Dar seafood ppp standard

Table 5: Summary of selected seafood commodities including current risk management*.

Commodity	Hazard/Environment or species	Severity	Likelihood	Relative risk Ranking^1	Current risk management
Raw Oysters	V. vulnificus	Serious	Likely	Medium	ASQAP/Ch 3^2
	V. cholerae O1/O139	Severe	Unlikely	Medium	ASQAP/Ch 3^2
	Noroviruses/Uncontrolled^3	Moderate	Very likely	Medium
	Noroviruses/Managed^4	Moderate	Unlikely	Low	ASQAP
	Hepatitis A virus/Uncontrolled^3	Serious	Very likely	High
	Hepatitis A virus/Managed^4	Serious	Unlikely	Low	ASQAP
	Algal biotoxins/Uncontrolled^3	Severe	Likely	High	Ch 1
	Algal biotoxins/Managed^4	Severe	Unlikely	Medium	ASQAP/Ch 1
	Arsenic, Cadmium, Lead	Severe	Unlikely	Medium	ASQAP/Ch 1
Cooked Oysters	V. cholerae O1	Severe	Unlikely	Medium	ASQAP/Ch 3^2
	Noroviruses/Uncontrolled^3	Moderate	Very likely	Medium	Ch 3^2
	Noroviruses Managed^4	Moderate	Unlikely	Low	ASQAP/Ch 3^2
	Hepatitis A virus/Uncontrolled^3	Serious	Very likely	High
	Hepatitis A virus/Managed^4	Serious	Unlikely	Low	ASQAP
	Algal biotoxins//Uncontrolled^3	Severe	Likely	High	Ch 1
	Algal biotoxins/Managed^4	Severe	Unlikely	Medium	ASQAP/Ch 1
	Arsenic, Cadmium, Lead	Severe	Unlikely	Medium	ASQAP/Ch 1
Cooked abalone /roe-off scallops	Algal biotoxins	Severe	Unlikely	Medium	Ch 1
Green prawns	V. cholerae O1^5	Severe	Unlikely	Medium	Ch 3^2
	Salmonella Typhi^5	Severe	Unlikely	Medium	Ch 1/Ch 3^2
	Arsenic	Severe	Unlikely	Medium	Ch 1
Cooked prawns	V. cholerae O1^5	Severe	Unlikely	Medium	Ch 3^2
	Salmonella Typhi^5	Severe	Unlikely	Medium	Ch1/Ch 3^2
	Arsenic	Severe	Unlikely	Medium	Ch 1
Chilled/ frozen whole fin fish and fillets	Mercury, Ciguatoxin^6	Serious	Unlikely	Low	Ch 1/Advisory Notes
	Ciguatoxin/Tropical^7	Serious	Likely	Medium	Advisory Notes
	Mercury/Predatory species^8	Serious	Likely	Medium	Ch 1/Advisory Notes
	Arsenic	Severe	Unlikely	Medium	Ch 1
Canned fish products	C. botulinum^4,9	Severe	Unlikely	Medium	GMP/GHP
	Arsenic	Severe	Unlikely	Medium	Ch 1
Cold-smoked fish products	C. botulinum^4,9	Severe	Unlikely	Medium	GMP/GHP
	L. monocytogenes	Serious	Unlikely	Low^10	Ch 1/Ch 3^2/Advisory
	L. monocytogenes	Severe	Likely	High^10, 12	Ch 1/Ch 3^2/Advisory
	L. monocytogenes	Serious	Likely	Medium^11
	L. monocytogenes	Severe	Very likely	High^11, 12
Hot-smoked fish products	C. botulinum^4,9	Severe	Unlikely	Medium	GMP/GHP

Footnotes for Table 5:

* Relative risk rankings are under constant review to identify emerging significant information.

1. Risk ranking reflects current practice for that commodity/seafood sector. The risk ranking is based on the severity of the hazard and an estimate of the likelihood of illness that takes into account various factors, including current risk management practices.

2. Chapter 3 provisions in the Code apply to the processing sector only.

3. Uncontrolled describes a growing environment not under a shellfish safety management scheme and/or likely to be exposed to faecal contamination. Includes growing waters adjacent to urban areas and rural habitation. In contrast, a growing environment considered pristine is unlikely to be exposed to faecal contamination. Pristine environments would typically include growing waters remote from human habitation and even if uncontrolled, present similar risk to managed waters for enteric pathogens. Algal toxins remain a risk for pristine environments.

4. Where a food safety hazard is controlled under a management system/program, the likelihood of illness is very low.

5. For product from intensive farming systems or estuarine harvest areas subject to human faecal contamination.

6. Majority of finfish present a low risk to consumers (Serious x Unlikely) due to mercury or ciguatoxin.

7. Ciguatoxin may be found in larger specimens of particular species of tropical and sub-tropical finfish from certain fishing areas. It is predominantly a problem in the recreational fishing sector (See Appendix 4, Table 19).

8. Predatory species – mercury is a problem in big, long living or predatory fish, such as swordfish, shark/flake and some tuna. These fish tend to accumulate higher levels of methylmercury than other species. The relative risk ranking is medium for the at-risk sub-population (the foetus) when the mother consumes mainly large, predatory or long-lived fish species.

9. Industry adherence to GMP, GHP and appropriate product formulation (e.g. pH, levels of salt, preservatives) control this hazard.

10. When correctly managed, the risk ranking is low for the general population (Serious x Unlikely), but high for at risk sub populations.

11. When not managed, i.e. processing, product handling and storage not adequately controlled, the risk ranking is medium for the general population and high for at risk populations.

12. L. monocytogenes is a severe hazard for at risk populations.

4.5 Examination of existing management systems and their control of identified risks

The previous section concludes that there are a small number of seafood commodities that may pose a higher relative risk to public health and safety when compared with other commodities in the seafood sector. It also concludes that the remaining seafood commodities pose a lower individual risk, but that when the risk is aggregated, these contribute significantly to the background incidence of food-borne illness associated with seafood.

It is noted that in identifying risks, use was made of the available epidemiological data. However, this data is limited due to significant underreporting (one per cent of cases are estimated to be reported). With this in mind, well over 90 per cent food-borne illness related to seafood is likely to be unreported. However, the relative risk ranking took into account other information, as detailed previously, to develop a view of the overall risks posed.

The following section of this Report further examines current management systems for higher risk sectors as well as the remaining sectors, to identify where these would benefit from application of additional or different risk management practices or a single integrated national scheme. Table 5 summarises current regulatory and food safety control measures in place for those seafood commodities ranked as either medium or higher relative risk.

4.5.1 Seafood ranked as high (relative to other seafood)

4.5.1.1 Oysters and other bivalve molluscs

Bivalves¹⁶ were assessed as posing a higher relative risk to public health when harvested from growing environments likely to be exposed to faecal contamination and/or not under a shellfish safety management scheme.

The food safety of bivalves is controlled through State-based programs that utilise ASQAP as a guide to safe production and harvesting. All Australian producers must now comply with the State-based programs as a condition of their aquaculture licence.
State ASQAP programs adopt measures to prevent the growing and harvesting of bivalves from waters made unsuitable by the presence of biological or chemical hazards at levels likely to present a public health risk. These programs allow for the purification of bivalves from such waters, under certain conditions, through the application of techniques such as relaying and depuration. However, the vibrios, algal biotoxins and enteric viruses, in particular, tend to be removed ineffectively by these purification techniques, so that the higher inherent risk cannot be completely managed by these practices. Because of this, ASQAP prescribes the testing of bivalve flesh for biotoxins under certain circumstances, and requires temperature control to limit outgrowth of bacterial pathogens post-harvest.

The State ASQAP programs are essential tools for the management of the safety of bivalve molluscs. It is clear that bivalve mollusc producers achieve a satisfactory level of safety for this inherently hazardous food through adherence to the requirements stated in ASQAP by the State Shellfish Control Authorities (SSCA). The use of very similar systems is mandated in many developed countries as the only recognised and effective means of producing safe bivalve molluscs. The control of waters from which the product is harvested is beyond the capacity of individual growers. Additionally, the current system ensures that the extensive sampling regime undertaken under the program is affordable for each grower.

The recent achievement of a national approach for industry compliance with the requirements set out in ASQAP for the safe production of shellfish has closed some of the gaps in the food safety management system for bivalves. The industry and the State regulators of the Program, through ASQAAC, have recommended to FSANZ that compliance with the pre-harvest requirements of ASQAP as well as biotoxins management plans be mandated in the Code and that food safety plans be mandated for certain post-harvest activities associated with these products. This aims to ensure that the current legislative basis for shellfish standards are based on food safety requirements, that States/Territories regulate shellfish safety through a nationally consistent standard and that there is a means to recognise ASQAAC as the body that maintains and updates ASQAP. Given the proven effectiveness of the ASQAP system, it would be appropriate to mandate compliance with requirements of the program as administered by the SSCA within the Code.
This approach would have the benefit of ensuring:

• 
  an appropriate legislative basis by bringing it under the health umbrella;
  
• 
  national consistency as all States would pick up the requirement uniformly and fully;
  
• 
  once in the Code it would allow health portfolios to verify compliance by industry; and
  
• 
  provide a mechanism for maintenance of guidelines that are essential for the safety of this food.
  

The development of mandatory documented risk management standards in the Code is consistent with the recent Ministerial decision and Guidelines on Food Safety Management Options in Australia.

In conclusion, the potential public health and safety risks associated with oysters and other bivalve molluscs are considered higher relative to other seafood and, therefore, voluntary or other non-regulated mechanisms to address this level of risk are not considered appropriate or sufficient to address the problem.