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Proposal P265 IAR Exec summary

18 December 2002


(Initial Assessment – Prepare a Proposal
Under s.12AA of the FSANZ Act 1991)

DEADLINE FOR PUBLIC SUBMISSIONSto the Authority in relation to this matter:

28 February 2003

(See ‘Invitation for Public Submissions’ for details)

Full Report [ Pdf 340kb ]


Food Standards Australia New Zealand’s (FSANZ) role is to protect the health and safety of people in Australia and New Zealand through the maintenance of a safe food supply. Under the new food regulatory arrangements and the newFood Standards Australia New Zealand Act 1991,FSANZ has assumed responsibility for the development of Primary Production and Processing Standards for food produced by the primary industry sector within Australia.

These standards are developed within the framework of theFood Standards Australia New Zealand Act 1991.The initial stage of the process is the preparation of a proposal, along with the release of an Issues Paper to generate public input to assist the Authority in developing the standard. This first round of public consultation is part of a process whereby FSANZ gathers information and evidence in order to allow it to undertake a thorough and rigorous scientific risk assessment and analysis of the regulatory impacts of any proposed standard. The process continues at a later stage with the Draft Assessment whereby the legal drafting of proposed standards is developed after all issues have been considered. The Draft Assessment report is also released for public comment prior to the FSANZ Board’s deliberation at the Final Assessment stage.

Seafood, like all other food products, needs to be produced under conditions that result in a safe product. Regulatory measures need to place minimum requirements on the seafood industry while achieving optimal food safety outcomes with respect to protecting public health and safety. The Australian population consumes significant amounts of seafood, approximately 300,000 tonnes of seafood being consumed in the year 2000-2001. A significant proportion of seafood consumed by the Australian population is imported.

The development of the proposal must consider the broad range of products, food safety risks and management systems in place and harmonise, where possible, with international standards. This Issues Paper raises a number of issues for consideration, covering the scope of the proposal, the scientific process used, options for food safety management systems and compliance issues. These issues are summarised below.

For more detailed background and description of specific issues please refer to the sections of this paper as indicated. The paper may not cover all issues necessary for consideration in the development of the seafood standard and further issues may be identified during this public consultation.

All stakeholders are invited to participate in the standard development process by providing comment on the issues raised.


  • Are there any chemical or biological hazards either further to, or currently included in Chapters 1 and 2 of the Food Standards Code, that need to be addressed in the proposed seafood standard, or that should be additionally included in the current chapters of theFood Standards Code? (Section 4.2.2)
  • What should be the scope of the proposed seafood standard? (Section 5)
  • Is the current definition of seafood in the Food Standards Code adequate in terms of defining the commodities that the standard need to cover? (Section 5.1)
  • Should the proposed standard include aquatic plants, reptiles and mammals (which has implications for native fishing rights)? (Section 5.1)
  • 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? (Section 5.2)
  • 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? (Section 5.2)
  • To what extent should the standard regulate harvesting, handling and processing of seafood onboard fishing vessels? (Section 5.2)
  • Comment is sought on the scientific risk assessment process (detailed in Section 6) which forms the basis of the FSANZ regulatory measures.
  • Technical data is sought from industry and relevant agencies for incorporation into the scientific risk analysis process (Section 6)
  • 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 (Section 7.2.3)
  • 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.
  • 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 (Section 7.2.4)
  • 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. (Section 7)
  • Information on the costs and benefits of the food safety management systems is sought. (Section 7)
  • Comment is sought on issues relevant to compliance by the industry with respect to the food safety management options outlined in this paper. (Section 8)
  • Comment is sought on food safety management options from an enforcement perspective (Section 8). 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;
  • ways that industry could comply with the food safety management options, for example by compliance with current industry or legislative requirements;
  • other methods of cost effective compliance;
  • 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;
  • 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;
  • the role of incentive based compliance schemes, such as reduced frequency of audits; and
  • 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

Full Report [ Pdf 340kb ]


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