Dar seafood ppp standard
Attachment 4A Consultation on Initial Assessment Report
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Attachment 4AConsultation on Initial Assessment ReportFSANZ has a statutory obligation to consult with stakeholders in relation to food regulatory measures. This is undertaken through two rounds of public consultation: one following release of the Initial Assessment Report, and the other following the release of the Draft Assessment Report, as described on Pages (ii) and (iii). In addition to statutory consultation, further consultative mechanisms have been built into the development process for the Primary Production and Processing Standard for Seafood. This reflects recognition of the need for close consultation with industry, regulators and consumers throughout the development of the Standard. This is considered particularly important as the setting of primary production and processing standards is a new function of FSANZ. Accordingly, in the early stages of standard development, the level of awareness of FSANZ processes in the community and within the primary production sector may be minimal. In recognition of the need for broad and active consultation throughout the development of the seafood standard, FSANZ is committed to seeking stakeholder involvement via the following mechanisms:
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:
- 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;
- costs and benefits of management options; - compliance and enforcement costs, mechanisms and concerns; and - the need for, and development of, guidelines.
In line with the Ministerial Council Guidelines, other policy advice and FSANZ’s statutory objectives, the draft Seafood Standard (Attachment 1) put forward for comment in this Draft Assessment Report is an outcomes-based, non-prescriptive standard focussed on food safety. It covers the entire seafood industry to the extent determined by the level of public health risk posed by each industry sector and by the need to avoid duplication of, or inconsistency with, existing standards in the Code. Inclusion of chemical and biological hazards within the Standard Submissions highlighted a number of food safety hazards that were perceived as not being adequately addressed in the Code. These included allergens and physical hazards (e.g. fish bones), escolar wax esters, ciguatoxin and some microbial pathogens. It was also suggested that maximum residue levels (MRLs) for pesticides and veterinary chemicals in seafood needed to be reassessed. A range of strategies to address these various hazards were suggested, including relying on interpretive or advisory guidelines to the standard, referencing relevant sections of other Chapters of the Code, and including specific provisions in the Seafood Standard. Industry generally preferred that the current provisions in Chapters 1 and 2 of the Code should be relied upon and simply referred to in the Seafood Standard. The scientific evaluation and ranking of the public health risks posed by hazards in seafood in Australia (Attachment 10), conducted by FSANZ to underpin the development of suitable risk management strategies in the seafood sector, did not highlight any hazards that should be addressed by amendment to Chapters 1 and 2 of the Code. The draft Seafood Standard does not contain requirements concerning maximum levels of physical, chemical or microbiological hazards in seafood. Certain hazards mentioned in submissions cannot routinely be assayed e.g. ciguatoxin, escolar wax esters. Maximum Residue Levels for pesticides and veterinary chemicals are (re)assessed on a routine basis by FSANZ, in conjunction with the Australian Pesticides and Veterinary Medicines Authority (APVMA), taking into consideration total dietary exposure from all food sources. Coverage of the production and processing supply chain Comments received on the coverage of the production and processing supply chain showed a broad range of opinion. Several submissions mentioned that the entire chain should be covered from harvest to retail, inclusive. However, others felt that it should only apply up to, but not including, the point of retail sale, or up to the point at which the Code currently applies. The question of whether the pre-harvest sector of aquaculture should be regulated also engendered varying opinions, with some believing that production inputs into aquaculture need to be covered by the standard. The Seafood Standards Development Committee (SDC) advised that the seafood PPP Standard should cover all aspects of primary production and processing of seafood, from harvest/ capture (whether wildcatch or aquaculture) through to retail sale, to the extent determined by the level of public health risk posed by each industry sector. The draft Standard covers the pre-harvest sector to the extent that it requires seafood businesses to adopt an ‘inputs’ approach, using only inputs that do not contaminate seafood or adversely affect its safety and suitability. Ready-to-eat seafood The question of whether ready-to-eat seafood should remain covered under existing sections of the Code or be included in the Seafood Standard received comments supporting both views. It is proposed that the primary production and processing of ready to eat seafood is covered in the draft seafood PPP Standard, to the extent determined by the level of public health risk posed by such products. Provisions elsewhere in the Code applying generally or specifically to such products will continue to apply. Processing on board fishing vessels The extent to which the standard should regulate seafood harvesting, handling and processing on board fishing vessels was the subject of many comments from submitters. Recommendations ranged from the view that no standard should apply, as the risks were low, to suggestions that food safety plans should be required. Mandating Good Hygienic Practice, addressing the risks through a voluntary code of practice and implementing a receival standard at the dock were also put forward as options. Several submissions advised that enforcing a standard on board vessels at sea would be difficult. The need for awareness programs or accredited food safety training was also raised. The Seafood SDC advised that Good Hygienic Practices can and should be required of fishing vessels, including those only involved in harvesting and minor processing (such as gutting and gilling). The SDC recommended that the draft Standard require that fishing vessels must be constructed, maintained and used in ways that minimise the risks to the safety of seafood. The definition of seafood Most submissions agreed that the term ‘seafood’ should be defined so as to cover aquatic vertebrates and invertebrates including finfish, molluscs and crustaceans but excluding aquatic plants, reptiles and mammals. Three submissions suggested inclusion of aquatic plants within the definition, and one suggested inclusion also of aquatic reptiles and mammals, along with a suitable definition of the point at which they are considered to become seafood and thus subject to the provisions of the standard. Most submissions were in agreement that seafood taken for traditional purposes should also be excluded. The Seafood SDC agreed that ‘seafood’ should be defined as ‘all aquatic vertebrates and aquatic invertebrates, excluding amphibians, mammals and reptiles’. This definition excludes crocodile meat, seaweed and other aquatic plants, but includes ready-to-eat seafood. The SDC also recommended that the standard should not cover indigenous or traditional fishers, unless such seafood is offered for sale. The scientific risk assessment process The scientific risk assessment process, which underpins the FSANZ regulatory approach, received broad support. However, comments were received on the need to consider risk assessment work undertaken by others and to apply risk analysis in context. One submission suggested that the process seemed to be more appropriate to the establishment of food product standards. Some individuals identified that they were willing to provide data necessary for the risk assessment process, noting that significant data gaps existed. In one case, data could not be provided unless confidentiality could be assured. In order to estimate and compare the relative risks associated with consumption of seafood in Australia, FSANZ prepared a risk ranking report (Attachment 10). It takes into consideration the multiple hazards potentially present, and assigns each commodity or group of commodities to a broad risk category: low, medium or high. Through this process, sectors of the seafood industry posing a higher public health risk were identified. In compiling the risk ranking report, a wide range of literature and information from Australia and overseas was reviewed and evaluated. The report also drew on recent risk assessments that have been undertaken on Australian seafood. Suitability of existing standards Submissions generally suggested that existing voluntary regulations, codes of practice and guidelines should be recognised, in some form, under the Standard. The suitability of using the industry-developed Australian Seafood Standard as a basis for development of the Primary Production and Processing Standard for Seafood was discussed, with views ranging across the spectrum. In general, most submissions suggested it would need modification or could be used, in part or in total, as a guideline to the Standard. Submissions also expressed the view that other regulations and standards, Australian and international, should be taken into account in developing the Seafood Standard, and parts used, as appropriate, in the standard or in the guidelines. The NSW Seafood Safety Scheme, the AQIS Export Control (Processed Food) Orders and the Codex Code of Practice for Fish and Fishery Products were mentioned as examples of existing measures that might be drawn upon. FSANZ considered all appropriate existing seafood standards, regulations and codes of practice when developing the draft Seafood PPP Standard. Many of the principles upon which the industry-developed Australian Seafood Standard is based, also underpin the draft Standard. Options available to manage food safety risks Submissions canvassed options for appropriate food safety management systems. Implementation of HACCP-based systems and food safety plans for areas where the public health risk was judged to be highest received broad support, although questions regarding industry and government support and resourcing were raised. Industry were concerned about the criteria to be used for determining the extent to which HACCP-based food safety programs would be required of businesses. Voluntary codes of practice and non-regulatory guidelines were mentioned as being suitable where risks were low. The proposed strategy for management of public health risks in the draft Seafood PPP Standard is based on a requirement for Good Hygienic Practice for all seafood businesses, supported by guidelines and industry codes of practice, and the implementation of HACCP-based systems (food safety plans) for areas where the public health risk is judged to be highest. Compliance and enforcement issues Industry bodies and representatives expressed concern regarding the impact of any standard on the industry and on practices within seafood businesses. In particular, industry expressed a desire to avoid unnecessary imposts and the potential for excessive cost-recovery revenue-raising by regulators at the expense of industry. Industry and government submissions expressed the view that compliance and implementation costs associated with HACCP-based food safety plans were significant and had been under-estimated by FSANZ in the past. Information was provided detailing the costs of complying with current (HACCP-based) export certification schemes. Industry also emphasised the need to avoid duplication of auditing and compliance activities (and hence costs) where a business supplied both domestic and export markets. Several submissions stated that businesses complying with export requirements should be deemed to comply with the domestic standard. Submissions also raised questions about the role, extent and system of audits that may be required under the standard. A period of two to three years was generally nominated by industry as a preferred time frame for implementation of the Standard and for stock-in-trade provisions to apply. The need for government support to provide education and training was also raised. Comment from government bodies covered issues including which level of government, and/or which government department, would have responsibility for regulation, implementation and enforcement of the standard. Audits were also discussed, incentive-based compliance schemes were generally supported, as was harmonisation with existing audit systems, such as those required by AQIS. Government bodies expressed a desire to avoid any duplication of current legislation, and to achieve genuine consistency on a national basis under the standard. Once adopted into State and Territory legislation, enforcement of the Standard will become the responsibility of those jurisdictions. Policies regarding cost-recovery revenue-raising by regulators are set at that level of government in Australia. FSANZ understands that a nationally agreed date for commencement of the Primary Production and Processing Standard will help to ensure national consistency, and will focus industry and regulators on the task at hand. It is envisaged that a number of tools and resources will be developed to assist both industry and regulators in the implementation of the standard. A prime tool will be an interpretive guide to the Standard. This document will be developed by FSANZ in consultation with stakeholders. In addition, existing codes of practice developed and adopted by jurisdictions and industry, will provide further practical information. Existing codes of practice may be readily adapted to this purpose. Responses to Jurisdictional Meetings In the period since commencing the development of a primary production and processing standard for seafood, consultation meetings have been held in the following jurisdictions: Tasmania, Victoria, Queensland, Western Australian, South Australia, New South Wales and the Northern Territory. Innovative strategies have included the use of video conferencing to engage distant communities in Western Australia (i.e. Broome, Karratha, Carnarvon, Albany, Geraldton, and Esperance). Participants at each consultation were invited to provide their views orally, as well as through written submissions. Industry participants at the workshops focussed on the impact of any regulatory measures on their businesses, while regulators were interested in jurisdictional issues and the responsibilities. These consultations were held during the period leading up to and following the release of the Initial Assessment Report and prior to the release of the Draft Assessment Report. In the lead-up to the release of the Draft Assessment Report, consultations have continued and have elicited valuable industry data and considerable feedback on support for the regulatory options being proposed. Identification of Potential Non-Scientific Risks The development and implementation of good regulation can be influenced by a range of factors outside the potential hazards to the food supply that are evaluated in the scientific risk assessment. This broader set of risks typically includes factors such as community perceptions, political implications, regional implications and industry issues. In developing options for the regulation of the primary production and processing of seafood, FSANZ discussed this issue with State and Territory regulators, a consumer representative, and various members of the seafood industry. Such consultation assisted FSANZ to identify a range of non-scientific risks that, potentially, could affect the development and implementation of regulation for the seafood industry. Consumer perceptions of seafood are ambivalent and pose a potential risk to the acceptance by consumers of any improvements to safety that new regulation may offer. A study of consumer attitudes revealed that, while consumers believe that seafood has some nutritional benefits, they lack sound knowledge about seafood products and are uncertain about the safety and possible contamination of seafood63. Furthermore, the study revealed that the correct labelling of fish was very important for 70% of consumers surveyed in Perth, and 73% of those surveyed in Sydney. Communication with consumers during the process of developing new regulation will continue to be important to foster greater consumer confidence. Industry is concerned that implementation of any new regulation may bring with it large compliance costs, either through excessive regulation that is disproportionate to manage the hazards or through excessive government charges. Such concern, if not addressed, could result in a low level of compliance with new regulation and a lower level of benefit to the Australian community. This concern can be addressed through a transparent process that demonstrates to all parties how the proposed regulatory measures relate to the scientific risk and provides benchmarks for industry to gauge the likely level of government charges. The seafood industry contains a high proportion of small businesses, dispersed along rural and some remote coastlines, which potentially can make the implementation of any new regulation very difficult. Many regional communities are highly dependent on the continuing viability of their local seafood industry and may be resistant to change. These factors can be taken into account in the process of developing a new regulation, through a transparent process that demonstrates minimum effective regulation, and also the benefits to industry of consistently maintaining good hygiene and safety practices. The staged approach to implementing food safety regulations in the NSW seafood industry indicates that regional dispersion of the industry need not be a barrier to the successful introduction of new regulations. A further risk involves the potential for uneven implementation of a new regulation by the States and Territories. While each jurisdiction has responsibility to determine its priorities for enforcement, and the level of resourcing for its enforcement and auditing activities, there is nonetheless the issue that similar seafood activities anywhere in Australia should be subject to similar regulatory requirements. The consequence of uneven implementation would be to reduce the credibility of the new regulation amongst industry, which would then be sceptical of its claims to be ‘nationally consistent’ and may doubt its other benefits. This risk can be addressed by clarity in the description of the new regulation, the provision of a comprehensive Interpretive Guide, and coordination between the jurisdictions in their implementation and enforcement of the Standard. Yüklə 2,7 Mb. Dostları ilə paylaş:
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