| Live Seafood Premises
It appears that there may have been a need in earlier versions of the standard for the definition of live seafood premises. However now it appears that there is no longer a need as there is no longer a reference to live seafood premises in the standard.
suggests the definition for live seafood premises be removed.
Seafood Safety Management and Preventing Contamination
Clauses 3 and 4 will be difficult to verify by regulators in the absence of a documented program. Clause 3 will also be difficult for small operators who will tend to seek a list of actions, or advice on actions, that they need to follow, rather than doing a primary assessment of the hazards. Both clauses also seem to be covered by subsequent clauses 5 to 14.
suggests clauses 3 and 4 be deleted. Clause 3 may become a policy statement in the preamble to the standard.
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