Dar seafood ppp standard

Public Consultation
Written Submissions in Response to the Initial Assessment Report
A total of twenty-five written submissions were received by FSANZ in response to the Initial Assessment Report of Proposal P265. Submissions originated from a range of organisations and individuals representing industry sectors across the supply chain and all levels of government. A summary of the individual submissions is presented at Attachment 5.

A compilation of the responses to the specific issues raised for comment in the Initial Assessment Report is presented at Attachment 6. These issues mainly concerned:

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  scope of the Standard, including:
  
  
  

- the inclusion of chemical and biological hazards within the standard and the Code as a whole;

- at what point within the seafood industry the Standard should commence and cease to apply;

- the position of ready-to-eat seafood under the Standard; and

- the position of harvesting, handling and processing seafood on board fishing vessels under the standard;

• 
  definition of seafood, including whether aquatic plants, reptiles and mammals should be regulated under the Standard;
  

• 
  scientific risk assessment process which underpins FSANZ’s development of regulatory measures, and the provision of technical data for this purpose;
  

• 
  suitability of existing standards, such as the industry-preferred voluntary standard (the Australian Seafood Standard), any State government standards and any international standards, to form the basis for the national mandatory standard; and
  

• 
  options available to manage food safety risks, including:
  
  
  

- costs and benefits of management options;

- compliance and enforcement costs, mechanisms and concerns; and

- the need for, and development of, guidelines.
The range of opinion on each of these issues is presented below, along with a short explanation of the approach taken in this Draft Assessment.