Believes that the risk of a seafood safety accident happening at all should be clearly explained to the consumer in a manner than promotes the health benefits of eating seafood, rather than in a manner that creates public uncertainty about seafood. Does not understand the need to highlight Listeria in certain seafoods when RA cannot demonstrate incidents in Australia. [Fishy Business, Tigrey]
Notes that proposal deals principally with high risk seafood and there is little information addressing medium risk seafood. Questions what FSANZ proposes to do regarding medium risk seafood and how processing will have to meet the requirements of the standard. [QLD Health]
Believes that the mandatory requirements of a food safety program should be necessary for anyone producing hot or cold smoked seafood and mandatory instructions. [QLD Health]
Seeks assurance that the MRLs for pesticides and veterinary chemicals relative to seafood will be reviewed by FSANZ in conjunction with the Australian Pesticides and Veterinary Medicine Authority. [QLD Health]
Suggests that other businesses could be encouraged to adopt these measures as a voluntary standard. This could include the acceptance of the industry-supported Australian Seafood Standard. Would allow businesses to willingly accept a level of food safety management even where the products are not currently high risk. [QLD Health]
Other sectors
Stakeholders sought information about whether other sectors would be required to have PP Standards and whether consideration had been given to having some basic requirements for all primary production sectors. [VIC *]
Ready-to-eat seafood guidelines
The issue of bacteriological pathogens currently absent from the Code (e.g. V. parahaemolyticus, Clostridium etc) needs to be addressed in the ready-to-eat food guidelines. [QLD Health]
Industry guides
There is a need for industry guides (scallops and calamari in particular) to guide individuals on good industry practice. [TAS *]
Country of Origin
Will the transitional arrangements prevail or will FSANZ go back to review? [NSW *]
Fish bone injuries
Believes the proposed standard needs to address the issue of physical hazards in fish marketed as filleted and boned. [QLD Health]
Freshwater crayfish/Yabbies
Has concerns over impact of the Victoria governments implementation of the Seafood Safety Act 2003 and the enforcement of this Act through Primesafe and subsequent adoption of the FSANZ PPPS for Seafood. Requests the exemption of the sale of live yabbies from the regulation under the Victorian Seafood Safety Act 2003. Requests food safety risks be managed by agreed industry codes of practice. [Aust Freshwater Crayfish Assoc]
Calls on FSANZ to exempt all low risk live seafood as the yabby industry cannot continue to viably exist under the proposed Primesafe licensing and audit plans. [Vic Yabby Growers Assoc]
Guard dogs
Seeks rewording of Clause 24 in Division 6 of 3.2.2 to permit the use of guard dogs in processing areas under controlled circumstances but not while processing is going on. [Oakley Food Advisory Services]
