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Core Requirements of Industry & Regulatory Systems: Seafood Industry. Alastair Macfarlane. Key NZ Seafood Markets. About 90% of seafood industry revenue is from export sales. Over 85% by value of seafood exports are to 6 market areas.
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Core Requirements of Industry & Regulatory Systems: Seafood Industry Alastair Macfarlane
Key NZ Seafood Markets • About 90% of seafood industry revenue is from export sales. • Over 85% by value of seafood exports are to 6 market areas. • Over 75% by volume (20% global volume) and 28% by value of sales to China are fish for further processing and re-export – mainly to EU, US and Japan.
Components of Core Regulatory System Requirements • Harvest/Production • Transportation • Processing • Product security/integrity and traceability • Approvals/accreditations and third party verification • Horizontal elements
Harvest/Production • Access to fisheries governed through Quota Management System and aquaculture through permitting. • Food safety risk management of bivalves is regulated pre-harvest through Regulated Control Scheme governing assessment of water and flesh quality plus strict time/temp parameters for harvest. • Integrity of wild catch governed by supplier codes and regulated requirements to assess fitness for purpose at point of landing to a processor. • Factory vessels regulated under same risk management requirements as land-based processors.
Transportation • .
Transportation • For freezer factory vessels there is no transport step between harvest (landing on board) and reception at the factory! • For non-processing fishing vessels, “transportation” to processing reception point on shore is part of the harvest step. Requirements for preserving integrity are largely unregulated, but incentivised by the regulated requirement to assess fitness for purpose at point of reception. • Time and temperature conditions for transport of aquacultured bivalves from point of harvest to processing reception are regulated as part of national Regulated Control Scheme.
Processing • Processing regulated under the Animal Products Act by a mix of legislation, regulation, Codes of Practice. Processor performance is subject to regular official performance-based audit. • Processors required to specify processes, identify risks and determine how risks are to be managed or mitigated in Risk Management Plans. • Competence defined by specified/audited competency-based training. • RMPs developed using MPI accredited technical service providers and approved by MPI. Changes to products or processes require specific approval. • Processors accountable for performance-based audits against their RMPs. Non-conformance is sanctioned by remedial action and greater audit frequency until control is determined to have been restored.
Product Integrity and Traceability • Product and production integrity must be both physically secured and secured in a documented sense. • MPI’s e’cert system provides an integrated platform for batch creation, inventory identification, approval and control from point of reception, through processing, into and out of store, selection and pack for export, transport to port and final load. • The e’cert system is information “backbone” for other documentation – notably Catch Certification for the EU.
Approvals, Accreditation & 3rd Party Certification • Seafood trade is assisted by other assurances of product integrity and legality, e.g. assurance of lab results through independent accreditation. • New EU regulations for 2015 on EU food businesses dealing in fish for further end-to-end traceability are outside the scope of official assurances. NZ industry is addressing the challenge by developing new guidance based on adopting enhanced GS1 traceability standards. • Several NZ fisheries are 3rd party (MSC) certified. A key component is Chain of Custody certification from fishery to final point of sale for certified product.
Horizontal Elements – seafood safety and seafood “integrity”
Horizontal Elements – seafood safety and seafood “integrity” • EU demands for seafood safety assurance, end to end traceability back to point of harvest and certification that catches have been authorised is demanding a much more pervasive oversight than is the norm for other foods. • Norms for assurance of seafood legality or provenance are not subject to international agreed standards – despite considerable debate in FAO and EU is setting the agenda with Catch Certification. • Obtaining market access for seafood requires more than effective food safety management and assurance, it increasingly requires assurance that fish has been obtained legally. The US is already active. • Concern among major brand owners that seafood has been produced “sustainably” creates a further layer of need for assurance and independent verification.