Dar seafood ppp standard

EXECUTIVE SUMMARY

This Report proposes, for the first time, that there be a single, national food safety standard for the primary production and processing of seafood.

Australia enjoys a high level of food safety protection but, like many other nations, we face the challenge of improving food safety. It is recognised that the risks from seafood are usually well managed and are therefore considered low. There are only a very small number of products that may present higher public health and safety risks.
Food-borne illness is a growing public health problem globally because of the increasing global trade in food, changes in the way food is produced and consumers’ changing requirements. These changing patterns are causing new challenges in the way food safety is managed.
A recent study conducted by the food-borne illness surveillance network of Australia, OzFoodNet, estimates that there are 5.4 million cases of food-borne illness in Australia each year from a variety of foods. There is a need to ensure that there are appropriate strategies in place to effectively manage food safety across all food sectors in the current environment of global food trading and in light of the estimates of the incidence of food-borne illness.
A whole of government approach is now being taken in Australia to the management of food safety. Governments have agreed that food safety should be managed throughout the food supply chain. This approach aims to improve public health and safety and ensure that consumers continue to have the highest confidence in the safety of the food they consume.
FSANZ has been given responsibility for the development of food safety standards in the primary production and processing part of the food supply chain – in addition to its existing responsibilities for the manufacturing, retail and food service sectors. Under the FSANZ Act, the objectives for developing all food standards, in descending order of priority, are:

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  the protection of public health and safety;
  
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  the provision of adequate information relating to food to enable consumers to make informed choices; and
  
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  the prevention of misleading or deceptive conduct.
  

Seafood is one of the first industries to be examined in relation to a national approach to improving the primary production end of the food supply chain. The seafood industry itself has encouraged this early work.

Seafood is an important part of the diet for consumers in Australia and New Zealand. The sector is an important part of the Australian food industry - the fourth largest after beef, wheat and milk – with a considerable focus on exports.
This Final Assessment Report outlines how industry and government currently achieve seafood safety in Australia – generally with a mixture of industry self-regulation, licensing schemes, and general and specific (albeit differing) State legislation. While providing a measure of assurance, this mix of arrangements, both voluntary and mandatory, creates some gaps in the management of food safety.

FSANZ has consulted widely in the development of this proposed Standard. A Standards Development Committee, consisting of representatives from State and Territory jurisdictions and New Zealand, and industry and consumer representatives, has carefully considered the results of committee discussions, opinion at public fora and written feedback from stakeholders on both the Initial Assessment Report and the Draft Assessment Report for this Proposal.

FSANZ, with assistance from the Seafood Standards Development Committee, has examined how to improve further the management of public health and safety issues in the sector in Australia. A number of options have been considered and these are outlined in the table below:

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

States and Territories will be responsible for compliance with and enforcement of this Standard. Government costs may vary from State to State, but overall arrangements for industry will be more efficient by having a single national standard.

A regulatory impact analysis has been undertaken to consider which option provides the maximum public health protection, with least impost on industry. The estimated benefits of introducing Option 2 (before costs) is $26.4 million per year, while benefits of introducing Option 3 are estimated between $30 million to $75 million per year. The preferred option is Option 3.
Option 3 is preferred as it provides a single set of national standards to protect public health and safety (the primary objective of the FSANZ standard-setting process under section 10 of the FSANZ Act). It would do this by requiring an approach that is more rigorous for the higher risk products, which were identified from a review (risk ranking report) of the public health and safety risks associated with the consumption of seafood. The products include oysters and other bivalve molluscs (with some exceptions).

For seafood businesses producing bivalves¹, compliance with pre-harvest provisions of the Australian Shellfish Quality Assurance Program and the implementation of food safety programs for the post-harvest sector up to the beginning of the retail sector is proposed. Food safety requirements for retail and the food service sector are already covered under Chapter 3 of the Code.

For the majority of the seafood industry - that poses lower risk (medium and low risk categories according to the risk ranking report) – a basic set of food safety provisions (called general provisions) are proposed. Such provisions would include requirements to ensure that food is not contaminated during its production or handling, that adequate temperature control of food is maintained and that staff have the skills and knowledge about food safety that is necessary for the work they undertake. Some of the medium risk products may benefit from more specific risk management strategies. However, these may vary according to geographic/climatic and other factors, as well as existing jurisdictional and industry infrastructures.
For this reason, the proposed Standard does not prescribe a documented seafood safety management system for the lower risk products as for the high risk products. Nevertheless, the Standard will require a seafood business to systematically examine all its primary production operations to identify potential seafood safety hazards and implement controls that are commensurate with the food safety risk The extent of hazard identification, implementation of control measures and verification required should also be commensurate with the level of food safety risk involved. This is most appropriately determined by State and Territory jurisdictions in consultation with industry, taking account of local environmental factors. Where possible, State and Territory jurisdictions should use national forums such as the Implementation Subcommittee (ISC) if the Food Regulation Standing Committee to develop nationally consistent approaches to verification.
The philosophy behind this approach is about taking a preventive approach to managing food safety hazards and for industry, at all parts of the food supply chain, to play their role in minimising such hazards.
Option 3 proposes an approach based on risk – where risk is lower, the requirements are basic and where risks are higher, more significant requirements are proposed to manage food safety. The Australia and New Zealand Food Regulation Ministerial Council (Ministerial Council) made a decision in December 2003 – that food safety management approaches be based on risk and that food safety programs only be introduced where the benefits outweighed the costs of their implementation. Ministers also decided, based on the outcomes of the National Risk Validation Project, to require the introduction of food safety programs for oysters and other bivalves, up to the back door of the retail sector. The proposed Standard will implement the decision of Ministers.
Specific recommendations are made in this Draft Assessment about implementation (effectively over a two year period) and a draft of the proposed Standard is included at Attachment 1.
The Standard will be supported by an interpretive guideline for enforcement officers, developed by FSANZ, and industry developed guides to assist industry comply with the Standard. The framework for Option 3 is outlined below.
Proposed Regulatory framework for food safety management in seafood

Consideration has also been given to fish names labelling requirements. While a comprehensive regulatory analysis has not been undertaken to support a case for mandating prescribed labelling of all fish species in all circumstances across the catching/production, processing, wholesale and retail sectors of industry, consultations have been undertaken with Standards Australia on the development of a national fish names standard for fish names.

To assist industry, FSANZ has facilitated discussions and agreements with various Australian government and industry agencies, to help develop an Australian Standard for fish names that could serve as a reference document for action under trade practices laws. Following implementation of these arrangements, further consideration will be given (through FSANZ’s standards development processes) to whether any further coverage in the Code is required.