Dar seafood ppp standard

Consultation on the Draft Assessment Report

8.1 Consultation on the Draft Assessment Report.

FSANZ conducted face to face consultations in each State and the Northern Territory on the Draft Assessment Report to explain the draft assessment report and its implications to stakeholders and to receive feedback on the proposed Standard.

Twenty nine public submissions were received in response to the Draft Assessment Report.
The issues raised in the public submissions and at the face-to-face consultations at the Draft Assessment stage are detailed at Attachments 5 (Summary of each Submission) and Attachment 6 (Summary of Submissions by Issue Raised).
The SDC met on October 2004 to consider the issues raised during the public consultation process and responses to these issues, including modifications to the drafting of the Standard. FSANZ also undertook further targeted discussions with State and Territory governments and industry on a number of issues following the October SDC meeting.
Given the concerns of industry members on the SDC in relation to consistent implementation of the Standard, FSANZ raised these matters at the ISC meeting held in October 2004. ISC agreed to a process to engage with members of the group to address these issues as well as discuss issues related to guidelines to support the Standard.
A further meeting of the SDC was held in January 2005 attended by the Chair of ISC, to resolve the remaining issues to enable finalisation of the Standard. The meeting was also to agree on a process for further consideration of implementation issues.
The main issues at Draft Assessment included:

• 
  drafting issues, including:
  

- the divide between Chapter 3 and Chapter 4

- the scope of the Standard for seafood

- definitions such as ‘frozen’, ‘chilled’, ‘thermal centre’, ‘thawed’ ‘live seafood’ and the exclusion in the definition for bivalve molluscs

- the definition of ‘primary production and processing’

• 
  consistent implementation across the jurisdictions
  
• 
  audit costs and third party audit arrangements
  
• 
  the exclusion of mandatory fish marketing names from the Standard
  
• 
  labelling of imported product
  
• 
  enforcement of the Standard at the border
  
• 
  the risk ranking report
  

In response to the issues raised at the Draft Assessment stage, the drafting of the Standard has been reconsidered. In summary, the Standard has been amended as follows:

• 
  to clarify the issues around the scope and application of the Standard, including the division between Chapters 3 and 4 of the Code. This has been achieved through amendments to the definition of primary production and the processing of seafood, the purpose and commentary section and additional editorial notes;
  

• 
  a number of definitions within the Standard have been amended or removed to address issues identified through the consultation process;
  

• 
  other amendments to clauses to simplify the legal drafting, clarify the intent of the Standard or rectify other identified issues.
  

A number of issues relating to implementation of the Standard have been raised by industry. A process has been established with the Implementation Sub-Committee of the Food Regulation Committee and representatives of the SDC to consider implementation issues raised and assist with consistent implementation of the Standard. This matter is discussed further in the next section of this report.

Further details on the issues raised and their consideration are outlined at Attachment 4B of this Report.