Victoria announced shakeup to PrimeSafe meat regulator red tape and anti-business attitude

Posted by AFN Staff Writers on 2nd November 2015

Victorian meat and seafood regulator PrimeSafe will not become the regulator for meat sold at supermarkets with the state government rejecting this recommendation by an independent review of PrimeSafe and meat and fish regulations in the state of Victoria.


The organisation will also not be responsible for products sold at farmers’ markets and mobile butchers with regulation left up to local councils.


PrimeSafe has accepted 23 out of 24  recommendations from the recent independent review of PrimeSafe which addressed criticism regarding PrimeSafe in relation to factors such as poor communication, excessive regulatory paperwork and over-regulation. 


The review also recommended that PrimeSafe develop a rewards system where those who have a good track record are not subjected to audits as frequently as others.


Despite agreeing to take up the recommendations, PrimeSafe Chairman, Leonard Vallance says some recommendations will take time and possibly testing before they can come into effect.


“We can make some procedural changes immediately – for example approvals for variation to the processing of an existing product,” said Vallance.


“Other whole of system modifications may require testing and analysis to ensure that best practice for food safety in Victoria is maintained. However, we’re committed to addressing the recommendations and will regularly engage with our licensees and stakeholders throughout this process,” Vallance said.

“Consumers rely on the regular independent assessment of food businesses achieving Australian food safety standards. The regulations under which PrimeSafe operates are prescribed by Government but everyone has a role to ensure that food is safe to eat,” Vallance said.


The review was based on the outcome of 45 interviews with meat and fish licence-holders, and industry and support groups. It also received 20 written submissions.


PrimeSafe was officially established in July 2003 under the Seafood Safety Act 2003 and the Meat Industry Act 1993. It is responsible in Victoria for the safety and regulatory enforcement of the rules of production and sale of meat, seafood and pet food, but with certain exceptions as mentioned above.


Complete list of recommendations


The complete list of recommendations as published by PrimeSafe is as follows:






  1. That PrimeSafe consider providing regular updates to licensees, containing information about relevant regulatory developments, PrimeSafe’s activities, and developments in food safety science and technology.


  1. That PrimeSafe continue its program of hosting “forums” on aspects of food safety compliance, in both metropolitan and regional areas.




  1. That, in its communications with licensees, PrimeSafe clearly distinguish between: (a) documents that contain uncontroversial general information; and (b) documents (like PrimeNotes) in the nature of guidelines, which set out PrimeSafe’s views on how the standards should be interpreted.


  1. That, where PrimeSafe proposes to release a document in the nature of a guideline, it adopt the following process: (a) develop a draft guideline; (b) make the draft guideline available for comment, and invite consultation from licensees and other stakeholders; (c) make appropriate changes in light of the consultation process; (d) provide licensees with notice of when the guideline will come into effect; and (e) give licensees sufficient time to adjust their practices (if necessary) before the guideline comes into effect.

Education and training


  1. That PrimeSafe consider ways in which it can encourage the development of education and training programs, in particular, in relation to quality assurance practices in the meat industry and the manufacture of smallgoods and UCFMs.




  1. That PrimeSafe introduce a system of pre-application consultation, allowing applicants to consult with PrimeSafe in relation to a proposed application for a new licence, an amendment to an existing licence or approvals relating to new products and processes, before a formal application is made to PrimeSafe.


  1. That this system of pre-application consultation should identify for the applicant the criteria that PrimeSafe will consider when assessing the application and, where appropriate, make suggestions as to how the applicant might be able to meet those criteria. 2




Reducing Paperwork


  1. That PrimeSafe investigate whether it is possible to reduce the paperwork associated with compliance through the use of technology, building on its existing commitment to work with third party auditing companies to implement electronic reporting and data transfer. Sample Sizes for Listeria Testing


  1. That PrimeSafe consider amending its listeria testing requirements so that testing is only required of samples of products rather the product “as sold”.




  1. That PrimeSafe consider developing a simplified process for licensees to seek approval for variations of an approved product in circumstances where PrimeSafe determines there is little risk associated with the proposed change.




Reward for Performance


  1. That PrimeSafe develop a new reward for performance program which will result in audit frequency being reduced in circumstances where a licensee has a good audit track record (determined by reference to the licensee’s immediate past audit history).


  1. That PrimeSafe adequately publicise the new reward for performance program so that licensees are aware that it is available to them.


Auditor’s Code of Conduct and Complaints


  1. That PrimeSafe inform licensees of the Code of Conduct applicable to auditors and the avenues that are available to raise complaints against auditors.


  1. That PrimeSafe implement a process by which audit companies must notify PrimeSafe of any complaints made in relation to auditors who are used by PrimeSafe licensees to enable PrimeSafe to monitor the progress and outcome of those complaints.


Internal Review of Auditor’s Decisions


  1. That PrimeSafe consider implementing a system under which decisions by auditors to issue major or critical CARs are subject to review by a suitably qualified person within PrimeSafe who is able to substitute his or her own decision for that taken by the auditor.


  1. That PrimeSafe adequately publicise any such internal review process so that licensees are aware that it is available to them.


Escalation of Audits


  1. That PrimeSafe identify for licensees the decision-making process in relation to escalation of audit frequency, so that licensees can be fully informed of the steps taken by PrimeSafe before a decision is made to increase audit frequency.


  1. That PrimeSafe provide licensees with an opportunity to make submissions to PrimeSafe before a decision is made by the Chief Executive Officer to increase the frequency of audits. 3




  1. That PrimeSafe continue to engage with government and other stakeholders to bring about the legislative changes necessary to allow PrimeSafe to regulate farmers’ markets, mobile butchers, and supermarkets.


*Note: Recommendation 19 is for Government’s consideration.




  1. That PrimeSafe communicate to the seafood industry the results of its consideration of its wildcatch and aquaculture compliance and auditing arrangements.


  1. That PrimeSafe consider whether the licensing fees charged to the seafood industry are disproportionate to the costs of regulating that industry and, if they are, that PrimeSafe take that matter into account in its next review of licensing fees.


  1. That PrimeSafe consider whether the water and shellfish testing requirements it has imposed at fisheries in Victoria are warranted, and comply with PrimeSafe’s obligations under the Statement of Expectations.




  1. That PrimeSafe express in writing all significant decisions and other communications that affect the rights and interests of licensees.


  1. That PrimeSafe ensure that it responds to communications from licensees and other individuals in a timely fashion, and communicates appropriately where there iis likely to be a delay.”