Dar seafood ppp standard

6.5 Summary of options

The three options proposed above may be summarised as follows:

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

The proposed options are considered further in the next section of the report where an impact (benefits versus cost) analysis of the various options is undertaken.

7. Impact analysis for seafood

FSANZ must consider the impact of various regulatory (and non-regulatory) options on all sectors of the community when it considers measures to mitigate public health and safety risks, including the seafood sector, governments, and consumers. The benefits and costs associated with any proposed amendment to the Code must be analysed using regulatory impact principles with the view to choosing the alternative with the maximum positive impact, whist minimising the regulatory burden on industry.

7.1 Affected Parties

The main stakeholders in the introduction of a new Standard are:

• 
  Consumers – Australian consumers of seafood and the community.
  
  
  
• 
  Seafood industry – businesses involved in the primary production, processing, distribution and wholesaling of seafood products and those involved in the importation of seafood for the Australian market.
  
  
  
• 
  Government – Government agencies (National, State and Territory, and Local) responsible for the enforcement of food safety regulations and for providing health care.
  

7.2 Option 1: the status quo

7.2.1 Benefits of Option 1

7.2.1.1 Consumers and the community

Australian households spend about 2.5 per cent of their food budgets on seafood products, which is about the same level as for poultry¹⁹. A study of consumer attitudes in Sydney and Perth found that the perceptions that fish is healthier than meat and that it adds variety to the diet were major factors influencing consumption. However uncertainty about safety and contamination, a lack of knowledge about seafood and high prices were major barriers to increased consumption²⁰. Public health professionals also advocate seafood in the diet as a means to address obesity and as a good source of omega-3 fatty acids²¹.

The consumption of seafood is valued by consumers and can confer considerable nutritional benefits. For example, fish is an excellent source of protein, is low in saturated fat, is a good source of some vitamins and is an excellent source of iodine.

7.2.1.2 Seafood industry

Apart from the current obligation in Food Acts to produce safe food, the regulatory regime of most State and Territory governments, with some exceptions, places few specific food safety requirements on seafood businesses in the primary production sector. Only NSW and Victoria, the smaller seafood production States, have put in place mandatory safety and hygiene regulations over the entire seafood supply chain.

In the other jurisdictions, hygiene and safety outcomes are mainly influenced by industry guidelines and codes of practice and by the regulation of export establishments (where these establishments also supply the domestic market) based on HACCP programs²².
Industry bodies report that a significant majority of Australian seafood businesses do follow industry guidelines and codes of practice and incorporate good hygiene practices into their normal business operations²³. The consequence of applying self-regulation is of commercial benefit to these businesses because good food safety practices enhance their capacity to meet market needs and achieve higher returns from their products²⁴.
Seafood businesses that meet food safety needs through a formal food safety program report additional benefits including: reduced wastage, lower maintenance costs, production savings, enhanced understanding of their own business and improved management practices²⁵.

7.2.1.3 Government

The current regulatory regime places few specific safety requirements for the hygienic production and processing of the seafood in most jurisdictions. Hence there is little pressure on Government enforcement resources.

7.2.2 Costs of Option 1

7.2.2.1 Consumers and the community

Current regulatory arrangements mean that some businesses are not required to undertake specific action to effectively manage food safety. The current Food Acts have a general obligation for primary producers to produce safe food – but does not give industry any guidance on these obligations. Where there is unmanaged risk, this gives rise to food-borne illness and imposes costs on consumers. Costs include personal distress, medical treatment, and time off work (patients and carers), with possible implications for forgone household income.

Australians consume over 1.1 billion seafood meals annually²⁶²⁷. Demand for seafood continues to grow, reflecting its role in a balanced, nutritious diet. As with all food commodities, seafood is responsible for some of the burden of food-borne illness in the community. FSANZ has estimated the annual burden of food-borne illness that might be attributed to seafood in Australia, drawing on two studies published by the Food and Agriculture Organization (FAO)²⁸²⁹ which reported that:

1. 
   seafood accounted for between 4.4 and 16.1 per cent of food-borne illness outbreaks in Western countries, in cases where the food vehicle for the outbreaks was known; and
   

2. 
   seafood was involved in 10-25 per cent of food-borne disease outbreaks in developed countries.
   

Based on this information, FSANZ estimates that 10 per cent of all food-borne illness in Australia might be attributable to seafood (approximately 500,000 cases annually). Clearly, only a very small percentage of seafood meals cause food-borne illness.

The direct cost of food-borne illness to the Australian community was estimated by the Allen Consulting Group to be $350 per case³⁰. Hence, taking account of the 5.4 million cases of food-borne illness annually, discounting an estimated 20 per cent of cases for in-the-home contamination, provides an estimate of $150 million per year as the cost of food-borne illness to the Australian community associated with the consumption of seafood.
Raw-ready-to-eat seafood (oysters and other bivalve molluscs) was ranked in the top five high-risk food industry sectors in Australia by the National Risk Validation Project³¹, on the basis of this sector’s history of food-borne illness. The NRVP estimated the average cost of illness from eating raw-ready-to-eat seafood at $4.87 per meal, far higher (by a factor of 10) than the cost of any other high-risk food sector considered in the report³².
Improvements in the risk management of bivalve molluscs since the NRVP collected this data imply that, currently, the costs to consumers should be lower than this estimate³³.
Consumers typically respond to outbreaks of food-borne illness in seafood by reducing their demand for seafood products. For example, following contamination of NSW oysters in 1997, NSW consumers immediately reduced their demand for oysters by 85 per cent. They also immediately reduced their demand for all seafood products by 30 per cent, indicating that consumers readily generalise a specific seafood risk to the broad category of seafood products³⁴.
However, despite consumers’ immediate reactions to outbreaks of food-borne illness, demand for seafood recovers over time. Notwithstanding 24 outbreaks associated with raw-ready-to-eat seafood³⁵ during the 1990s, consumer demand for seafood has increased steadily over the medium term³⁶. The implication is that while consumers immediately perceive costs when outbreaks of food-borne illness occur, these short-term costs are not sufficient to outweigh the perceived benefits of seafood to consumers over the medium-term.

7.2.2.2 Seafood industry

Each outbreak of food-borne illness imposes an immediate cost on industry, by reducing sales revenues for the implicated product and with follow-on effects to the seafood industry more generally³⁷. A succession of outbreaks will repeatedly reduce industry sales revenues in the short term. In addition, small remote communities that derive a very substantial part of their income from fishing would be particularly vulnerable to outbreaks of food-borne illness. An adverse incident would have very serious implications for the economic base for these communities³⁸.

Apart from the bivalve mollusc sector, under current regulations, only seafood businesses in the primary production sector in NSW and Victoria incur compliance costs for food safety. These costs are very small.

Under current arrangements, the bivalve mollusc sector must pay the majority of the cost incurred by their SSCA who implement and examine requirements set out by the ASQAP in their jurisdiction.

7.7.7.3 Government

The current regulatory regime places few specified safety requirements on the primary production end of seafood supply chain in most jurisdictions. Hence there is little pressure on the resources of enforcement agencies. Only NSW and Victoria currently apply hygiene and safety regulation on the seafood industry from the production end of the chain; and only one seafood sector is regulated (through licensing arrangements and not under health legislation) by all jurisdictions: the sector producing oysters and other bivalve molluscs.

The public health system e.g. hospitals, provision of pharmaceuticals, etc contributes to the care of people with food-borne illness and hence any food-borne illness associated with seafood imposes cost on government.