Dar seafood ppp standard

4.5 Examination of existing management systems and their control of identified risks

The previous section concludes that there are a small number of seafood commodities that may pose a higher relative risk to public health and safety when compared with other commodities in the seafood sector. It also concludes that the remaining seafood commodities pose a lower individual risk, but that when the risk is aggregated, these contribute significantly to the background incidence of food-borne illness associated with seafood.

It is noted that in identifying risks, use was made of the available epidemiological data. However, this data is limited due to significant underreporting (one per cent of cases are estimated to be reported). With this in mind, well over 90 per cent food-borne illness related to seafood is likely to be unreported. However, the relative risk ranking took into account other information, as detailed previously, to develop a view of the overall risks posed.

The following section of this Report further examines current management systems for higher risk sectors as well as the remaining sectors, to identify where these would benefit from application of additional or different risk management practices or a single integrated national scheme. Table 5 summarises current regulatory and food safety control measures in place for those seafood commodities ranked as either medium or higher relative risk.

4.5.1 Seafood ranked as high (relative to other seafood)

4.5.1.1 Oysters and other bivalve molluscs

Bivalves¹⁶ were assessed as posing a higher relative risk to public health when harvested from growing environments likely to be exposed to faecal contamination and/or not under a shellfish safety management scheme.

The food safety of bivalves is controlled through State-based programs that utilise ASQAP as a guide to safe production and harvesting. All Australian producers must now comply with the State-based programs as a condition of their aquaculture licence.
State ASQAP programs adopt measures to prevent the growing and harvesting of bivalves from waters made unsuitable by the presence of biological or chemical hazards at levels likely to present a public health risk. These programs allow for the purification of bivalves from such waters, under certain conditions, through the application of techniques such as relaying and depuration. However, the vibrios, algal biotoxins and enteric viruses, in particular, tend to be removed ineffectively by these purification techniques, so that the higher inherent risk cannot be completely managed by these practices. Because of this, ASQAP prescribes the testing of bivalve flesh for biotoxins under certain circumstances, and requires temperature control to limit outgrowth of bacterial pathogens post-harvest.

The State ASQAP programs are essential tools for the management of the safety of bivalve molluscs. It is clear that bivalve mollusc producers achieve a satisfactory level of safety for this inherently hazardous food through adherence to the requirements stated in ASQAP by the State Shellfish Control Authorities (SSCA). The use of very similar systems is mandated in many developed countries as the only recognised and effective means of producing safe bivalve molluscs. The control of waters from which the product is harvested is beyond the capacity of individual growers. Additionally, the current system ensures that the extensive sampling regime undertaken under the program is affordable for each grower.

The recent achievement of a national approach for industry compliance with the requirements set out in ASQAP for the safe production of shellfish has closed some of the gaps in the food safety management system for bivalves. The industry and the State regulators of the Program, through ASQAAC, have recommended to FSANZ that compliance with the pre-harvest requirements of ASQAP as well as biotoxins management plans be mandated in the Code and that food safety plans be mandated for certain post-harvest activities associated with these products. This aims to ensure that the current legislative basis for shellfish standards are based on food safety requirements, that States/Territories regulate shellfish safety through a nationally consistent standard and that there is a means to recognise ASQAAC as the body that maintains and updates ASQAP. Given the proven effectiveness of the ASQAP system, it would be appropriate to mandate compliance with requirements of the program as administered by the SSCA within the Code.
This approach would have the benefit of ensuring:

• 
  an appropriate legislative basis by bringing it under the health umbrella;
  
• 
  national consistency as all States would pick up the requirement uniformly and fully;
  
• 
  once in the Code it would allow health portfolios to verify compliance by industry; and
  
• 
  provide a mechanism for maintenance of guidelines that are essential for the safety of this food.
  

The development of mandatory documented risk management standards in the Code is consistent with the recent Ministerial decision and Guidelines on Food Safety Management Options in Australia.

In conclusion, the potential public health and safety risks associated with oysters and other bivalve molluscs are considered higher relative to other seafood and, therefore, voluntary or other non-regulated mechanisms to address this level of risk are not considered appropriate or sufficient to address the problem.

4.5.1.2 Cold-smoked finfish

Cold-smoked finfish (and other cold-smoked seafood products) were found to present a higher relative risk to public health for at-risk population sub-groups, due mainly to the severity of illness caused by contamination with Listeria monocytogenes. Listeriosis is a serious food-borne illness that affects susceptible populations and can lead to death. Because of its long incubation period (up to three months), it is often difficult to identify the food vehicle responsible for the illness.

Listeria is a ubiquitous organism in the environment and because the cold-smoking process does not contain a listericidal step, it is difficult to eliminate this pathogen from the product.

Instead, strict adherence to good hygienic practices and proper maintenance of the processing environment are essential for controlling this organism. The long storage periods of the products at low temperatures favour the growth of the pathogen. Typically the shelf-life for vacuum packed cold smoked fish is up to 4 weeks at 5C.

The Code sets a limit for L. monocytogenes in smoked fish and processors use this limit as one criterion for evaluating the safety of their products before release into the marketplace and in setting use-by-dates. Testing of products in the marketplace also contributes to recall of contaminated product. However, good hygienic practices and clean premises are essential tools in maintaining low levels of the pathogen in the product. These practices are already mandated for processing of this product in Chapter 3 of the Code.
In addition, FSANZ publishes and distributes information material to alert susceptible populations such as pregnant women to the high risk posed to them by this food. It must be concluded, however, that these current management strategies for Listeria in cold-smoked finfish leave a residual, albeit small, risk to public health.
One approach to manage the residual risks posed to public health by cold-smoked finfish would be to propose implementation of additional risk management systems. These could consist of a HACCP system or food safety program as described in the voluntary Standard 3.2.1 in the Code. It is clear that the risks lie mainly in the processing part of the food chain where the pathogen may be introduced, and also in the retail shop where Listeria growth may occur during the long shelf life of the product.
The implementation of HACCP or food safety programs would need to be justified by a positive benefit-cost ratio demonstrating that the burden would be clearly outweighed by the public health improvements. Such a benefit-cost study has not been done and until it is done, the proposal to mandate HACCP-based approach for this food would not meet with stakeholder agreement.
As the main sub-populations at risk are pregnant women and the elderly, improved education of these vulnerable populations may be the best approach, in the short-term, to manage the residual risk, combined with improved compliance and enforcement of the existing mandatory Standards in Chapters 1 and 3 of the Code. FSANZ has recently reviewed the Listeria pamphlet for pregnant women to broaden its audience to the main vulnerable population groups at risk.
In summary, at this point in the standard development process, no additional regulatory requirements are proposed for cold smoked finfish.

4.5.2 Lower risk seafood

The majority of seafood commodities were ranked as presenting a lower public health risk than bivalve molluscs and cold-smoked finfish. The lower risk seafood products, when grouped together, do contribute to the overall level of food-borne illness and therefore have an impact on public health and safety. Because of the continuing burden this will have on the community and the consequent costs it imposes, there is an argument for the introduction of basic measures, at low cost, across the seafood industry that would have a broad impact in improving public health and maintaining the high level of consumer confidence in the consumption of seafood.

The existing food safety provisions in the Code recognise that good hygienic practices and pre-requisite programs must apply to all food businesses (other than primary production) to ensure a basic level of food safety for all food. Codex, in its General Principles of Food Hygiene¹⁷, also takes the approach that the primary production and processing of all food must meet basic requirements of food safety. The work of both the WHO and Codex indicates that reducing the hazards introduced at the primary end of the food supply chain will minimise food safety hazards at the later stages of the food chain.¹⁸ The approach in Standards 3.2.2 and 3.2.3 of the Code that mandate minimum requirements for food safety do not apply to businesses in the primary production and processing sector - they apply to manufacturers through to retailers.
The various voluntary industry codes of practice and industry guidelines, in some cases, do pick up such requirements, but national consistency of coverage would be improved through the introduction of a single national scheme.
Therefore, there is a strong case to extend the basic food safety provisions of the Code throughout the primary production and processing supply chain to ensure there are basic food safety practices underpinning the production of all food, rather than at just one end of the supply chain. 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 oysters and other bivalve molluscs. Nevertheless, the Standard requires 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 risks. 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 jurisdictions in consultation with industry, taking account of local environmental factors. Where possible, jurisdictions should use national forums such as the Implementation Subcommittee (ISC) of the Food Regulation Standing Committee to develop nationally consistent approaches to verification.

One example of a specific risk management strategy that is required is in relation to escolar (or rudderfish), where specific advice may be required at the retail and consumer level to advise people of the risk of consuming wax esters that are found in this fish.