Supportive of this proposal and of standards development, but has concerns regarding the definitions and interpretations where they could be inconsistent with or a duplication of Part 3 and Part 4 of the Food Standards Code.
The Committee supports the proposal to introduce mandatory FSP or equivalence to high risk sectors and also recognises that the seafood industry would benefit form national guidelines on GMP to ensure whole of chain food safety.
Notes that verification and enforcement of the proposed FSP and any GMPs hinge on requiring documentation and keeping of monitoring records for future records.
Recognises that the bivalve industry has been identified through risk profiling as requiring mandatory FSP. Notes that this sector is currently managed through the ASQAP quality systems, which has been adopted by all States and Territories where such industry exists. Notes that the consolidation of the ASQAP model into the Food Standards Code will enable a national consistent application of a recognised and proven FSP.
Recognises industry and consumer concerns about the uneven playing field for local and imported seafood, with local industry being expected to comply with higher standards without reciprocal requirement for imported foods. Consumers should have the same level of confidence in all available seafood supplies.
A similar requirement for imported foods should be considered to the extent permissible by Australia’s international trade obligations.
Notes the confusion between ‘primary production’ and ‘primary processing’, and the uncertainty regarding the point in the seafood chain that Part 3 of the Code commences to apply. Suggests that Part 3 of the Code apply for finfish from the filleting process and beyond.
Neil Murphy
General Manager
SA Freight Council Inc
Notes that inadequate and inappropriate transport and logistics activities represent a significant risk to the integrity of seafood products.
SAFC has several resources available to assist producers and transporters improve their handling of perishable goods, including a specific Seafood Handling Guideline.
Currently developing a Seafood element to its Food Export Logistics Training Program.
SAFC’s Cold Chain Centre will be the national focus for the delivery of the Australian Quality Logistics (AQL1) program.
Suggests that it is imperative that FSANZ ensure that there is no duplication between this proposed standard and other standards already in existence or under preparation.
Suggests that all regulations and standards regarding food standards in Australia, including those relating to seafood, must be uniform between States and Territories.
Suggests that to ensure that product integrity is maintained, and potential contamination and deterioration of product is minimised, all perishable products including seafood products, must be handled within a secure cold chain environment. Any regulations aimed at achieving this objective must be uniform between States and Territories.
