Dar seafood ppp standard


NATURE OF FOOD SAFETY CONTROL



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NATURE OF FOOD SAFETY CONTROL

OPTION

1

Status quo

OPTION

2
Mgt of higher risk only
OPTION
3

Basic Safety Provisions + Mgt of higher risk

Current arrangements:

-General obligation under Food Acts to produce safe food

-Food Std Code provisions (except for primary production)

-State and Territory schemes (NSW, VIC)

-Voluntary industry codes of practice


P

P

P

P

P

P

P

P

P

P

P

General Provisions:

Food safety practices applied to primary production end of seafood sector (similar to current hygiene requirements for the manufacturing, retail and food service sectors but tailored to seafood industry)









P

Specific Provisions:

Standard 3.2.1 (Food Safety Programs) or equivalent applied to higher risk activities of the seafood industry






P

P

States and Territories will be responsible for compliance with and enforcement of this Standard. Government costs may vary from State to State, but overall arrangements for industry will be more efficient by having a single national standard.


A regulatory impact analysis has been undertaken to consider which option provides the maximum public health protection, with least impost on industry. The estimated benefits of introducing Option 2 (before costs) is $26.4 million per year, while benefits of introducing Option 3 are estimated between $30 million to $75 million per year. The preferred option is Option 3.
Option 3 is preferred as it provides a single set of national standards to protect public health and safety (the primary objective of the FSANZ standard-setting process under section 10 of the FSANZ Act). It would do this by requiring an approach that is more rigorous for the higher risk products, which were identified from a review (risk ranking report) of the public health and safety risks associated with the consumption of seafood. The products include oysters and other bivalve molluscs (with some exceptions).

For seafood businesses producing bivalves1, compliance with pre-harvest provisions of the Australian Shellfish Quality Assurance Program and the implementation of food safety programs for the post-harvest sector up to the beginning of the retail sector is proposed. Food safety requirements for retail and the food service sector are already covered under Chapter 3 of the Code.


For the majority of the seafood industry - that poses lower risk (medium and low risk categories according to the risk ranking report) – a basic set of food safety provisions (called general provisions) are proposed. Such provisions would include requirements to ensure that food is not contaminated during its production or handling, that adequate temperature control of food is maintained and that staff have the skills and knowledge about food safety that is necessary for the work they undertake. Some of the medium risk products may benefit from more specific risk management strategies. However, these may vary according to geographic/climatic and other factors, as well as existing jurisdictional and industry infrastructures.
For this reason, the proposed Standard does not prescribe a documented seafood safety management system for the lower risk products as for the high risk products. Nevertheless, the Standard will require a seafood business to systematically examine all its primary production operations to identify potential seafood safety hazards and implement controls that are commensurate with the food safety risk The extent of hazard identification, implementation of control measures and verification required should also be commensurate with the level of food safety risk involved. This is most appropriately determined by State and Territory jurisdictions in consultation with industry, taking account of local environmental factors. Where possible, State and Territory jurisdictions should use national forums such as the Implementation Subcommittee (ISC) if the Food Regulation Standing Committee to develop nationally consistent approaches to verification.
The philosophy behind this approach is about taking a preventive approach to managing food safety hazards and for industry, at all parts of the food supply chain, to play their role in minimising such hazards.
Option 3 proposes an approach based on risk – where risk is lower, the requirements are basic and where risks are higher, more significant requirements are proposed to manage food safety. The Australia and New Zealand Food Regulation Ministerial Council (Ministerial Council) made a decision in December 2003 – that food safety management approaches be based on risk and that food safety programs only be introduced where the benefits outweighed the costs of their implementation. Ministers also decided, based on the outcomes of the National Risk Validation Project, to require the introduction of food safety programs for oysters and other bivalves, up to the back door of the retail sector. The proposed Standard will implement the decision of Ministers.
Specific recommendations are made in this Draft Assessment about implementation (effectively over a two year period) and a draft of the proposed Standard is included at Attachment 1.
The Standard will be supported by an interpretive guideline for enforcement officers, developed by FSANZ, and industry developed guides to assist industry comply with the Standard. The framework for Option 3 is outlined below.
Proposed Regulatory framework for food safety management in seafood

Consideration has also been given to fish names labelling requirements. While a comprehensive regulatory analysis has not been undertaken to support a case for mandating prescribed labelling of all fish species in all circumstances across the catching/production, processing, wholesale and retail sectors of industry, consultations have been undertaken with Standards Australia on the development of a national fish names standard for fish names.


To assist industry, FSANZ has facilitated discussions and agreements with various Australian government and industry agencies, to help develop an Australian Standard for fish names that could serve as a reference document for action under trade practices laws. Following implementation of these arrangements, further consideration will be given (through FSANZ’s standards development processes) to whether any further coverage in the Code is required.


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