The following additional principle is DPP 1: Should relate to the 26. Queensland The draft policy suggested: The regulation of residues development of food regulatory Whole principles need to be of agricultural and veterinary measures and amendments to the more specific. of chemicals in food should include a ANZFSC, it is not considered Government default residue level for minor appropriate for the policy guideline inadvertent agvet residue to refer to ‘response’ measures. contamination. DPP 2: it is not appropriate to refer to of governments. ‘capacity’issues DPP 3: this principle may be inadequate if: it is insufficiently flexible to allow regulatory agencies to manage the disposition of food containing residues from inadvertent contamination or legitimate chemical use on imported product; and is inconsistent with the more flexible risk based approach use for other constituents or hazards in food. DPP 4: necessary to establish a unique set of trade based MRLs that take into account case by case consideration of current domestic MRLs and Codex MRLs. The higher level of APVMA MRL and Codex MRL should be established for trade purposes. If individual case by case residue levels are not established residues of agvet chemicals in imported foods must comply with either: the relevant Food Standards Code MRL, or the relevant Codex MRL, or if neither (a) or (b) exist then residues must not exceed any established default level. DPP 5: Support, provided •
26. Queensland Whole of Government The draft policy principles need to be more specific. The following additional principle is suggested: The regulation of residues of agricultural and veterinary chemicals in food should include a default residue level for minor inadvertent agvet residue contamination. DPP 1: Should relate to the development of food regulatory measures and amendments to the ANZFSC, it is not considered appropriate for the policy guideline to refer to ‘response’ measures. DPP 2: it is not appropriate to refer to ‘capacity’issues of governments. DPP 3: this principle may be inadequate if: it is insufficiently flexible to allow regulatory agencies to manage the disposition of food containing residues from inadvertent contamination or legitimate chemical use on imported product; and is inconsistent with the more flexible risk based approach use for other constituents or hazards in food. DPP 4: necessary to establish a unique set of trade based MRLs that take into account case by case consideration of current domestic MRLs and Codex MRLs. The higher level of APVMA MRL and Codex MRL should be established for trade purposes. If individual case by case residue levels are not established residues of agvet chemicals in imported foods must comply with either: the relevant Food Standards Code MRL, or the relevant Codex MRL, or if neither (a) or (b) exist then residues must not exceed any established default level. • DPP 5: Support, provided