1: Summary of issues Issue Comments FSANZ Response Sale of raw goat milk Many submissions provided during the assessment of P1007 FSANZ will not be considering the exemption allowing the laws of States and were from consumers in support of access to raw drinking milk. Territories to provide otherwise in relation to pasteurised milk under P1022. In the approval report for P1007 FSANZ stated that it would This remains a State and Territory issue. further assess the current exemption in subclause 15(1) allowing the laws of States and Territories to provide otherwise in relation to pasteurised milk. Additional detail on the Submissions from enforcement agencies, in particular, raised has developed and is seeking comment on a draft guidance document on the measures to be specified for the need for additional information around the proposed control measures proposed for raw milk products. raw milk products measures for raw milk products so that it could be clearly understood what outcomes were required and how these could be monitored and verified. This would assist implementation. Microbiological criteria Submissions from government agencies, industry and Amendments to Standard 1.6.1 to set appropriate limits for raw milk products will consumers raised the need to amend the microbiological be progressed through P1022. standards in Standard 1.6.1 to reflect the approach that has been taken. The current E. coli limit in cheese was highlighted as too onerous and inconsistent with international standards. In addition to limits in Standard 1.6.1, submissions from FSANZ has developed and is seeking comment on a draft guidance document that government and industry recommended that microbiological includes criteria for monitoring and verification purposes. criteria for testing raw milk (at primary production) and finished product is needed. Imported products The need for clearly defined and verifiable processes to FSANZ will work closely with the Department of Agriculture to inform the risk manage the risks from imported raw milk products was raised. management approach to be applied to imported products. This approach will be outlined in the 2nd call for submissions report.
1: Summary of issues Issue Comments FSANZ Response Sale of raw goat milk Many submissions provided during the assessment of P1007 were from consumers in support of access to raw drinking milk. In the approval report for P1007 FSANZ stated that it would further assess the current exemption in subclause 15(1) allowing the laws of States and Territories to provide otherwise in relation to pasteurised milk. FSANZ will not be considering the exemption allowing the laws of States and Territories to provide otherwise in relation to pasteurised milk under P1022. This remains a State and Territory issue. Additional detail on the measures to be specified for raw milk products Submissions from enforcement agencies, in particular, raised the need for additional information around the proposed control measures for raw milk products so that it could be clearly understood what outcomes were required and how these could be monitored and verified. This would assist implementation. has developed and is seeking comment on a draft guidance document on the measures proposed for raw milk products. Microbiological criteria Submissions from government agencies, industry and consumers raised the need to amend the microbiological standards in Standard 1.6.1 to reflect the approach that has been taken. The current E. coli limit in cheese was highlighted as too onerous and inconsistent with international standards. In addition to limits in Standard 1.6.1, submissions from government and industry recommended that microbiological criteria for testing raw milk (at primary production) and finished product is needed. Amendments to Standard 1.6.1 to set appropriate limits for raw milk products will be progressed through P1022. FSANZ has developed and is seeking comment on a draft guidance document that includes criteria for monitoring and verification purposes. Imported products The need for clearly defined and verifiable processes to manage the risks from imported raw milk products was raised. FSANZ will work closely with the Department of Agriculture to inform the risk management approach to be applied to imported products. This approach will be outlined in the 2nd call for submissions report.
P1022-PPPSRawmilk-1CFS.docx