Dar seafood ppp standard

Attachment 6A

Summary of Submissions by Issue at Initial Assessment

Are there any chemical or biological hazards either further to, or currently included in Chapters 1 and 2 of the Code, that need to be addressed in the proposed seafood standard, or that should be additionally included in the current chapters of the Code? - Need to revisit MRLs in seafood. - Should not be duplication of existing legislation. - Reference / rely on / review chemical and biological hazard standards from other Chapters. - Address these in an easily updated dynamic interpretive guideline. - Should specify the species that the histamine standard applies to. - Metabisulphites may cause serious health problems – 4-hexylresorcinol is a safe approved alternative. - Mercury in predatory fish should be resolved through advisory guidelines. - Attention needs to be given to allergen issues not covered by Code. - Non-micro risks such as fish bones must be addressed. - Need appropriate process controls for histamine, ciguatera, Vibrio in prawns, agvet chemicals in aquaculture (esp. antibiotics), and micro, biotoxin and heavy metal contamination in shellfish Escolar, often sold as rudderfish, may need to be addressed. - general micro criteria should be included, similar to for food chemicals, i.e.: no residues are allowed unless there is a specific permission	Qld Health, SFQ Qld Health TFIC, SASC, SSA TFIC TSGA Kanins Simplot Simplot Simplot PIRSA SA DHS DAFF
What should be the scope of the proposed seafood Standard? - Should cover the entire seafood industry. - Should have consistency between definitions in the PP&PS and the SSA / ASIC standard, and an agreed process to change these. - Outcomes based, not prescriptive. - Outcomes focussed and based on food safety risk. - Refer to, but not duplicate, other Chapters. - Review Code as it does not allow health claims for omega 3 oil content. - All foods should come under the standard not just foods for human consumption. - Must apply equally to local and imported produce. - Should apply to all seafood produced or traded in Australia, including imports and exports. - Should not consider policy and regulatory issues other than food safety, and should not consider jurisdictional issues. - Recognise and reference Australian Fish Names List. - Don’t incorporate fish names. - Exclude quality attributes and production methodologies. - If the onus is on the supplier to source safe product, don’t need to heavily regulate primary production. - Only regulate where significant risks and the benefits outweigh the costs. - Standard should allow for voluntary codes of practice for GHP. - Should simply apply Chapter 3 to primary production and processing, thus removing the need for a specific seafood standard. - Difficult to legislate marketing names, but if done then should include Tasmanian Atlantic salmon and ocean trout. - Self regulation is preferable to government regulation – use the SSA guidelines on GMP and specific industry codes of practice. - Where regulation is deemed necessary it must be targeted at addressing the specific food safety problem and not have general application. - Follow Codex Draft Code of Practice, except where too vague. - EU or FDA regulations and micro criteria acceptable for export / import. - Deceptive or misleading conduct best left to Trade Practices legislation. - Reference to cold chain compliance through supply chain recommended. - Should not extend labelling obligations beyond those in the Code. - Seafood industry should only have to comply with standards 3.1.1, 3.2.2 and 3.2.3. - Standards 3.1.1, 3.2.2 and 3.2.3 should continue to apply, with other requirements added where risk and cost-benefit indicates - Need to differentiate between low inherent risks and higher risks through external impacts, and manage pollution of waterways. - Will inevitably cross over into quality aspects – not undesirable. - Residue accumulation as a consequence of prior land use in aquaculture requires attention - Food safety risks should be managed according to the degree of risk. - Avoid prescriptiveness – deal with actual not hypothetical risks. - Must have regard to existing market- and export-driven HACCP-based QA systems. - A full HACCP plan warranted for activities and products that carry a high food safety risk. - Food safety should be managed using a preventative approach based on through-chain risk management, with standards implemented in consultation and partnership with industry.	SSA SSA NTSC, Simplot SFM, SSA, MFMAA, AIEH SA, DAFF NTSC, SA DHS, PIRSA Springs Springs TFIC SFM, MFMAA SSA NTSC, SSA Sontari Sontari NT Govt SASC SASC TSGA TSGA TSGA TSGA Simplot Simplot Simplot Simplot Simplot AFFS PIRSA SASMPA SFQ SFQ SFQ SASMPA SASMPA SFM, MFMAA NSWFIC
Is the current definition of seafood in the Code adequate in terms of defining the commodities that the standard needs to cover? - Should be revisited to provide clarity. - Definition appears satisfactory. - The Seafood Definition used by Codex would appear to be suitable. - Should include fish, crustacea, molluscs and other marine invertebrates. - Definition should not include crocodile or seaweed.	Simplot SA DHS SASMPA PIRSA SFM, MFMAA
Should the proposed standard include aquatic plants, reptiles and mammals (which has implications for native fishing rights)? - No. - No, unless significant public health risks identified. - Include aquatic plants, exclude crocodile and mammalian meat. - Include these, but define the point at which they become seafood subject to the provisions of the standard. - Include aquatic plants, as some States already include these in legislation. - Questions whether the current crocodile meat standard is adequate. - Food safety still relevant to native rights, but low risk best addressed through risk communication	SADHS, SFM, MFMAA, Simplot PIRSA TFIC Sontari Qld Health, SFQ Qld Health, SFQ SFQ
Should the standard regulate seafood production (aquaculture) from the point of harvest up to the back dock of retail establishments, or through to the point of retail sale? - Entire chain from harvest to retail, inclusive. - Aquaculture should be covered from production inputs to point of sale. - Aquaculture should be covered from harvest to point of sale. - Up to but not including point of retail sale. - From harvest up to point at which the Code currently applies. - Should only apply to seafood production. - Apply to whole chain, but focus on where the major risks and problems lie, in the lack of knowledge of cold-chain management and seafood handling in the food service and retail sectors - Reference other standards in the Code in relation to retail	NTSC, TSGA, Sontari, Qld Health, SFM, MFMAA, Springs, PIRSA SFQ Simplot TFIC SA DHS AIEH SA SASMPA DAFF
Should businesses selling ready to eat seafood remain covered under the current arrangements, or should these businesses be covered by the Primary Production and Processing Standard for seafood? - Leave them under the current arrangements. - Incorporate in primary production and processing standards. - Should remain covered by the PP&PS by reference to Chapter 3 - Need to consider sushi and sashimi specialty shops.	SA DHS, AIEH SA, Springs Qld Health Simplot SASMPA
To what extent should the standard regulate harvesting, handling and processing of seafood onboard fishing vessels? - An outcomes based approach is recommended - Vessels may not need a full Codex HACCP system where risks are low. - Should include food safety plans / programs (FSPs) in line with the industry preferred standard - Should address in same manner as for food processing establishments. - The risks are low, so a standard should not apply. - Specific risks may need mandated controls e.g. cooking prawns on boats. - Voluntary code of practice for GHP and vessel design may be useful. - No need to have a FSP if only producing live catch. - Limited space on vessels may preclude on-board inspectors, so vessel skippers should obtain accredited food safety training. - Need an awareness program to reinforce the basics of food safety on-board. - One option is to have a receival standard with regulation / enforcement beginning at dock, to encourage compliance. - Need to apply GHP unless processing on-board, then need a FSP. May need to address by a code of practice, as a standard will be difficult to enforce on-board.	Simplot, SSA SFM, MFMAA Qld Health Springs, Simplot SASC, PIRSA, SASMPA PIRSA PIRSA TFIC TFIC TFIC TFIC AFFS SA DHS
Comment is sought on the scientific risk assessment process which forms the basis of the FSANZ regulatory measures. - Risk assessment process is supported. - Risk assessment process needs to be appropriate for the level of risk. - Should rely on work already undertaken by authorities and the seafood industry. - Assessment required of special techniques , the use of antibiotics, hormones and GM. - A scientific risk assessment is needed for each link in the chain. - The FSANZ risk assessment process does not properly consider risk analysis in context, ignores data already available to aid businesses implement HACCP, and places undue emphasis on risk assessment more appropriate to the establishment of food product standards. - The analysis to relate production processes to hazards should occur after the standard is established	SA DHS, Simplot, DAFF TFIC SFM, MFMAA Simplot NSWSIC SSA SSA
Technical data is sought from industry and relevant agencies for incorporation into the scientific risk analysis process. - The reported data for the relative amounts of local and imported seafood consumed in Australia is wrong – correct ratio is given. - Need more data on chemical / pesticide residues in aquaculture. - Industry should be encouraged to fill the few remaining gaps in Australian risk assessment data - Can supply data from food microbiological surveys, if required. - Supports provision of technical data for incorporation into the scientific risk assessment process - Prepared to assist with provision of technical data for incorporation into the scientific risk assessment process. - Won’t supply data if confidentiality can’t be assured.	Sontari Qld Health SFQ SA DHS SFM, MFMAA TSGA
Comment is sought on the suitability and/or any deficiencies of the industry-preferred standard proposed under the SSA/ASIC Application, if it were to be considered as a basis for a national mandatory Primary Production and Processing Standard for seafood. - Supports industry developing and implementing voluntary standards. - Don’t use it as basis of seafood standard (reasons given). - Use the SSA / ASIC standard as an interpretive guideline. - Needs to be modified if to be used as a guideline. - Some parts would be useful as a guideline document. - Use it as a basis for the seafood standard. - Use it as a basis, but it has some anomalies. - Sections 9 and 10 should apply to trawlers and premises used for live fish. - A wider view is required.	PIRSA PIRSA TFIC SASC SA DHS NTSC, SFM, MFMAA, DAFF Qld Health, SA DHS, SFQ AFFS Sontari
Comment is sought on the suitability of any existing government standards, such as the NSW Food Production (Seafood Safety Scheme) Regulation 2001, and any international standards, as a model on which to base a national mandatory Primary Production and Processing Standard for seafood. - All existing Australian and international standards should be considered as part of the process of developing the PP&PS for seafood. - Work undertaken by SafeFood NSW and issues raised in the NSW ‘Section 73’ review should be taken into account in developing the standard. - There is anecdotal evidence of complexity and cost in the NSW and VIC schemes. - NSW scheme is deficient for several reasons. - NSW seafood safety manual should be the standard. - Current legislation covering imports is working. - The NSW scheme is a regulation, not a standard, but some of the oyster management parts would be useful as a guideline. - Incorporate into interpretive guidelines as appropriate. - Utilise industry codes of practice etc. where mandatory measures would be ineffective.	SSA SFM, MFMAA TSGA Sontari AFFS Sontari Qld Health TFIC TFIC
Comment is sought on the range of options available to manage food safety risks in the seafood sector and their appropriateness, including the costs and benefits of such approaches. - Should mandate ASQAP principles for all bivalve molluscs. - should cite ASQAP - FSPs for bivalve mollusc production and handling and for control of Listeria in cold smoked salmon - Since seafood is mainly low risk, only need to apply minimum regulatory controls where necessary. - Management focus and costs should be directed towards those segments presenting the greatest risk. - HACCP must be the basis for food safety management.	SASC, PIRSA DAFF PIRSA SA DHS NSWSIC SASMPA
Stakeholders are invited to provide their views on issues relating to food safety management systems and whether options further to those raised in this paper should be considered in managing the potential public health and safety risks associated with seafood. - the Ministerial Council has established that risk management in relation to PP&PS is to be consistent with Chapter 3, HACCP based and implemented according to risk classification. - The solution, whether HACCP or GMP, should be appropriate to the level of risk. - Develop voluntary code for harvesters, as low risk. - Only need effective risk communication and targeted industry education. - FSPs should only apply where the risk is high. - Non-regulatory guidelines and codes of practice could be effective where risks are low. - FSPs should not be implemented unless there is strong industry and government leadership and it is supported by appropriate resources.	SSA NTSC, SASC, Qld Health PIRSA Qld Health Qld Health SFM, MFMAA SA DHS, PIRSA
Information on the costs and benefits of the food safety management systems is sought. - The RIS in support of Chapter 3 of the Code is relevant. - Additional costs of implementation of FSPs are significant - Consumer confidence that seafood is safe is vital to the industry. - Information on the costs of compliance with, and administration of, the AQIS export certification program are presented.	SSA PIRSA SSA SECC
Comment is sought on issues relevant to compliance by the industry with respect to the food safety management options outlined in this paper. - Compliance with FSPs by 3^rd party audit, approved by govt, paid by industry, reporting to regulators. - Compliance measures and costs need to be commensurate with risks. - There needs to be consistency between jurisdictions. - Complexity of compliance and difficulties with enforcement argue against regulation. - Will there be a national accreditation mark? - Will there be consideration for good compliance history? - Multiple audits are very undesirable.	PIRSA SA DHS SASMPA TSGA NT Govt NT Govt NT Govt, SASMPA, SASC, SFM, MFMAA

Comment is sought on food safety management options from an enforcement perspective. Specific issues that have been identified are listed below, but comment need not be confined to these issues: - the costs of meeting current requirements and costs or difficulties in meeting the range of food safety management options that are mentioned in this paper; - This is no time for a cash grab via licensing fees. - Information on the costs of compliance with, and administration of, the AQIS export certification program are presented. - ways that industry could comply with the food safety management options, for example by compliance with current industry or legislative requirements; - A business complying with the SSA / ASIC standard should be recognised as complying with the PP&PS standard. - Need to recognise export establishments as complying with the standard. - Industry would not support duplication of export and Australian domestic standards for seafood - other methods of cost effective compliance; Need education and training supported by a significant increase in government contributions. - how a Primary Production and Processing Standard for seafood would fit with any existing standards and State and Territory regulations governing primary products; - additional matters at State/Territory level that the States and Territory governments may have to consider in order to ensure compliance and enforcement with any national standard; - Local government enforces Chapter 3, Health Chapters 1 and 2. - Seafood production best regulated by Primary Industry, processing by Human Services and local authorities. - Production should be regulated by Primary Industry, processing and retail sale by Health. - how equivalence between existing requirements and any new standards could be established; - the timeframes that industry may need to comply with the food safety management options; - Timeframes will vary according to the requirements of food safety systems and the readiness of the industry sector (over two years in some sectors). - Need 3 year compliance and 2 year stock in trade timeframes - Timeframes should be set in close consultation with industry. - the role of incentive based compliance schemes, such as reduced frequency of audits; - An initial high audit frequency should be reduced, unless there is evidence that the system is not under control. - This is a real opportunity to incorporate incentive-based compliance. - the need for comprehensive guidelines for those sectors of the seafood industry affected by a Primary Production and Processing Standard for seafood, including the role of industry and regulatory agencies in the development of any guidelines - Guideline a vital support to any legislation. - Supports nationally developed guidelines. - Many guides and codes of practice exist and SSA is helping industry develop GMP guidelines - Will need guidelines, but not all industry codes of practice will be acceptable – issues of adequacy and equivalence will need national review. - Other Comments - State regulators are unlikely to have the capacity to implement and police a single standard that would also replace the AQIS requirements - Concerns with harmonisation with international standards. - Need mutual recognition of audits between AQIS and jurisdictions. - Need mutual recognition of audits and acceptance of third party audits. Past audit performance and risk profile need to be taken into account - How will producers / processors who are also retailers be regulated? - State regulators will require a major re-education to be able to police the standard. - Need to strengthen HACCP awareness and training. - Auditing should be in realm of market forces. - Number of skilled auditors for seafood in Australia is low. - Need a national approach aimed at eliminating inconsistencies between jurisdictions. SSA is working with FAS-ANZ on a national framework for food safety auditing, accreditation and certification.

TFIC SECC SSA NTSC, SECC, SASC SASMPA NSWSIC AIEH SA Unley PIRSA Simplot TFIC SASC, PIRSA Qld Health, SFQ Simplot PIRSA, SSA SSA Qld Health, SFQ SECC Simplot SECC, SSA SFM, SSA, MFMAA NT Gov SASMPA Simplot Simplot Simplot NSWSIC SSA