Drafting – Clause 15
Considers that in the third line of the definition of State Shellfish Control Authority, ‘control and relaying’, is a typographical error and should read ‘and control relaying’.
Considers also that there is a typographical error in line 4 and ‘that is contaminated or has’ should read ‘that are contaminated and have’.
Drafting - Subclause 18(a)
Considers subclause 18(a) does not read correctly and the word ‘continue’ at the start of the second line should be preceded by the word ‘must’.
Ray Brown
Manager
Tasmanian Shellfish Quality Assurance Program
Tasmanian Dept of Health and Human Services
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Supports submission from the Chairman of ASQAAC that went to FSANZ in November 2003, and notes that the recommendations of that committee were supported in the recent draft. Aware that these comments, on behalf of DHHS, are duplication the ASQAAC input, but wishes to make them on behalf of this agency.
Under Division 3 Clause 15 the definition of ‘bivalve molluscs’ excludes pearl oyster where the only part consumed is the adductor muscle. This exclusion is based on the assumption that there are no biotoxin issues with adductor meat of pearl oysters as is the case with scallop adductor muscle. Issue was raised at the last ASQAAC meeting and it was agreed that there was insufficient toxin data at this stage to exclude the adductor muscle.
Recommends to not exclude pearl oyster adductor muscle meat from the definition until this work has been done and endorsed by ASQAAC.
The intent of Division 3 Clause 19 to prevent co-mingling of lots of bivalves is strongly supported. No doubt that this will represent an inconvenience to certain sectors of the seafood industry but the benefits to industry as a whole will outweigh this.
States it is important that there are labelling requirements on the product through to the retail end to prevent co-mingling of molluscs. In addition to any general labelling provisions of the FSC, molluscan shellfish (not just oysters) should have the name of the harvest area and date of harvest attached to any containers/packets right through to retail outlets.
Strongly supports the requirement for all food businesses handling bivalve molluscs for sale to have a food safety management system.
Notes that an emerging issue for some states will be the shortage of appropriately trained and qualified food safety auditors.
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Hans Heilpern, Chairperson
for Warren Matthew
Executive Officer, Operations
NSW Seafood Industry Conference
NSW Food Authority
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Notes that the draft standard requires live seafood to be stored at a temperature that will not adversely affect the safety and suitability of the seafood (Sec 6(3)), and businesses involved in primary production of bivalve molluscs to implement a documented seafood safety management system (Sec 20). ASQAP has specified storage temperature and depuration conditions for live oysters and different types of oysters have different requirements. The optimal storage temperature for live Sydney Rock oysters is still a matter of some debate. States that FSANZ’s clear guidance on this matter will be essential for consistent implementation and enforcement of the relevant provisions of the standard.
The definition of bivalve molluscs in Sec 15 excludes pearl oysters. This would effectively exempt pearl oysters from the provisions specific to bivalve molluscs, including requirement of a marine biotoxin management plan. Seeks confirmation from FSANZ that there is sufficient scientific justification for the exemption.
Concerned about the increased audit costs as a result of the introduction of the PPPS for Seafood. States that it is important that mutual recognition arrangements are put in place between states, commonwealth (AQIS) and commercial organisations to minimise duplication.
The requirements of Division 3, subdivision 3 for a ‘seafood business’ are less stringent than the corresponding requirements in Chapter 3 of the Code for a ‘food business’. Considers this appropriate when applied to primary production environments such as those found on fishing vessels, sea cages and live seafood premises. Notes that the Editorial Notes to Clauses 13 and 24 emphasis the point that any businesses engaging in activities beyond primary production will have to comply with Standard 3.2.2 and Standard 3.2.3. It is requested that FSANZ provide very clear criteria as to the boundary of ‘primary production’. For example, questions if heading, gutting and/or filleting of fin fish onboard a vessel is within the scope of primary production.
States that it is not clear how far down the supply chain the prohibition f co-mingling (sec 19) is intended to apply. Notes that as this requirement is only proposed for the PPPS for Seafood but is not currently in Chapter 3 of the Code, presumes that it is FSANZ’s intent to allow co-mingling beyond primary production. Seeks FSANZ’s advice on the rationale of this. Also reinforces the need to have a clear distinction between what is considered primary production. Questions whether shucking of oysters is considered primary production or processing.
Draw’s FSANZ’s attention to the fact that NSW is well underway in implementing the Seafood Safety Scheme developed by NSW Food Authority in consultation with industry.
Urges FSANZ to ensure that the national standard will not compromise regulatory measures already set in place in NSW.
Looks forward to receiving information on the status of ASQAP requirements in the draft standard and the time-line for the Transitional Standard for Country of Origin Labelling Requirements.
Congratulates FSANZ on having made good progress on the development of the PPPS for Seafood, which is essential for ensuring consistent production of safe seafood in Australia.
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