and specific industry codes of practice.
- Where regulation is deemed necessary it must be targeted at addressing the specific food safety problem and not have general application.
- Follow Codex Draft Code of Practice, except where too vague.
- EU or FDA regulations and micro criteria acceptable for export / import.
- Deceptive or misleading conduct best left to Trade Practices legislation.
- Reference to cold chain compliance through supply chain recommended.
- Should not extend labelling obligations beyond those in the Code.
- Seafood industry should only have to comply with standards 3.1.1, 3.2.2 and 3.2.3.
- Standards 3.1.1, 3.2.2 and 3.2.3 should continue to apply, with other requirements added where risk and cost-benefit indicates
- Need to differentiate between low inherent risks and higher risks through external impacts, and manage pollution of waterways.
- Will inevitably cross over into quality aspects – not undesirable.
- Residue accumulation as a consequence of prior land use in aquaculture requires attention
- Food safety risks should be managed according to the degree of risk.
- Avoid prescriptiveness – deal with actual not hypothetical risks.
- Must have regard to existing market- and export-driven HACCP-based QA systems.
- A full HACCP plan warranted for activities and products that carry a high food safety risk.
- Food safety should be managed using a preventative approach based on through-chain risk management, with standards implemented in consultation and partnership with industry.
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