- how equivalence between existing requirements and any new standards could be established;
- the timeframes that industry may need to comply with the food safety management options;
- Timeframes will vary according to the requirements of food safety systems and the readiness of the industry sector (over two years in some sectors).
- Need 3 year compliance and 2 year stock in trade timeframes
- Timeframes should be set in close consultation with industry.
- the role of incentive based compliance schemes, such as reduced frequency of audits;
- An initial high audit frequency should be reduced, unless there is evidence that the system is not under control.
- This is a real opportunity to incorporate incentive-based compliance.
- the need for comprehensive guidelines for those sectors of the seafood industry affected by a Primary Production and Processing Standard for seafood, including the role of industry and regulatory agencies in the development of any guidelines
- Guideline a vital support to any legislation.
- Supports nationally developed guidelines.
- Many guides and codes of practice exist and SSA is helping industry develop GMP guidelines
- Will need guidelines, but not all industry codes of practice will be acceptable – issues of adequacy and equivalence will need national review.
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