Dar seafood ppp standard

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

7.3.1 Benefits of Option 2

7.3.1.1 Consumers and the community

Consumers and the community will benefit from the greater assurance of the safety of the high risk seafood products: oysters and other bivalve molluscs. Outbreaks of food-borne illness have arisen from these high risk products in the past and imposed costs on consumers in the form of personal distress, incidents of death, costs of medical treatment, and time off work (patients and carers) which also implies some forgone household income. Under Option 2 the risk of future outbreaks will be minimised and hence the costs to consumers will be substantially reduced.

The benefits to the community of introducing food safety programs into the high risk bivalve mollusc industry were calculated by the National Risk Validation Project at $26.4 million per year³⁹. These benefits mainly accrue from a nationally consistent approach to managing bivalve safety, through a system that doesn’t permit opt-out by any State or Territory, and which enables food safety portfolios in all jurisdictions to audit the system.

7.3.1.2 Seafood industry

Improvement to the management of the safety for high risk seafood products will benefit industry because the recurring reductions in consumer demand and product sales that have resulted from incidences of food-borne illness, such as those that occurred as a result of the Wallis Lake outbreak, would be minimised under this option.

The consequence will be fewer incidents of food-borne illness and fewer highly visible outbreaks that have been a feature of the past and may still occur under the status quo.
The National Risk Validation Project showed that reductions in demand occur not only for the high risk product that caused the food-borne illness, but flow through to all seafood products. Ensuring that the safety of high risk products is appropriately managed on the basis of risk from boat to plate will improve safety overall and protect the sales revenues of the seafood industry. This is likely to have a positive impact on both the local and international markets.
Nationally consistent, mandatory requirements that ensure compliance with ASQAP and with food safety programs will contribute to a consistent record of safety for bivalves, thereby reducing the chance of something going wrong in one State and putting the entire sector at risk.

7.3.1.3 Government

The government sector may benefit from the material improvement in the safety of seafood products and fewer incidents of food-borne illness through lower utilisation of public health services. While this is a true benefit to government it may not translate into lower public expenditure. For example, public hospitals have an obligation to provide health care for the whole community and for a broad range of ailments and medical emergencies, and will respond to lower utilisation of their services from food-borne illness by providing quicker services to patients with other ailments. In practical terms the benefits to government could be negligible⁴⁰.

7.3.2 Costs of Option 2

7.3.2.1 Consumers and the community

This option will not impose costs on consumers or the community, over and above the costs incurred under the status quo.

7.3.2.2 Seafood industry

The impact of Option 2 limited to the high risk industry sector producing oysters and other bivalve molluscs. Businesses in this industry sector already comply with State based versions of ASQAP and, in some States, are required to have post harvest food safety programs. These requirements are administered by the States and Territories as a condition of obtaining an aquaculture licence. The additional costs on oyster growers and other primary producers in this sector as a result of this option will impact on those not already required to have food safety programs post harvest.

The effectiveness of ASQAP requirements in addressing the health and safety risks in the pre-harvest shellfish sector (including biotoxin testing) is recognised by all jurisdictions, although only recently by NSW. The cost of mandating compliance in the Code with specific pre-harvest requirements (stated in ASQAP) and food safety programs for the post-harvest activities is expected to be small, as compliance is mostly in place.
There will also be some additional compliance costs incurred further along the supply chain, for example by distributors and wholesalers, in meeting the requirements of a food safety program for these products.

7.3.2.3 Government

This option will not significantly expand the responsibilities of government enforcement agencies for the shellfish sector, as these arrangements already exist (e.g. ASQAP), and hence the impact on their resource requirements should be small.

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

7.4.1 Benefits of Option 3

7.4.1.1 Consumers and the community

Consumers benefit from the greater assurance of safety of the high risk seafood products of oysters and bivalve molluscs, as with the previous option.

In addition, Option 3 addresses safety risks comprehensively across the seafood industry so that consumers also benefit from greater assurance of the safety of all the lower risk products. This option will achieve a through-chain consideration of food safety, and eliminate gaps and inconsistencies in State and Territory approaches to the current management of seafood safety. It will improve on the status quo where there are inconsistencies in safety practices, particularly at the primary production and processing end of the seafood industry, and at the interfaces between the primary production and the processing sectors.
While the seafood industry has benefited from industry codes of practice and guidelines, these codes and guidelines are voluntary and a proportion of seafood businesses are not compliant with them⁴¹. The proposed Standard would make a clear statement, obliging all seafood businesses involved in primary production and processing to achieve an appropriate level of hygiene and safety. Basic food safety requirements across these sectors of the industry will improve the safety of seafood products for consumers by reducing food-borne illness.
The international literature shows that the burden of food-borne illness attributable to seafood is sourced from a broad range of products, the high risk and the lower risk products.⁴² The consequence of implementing a comprehensive set of management strategies under this option, including for the majority of seafood products that are lower risk, will be to significantly reduce the likelihood and severity of food-borne illness in the Australian population. The costs to consumers of food-borne illness – personal distress, medical treatment, and time off work (both patients and carers) which implies some foregone household income – will be reduced under this option and the greater assurance of the safety of all seafood products will benefit consumers.
Imported seafood products will be required to demonstrate an equivalent level of safety to domestically produced products. This measure will ensure that consumers can feel secure in the knowledge that all seafood, regardless of where it is sourced, meets the same level of food safety.
If the current cost of food-borne illness associated with seafood is estimated to be $150 million p.a. and the greater safety of the full range of seafood products under this option can reduce food-borne illness by between 20 and 50 per cent, then the benefit to the community would be in the range of $30 million to $75 million per year.

7.4.1.2 Seafood industry

Industry will benefit from the reduction of the periodic disruptions to sales that occurred in the past in association with highly visible outbreaks of food-borne illness, because under this option (as with the previous option) these outbreaks will be further minimised.

This option also supports the widespread adoption of good hygiene practices, by all seafood businesses in all sectors of the industry. The minority of seafood businesses that currently do not follow industry codes of practice, and whose hygiene can be improved, will be required to comply with the new Standard. Hence the level of food-borne illness associated with poor hygiene practices in the industry can be reduced. For consumers, this means fewer experiences of food-borne illness and a higher regard for the safety of seafood. Industry will benefit from the greater consumer satisfaction with the safety of seafood, which translates into a lift in demand for its products and higher sales.

7.4.1.3 Government

The government sector may benefit from the material improvement in the safety of seafood products under this option, compared with the status quo, because the lower incidence of food-borne illness should result in lower utilisation of public health services. While this is a true benefit to government, it may not translate into lower public expenditure. For example, public hospitals have an obligation to provide health care for the whole community and for a broad range of ailments and medical emergencies, and will respond to lower utilisation of their services from food-borne illness by providing quicker/enhanced services to patients with other ailments. In practical terms the benefits to government could be small⁴³. However, government will benefit in terms of greater consumer confidence in the ability to ensure a safe food supply.

Mandating specific requirements for bivalve molluscs in the Code will provide government with a more appropriate legislative basis for regulation i.e. the approach is centred on food safety rather than existing aquaculture legislation that focuses on licensing rather than food safety. It will ensure a single, national approach to the safe production these higher risk products.

7.4.2 Costs of Option 3

7.4.2.1 Consumers and the community

This option will not impose costs on consumers or the community, over and above the costs incurred under the status quo.

It is considered that the additional compliance costs incurred by seafood businesses under this option are unlikely to be passed on to consumers. However, if it did occur, any increase would be minimal, as the wholesale price of seafood is frequently set by auction. Furthermore, industry bodies have advised that the majority of seafood businesses already undertake basic safety practices.
Therefore, for these businesses, the proposed provisions would not adversely affect their operating costs and there would be no costs passed on to the consumers.

7.4.2.2 Seafood industry

The impact on producers of oysters and other bivalve molluscs under this option will be the same as under the previous option, essentially imposing some additional compliance costs where post harvest food safety programs are not yet in place.

In addition, the general provisions of this option mandate basic food safety obligations on all seafood businesses. The mandatory nature of the basic food safety obligations will be new for businesses in the primary production sector. Fulfilling the basic food safety provisions required by the general provisions under this option is anticipated to have little impact on those seafood businesses which either supply the domestic market to the standards required under export controls, or fully comply with the voluntary industry standards and codes of practice. Advice from industry bodies such as Seafood Services Australia and the Sydney Fish Market indicates that the majority of seafood businesses already undertake basic safety practices as set out in industry codes of practice and guidelines to at least the level required under this option. For these businesses, the proposed general provisions will not affect their operating costs.
FSANZ undertook a number of interviews with fisheries, enforcement agencies, inspection auditors and commercial fishers from around Australia’s coastline, to obtain detailed information about the effect of mandating good hygiene practices on industry operating costs. The interviews revealed a consistent picture of hygiene practices across the seafood industry (although the examples differed). The principal themes are documented below.

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  Good hygiene practice is basic and easily achievable by the seafood industry. Examples include: appropriate temperature control of the catch, typically an ice slurry or refrigerated holding tank; ensuring water for holding tanks is sourced from clean sea water, and changed as required; keeping bait and chemicals separate from the catch; ensuring there is no contamination of the catch; keeping haulage areas clear of weeds; regular cleaning of desks and protective clothing; appropriate vessel maintenance to address cracks and crevices in surface areas or holding tanks, and to ensure there are no oil leaks over the deck; use of gilling and gutting boards (rather than the boat’s gunnels); regular cleaning of prawn cookers; and advice such as ‘don’t take your dog fishing’.
  
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  The practice of good hygiene does not require additional equipment. Good temperature control is widespread across the industry and hence the equipment such as iceboxes and refrigerated holding tanks are already widely used (where required). Good hygiene practice will require some fishers to purchase tools such as gilling and cutting boards. Where this is the case, it is estimated that these boards would cost between $100-$200 and have a life expectancy of five years.
  
  
  
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  Good hygiene practice is essentially a matter of the practical adaptation of hygiene and sanitation principles to fishers’ work practices.
  
  
  
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  Most fishers already incorporate hygiene into their work practices. They achieve hygiene outcomes through traditional methods and by following existing industry guidelines and codes of practice. While there are a large number of these guides and codes available, the industry Code of Practice developed in NSW for commercial fishers, could be considered indicative. This code is generally outcomes based and the little prescription that may bring a relatively small cost is the requirement to use a chemical sanitiser.
  
  
  
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  The principal reason that some fishers do not comply with good hygiene practice is lack of awareness. When given clear guidance on the requirements of hygiene standards, advice from auditors in the NSW Food Authority or the Southern Rocklobster Fishery is that the fishers easily and enthusiastically embrace industry best practice. Some fishers follow traditional methods, which achieve hygiene outcomes in most circumstances, but training (a one-day workshop⁴⁴) that explains why hygiene outcomes are achieved provides the fishers with the knowledge to achieve good hygiene in unusual circumstances too.
  
  
  
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  A mandated hygiene standard, even where outcomes-based and allowing for variation in approaches between fishers and fisheries, will be superior to a voluntary industry code of practice in achieving good hygiene outcomes.
  
  
  
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  Implementation of good hygiene practices is typically a matter of refining current work practices. This can be achieved easily. In NSW the Food Authority ran workshops in each of the fisheries, which cost the fishers $50 and one day’s participation at a workshop. The cost of foregone earnings to attend the workshops were minimised by scheduling a range of days when training was available and at times when boats were in port. The fishers left with the ability to develop a simple food safety plan for their operation (which is more than is required under the proposed general provisions of Option 3). Likewise the Southern Rocklobster Fishery provided training and support for its members in a comprehensive integrated program covering all aspects of fishing, at a cost of $275 per operator, and by the end of 2004 the fleet will be performing at a level that will satisfy third party auditors.
  
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  The industry acknowledged that good hygiene practice is essential for high quality seafood. However the industry gave a qualified response as to whether quality would attract a price premium – i.e. whether the commercial incentives in the market supported hygiene practices and quality seafood.

  For example, one fishery acknowledged that market recognition of quality would take time, but in due course a price premium would be possible with effective branding. Other sectors mentioned that poor quality product would be penalised with a price discount, or not accepted at all by the wholesale markets. Another fishery achieved premium prices for its quality product at times of strong demand, but not all the time. However its reputation for quality product meant that it was able to sell its products all year round, hence it could depend on income throughout the year and on this basis plan to undertake investments to maintain the quality of its products. Continuing market access was a significant benefit from its focus on quality.

  
  

This information indicates that the seafood industry can readily achieve good hygiene outcomes through refinements to their work practices, with minimal impact on their costs of operation. Higher quality of product that is associated with good hygiene is recognised in the market, although what this means for price and sales revenue will depend on the type of product and market conditions. Overall, attention to good hygiene, with the outcome of higher quality product, appears to be commercially viable for the seafood industry.

There may be costs to industry as a result of States’ recovery costs to implement the proposed Standard. These costs may be comparable to those experienced by NSW in the implementation of their State-based hygiene and safety regulations.
In NSW there is a $50 cost for a licence and annual fees have recently been introduced to cover enforcement costs. Annual fees for commercial fishers are $310 and for finfish and crustacea aquaculture fees vary from $250 (for businesses with less than 10 employees) up to $2,000 for businesses with more than 50 employees.
Victoria has enacted legislation for a through-chain regulation of all seafood businesses. The legislation came into force on 1 July 2004 for wildcatch and aquaculture businesses and requires businesses to obtain a licence and demonstrate they are meeting the basic requirements of the Victorian Food Act. The are required to prepare a food safety plan by the end of the first year. The regulator, Primesafe, requires annual fees to be paid by businesses, dependent on the level of annual throughput. Hence the fees are less costly for the smaller operators (e.g. $200 for lower annual catch) and more expensive for larger operators (up to $800 for high annual throughput). Audit costs will be additional to these costs, however there is no advice on the likely audit costs.
The examples above of the flow on costs to industry of States’ recovery costs to implement food safety schemes are indicative. It should be recognised that the costs to implement food safety schemes may vary across jurisdictions.

7.4.2.3 Government

The new Standard will expand the responsibilities of government enforcement agencies at the primary production end of the seafood chain. The agencies have indicated that they are not expecting an increase in resources to address their new responsibilities and will respond to the situation by prioritising their efforts where enforcement will be most effective⁴⁵.

A possible management option would differentiate between the lower risk businesses, that could be licensed but not systematically inspected, and the higher risk businesses that would be subject to rigorous enforcement⁴⁶.
Enforcement agencies will be assisted by the development of a guide developed by FSANZ, to aid in the interpretation of the Standard.
Some jurisdictions are likely to be faced with a major effort in implementing the new Standard. The experience of SafeFood Production NSW, bearing in mind that it is one of the smaller seafood producing jurisdictions, is that implementation can be accomplished within existing resources, where assistance to specific sectors of industry is staged over a period of years.
The staged implementation of the regulations in NSW - focusing initially on the wild catch sector and progressing to the smoked fish and aquaculture sectors - means that SafeFood Production NSW could apply the regulations within existing resources. The cost of running the training workshops for fishers was covered by industry ($50 per fisher) together with a subsidy from the Australian Department of Agriculture, Fisheries and Forestry. Extending hygiene and safety regulations to the seafood industry in NSW did not, in practice, impose new costs on the NSW Government but will vary across States. It did incur costs on the Commonwealth government, and would result in additional costs if the program were rolled-out to other jurisdictions.

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