Technical data is sought from industry and relevant agencies for incorporation into the scientific risk analysis process. - The reported data for the relative amounts of local and imported seafood consumed in Australia is wrong – correct ratio is given.
- Need more data on chemical / pesticide residues in aquaculture.
- Industry should be encouraged to fill the few remaining gaps in Australian risk assessment data
- Can supply data from food microbiological surveys, if required.
- Supports provision of technical data for incorporation into the scientific risk assessment process
- Prepared to assist with provision of technical data for incorporation into the scientific risk assessment process.
- Won’t supply data if confidentiality can’t be assured.
Sontari
Qld Health
SFQ
SA DHS
SFM, MFMAA
TSGA
Comment is sought on the suitability and/or any deficiencies of the industry-preferred standard proposed under the SSA/ASIC Application, if it were to be considered as a basis for a national mandatory Primary Production and Processing Standard for seafood. - Supports industry developing and implementing voluntary standards.
- Don’t use it as basis of seafood standard (reasons given).
- Use the SSA / ASIC standard as an interpretive guideline.
- Needs to be modified if to be used as a guideline.
- Some parts would be useful as a guideline document.
- Use it as a basis for the seafood standard.
- Use it as a basis, but it has some anomalies.
- Sections 9 and 10 should apply to trawlers and premises used for live fish.
- A wider view is required.
PIRSA
PIRSA
TFIC
SASC
SA DHS
NTSC, SFM, MFMAA, DAFF
Qld Health, SA DHS, SFQ
AFFS
Sontari
Comment is sought on the suitability of any existing government standards, such as the NSW Food Production (Seafood Safety Scheme) Regulation 2001, and any international standards, as a model on which to base a national mandatory Primary Production and Processing Standard for seafood. - All existing Australian and international standards should be considered as part of the process of developing the PP&PS for seafood.
- Work undertaken by SafeFood NSW and issues raised in the NSW ‘Section 73’ review should be taken into account in developing the standard.
- There is anecdotal evidence of complexity and cost in the NSW and VIC schemes.
- NSW scheme is deficient for several reasons.
- NSW seafood safety manual should be the standard.
- Current legislation covering imports is working.
- The NSW scheme is a regulation, not a standard, but some of the oyster management parts would be useful as a guideline.
- Incorporate into interpretive guidelines as appropriate.
- Utilise industry codes of practice etc. where mandatory measures would be ineffective.
SSA
SFM, MFMAA
TSGA
Sontari
AFFS
Sontari
Qld Health
TFIC
TFIC
Comment is sought on the range of options available to manage food safety risks in the seafood sector and their appropriateness, including the costs and benefits of such approaches. - Should mandate ASQAP principles for all bivalve molluscs.
- should cite ASQAP
- FSPs for bivalve mollusc production and handling and for control of Listeria in cold smoked salmon
- Since seafood is mainly low risk, only need to apply minimum regulatory controls where necessary.
- Management focus and costs should be directed towards those segments presenting the greatest risk.
- HACCP must be the basis for food safety management.
SASC,
PIRSA
DAFF
PIRSA
SA DHS
NSWSIC
SASMPA
Stakeholders are invited to provide their views on issues relating to food safety management systems and whether options further to those raised in this paper should be considered in managing the potential public health and safety risks associated with seafood. - the Ministerial Council has established that risk management in relation to PP&PS is to be consistent with Chapter 3, HACCP based and implemented according to risk classification.
- The solution, whether HACCP or GMP, should be appropriate to the level of risk.
- Develop voluntary code for harvesters, as low risk.
- Only need effective risk communication and targeted industry education.
- FSPs should only apply where the risk is high.
- Non-regulatory guidelines and codes of practice could be effective where risks are low.
- FSPs should not be implemented unless there is strong industry and government leadership and it is supported by appropriate resources.
