Dar seafood ppp standard

5. Objective

The objective of the measures proposed in this draft assessment is to effectively address the public health and safety risks associated with seafood through the development of a single, nationally consistent, set of risk management measures that address food safety issues across the food chain, are preventive, outcomes-based and cost-effective.

6. Regulatory options

6.1 Scope of the Standard and Definition of Seafood

Any mandatory regulatory approach for managing public health risks associated with seafood will be defined by the scope of the Standard and the definition of seafood. After consideration of issues raised by responses to the Initial Assessment Report and advice from the SDC and the Ministerial Council, it was determined that:

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  The scope of the Standard should cover all aspects of primary production and processing, from harvest/capture (whether wild-catch or aquaculture) up to the point at which Chapters 1, 2 and 3 of the Code currently apply.
  
  
  
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  The Standard should not cover indigenous/traditional fishers or recreational fishers, as the Standard applies only if the seafood is intended for sale.
  
  
  
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  The Standard should be outcome-based, developed by utilising a risk-based approach, with the level of regulatory intervention to be commensurate with the level of public health risk.
  
  
  
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  The Standard should apply to both imported and domestically produced seafood, and should avoid duplication of existing food safety Standards, such as Standards 3.2.2 and 3.2.3.
  

Options 2 and 3 are considered to be feasible and address the objectives of this proposal. Option 1 is included in the Impact Analysis for comparative purposes.

Option 1: The status quo - continuing the current regulatory arrangements.

Option 2: A Primary Production and Processing Standard targeting high-risk seafood activities only.

Option 3: A risk-based Primary Production and Processing Standard to improve the overall safety of the seafood supply chain.

6.2 Option 1 – The status quo

The status quo option involves continuation of current State and Territory regulatory arrangements, including the obligation to produce safe food under the Food Acts, and application of the current provisions of the Code as administered and enforced by the States and Territories. This includes provisions applicable to seafood in Chapters 1, 2, and 3 of the Code. States and Territories and AQIS would continue to test for compliance against the Code and undertake other enforcement measures.

State-based standards for the primary production of seafood have been implemented in NSW and Victoria’s scheme will commence for wild catch and aquaculture in 2004. It is likely that other States will develop their own standards if there is no nationally consistent standard. These schemes would continue to be enforced by States and Territories. The regulation of bivalve molluscs through aquaculture licensing arrangements would continue on a State-by-State basis.
The status quo would include the voluntary uptake of the Seafood Services Australia industry standard for seafood safety and the ongoing utilisation/implementation of various industry guidelines and codes of practice addressing seafood safety and quality (industry self-regulation).

6.3 Option 2 – A Primary Production and Processing Standard targeting high-risk seafood activities only

A Primary Production and Processing Standard addressing only high-risk seafood activities will require identified high-risk seafood sectors (bivalve molluscs) to implement written food safety management systems such as Standard 3.2.1. It will not contain general provisions for the primary production and processing sector.

In the case of seafood businesses producing bivalve molluscs, it will be mandatory to comply with pre-harvest provisions identified in the Australian Shellfish Quality Assurance Program to ensure that bivalve molluscs are harvested under conditions that assure their safety. In addition, these businesses will be required to implement food safety programs for the post-harvest sector up to the back door of the retail sector.

6.4 Option 3 – A risk-based Primary Production and Processing Standard to improve the overall safety in the seafood supply chain

A new Primary Production and Processing Standard to address food safety risks in two ways:

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  basic hygiene requirements for all primary production of seafood; and
  
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  a requirement for specific provisions for higher risk primary production of seafood.
  
  
  

This Standard would provide a single, nationally consistent and risk based approach to facilitate the safe production of seafood. Having a consistent approach to the management of food safety during seafood primary production will positively impact on safety across the seafood supply chain.
The Standard (Documented as Chapter 4 in the Code) would be divided into two main components as follows:

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  General provisions which set out basic food safety requirements for the hygienic primary production and processing of seafood, and
  
  
  
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  Specific provisions for higher risk primary production seafood sectors, requiring the implementation of food safety management systems.
  
  
  

Figure 1 outlines the relationship between general provisions, specific provisions for higher risk sectors, and guideline documents that will assist regulators to interpret the Standard and industry to comply with the Standard.

Figure 1: Regulatory framework for food safety management in seafood

The general provisions are designed to minimise food safety hazards, and cover seafood primary production and processing activities that are not currently regulated under the Code. Such provisions are similar to the provisions in Chapter 3 of the Code (Standards 3.2.2 and 3.2.3), but tailored to the needs and situation of the seafood primary production sector. These provisions would include requirements to ensure that food was not contaminated during its production or handling, that adequate temperature control of the food is maintained, and that staff have the necessary skills and knowledge about food safety for the work they undertake. This option is intended to include simple on-vessel processing such as the gutting and filleting of finfish.
The specific provisions address identified higher risk seafood sectors, and require those seafood businesses to implement written food safety management systems such as Standard 3.2.1. In the case of seafood businesses producing bivalve molluscs, it will be mandatory to comply with pre-harvest provisions identified in the Australian Shellfish Quality Assurance Program. This will ensure that bivalve molluscs are only harvested under conditions that assure their safety. Additionally, these businesses will be required to implement food safety programs for the post-harvest sector up to the back door of the retail sector. This is consistent with the Ministerial decision of December 2003 on food safety management in Australia to only have requirements for food safety programs for sectors that have been identified as higher risk and where it has been demonstrated that the benefits will outweigh the costs. In this regard, Ministers agreed to specifically recommend the introduction of food safety programs for oysters and other bivalves following a benefit-cost analysis undertaken as part of the National Risk Validation Project.
Regulators will be assisted with enforcement by the development of an interpretive guide prepared by FSANZ, and industry will be assisted by tools such as guidelines and templates to comply with the Standard. States will replace any existing Standards with the new Primary Production and Processing Standard for Seafood (in the Code) and thus achieve a single, national, approach to food safety along the seafood supply chain.