July 22nd, 2004
Food Standards Australia New Zealand
P. O. Box 7186
Canberra BC
ACT 2610
To Whom It May Concern:
Submission:
Draft Assessment Report, Proposal P265
Primary Production and Processing Standard for Seafood (PPPSS)
Thank you for the opportunity to contribute to the proposed standard for seafood.
The Tasmanian Fishing Industry Council (TFIC) has in excess of 960 licenced members, including commercial fishermen, marine farmers and seafood processors. Many more non-members (family, employees, transporters, handlers, retailers etc) also work directly within the seafood industry in Tasmania.
During the course of the development of the PPPSS (and in conjunction with the Tasmanian Department of Primary Industries, Water and Environment (DPIWE) and FSANZ) we have hosted numerous stakeholder consultation meetings in the state to gain valued input from our members and other experts. This has been extremely beneficial, as the unique nature of the Tasmanian seafood industry has been considered and included into the draft standard.
We would like to take this opportunity to endorse the Draft Assessment Report for Proposal P265 in its current form, recommending that (7.4) Option 3 be adopted.
Co-mingling of seafood from different sources:
One issue of concern that perhaps needs to be discussed is 'co-mingling'. TFIC believes that while co-mingling of seafood from different sources may not (in itself) present an elevated level of risk to food safety, for traceability and consumer confidence reasons, the PPPSS should ensure that co-mingling is not permitted in the market place.
For example, a trend at some fish markets is to mix oysters from various sources, sometimes selling them all as Tasmanian oysters, when in fact some may possibly have come from South Australia. While Tasmania has recently celebrated the milestone of marketing 100 million serves (half a dozen) of oysters without one confirmed foodborne illness being reported (Health Department records), the practice of co-mingling produce from varying sources causes significant concern.
From a food safety perspective, a foodborne illness may be adequately dealt with by simply recalling the entire co-mingled batch. However, from a state/region perspective, traceability of the offending product would then allow adaptive management of the program to prevent any further illness. It also ensures that the good name of perfectly safe produce from one region is not tainted in the market place by being mixed with a poor product from another region that may present a food safety risk. This will have the added benefit of protecting (as much as is possible) consumer confidence in the similar product that does not present a risk of foodborne illness.
Again, thank you for the opportunity to comment and for the extensive stakeholder consultation that has been facilitated in Tasmania.
The Tasmanian Aquaculture Council (TAC) endorses this submission.
Yours sincerely,
Ralph Mitchell
Executive Officer