Dar seafood ppp standard

Implementation (in general) and existing standards
There is unresolved understanding of the arrangements in the NT for the implementation and enforcement of the standard. [NT *] There was strong interest in how the standard will be enforced by Tasmanian regulators. Questions were raised over who would implement the standard, and how it would be implemented, and the costs involved. Training would need to be low cost and user friendly. [TAS *] There is uncertainty about what the standard will require in practice for scalefish fishermen. [TAS *] There was discussion around the role of EHOs in implementation. EHO responsibility ends at the high water mark. [WA*]
	Urges FSANZ to ensure that national standard will not compromise regulatory measures already in place in NSW. [NSW Seafood Industry Conference]
	Imperative that FSANZ ensure there is no duplication between this proposed standard and other standards already in existence or under preparation. [SA Freight Council]
	Primesafe stated that there had been a broad policy decision by the government to the implementation of food safety programs to meet national food safety requirements. The Primesafe view is that the proposed national seafood standard proposes how to implement the standard for the high risk areas but does not for the remainder of the seafood sectors. [VIC *] Primesafe advised that Victorian requirements start at the point of harvest for seafood. [VIC *]
	There was support to ensure that the ASQAP manual is kept alive/amended and that a suitable national linkage was developed with the committee responsible for the manual. [NSW *]
Audits	Believes that FSANZ should ensure that third party audited seafood safety plans that satisfy the conditions of the standard are deemed to comply with the standard. [Fishy Business, Tigrey] Important for PPPS for seafood to be harmonised with other relevant standards and a process for recognition of equivalence by implemented. [Seafood Services Aust] A high priority for industry is the ability to demonstrate compliance with the standard through a single audit system. [Seafood Services Aust] WAFIC calls for the recognition of third party audit against the Standard. [WAFIC] There is a need for a consistent approach to auditing of the measures required in the standard. [NT *] The issue of harmonisation between domestic and export requirements was raised. Primesafe gave an undertaking that they will be aiming to minimise duplication between AQIS and Primesafe audits (i.e. recognising AQIS audits). [VIC *] Questions raised about duplication of audit and discussion on possibilities to reduce e.g. recognition arrangements re export audits. [NSW *] WA would like to work towards recognition of AQIS audits. [WA *]
	Believes the outcome-based, non-prescriptive, standard will cause ambiguity in auditing and will add to expense. [Melshell Oysters] Concerned about increased audit costs as a result of the PPPS. Mutual recognition arrangements should be put in place between states, commonwealth (AQIS) and commercial organisations to minimise duplication. [NSW Seafood Industry Conference] Concerned about the potential for unrealistic expectations of State Govts for cost recovery by food regulators. This is a state jurisdictional issue, but believes FSANZ should be committed to resolve this or risk non-achievement of nationally consistent standards. [Seafood Services Aust] An emerging issue for some states will be the shortage of appropriately trained and qualified food safety auditors. [Dept Health & Human Services Tas] QLD had concerns with implementation e.g. in terms of accreditation and of skills and knowledge of seafood handlers. [QLD *]
Imported product –Labelling	WAFIC calls for the mandatory labelling of imported seafood at the food service level as well as at retail. [WAFIC] Requests that the provision of adequate labelling of imported seafood and prevention of false and deceptive conduct by the food service sector be mandated. [Fishy Business, Tigrey] Notes that the anomaly of imported seafood not requiring to be labelled as such is inconsistent with objects 1,2 and 3 of the FSANZ ACT. [Seafood Services Australia]
Imported product – Imposition of standard	Questions whether imported seafood will be required to demonstrate it has been grown/collected/harvested in accordance with this standard. Also questions whether food imported into NSW and Victoria and all bivalve molluscs into Australia will be required to demonstrate that they have food safety programs that comply with 3.2.1. [Laister Consulting] The standard must be capable of being applied to imported seafood. [QLD Health] Notes uneven playing field with local industry expected to comply with higher standard without reciprocal requirement for imported product. A similar requirement for imported food should be considered to the extent permissible by Australia’s international trade obligations. [Dept of Health WA] Understands that there are no plans to impose the standard on imported seafood. [Private - Ms Halais] The standard is not clear in what the intention is in relation to imports. [DAFF] Is of the view that an Australian standard is just that and cannot be mandated in other countries. [DAFF] There is uncertainty about how the measure will be applied at the border. There is the view that imported product should meet the same requirements as imposed domestically. [NT *] There were concerns about the standard would be enforced for imported product via end-point testing as opposed to inspection of their facilities. [SA *] How the standard would apply to imported product was an issue raised. [VIC *] Questioned how the standard will be enforced at the border for imported product. [NSW *] The issue of how imports will be dealt with was raised. [TAS *] The exclusion of NZ from the standard was an issue raised. [TAS *]