Dar seafood ppp standard

3. Current management strategies to address seafood safety

The safety of Australian seafood is controlled under a variety of schemes from primary production through processing, manufacture, wholesale, retail and food service. Regulatory and non-regulatory approaches are taken and these are outlined below.

3.1 Domestic Production - regulatory requirements for food safety

3.1.1 Australia New Zealand Food Standards Code - adopted nationally under State/Territory legislation

Domestic seafood production and imported seafood sold in Australia are subject to the requirements of the Code, as adopted under State and Territory legislation. State and Territory governments enforce compliance with the Code under their Food Acts.

Management of the public health and safety risks and consumer information needs associated with wholesale trade, processing, manufacture, retail and foodservice of seafood products are covered by existing standards.
Chapter 1 of the Code specifies permissions for the use of food additives, processing aids and pesticides and also sets maximum limits for chemical and microbiological contaminants in seafood. There are also requirements for the labelling of seafood. Chapter 2 of the Code contains specific requirements for fish and fish products.
Chapter 3 of the Code contains provisions for the hygienic processing and handling of food, and voluntary provisions covering the application of Food Safety Programs to the processing and retail part of the food chain. The Food Safety Standards in Chapter 3 do not currently apply to the primary production of seafood, except where there is direct sale to the public or the primary producer substantially processes the seafood.
It should be noted that the point in the processing part of the food chain at which the Food Safety Standards apply is not the same in all jurisdictions. Generally, the Standards do not apply on board vessels for activities such as gutting and filleting.
Attachment 7 provides a summary of these national standards impacting on seafood.

3.1.2 State and Territory regulations for the primary production of seafood

Different regulatory arrangements for seafood are in place in each of the States and Territories. These schemes are outlined in the sections below. (See also Table 1.)

Table 1: Seafood activities covered by food safety standards (Chapter 3) and State primary production food safety schemes

State/Territory	Seafood industry activities covered by
	State/Territory Primary Production food safety schemes	Food Safety Standards (Chapter 3) under the Code and State/Territory Food Acts
New South Wales	Capture/harvest to wholesale* Bivalve molluscs	Manufacturing, retail and food service
Queensland**	Bivalve molluscs	Manufacturing, retail, food service
Victoria ***	Capture/harvest, processing, wholesale, transport and retail fresh fish outlets Bivalve molluscs	Retailers selling cooked seafood
South Australia	Bivalve molluscs	Gutting or filleting off-vessel or off-farm, bivalve molluscs from storage onwards (cleaning, grading, packing, shucking), wholesale, manufacture, retail, foodservice
Western Australia	Bivalve molluscs	From land based seafood-processing facilities to retail sale. Shellfish - handled after harvest
Tasmania	Bivalve molluscs	Shellfish - bagging, holding tanks, shucking. Finfish - filleting, thermal packaging, smoking and other manufacturing, retail sale and foodservice
Northern Territory	-	Wholesale, manufacture, retail, food service
Australian Capital Territory	-	Wholesale, manufacture, retail, food service

* State-based scheme under NSW Food Production (Seafood Safety Scheme) Regulation 2001.

** Initial/preparatory work on a Queensland Seafood Safety Scheme, which covers capture/harvest, gutting and filleting, shucking, boiling, freezing and wholesaling fresh fish. Note this scheme is not yet in place (pending outcome of the development of a national seafood standard)

*** Victorian scheme under the Seafood Safety Act.

3.1.2.1 New South Wales

The NSW seafood industry is regulated under the NSW Food Production (Seafood Safety Scheme) Regulation 2001. The original requirement for HACCP-based food safety programs⁹ for all seafood businesses has subsequently been modified to match the rigor and complexity of the food safety systems, and the degree to which they are to be audited, with the level of risk to public health and safety.

For example, a food safety plan for a low risk business will not fully implement all HACCP principles and will only need to cover activities that impact on hygiene, sanitation and any necessary temperature controls. Roll-out of the system is being staggered, with the catch/harvest sector (excluding shellfish aquaculture), deemed to be mostly low-medium risk, being the first sector considered.
The NSW Food Production Regulation 2001 also incorporates a shellfish quality assurance program. Principles of the Australian Shellfish Quality Assurance Program (ASQAP) have been incorporated into the mandatory Shellfish Program to ensure safety in the consumption of bivalve molluscs.

3.1.2.2 Victoria

In Victoria, legislation for a new seafood safety system came into effect on 1 July 2003, with the exception of the wild catch and aquaculture sectors, which will come under the new legislation on 1 July 2004. The Seafood Safety Act extends the responsibilities of the Victorian Meat Authority (now called Primesafe) to cover the primary production, processing and retail sectors of the seafood industry. All seafood businesses must be licensed by Primesafe, and operate to approved food safety programs audited under the authority of Primesafe.

Seafood processors, wholesalers and retailers of fresh fish transferred from supervision under the Victorian Food Act to Primesafe on 1 January 2004. Victoria will adopt the national primary production and processing standard for seafood under this legislation.
In addition to the requirements imposed on primary production and processing of seafood under the proposed Seafood Safety Act, supermarkets and businesses engaged in retail sale of cooked seafood, such as fish and chip shops and restaurants, are required to implement a food safety program under provisions of the Food Act 1984.

3.1.2.3 Queensland

Queensland commenced consultation and development work on a seafood safety scheme, but is now waiting for the development (by FSANZ) and gazettal of the national primary production and processing Standard for seafood in the Code.

3.1.3 Australian Shellfish Quality Assurance Program (ASQAP)

The safe production of bivalve molluscs is effectively managed through a single management system, the ASQAP. ASQAP is a national program modelled on the United States Food and Drug Administration’s National Shellfish Sanitation Program. The Program was initially developed to meet AQIS export requirements and adapted to local conditions by the Australian Shellfish Quality Assurance Advisory Committee (ASQAAC), to provide guidelines for the safe production and marketing of bivalve molluscs for domestic production.

Bivalve molluscs are filter feeders, extracting phytoplankton, bacteria and suspended organic and inorganic particles (including heavy metals, toxins, enteric pathogens and endogenous marine pathogens) from the surrounding water. Waters from which bivalves are harvested may be subjected to pollution from discharges of untreated or poorly treated human waste, direct discharges of industrial wastes and runoff from urban and agricultural areas. Bivalves have been associated with numerous outbreaks of human illness because of their ability to bio-accumulate pathogens and toxins derived from contaminated waters, and because they are often eaten raw or only lightly cooked with their gastrointestinal tract intact.
The most commonly used approach for managing these risks involves harvesting shellfish only from waters that are shown to be free from harmful contaminants or pathogenic micro-organisms.
Federal, State and (sometimes) local government agencies share administrative responsibilities for the management of bivalves; sanitation controls for growing areas (including sanitary surveys and water classification); harvesting controls; and post-harvest processing and handling of bivalves consumed in Australia. ASQAP is administered on a co-operative basis by these agencies. For bivalves destined for export markets, AQIS administers sanitation controls for post-harvesting processing and handling of product.
In each State, the State Government regulates and manages the strict water and environmental monitoring provisions in the State program e.g. QSWAMP (Queensland Shellfish Water Assurance Monitoring Program), VSQAP (Victorian Shellfish Quality Assurance Program), TSQAP, SASQAP, NSWSQAP, WASQAP etc. Under these arrangements, there is a State Shellfish Control Authority (SSCA) that undertakes shoreline sanitation surveys, sanitation reviews, and risk management procedures.
Under ASQAP, harvest areas must be classified by the SSCA on the basis of the shoreline sanitary survey and an on-going water-sampling program. Production areas are classified as: Approved; Approved conditional; Restricted; Restricted conditional; and Prohibited. ASQAP also imposes controls on bivalve harvesting and ensures protection from contamination after harvesting.
The success of the program is based on continual and extensive monitoring of all commercial growing areas. It entails a precautionary approach, resulting in the closure of a harvesting area following a trigger event such as heavy rainfall or toxic algal bloom. Rainfall can flush microbiological and other pollution into harvesting areas and may also lead to conditions that encourage blooms of toxic phytoplankton.
Australian States and Territories also regulate bivalve safety through aquaculture licences, making it a condition of the licence to be part of the State shellfish quality assurance program. The approach under this system, while not embedded in the food regulation system, is recognised to be effective.