It is considered that sanitary surveys in the current format serve little purpose, as well as being extremely costly and largesse in nature, at a time when public sector organisations examine cost-reducing measures. Desk studies could, perhaps be implemented, if considered to be necessary and a worthwhile pursuit of collating sanitary information. monitor a defined area in a way ensures that, in tandem with harvesters’ own risk management processes, serves to protect public health. Whilst our current approach is considered suitably robust by EU food safety auditors, we are keen to explore what changes could be applied. Despite the full survey programme being suspended at present pending a formal review, FSS continues to commission desk top preliminary surveys on receipt of valid applications where no survey report exists. Cefas 7. We note that there is a requirement of the current food safety legislation that competent authority classifies production areas from which it authorises the harvesting of shellfish and that Noted. The decision to classify an area in the first place is one underpinned by a wider public interest and invites discussion: Is it always
2. Views are sought on the ways in which FSS and industry involved in wild harvest areas and those out with SWPAs might better work together to deliver the sanitary survey requirement in future. Seafish Industry Authority 1. A approach might be the best option as this would be a major undertaking. Away from the coast and in areas away from major human habitation or farm input, a desk review of likely sources and risk effects may suffice. In locations more likely to have some form of input that is likely to be of interest, then samples could be requested from industry, collected under an agreed protocol, and tested at joint FSS / SEPA / Scot Water / industry expense. As the majority of shellfish from these sources are likely to undergo some form of processing before being placed before consumers, consideration could be given to relying upon EPS testing by the FBO of the final product. Cost sharing between businesses is unlikely and if a single business were to bear the cost of classifying an area, there is no easily accessible protection available, at present, to prevent a These points will be considered in the course of the survey review outlined in response 1.
Highland Council 9. FSS should oversee and approve any industry-funded sanitary surveys outwith SWPAs prior to implementation Noted, agree. Fife Creel Fishermen’s Association 10.. Good communication is required between harvesters and the FSS Noted, agree. 3. We intend to ask all new classification applicants to provide classification samples in accordance with an agreed protocol. Is it reasonable to expect businesses to contribute Seafish Industry Authority 1. Businesses already bear the cost of providing stock for testing. Every effort should be made to minimise any additional costs to industry of this proposal. If industry is permitted to provide sample in accordance with the protocol proposed, and the presence of an approved Sampling Officer is not required, then it may assist industry. Noted. All proposals developed will be considered in the wider context of the FSS Regulatory Strategy which seeks amongst other things to minimise any unnecessary additional burdens on business. Blueshell Mussels Ltd 2. What the FSS are suggesting is a 2 tier system regarding shellfish classification. FSS seems reluctant to rely on harvesters own results for ongoing classifications, yet under this proposal, and entirely as a cost control exercise are seeking to pass on this to industry. FSS do not propose a 2 tier classification process, rather we seek to accommodate industry samples, where they have been taken in accordance with a robust and transparent process and to utilise
As an industry we be content to propose a system harvesters submit all the samples that are used for OC, or else the sole responsibility and cost should remain with the FSS. If the consultation only ends on 12th May 2017 how realistic is it to fully answer stakeholder comments of this consultation and then to get a proposal in place by June 2017? industry samples prior to classification being made in new areas. This is permissible by law and we are aware that samples are taken by industry on a regular basis. We are keen to explore how best we can achieve an efficient and effective way of delivering classification (and other) samples and will work with industry to achieve that. Whilst the consultation proposed applying certain changes in June, these have obviously been delayed pending consideration of the points raised. It remains our intention that for new areas, harvesters should provide samples in order to allow FSS to provide an initial classification. This
Noted. Following the views expressed in consultation, FSS will reconsider this point, but in the meantime would ask that information on harvesting activities – when known – is communicated to FSS as soon as possible. Seafood shetland 6. It is not reasonable to request harvesting plans 12 months in advance. Harvesting is subject to the vagaries of site closures, inclement weather, and day to day challenges such as vessel breakdowns, staffing issues etc. 7. This is a question that industry is best placed to answer. As an OC laboratory, our experience is that keeping track of harvesting activity to inform the monitoring programme requires a lot of information gathering by LAs, sampling contractors and co-ordination by the laboratories. It is very dependent on individual FBOs. Following the views expressed in consultation, FSS will reconsider this point. Nevertheless we consider that we need to balance both the practicalities and cost effectiveness of running a ‘call off’ monitoring regime and will only make changes in consultation with all parties including contractors.
depuration system could incorporate an investigation into reducing depuration cycle times by taking multiple timed samples. This would demonstrate that a system is a) capable of producing safe food and (possibly) b) producing safe food in less than the current minimum time of 42 hours. 6. What do you about the proposal that FSS will no longer sample in closed areas on a weekly basis pending verifiable confirmation from food businesses that toxin levels have suitably Seafish industry Authority 1. On the face of it, this is a reasonable proposal. However, not every business, particularly those at the micro or small-scale, will have the resources and expertise to carry out and pay for these tests, even though costs have reduced markedly. Better resourced operators already undertake their own testing and would probably welcome this proposal. Blueshell Mussels Ltd. 2. Historically before a shellfish harvester can harvest from an “open” area the sampling officer has required 2 clear samples to keep sites open. During summer harvesting, because we need so many site options open, this results in frequent sampling.
reduced? Information on the volume of testing currently undertaken by businesses and access to testing facilities or equipment would also be useful. Fife Fishermen’s Association 11. It is felt that testing should continue by FSS until the toxin levels fall to a safe level and then Harvesting could recommence Noted. Only FSS testing would determine whether an area could be opened as is currently the case. 7. How could mobile technology assist in ensuring both sample collection and traceability controls are maintained for shellfisheries? Please describe Seafish Industry Authority 1. Mobile technologies offer many opportunities for this, and geo-tagging is commonplace in many devices. However, as with any technology, they can be misused, so what reliance would FSS place on the data when verification has been required previously. Whilst FSS will endeavour to ensure that only verified official control samples are taken, it is recognised that for some fisheries (particularly wild catch sectors) verified sampling is not possible. Therefore there may be opportunities to consider how mobile technology can be utilised in order to improve traceability in this sector. Blueshell Mussels Ltd 2. Much of Scotland is in signal black spots. Noted. We are currently exploring the use of e-logs within the scallop sector
8. For both wild and aquaculture shellfish businesses we be interested to hear about how phytoplankton is used at a local level. Do you apply different triggers to those used in either the monitoring programme or in the ‘toxin traffic Seafish industry Authority 1. Some of the larger businesses have the resources and expertise to undertake and process their own phytoplankton samples, but many, particularly those that operate at the smaller scales make use of the ‘toxin traffic light’ document. Blueshell Mussels Ltd 2. We use Phytoplankton levels to predict toxin closures and toxin trends and the general activity and movement of toxic algae onto sites. Shetland Mussels Ltd 3. This adds a lot of value for public food safety in being the main tool to see what is going to happen in the future. We use the data in the SAMS report too. We still test all harvests with the kits but where we harvest is steered to a great extent by plankton.