The technical program is underpinned by a strategy to identify current and emerging food safety and market access issues, prioritise these issues, and undertake technical work to provide potential solutions to overcome those of highest priority.
Three rounds of this strategy have been facilitated by SafeFish to date, the first in May 2011, second in June 2014 and the most recent in October 2016. In order to scope and prioritise the issues that were identified, SafeFish produced the following reports that contained information such as background, sectors affected, trade and market access information, public health impact, regulatory issues, economic impacts, reputational impacts – media and political, and environmental/sustainability issues that may have been present.
Hazards affecting Australian seafood
Hazards affecting Australian seafood
Hazards affecting Australian seafood
Using this information, the SafeFish partners then prioritised the issues through a risk ranking process. On the alternate years, a smaller in-house process of issue identification and prioritisation was run by the secretariat and the partners to set the work plan for that interim period.
For the 2017 to 2018 period, SafeFish is facilitating technical work on the following issues which were identified as High-Priority by the partners:
Harmonisation of marine biotoxin standards in the Food Standards Australian, New Zealand (FSANZ) Code
SafeFish is in the process of drafting an application to request FSANZ to review the current marine biotoxin maximum levels (MLs) applicable to seafood in Standard 1.4.1, section 19 of the FSANZ Food Standards Code (FSC), with a view to harmonising the FSC with Codex standards.
The FSC contains maximum allowable levels for paralytic shellfish toxins (PST), diarrhetic shellfish toxins (DST), amnesic shellfish toxins (AST) and neurotoxic shellfish toxins (NST), but not for Azaspiracid (AZA). The levels set in the FSC are currently not comparable to those set internationally (see below).
Currently in Australia, shellfish producers are facing the situation of having different regulatory standards applied for marine biotoxins, depending on whether the product is destined for domestic or international trade. This has caused confusion and extra work for regulators to prepare the data. By harmonising the MLs, it will allow the Australian industry to follow the same rules as other international bodies which will resolve the issues mentioned above, as well as facilitate improved market access.
The variations between Codex (Standard 292-2008 and Standard 312-2013) and the FSC are currently as follows:
- The maximum level (ML) allowed for DST in molluscan bivalve shellfish is 0.16mg/kg in Codex, but 0.20mg/kg in the FSC
- PST are reported in saxitoxin dihydrochloride (STX.2HCL) equivalents in Codex, but as STX equivalents in the FSC
- Codex lists toxin analogues to include for analysis in each marine biotoxin group, the FSC does not
- Codex lists criteria that appropriate methods for marine biotoxin analysis must meet, and provides guidance on the choice of toxicity equivalency factors (TEF), the FSC does not
- A ML for AZA in listed in Codex Stan 292-2008 but not in the FSC
- Codex Stan 312-2013 requires the application of the bivalve limit for PST to abalone
Discussions with FSANZ determined that the FSC does not include information on individual toxin analogs, methods of analysis or guidance on TEFs. At the 2017 ASQAAC workshop, it was requested that SafeFish focus on the PST application first as this was the matter of highest priority, following this it will be determined by ASQAAC if an application to amend the DST limit and to consider implementing a limit for azaspiracid should also be progressed.
National Strategy for Ciguatera Research and Risk Management
Ciguatera Fish Poisoning (CFP), a well-known illness in tropical regions, is caused by the consumption of fish that have accumulated naturally occurring toxins produced by certain benthic dinoflagellate species, such as Gambierdiscus spp. Ciguatoxins (CTX) are cyclic polyether toxins that accumulate through the food chain and can cause CFP, even when CTX levels in fish are very low. Ciguatoxins from the Caribbean (C-CTX) and Pacific regions (P-CTX) are structurally distinct and appear to have different potencies. Affected individuals often suffer a combination of gastrointestinal and neurological symptoms requiring hospitalisation. Although death due to CFP is rare (last confirmed death in Australia occurred in 2001), CFP often manifests itself as a chronic disease. Despite significant underreporting (only an estimated 10-20% of cases are reported in Australia ), the incidence of CFP is increasing in tropical regions (an estimated 10,000-50,000 people are globally affected each year ). The globalisation of trade has increased market exposure to potentially affected fish (e.g. the Rapid Alert System for Food and Feed of the EU notified the presence of CTXs on four occasions in 2016  and several NSW cases were linked to imported fish ). The apparent global increase in the frequency of CFP outbreaks has highlighted the paucity of scientific information available for informing effective management practices (currently limited to rudimentary, unverified guidelines rejecting certain fish based on species, size, and origin).
In Australia, the majority of CFP cases have historically occurred in the tropical regions (Queensland and the Northern Territory), yet an increasing number of incidents have been reported from New South Wales in recent years (12 cases in 2016 alone ). Despite CFP accounting for the majority of food safety outbreaks related to seafood consumption in Australia (106 outbreaks affecting 465 people since 2000 ), no consistent national response to ciguatera incidents currently exists. Record keeping and reporting is fragmented across state health departments, with little or no effective sample trace back.
As no rapid screening tools for CTXs are currently available, quantification relies on costly LC-MS methods. However, a lack of available CTX standards severely restricts the development of analytical test kits and hampers fundamental ecological research. A new joint initiative by the FAO, IAEA, IOC-UNESCO and WHO aims to address this paucity of information by better organising the international research effort and facilitating the development of large funding applications (e.g. to the Bill Gates Foundation). SafeFish is ideally situated to serve as an instrument facilitating the coordination of the Australian research effort on a national level to ensure Australia’s representation in future international funding applications.In addition to this, an Australian workshop will also be facilitated that will bring together international and local experts in the field to explore all of the Australian research that is available and to determine a national strategy for research efforts and capability development in the future.
Extension Activity: National Seafood Incident Response Plan
There is no current nationally co-ordinated seafood food safety incident response plan (SIRP) available in Australia. The development of such a plan will enable prompt, effective and unified response to any seafood related food safety incident, mitigating the negative impacts associated with such events.
A SIRP would include the following:
- Description of when the response plan will be activated, and who would activate and co-ordinate it
Key roles and responsibilities for parties involved
A blueprint for communication – who would communicate, how and when
Contact lists for key organisations and representative personnel for the seafood associations, regulators, technical experts
Media responses - who would speak to media, how media messages would be drafted and distributed
How follow up analysis would be undertaken to improve the plan
There are many examples of food safety incidents that have had significant impacts on the profitability of a business. Often these extend further and impact on the whole sector, not just the original company involved (melamine in milk powder (October 2008), Listeria in rock melon (March 2018), Hepatitis A outbreak from Wallis Lakes oysters  (1997)). Since 2016, FSANZ has been running annual workshops on incident response management and these events are attended by all the major food sectors in Australia. The importance of a sector wide incidence response plan has been highlighted in these workshops, as it enables industries to be better prepared to deal with emergencies when they arise, provides them with a standardised approach and format to follow, identifies the appropriate parties to engage with and keep informed, and gives them the tools and resources to manage the event in the most practical and timely way possible. Seafood is now the only primary industry sector that does not have a unified incident response management plan as Horticulture have recently completed this process. A SIRP was created in 2012 under the auspices of Seafood Services Australia (SSA), however SSA was disbanded soon after and there has not been an appropriate body to implement or maintain the SIRP since then.
During the 2018 SafeFish prioritisation process, it was determined that developing a SIRP was a high priority for the seafood industry but due to the scope and lack of resources available at the current time, the issue was not adopted for progression. SafeFish is however assisting Seafood Industry Australia with preparing a bid to obtain additional funding to progress the work in the future.