| 18 Wet Storage of bivalve molluscs / 19 Co-mingling of bivalve molluscs
Questions whether these items need to be listed separately, especially if the seafood business is required to have a food safety program based on HACCP principles. The food safety program would identify all hazards and provide ways to control their risks.
- recommends these clauses be deleted.
15 Interpretation
States that if clauses 16-19 were removed, this clause would be redundant.
20 Specified seafood safety management systems
Notes the editorial note provides a list of acceptable systems.
- believes a reference to at least Standard 3.2.1 should be put in clause 20 (preferably Commonwealth Export Control Orders as well) as the editorial notes are not enforceable.
- in addition 3.2.1 refers to ‘food safety programs’, but this draft standard refers to ‘safety management system’. Believes this inconsistency in the use of terms may cause unnecessary confusion.
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