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The impact on producers of oysters and other bivalve molluscs under this option will be the same as under the previous option, essentially imposing some additional compliance costs where post harvest food safety programs are not yet in place.
In addition, the general provisions of this option mandate basic food safety obligations on all seafood businesses. The mandatory nature of the basic food safety obligations will be new for businesses in the primary production sector. Fulfilling the basic food safety provisions required by the general provisions under this option is anticipated to have little impact on those seafood businesses which either supply the domestic market to the standards required under export controls, or fully comply with the voluntary industry standards and codes of practice. Advice from industry bodies such as Seafood Services Australia and the Sydney Fish Market indicates that the majority of seafood businesses already undertake basic safety practices as set out in industry codes of practice and guidelines to at least the level required under this option. For these businesses, the proposed general provisions will not affect their operating costs.
FSANZ undertook a number of interviews with fisheries, enforcement agencies, inspection auditors and commercial fishers from around Australia’s coastline, to obtain detailed information about the effect of mandating good hygiene practices on industry operating costs. The interviews revealed a consistent picture of hygiene practices across the seafood industry (although the examples differed). The principal themes are documented below.
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Good hygiene practice is basic and easily achievable by the seafood industry. Examples include: appropriate temperature control of the catch, typically an ice slurry or refrigerated holding tank; ensuring water for holding tanks is sourced from clean sea water, and changed as required; keeping bait and chemicals separate from the catch; ensuring there is no contamination of the catch; keeping haulage areas clear of weeds; regular cleaning of desks and protective clothing; appropriate vessel maintenance to address cracks and crevices in surface areas or holding tanks, and to ensure there are no oil leaks over the deck; use of gilling and gutting boards (rather than the boat’s gunnels); regular cleaning of prawn cookers; and advice such as ‘don’t take your dog fishing’.
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The practice of good hygiene does not require additional equipment. Good temperature control is widespread across the industry and hence the equipment such as iceboxes and refrigerated holding tanks are already widely used (where required). Good hygiene practice will require some fishers to purchase tools such as gilling and cutting boards. Where this is the case, it is estimated that these boards would cost between $100-$200 and have a life expectancy of five years.
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Good hygiene practice is essentially a matter of the practical adaptation of hygiene and sanitation principles to fishers’ work practices.
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Most fishers already incorporate hygiene into their work practices. They achieve hygiene outcomes through traditional methods and by following existing industry guidelines and codes of practice. While there are a large number of these guides and codes available, the industry Code of Practice developed in NSW for commercial fishers, could be considered indicative. This code is generally outcomes based and the little prescription that may bring a relatively small cost is the requirement to use a chemical sanitiser.
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The principal reason that some fishers do not comply with good hygiene practice is lack of awareness. When given clear guidance on the requirements of hygiene standards, advice from auditors in the NSW Food Authority or the Southern Rocklobster Fishery is that the fishers easily and enthusiastically embrace industry best practice. Some fishers follow traditional methods, which achieve hygiene outcomes in most circumstances, but training (a one-day workshop44) that explains why hygiene outcomes are achieved provides the fishers with the knowledge to achieve good hygiene in unusual circumstances too.
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A mandated hygiene standard, even where outcomes-based and allowing for variation in approaches between fishers and fisheries, will be superior to a voluntary industry code of practice in achieving good hygiene outcomes.
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Implementation of good hygiene practices is typically a matter of refining current work practices. This can be achieved easily. In NSW the Food Authority ran workshops in each of the fisheries, which cost the fishers $50 and one day’s participation at a workshop. The cost of foregone earnings to attend the workshops were minimised by scheduling a range of days when training was available and at times when boats were in port. The fishers left with the ability to develop a simple food safety plan for their operation (which is more than is required under the proposed general provisions of Option 3). Likewise the Southern Rocklobster Fishery provided training and support for its members in a comprehensive integrated program covering all aspects of fishing, at a cost of $275 per operator, and by the end of 2004 the fleet will be performing at a level that will satisfy third party auditors.
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The industry acknowledged that good hygiene practice is essential for high quality seafood. However the industry gave a qualified response as to whether quality would attract a price premium – i.e. whether the commercial incentives in the market supported hygiene practices and quality seafood.
For example, one fishery acknowledged that market recognition of quality would take time, but in due course a price premium would be possible with effective branding. Other sectors mentioned that poor quality product would be penalised with a price discount, or not accepted at all by the wholesale markets. Another fishery achieved premium prices for its quality product at times of strong demand, but not all the time. However its reputation for quality product meant that it was able to sell its products all year round, hence it could depend on income throughout the year and on this basis plan to undertake investments to maintain the quality of its products. Continuing market access was a significant benefit from its focus on quality.
This information indicates that the seafood industry can readily achieve good hygiene outcomes through refinements to their work practices, with minimal impact on their costs of operation. Higher quality of product that is associated with good hygiene is recognised in the market, although what this means for price and sales revenue will depend on the type of product and market conditions. Overall, attention to good hygiene, with the outcome of higher quality product, appears to be commercially viable for the seafood industry.
There may be costs to industry as a result of States’ recovery costs to implement the proposed Standard. These costs may be comparable to those experienced by NSW in the implementation of their State-based hygiene and safety regulations.
In NSW there is a $50 cost for a licence and annual fees have recently been introduced to cover enforcement costs. Annual fees for commercial fishers are $310 and for finfish and crustacea aquaculture fees vary from $250 (for businesses with less than 10 employees) up to $2,000 for businesses with more than 50 employees.
Victoria has enacted legislation for a through-chain regulation of all seafood businesses. The legislation came into force on 1 July 2004 for wildcatch and aquaculture businesses and requires businesses to obtain a licence and demonstrate they are meeting the basic requirements of the Victorian Food Act. The are required to prepare a food safety plan by the end of the first year. The regulator, Primesafe, requires annual fees to be paid by businesses, dependent on the level of annual throughput. Hence the fees are less costly for the smaller operators (e.g. $200 for lower annual catch) and more expensive for larger operators (up to $800 for high annual throughput). Audit costs will be additional to these costs, however there is no advice on the likely audit costs.
The examples above of the flow on costs to industry of States’ recovery costs to implement food safety schemes are indicative. It should be recognised that the costs to implement food safety schemes may vary across jurisdictions.
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