Dar seafood ppp standard

3.2 Voluntary industry standards and guidelines for domestic production

Many seafood businesses comply with voluntary industry guidelines and codes of practice developed by industry peak bodies to address seafood quality and safety issues. Examples of industry guidelines and codes of practice are listed in Attachment 8.

There are no data on the extent to which these guides are implemented by industry, but large operations and those that perceive a market advantage tend to implement and adhere to guidelines, while smaller, resource-constrained businesses are less likely to adopt them.

3.3 Imported seafood - regulatory requirements for food safety

Imported foods must meet the same standards as domestic foods.

At the border, the safety of imported seafood is regulated under the Imported Food Control Act 1992 administered by AQIS. FSANZ and AQIS have joint responsibility for regulating the safety of imported food, with their roles defined by a memorandum of understanding. FSANZ is responsible for conducting risk assessment of imported food, and AQIS provides operational services at the border, including inspections, verifications and tests in line with FSANZ’s advice and to ensure that imported foods comply with the Code.
Imported seafood that is currently classified as ‘Risk’ food and therefore subjected to 100 per cent inspection levels, consists of the following:

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  crustaceans, cooked and chilled or cooked and frozen. Includes cooked peeled prawns but excludes canned product that is commercially heat treated;
  
  
  
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  fish (whole, filleted, further processed or dried), all shark (including Dogfish), Rexea solandri (Gemfish) and tuna;
  
  
  
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  smoked vacuum packed fish and smoke flavoured vacuum packed fish;
  
  
  
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  marinara mix - chilled or frozen, whether blanched or not. Excludes canned product that is commercially heat treated; and
  
  
  
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  molluscs ready for consumption, whether chilled or frozen. Includes all bivalve molluscs such as mussels, clams, cockles and scallops. Excludes canned product that is commercially heat treated.
  

All other imported seafood products are included in the random surveillance category and inspected at a rate of 5 per cent. For further details on the current tests applied to imported seafood refer to Attachment 9.

FSANZ and AQIS are undertaking a review of the random and active surveillance categories. This review is considering existing limits in the Code, the risks to public health and safety and imported food data. The new imported food surveillance system is intended to reward those importers with a good history of compliance, and to allow greater flexibility in relation to inspection frequencies.
The involvement of domestic surveillance agencies in the review of imported food surveillance will result in a more inclusive consideration of issues and allow a greater integration of surveillance functions. It will also ensure that a broader range of information sources is considered when developing surveillance priorities.
The review of the imported foods random and active surveillance categories has been substantially progressed by FSANZ. In the next few months, proposals on inspection rates for classes of foods will be presented to State and Territories and industry for their comment. It is expected that implementation of the new, more flexible system will be in a phased approach with different rates of inspection being applied to some food categories by the end of 2004.
Importers can avail themselves of two mechanisms to reduce the level of inspection and testing at the border. These include (a) recognition of quality assurance arrangements and (b) certification provided by overseas governments (see below).

1. Recognised quality assurance arrangements

AQIS may enter into quality assurance arrangements with individual overseas manufacturers that are able to demonstrate that they operate to a HACCP based quality management system that ensures their products meet the requirements of the Code and other requirements of the Imported Food Control Act 1992 and are therefore eligible for importation into Australia. Shipments from that company will be monitored by AQIS at reduced rates. To be eligible to enter into an agreement a company must be certified by a third party certification body to the ISO 9000 quality management standards and be able to meet requirements of relevant Codex Codes of Practice. There are currently no such agreements in place.

2. Certification provided by overseas governments

Australia has voluntary arrangements to accept assurances from a number of governments on the safety of the food exported to Australia. Food that is accompanied by certificates issued by these governments will generally be released with document inspection only and without routine inspection of the food. Inspections will only be carried out for verification checks of the certification arrangement or if AQIS has concerns about a particular consignment. The certification arrangements may apply to risk, active or random surveillance foods from any country and to risk foods from New Zealand under terms of the Trans-Tasman Mutual Recognition Arrangement.

Currently certification is provided for a range of foods, including seafood, from at least nine countries.

3.3.3 Monitoring for food safety by States and Territories

In addition to border inspection, States and Territories test imported food to ensure it meets requirements of the Code at the point of sale. States and Territories also undertake specific food surveillance surveys on food sold in Australia. These surveys cover domestically produced and imported foods. Specific surveys on fish and fish products have been undertaken (see Table 2).

Table 2: State and Territory surveys of fish and fish products sold in Australia (covers domestic and imported products)

Survey Title	State	Year	Foods
Listeria Monocytogenes in nil-tolerance products	QLD	1995	Smoked Fish Products
Heavy Metals/Pesticides in Brisbane River seafoods	QLD	1996	Seafood (Fish/Prawns)
Microbial quality of marinara mix	ACT	1997	Marinara mix
Biogenic amines in fish and fish products	ACT	1997	Fish and fish products
How safe are smorgasbord foods?	WA	1998	Cooked Prawns
Sulphur dioxide in cooked prawns	QLD	1999	Prawns
Mobile seafood vendor survey	NSW	2000	Seafood
Metal contamination of major NSW fish species	NSW	2001	Fin fish
Metal contamination of major NSW fish species	NSW	2001	Crustaceans
Metal contamination of major NSW fish species	NSW	2001	Molluscs
Histamines – Storage Conditions in Fish	VIC	2002	Finfish
Fish speciation, Cairns Public Health Unit	QLD	2002	Fish
Fish substitution survey	National	2003	Finfish
Shelf life of Sushi products Nigiri pieces and Nori rolls	VIC	2003	Fish products

These surveys may provide information on compliance with the Code at point of sale, hazards in seafood and in some instances insights into hazards that may commonly be associated with particular foods. In relation to any public health and safety impact arising from food/hazard combinations, this would need to be established through epidemiological investigations.

In 2000, the OzFoodNet project was established in Australia as a collaborative project between the Commonwealth and States and Territories to enhance the surveillance of food-borne diseases and to provide a means for facilitating the national investigation of and determine the causes of food-borne illness. It is anticipated that as a result of these activities and over time, Australia will have access to improved information about the sources of food-borne illness.

3.3.4 Enforcement of process standards for imported food

Consumers need to have confidence that the food they consume is safe, irrespective of its source. Mandatory national food standards in the Code apply to both domestically produced and imported foods. However, the mechanisms used to determine that food is safe may differ between domestic and imported foods.

For imported foods, the monitoring system aims to achieve the same outcome i.e. that only safe and suitable food is sold on the Australian market. The monitoring of imported foods often examines the end point of production and tests against agreed microbiological or chemical residual limits in the Code.

For example, instead of being able to check that specified processing requirements were applied during the production and processing of food, product safety is determined by testing, for example, for coagulase-positive staphylococci, salmonella, E. coli or histamine etc.

End point testing can have limitations in terms of being able to reliably ensure safe food outcomes. Therefore, FSANZ and AQIS, in conjunction with the States and Territories, have begun to examine systems that can more reliably monitor the safety of imported foods. It is expected that the Implementation Sub-Committee of the Food Regulation Standing Committee will consider the outcome of this work in 2005.

3.3.5 Importation of seafood from New Zealand

Seafood imported from New Zealand operates under the Trans Tasman Mutual Recognition Agreement. The Imported Food Control Act of 1992 applies the standards in the Code to risk categorised food imported from New Zealand.