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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]