Dar seafood ppp standard

Attachment 4B

Consultation on Draft Assessment Report

Written submissions in Response to the Draft Assessment Report

A total of twenty-nine written submissions were received by FSANZ in response to the Draft Assessment Report of Proposal P265 during the period of consultation held from 26 May 26 through to 6 August 2004. Submitters originated from a wide range of organisations and individuals representing both industry sectors and government. A summary of the individual submissions is presented at Attachment 5B. A summary of the submissions grouped by issue is presented at Attachment 6B.

Responses to Jurisdictional Meetings

Following the release of the Draft Assessment Report for public comment, a series of consultation meetings were held in the jurisdictions. Meetings were held in Hobart and Launceston (Tasmania), Darwin, (Northern Territory), Brisbane (Queensland), Adelaide (South Australia), Melbourne (Victoria), Sydney (New South Wales) and Perth (Western Australia). Video conferencing was utilised in the WA meeting to engage the distant communities of Broome, Karratha, Carnarvon, Albany, Esperance and Geraldton.

Invitations to the meetings were sent out to industry and other interested parties by the hosting jurisdiction. Participants at the consultation sessions were invited to provide their views on the proposed draft standard as included in the Draft Assessment Report. Meeting outcomes notes were circulated to the hosting jurisdictions and the issues raised were noted for consideration during amendment of the drafting.

Main issues

The main issues raised in the submissions and during the consultation sessions were:

• 
  drafting issues, including:
  

- divide between Chapter 3 and Chapter 4

- scope of the Standard for seafood

- definitions such as ‘frozen’, ‘chilled’, ‘thermal centre’, ‘thawed’ ‘live seafood’

- the definition of ‘primary production’

• 
  consistent implementation across the jurisdictions
  
• 
  audit costs and third party audit arrangements
  
• 
  the exclusions of mandatory fish marketing names from the standard
  
• 
  labelling of imported product
  
• 
  enforcement of the standard at the border
  
• 
  risk ranking report
  
• 
  risk management
  
• 
  fish bone injuries
  
• 
  freshwater crayfish requirements in Victoria
  
• 
  the use of guard dogs in premises
  
• 
  the use of a marketing name for Salmon