| 3 General seafood safety management
Comments that the current wording does not require a business to document that it has systematically examined its operations. Therefore, a business will not be able to demonstrate that it has complied with the standard.
- recommends that the words “and document” be inserted in the Standard after “systematically examine”
or alternatively:
- delete clause 3 as it would be impossible to enforce.
5 Inputs and harvesting areas / Division 3 (16) harvesting bivalve molluscs for human consumption and (17) harvesting bivalve molluscs for depuration or relaying
Comments that Clause 5(2) adequately addresses the issue of harvesting seafood from only ‘safe areas’.
Believes these clauses duplicate this requirement in much unnecessary detail for bivalve molluscs. Clause 5(2) and clauses 16 and 17 provide the same outcome. Believes the reference to the SSCA requirements may place an unnecessary financial burden on small fishermen.
Cites an example if a scallop fisherman was harvesting scallops from many different areas, he would be required to supply and pay for the water analysis from each place the scallops were caught. This could involve many areas on one trip. Results of analysis would only be available after the fresh scallops had been sold which makes the results superfluous to the fisherman especially if the fisherman may never return to exactly the same area.
Samples from geographic areas need to be interpreted with weather conditions, currents and tides and the sea is an ever-moving object. In addition, fishermen would need to be trained on how water samples should be collected, stored and transported to ensure handling does not compromise results. However, the scallop fisherman would be able to demonstrate that scallops were not caught in restricted areas by recording the areas in which the catch was made and comparing them against the latest list of restricted areas. If State/Territory government(s) require water samples to be taken to provide them with more information to identify restricted areas, this would be outside the scope of the seafood standard.
As all States/Territories already operate the ASQAP, questions whether it is necessary to bring this quality requirement into a food safety standard?
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