Dar seafood ppp standard

Laister Consulting Services P/L

Carole Theobald

Cormorant Technical Services P/L

This title includes the word ‘processing’ which is not ordinarily associated with primary production. No definition is provided in Standard 4.2.1 to differentiate the use of this word in this Standard to the use of the word “process” in Standard 3.2.2.

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  Temperatures referenced in Standard (where it is stated “unless the contrary intention appears, the definitions in Chapter 3 of this Code apply for the purposes of this Standard”).
  

Questions whether there is a need for a chilled or frozen seafood definition. States they are only referenced in clauses 6 & 7 as examples of types of food. These definitions may lead to enforcement difficulties as an enforcement officer would not know which standard to apply.

For example:

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  should a frozen product be hard, below -18°C or another temperature that ensures the safety of the food;
  
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  if the product is between -2°C and -17°C it is under temperature control, is safe and suitable, but is outside the definitions of chilled seafood or frozen seafood. How would this be enforced? In reality, there would be a conflict of standards so standard 3.2.2 (temperature control definition) would prevail (clause 1(2)). Therefore, why put the conflicting definitions in the Seafood Standard in the first place?
  

Believes the reference to the thermal centre of the seafood after thermal stabilisation adds unnecessary complexity to the standard. The thermal centre is not always easily and readily identifiable and will be dependent on external influences at the time of freezing. Every block of fish will be different. It would therefore be virtually impossible to demonstrate compliance with this requirement and similarly difficult to enforce it.