12 Skills and knowledge One submission commented that the wording of this clause was in conflict with Clause 3 of 3.2.2, as it does not apply to the persons supervising food handling operations.
The definition of ‘seafood handler’ includes reference to persons who supervise the primary production of seafood. No amendment is considered necessary.
13 Health and hygiene requirements Two submissions noted the differences in health and hygiene requirements between Standard 4.2.1 and Standard 3.2.2. The suggestion was made to either include Clauses 14 and 15 from 3.2.2, or alternatively, amend 3.2.2 in line with the provisions required for 4.2.1 for consistency.
It should be noted that the requirements for 3.2.2 in Clause 15 are far more detailed that the equivalent clause in 4.2.1. The distinction is that 4.2.1 is aimed at primary production and processing, whilst 3.2.2 is for an industry that in some cases will be preparing ready-to-eat food and therefore necessarily will need greater food safety requirements. However, it is noted that this Clause, as drafted for the DAR, failed to provide for an important provision contained in Chapter 3 concerning a seafood handler who may have a food borne disease (see paragraph 14(1) of Standard 3.2.2). A similar provision has been added to Clause 13 as a new part (2). Food borne illness is defined in 3.2.2 and the definition applies to Chapter 4.