General comments
Believes the proposed Standard must be capable of being applied to imported seafood.
Subclause (2) of Clause 2 Interpretation
In (b) of the Editorial note defining ‘primary food production’, there is a need for activities listed to apply to ‘on premises’ as well as ‘off site’. As an example, the wild harvesting of oysters in natural open areas would not be included in the definition as it presently appears.
Clause 15 Interpretation in Division 3
‘bivalve molluscs’ – the word ‘processed’ as used in this definition appears unwarranted particularly where there is reference to ‘shucked’ product. This definition also seems out of context with [c] of the Editorial note which defines ‘primary food production’
Gillian Parton
Quality Control Services Manager
Coles Myer Ltd
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Thanks FSANZ for opportunity to make comments, and also for taking on board comments provided in previous submission March last year.
Would like to reiterate that the Seafood Standard should not apply to retail, which generally only involves the storage and display of seafood. Supports the introduction of proposed Standard from harvest, up to by not including retail sale. The Food Safety Standard 3.2.1 adequately addresses the issue of temperature requirements as do own good manufacturing practices (GMP) and food safety programs.
With regard to fishing vessels and the regulation of harvesting, handling and on board processing of seafood, previously recommended that all these operations should be required to have some form of (CODEX) HACCP based food safety program in place. Notes that unfortunately the revised Standard does not reflect this, but rather states simple that ‘vessels must be constructed, maintained and used in ways that minimise the risks to safety’.
Notes the omission from the revised Standard of reference to the book of Approved Fish Names. States that one of the obligations of FSANZ in creating standards is to minimise the possibility of misleading and deceptive conduct in the food industry. Believes that to some extent this could be achieved by mandating the use of this publication for the naming and sale of fish, via the Seafood Standard. States that if FSANZ still believes that this matter is more appropriately dealt with under trade practices law, the government support and resources will still be required to ensure that the development of an appropriate Australian Standard eventuates and within a reasonable time frame (i.e. 12 months).
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Clare Hughes
Food Policy Officer
Australian Consumers’ Association
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Supports ANZFRMC decision to develop through-chain standard to manage the safety of poultry meat (sic – seafood) from primary production to consumers.
Believes it will enhance consumer confidence in the safety of seafood products and could result in increased sale and consumption of seafood.
Supports mandatory food safety requirements for all seafood businesses.
Feels there is a gap that needs to be addressed at the primary production and processing level and that the proposed standard will help achieve this.
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