Risk Management Proposal  
 
Risk Management Proposal Pangasid 
Catfish Products for Human Consumption 
from Thailand   
FISFILIC.SPE  
 
 
 
 
1 June 2018   
  
 
 
Disclaimer  
This risk management proposal does not constitute, and should not be regarded as, legal advice. While every 
effort has been made to ensure the information in this document is accurate, the Ministry for Primary Industries 
does not accept any resp onsibility or liability whatsoever for any error of fact, omission, interpretation or opinion 
that may be present, however it may have occurred.  
© Crown Copyright - Ministry for Primary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for further information : 
Ministry for Primary Industries (MPI)  
Regulation & Assurance Branch  
Animal Imports  
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz  
Telephone:  04 890 0134  
 Risk Management Proposal:  Risk Management Proposal  Pangasid Catfish Products for Human Consumption from Thailand  1 
June 2018  
Ministry for Primary Industries   Page 1 Contents  
1 Purpose  3 
2 Background  3 
3 Objective  3 
4 Options assessment  3 
5 General import requirements for pangasid catfish products from Thailand  3 
5.1 Commodity definition  3 
5.2 Facility, processing, an d transport requirements  4 
6 Recommendations for identified risk organisms  4 
  
Ministry for Primary Industries   Page 3 1 Purpose  
The purpose of this document is to:  
 Show how options for the management of risk o rganisms in pangasid catfish products from Thailand have 
been assessed.  
 Provide recommendations for import requirements.  
2 Background  
Under t he Import Health Standard for Processed Tilapia and Catfish for Human Consumption  (FISFILIC.SPE) , 
pangas id catfish products for human consumption can be imported only from Vietnam and Malaysia.  Thailand 
requested MPI to include it as one of the specified countries . This document presents the outcome of the review 
of Thailand’s aquaculture and processing syst em and its capability to meet the requirements of the IHS.  
3 Objective  
The objective is to effectively manage biosecurity risks associated with the import of pangasid catfish products 
from Thailand  consistent with New Zealand’s domestic legislation and international obligations.  
4 Options assessment  
Under Article 3.3 of the World Organisation  for Animal Health (OIE)  Agreement on the Application of Sanitary and 
Phytosanitary Measures (the SPS Agreement), risk management measures which provide a level of pro tection 
greater than provided by international standards may be imposed only when they can be scientifically justified on 
the basis of a risk assessment.  
For a detailed analysis of potential hazards and their risks please refer to the following documents,  which contain 
the relevant risk assessment and an analysis of management options for each risk organism.  
 Import Risk Analysis: Frozen, Skinless and Boneless Fillet Meat of Pangasius spp. Fish from Vietnam for 
Human Consumption , dated September 2008  (IRA 2008).  
 
 Supplementary Risk Analysis: Extension  of Countries Eligible to Export Frozen, Skinless, Boneless Fillet 
Meat of Pangasius spp. under the Import Health Standard FISFILIC.SPE , dated April 2010  (IRA 2010) . 
 
 Import Risk Analysis: Eviscerated Fish for Human Consumption ; due for publication late 20 18. 
5 General import requirements  for pangasid catfish products 
from Thailand  
5.1 Commodity definition  
For the purposes of the Import Health Standard for Processed Tilapia and Catfish for Human Consumption  
(FISFILIC.SPE),  the commodity eligible for import to New  Zealand from Thailand is: 
(1) Skinless , boneless, frozen fillets (or mince derived fro m fillets) ; 
(2) Derived from  Pangasius  spp. that have been farmed and were con tinually resident in Thailand ; 
(3) Not derived from CITES listed species;   
Ministry for Primary Industries   Page 4 (4) Not derived from fish that were slaughtered as an official disease control measure as a result of an 
outbreak of disease ; 
(5) Derived from fish that at the time of harvesting for processing did not show any clinical signs of disease, 
septicaemia or skin ulceration;  
5.2 Facility, processing,  and transport requirements  
(1) The fish are sourced from aquaculture farms registered with the Competent Authority of Thailand.  
(2) The fish are processed in establishments approved by the Competent Authority of Thailand;  
(3) Commodity is d erived from fish processed using water fit for human consumption;  
(4) Commodity is frozen to -18°Celsius for at least 168 hours.  
6 Recommendations for identified risk organisms  
(1) IRA 2008 , IRA 2010 and the Import Risk Analysis: Eviscerated Fish for Human Consumption  identified the 
following  organisms of potential concern associated with Pangasiidae, or to which Pangasiidae are known 
or believed to be susceptible : 
 Acinetobacter spp. 
 Aphanomyces  invadans  
 Atypical Aeromonas spp.,  
 Chromobacterium violaceum  
 Digenean metacercaria,  
 Edwardsiella  ictaluri  
 Edwardsiella tarda  
 Enterobacter spp. 
 Flavobacterium  spp. 
 Grass carp haemorrhagic virus  
 Iridoviruses  
 Kabatana  arthuri  
 Larval nematodes  
 Myxobolus omari  
 Serratia marcescens  
 Stenotrophomonas maltophilia  
 Yersinia ruckeri  
(2) All of the above listed IRAs co ncluded that the organisms of potential concern in the commodity , as 
defined in Section 5.1 of this document , will have negligible likel ihood of entry into New Zealand.  
(3) MPI viewed documents the Competent Authority of Thailand had previously submitted, and is satisfied that 
the procedures that are in place in that country would meet MPI’s  facility approval and processing 
requirements  for the commodity . The documents that MPI specifically looked at are:  
a) Fish Inspection and Control Systems . 
b) Proces sing Establishment Inspection Manual . 
c) Condition Laying Down for Approved Processors . 
(4) MPI additionally took into consideration that the fish for processing would be sourced only from 
aquaculture farms registered to the Competent Authority of Thailand. Registered  farms are subject to 
monitoring for regulatory compliance.  
(5) Under the Import Health Standard for Processed Tilapia and Catfish for Human Consumption  
(FISFILIC.SPE),  which has been in place since 2011, Thailand can import into New Zealand fish products 
derived from Oreochromis spp. The conditions of import that are in place for Oreochromis spp. are the  
Ministry for Primary Industries   Page 5 same as being proposed for Pangasius spp. This gives MPI the confidence that Thailand would be able 
comply with the biosecurity import requirements for p angas id catfish products . 
(6) In conclusion, all biosecurity risks associated with pangasid catfish products from Thailand are mitigated to 
a negligible level as long as the requirements in Import Health Standard for Processed Tilapia and Catfish 
for Human Consumpt ion (FISFILIC.SPE) are complied with.