Download English Shellfish Industry Development Strategy

The Shellfish Association of Great Britain
Fishmongers’ Hall, London Bridge, London EC4R 9EL
Tel: 020 7283 8305
Director: Dr Tom Pickerell
Defra
Coastal Access Team
1/01 Temple Quay House
2 The Square
Bristol BS1 6EB
26th November 2009
..
Consultation on proposals to amend the Countryside and
Rights of Way Act 2000 for coastal land
Dear Sir/Madam
I am writing on behalf of the Shellfish Association of Great Britain (SAGB) the UK
industry trade association.
We note in section 4.18 you note “sites such as marinas may contain high-value
equipment and it was feared that unrestricted access could cause a security risk.”
This is followed by section 4.19 that “Natural England will discuss with site managers
the most appropriate position for the route and will take full account of the safety of
visitors and the security of the site when it proposes the position of the coastal route.”
We should point out there are many sites located in intertidal areas where shellfish
cultivation takes place. As it is proposed to make these areas available for public
access we are concerned by the prospect of potential theft of stock. What
precautions will be taken by Natural England to ensure the security of our members?
In question 28 you ask “Do you agree that slipways, hards and quays should be
included in the right of access?” The SAGB believes not as some are privately owned
and used commercially and can be potentially hazardous.
In the section on “Control of Dogs” we note there is no mention of the potential
impacts of dog fouling on intertidal shellfish beds. EC Regulations 853/2004 and
854/2004 set out criteria relating to the commercial production and sale of live bivalve
molluscs (clams, cockles, oysters, mussels etc) from classified production areas.
These Regulations are law in the UK and are implemented by means of the Food
Hygiene (England) Regulations 2006.
Data for shellfish waters in England and Wales is compiled by CEFAS, using the
results of monthly bacteriological sampling carried out by Local Authorities.
Production areas are then classified, by the Food Standards Agency, according to
the E. coli levels in the shellfish sampled from the harvesting areas.
Dog fouling can have a potential impact on bacterial load in classified production
areas and we urge Defra to include such areas in section 5.5 as another area where
“tighter control will be necessary”. Section 23(1) entitles landowners to exclude
people with dogs from managed grouse moors for up to five years – again by
notifying the relevant authority. Perhaps shellfish farmers could be afforded similar
protection?
http://twitter.com/sagb
www.youtube.com/user/ShellfishGB
Finally, and related to the above point, the classification categories of shellfish waters
are:



A class - can be harvested for direct human consumption.
B class - can be marketed for human consumption after purification
(depuration) in an approved plant or after relaying in an approved class A
relaying area or after being subjected to an EC approved heat treatment
process.
C class - can be marketed for human consumption only after relaying for at
least two months in an approved relaying area followed, where necessary, by
treatment in a purification centre, or after an EC approved heat treatment
process.
There are currently no class A waters in England & Wales which means that the
shellfish grown there should not be eaten straight from the water, and require further
processing to make them so. If members of the public take these shellfish to eat it
could result in serious illness which could have a serious negative impact on the
entire shellfish industry (see Fat Duck incident for example). What precautions will be
taken by Natural England to ensure public safety and reputational stability for the
industry?
I hope the above is useful, and should you have any further questions, please do not
hesitate to contact me.
Yours sincerely
Dr Tom Pickerell
Director
Shellfish Association of Great Britain
Tel:
Fax:
Mob:
:
020 7283 8305
020 7929 1389
07507 339156
[email protected]