Dar seafood ppp standard

Attachment 9

The Imported Food Inspection Scheme and Seafood Testing

The Imported Food Inspection Scheme (IFIS) is the subject of a memorandum of understanding (MOU) between Food Standards Australia New Zealand (FSANZ) and the Australian Quarantine and Inspection Service (AQIS). FSANZ is responsible for developing risk assessment policies and undertaking risk assessments when required to recommend on the appropriate risk categorisation of selected foods.

1. Categories of Inspection
Using scientific risk assessment, food is placed into one of three inspection categories that determine the frequency of inspection:

• 
  Risk,
  
• 
  Active surveillance and,
  
• 
  Random surveillance.
  

Foods in the risk and surveillance categories are determined and routinely reviewed by FSANZ. Upon advice from FSANZ, the Minister of Agriculture, Fisheries and Forestry may make an order specifying a food/test combination within the inspection categories.

All foods in the risk category are inspected and tested, whereas all foods in the surveillance category referred to IFP are inspected, but not all are tested.
Risk categorised food is food that has the potential to pose a high risk to public health. At the point of entry, the Australian Customs Service (ACS) refers 100 percent of risk categorised foods, electronically, to AQIS for inspection status.
A performance-based approach applies. Food products from foreign producers with a consistent history of compliance are inspected less frequently than products from new suppliers or those with a history of failure against Australian standards. The three inspection rates are defined in the Imported Food Control Regulations, and any failure results in immediate intensification of the inspection regime. Risk categorised food remains subject to AQIS control pending the analytical results. The performance-based inspection levels are as follows:

• 
  The first five shipments of a particular food first arriving from a particular producer are inspected; after five consecutively cleared shipments, inspection intensity drops to the next level;
  
• 
  One in four shipments is then inspected (the other three are automatically released); after 20 cleared inspections and, if importation follows a steady pattern, inspection intensity drops to the next level;
  
• 
  One in 20 shipments is then inspected (the other 19 are automatically released).
  

Active surveillance category 10 percent of shipments of designated active surveillance foods, from every supplying country, are inspected. These products are released upon sampling. The test results of active surveillance foods are analysed by FSANZ to determine the appropriate category classification for the foods.
Random surveillance category 5 percent of all consignments of foods not included in the risk or active categories are inspected. These products are released upon sampling. Neither AQIS nor the importer has the ability to predict which shipment or which foods will be selected for inspection.

A holding order can be issued where an active or random surveillance food does not comply with the standards. A holding order against a foreign supplier effectively raises the inspection category of the food to ‘risk’ status. This means that all future shipments of that food from the offending supplier are automatically detained and held until compliance with Australia’s requirements is confirmed. After five clear inspections, the food reverts to its prior category.

2. Imported Seafood Testing
There are currently tests applied to imported seafood on the random surveillance category and the risk list.
3. Current random category requirements

Product Group	Tariff Group	Food to be inspected	IFIS Testing Requirements	Limits
Fish -fish fillets and other fish meat	0302 0303 0304	All fish - fish fillets and other fish meat - fresh chilled or frozen and not on the risk list. All farmed fish	Histamine and metals (mercury only)	Refer to Code
Fish dried, smoked, in brine and fish meal	0305	All fish and fish meal - dried, smoked, salted, or in brine whether or not cooked Farmed fish products Ready-to-eat products	Histamine and metals (mercury only) As for 'all' plus Staphylococcus enterotoxin	Refer to Code nd
Crustaceans (raw)	0306	All crustaceans (raw) - chilled, frozen, dried or salted All farmed crustacea – Live crustaceans –	Metals (mercury only) and sulphur dioxide Prohibited Imports	Refer to FSC
Molluscs (including snails) – (raw).	0307 0307.6000	All Scallops, cuttlefish, octopus- (raw), chilled, frozen, salted or dried Terrestrial snails All unopened bivalve molluscs & live snails are >	Metals (mercury only) (Cooked) - SPC and E. coli Prohibited imports	Refer to FSC

Note: the following amendments will be made to the random surveillance category in the near future:

• 
  an antibiotic screen will apply to all fresh farmed fish;
  
• 
  the mercury test will be deleted for ‘all fish and fish meal’;
  
• 
  sea urchins are to be tested for L. monocytogenes (L. mono/25g n=5, c=0, m=0);
  
• 
  jellyfish are to be tested for L. monocytogenes (L. mono/25g n=5, c=1, m=0, M=100).
  

Current risk list requirements

FOOD	RISK	ANALYSES	LIMITS
Crustaceans - (cooked & chilled) including cooked peeled prawns Excluding canned product that is commercially heat treated.^1	H	E. coli, SPC Salmonella SET Vibrio cholera ^2	10/g 10^6/g nd nd nd
Crustaceans - (cooked & frozen) including cooked peeled prawns. Excluding canned product that is commercially heat treated.^1	H	E. coli SPC Salmonella SET Vibrio cholera ^2	9/g 10^5/g nd nd nd
Fish of the following kinds whether whole, filleted or further processed, whether dried or not. All Shark (including Dogfish), Rexea solandri (Gemfish, Note; sometimes mistakenly referred to as NZ hake), and tuna. --------------------------- Canned tuna and tuna products --------------------------- Smoked vacuum packed fish and smoke flavoured vacuum packed fish	M M # H	Mercury Histamines ---------------------- Mercury and histamines ---------------------- Listeria monocytogenes	Refer FSC 200 mg/kg Refer FSC, 200 mg/kg nd
Marinara mix Chilled or frozen whether blanched or not. Excluding canned product that is commercially heat treated.^1	H	E. coli SPC Salmonella Paralytic shellfish poison Domoic acid	See table 2 ‘ ‘ ^‘ ‘ 0.8 mg/kg 20 mg/kg
Molluscs, ready for consumption, whether chilled or frozen. Bivalve molluscs, mussels, clams, cockles, scallops etc. Excluding canned product that is commercially heat treated. ^1 -------------------- Mussels, Marinated mussels that are ready for consumption whether chilled or frozen. (excluding goods packed in metal cans, glass jars or glass bottles that have been commercially heat treated). ^1	H H	E. coli SPC Vibrio cholera Paralytic shellfish poison Domoic acid -------------------- As for Molluscs plus Listeria monocytogenes	See table 1 ‘ ‘ nd 0.8 mg/kg 20 mg/kg ---------- nd

¹ In this document ‘canned product that is commercially heat treated’ means:

Food that is enclosed in hermetically sealed containers such as:

• 
  metal cans,
  

• 
  retort pouches,
  
• 
  plastic containers that have heat sealed lids or lids closed by a double seam e.g. as for metal cans), but excludes those with snap on plastic lids,
  
• 
  glass jars with ‘twist off’ lids, but excludes those with screw top lids, and
  
• 
  glass bottles with ‘twist off’ caps but excludes those with screw top caps,
  

where the food has been subject to commercial heat treatment (retorting) in the closed container or the food has been ‘hot filled’ into the containers before closing.

² Vibrio cholerae: if the presence of serotypes, 01, or 0139, or non 01, or non 0139 is confirmed in cooked crustacea whether chilled or frozen, the food must be deemed non compliant.
Table 1: Molluscs, other than scallops

Test	n	c	m	M
E coli	5	1	2.3	7
Standard Plate Count	5	1	10^5	5 x 10^5

Table 2: Marinara mix (whether raw or cooked)

Test	n	c	m	M
E coli	5	1	2.3	7
Standard Plate Count	5	2	10^5	10^6
Salmonella	Absent in 25g composite sample

Abbreviations

M # = medium risk – Food may be released after initial inspection.

NOTE: The exception being where another test and hold risk test is applied e.g. if an aflatoxin test is applied to products containing peanuts or peanut products as an ingredient, such as with canned tuna in satay sauce, the food must be held pending the result of the aflatoxin analysis.

H = high risk - Food must be held pending results of analysis.

Nd = not detectable

SET = staphylococcal enterotoxin

SPC = Standard Plate Count
Note: the following amendments will soon be made to the risk list

• 
  the mercury test will be deleted for canned tuna’;
  
• 
  the histamine test will be deleted for all Shark (including Dogfish), Rexea solandri (Gemfish; sometimes mistakenly referred to as NZ hake), and tuna.