Australian Anglers Association, (WA Division) Inc.

Submission on Definition of Fillets and Filleting Rules.

The Australian Anglers Association has sent the following letter to the Minister for Fisheries.

We have finally received a reply from the Fisheries Minister as below which has shown that the Fisheries Department has ignored some of the important issues we raised. We'll be following these up with another letter.

31 July 2003
The Honourable Kim Chance, MLC,
Minister for Agriculture, Forestry and Fisheries
11th Floor, Dumas House
2 Havelock Street
West Perth 6005

Dear Mr Chance

Definition of Fillets in Possession Limits, and Filleting of Fish at Sea.

I refer to our informal discussions after the recent Recfishwest breakfast. Thank you for your invitation for the Association to write to you on two subjects, the definition of fillets in the proposed possession limits, and the proposed rules for filleting of fish at sea.

These two topics are among those of great concern to recreational anglers since the announcements of the proposed changes to recreational fishing rules.

Definition of "fillets"

The possession limits for recreational anglers from 1 October 2003 includes options of (1) two day's bag limit of whole fish, (2) one day's bag limit of whole fish plus 10 kg of fillets, or (3) 20 kg of fillets.

We understand from some verbal advice we have received from officers of the Department of Fisheries that the proposed definition of "fillets" would apply to anything other than a whole fish. That is, a fish which has been gilled and/or gutted, or with it's head or tail removed, or a long fish cut into two pieces, would be classed as "fillets" and the weight option limit applied. This definition would lead to some problems for people who want to care for and get the best from their fish.

The clear intention of the rules is to allow the angler to choose the option of keeping "whole" fish as part or all of his possession limit. However, when the possession limits apply, anglers are often away from their residence and usually have limited ice box and freezer size and space, and are unable to fit anything other than small to medium whole fish into storage.

If these whole fish options cannot be used in practise because of the definitions that are to be applied, then the application of the rules does not agree with the intention, and recreational anglers lose options which it was intended to and should actually be available to them.

We write this letter to ask for a realistic approach to the definition of "fillets" and "whole" fish so that the spirit of the limits can be maintained, and the details will allow some flexibility in storing and caring for the fish an angler is allowed under the possession limit options. This letter does not ask for any change to the possession limits.

The dictionary definition of "fillet" is "a strip or compact piece of boneless fish", however we prefer the generally accepted usage which includes a complete side of a fish taken off the backbone, as well as pieces processed to the "ready to cook and eat" stage.

We ask that the rules be amended and clarified so that:-

1. Fish which have been gilled and/or gutted will still be considered as "whole" fish.

2. Fish which have the head removed and/or tail removed will still be considered as "whole" fish, and if necessary, be called by a new category called "bodies", not "fillets".

3. Fish or "bodies" which have been cut in two or three pieces will still be considered as "whole" fish, to allow storage in ice boxes or freezers.

We trust in the ability of Department of Fisheries Inspectors to be able to identify fish species from their bodies, to match parts of large whole fish, and to decide how many fish were in possession to be counted for one of the "whole fish" options.

Ban on filleting at sea or on islands.

The proposed changes on 1 October include the following rules:- "No filleting at sea or on islands unless the fishing trip is longer than 48 hours. All fillets must be more than 30cm in length. Skin and scales to be left on. Two fillets or pieces of fish equals one fish."

It is understood the principal reason for these rules is to help with compliance checking. However, recreational anglers have noted the infrequent contacts for compliance checks in the past, and the changed organisational arrangements which will allow more checks to be made out on the water in future.

The "no filleting at sea...." rule has many unwanted side effects, including:-

People will be unable to process their fish soon after capture to maximise the eating qualities of the fish they want to keep.

More fish will be kept in unsuitable conditions because space is a premium on many recreational fishing boats, thus working against proper caring for fish, particularly during warmer weather.

The heads, carcasses and offal are better returned to the sea where they are not a problem and return the unusable parts to the food chain.

Many charter boat customers expect that fish will be processed during the idle time on the often long trip back to land, and be ready to be taken away when the boat docks.

Some people will clean and fillet fish when they return to boat ramps, leading to pollution of the water in the ramp area, or smells, fly, vermin and bird problems.

Local councils will be left with an extra noxious rubbish disposal problem, which could be very significant at popular locations at weekends and holiday times when rubbish clearance is delayed.

Many caravan parks or holiday accommodation have limited facilities for cleaning fish and others do not allow fish cleaning in their park or disposal of fish offal or waste in their bins.

The many families and people who go fishing on Rottnest on an overnight, weekend or two day trip will not be allowed to fillet the fish to take them back to the mainland.

The wording of the rule seems to apply to all species regardless of size and the risk of non compliance with size and number rules. In the extreme, it would seem to prevent the filleting of a catch of half a dozen herring.

The rule places restrictions on boat or island anglers which are not placed on mainland anglers, many of whom fish in locations or at times where compliance is not easy to check. This complicates the rules which must be followed by a recreational angler.

For all these reasons, we ask that the "no filleting at sea...." rule be removed from the proposed changes.

When this rule is removed, the remainder of the proposed rules make a simple situation into a complicated one for recreational anglers.

The limit on the fillet length seems to apply to all species, and would prevent the filleting of even category 3 (bread and butter) fish, with no obvious benefit for those species. It also prevents filleting of smaller fish or fish of a shape which will not produce a 30cm long fillet. Some fillets shrink after removal, particularly when washed or placed on ice, and a fillet which meets the size limit at the time of removal may be too small when measured back on land.

We are at a loss to see how the proposed rule "Two fillets or pieces of fish equals one fish" fits in with the options for possession limits which are meant to be available to all anglers. We would expect that if fish are filleted, then one of the weight limit possession options must apply. If cut into pieces then options as discussed above should apply.

The requirement for skin and scales to be left on places restrictions on boat or island anglers which are not placed on mainland anglers, and is of no benefit unless a significant number of compliance checks will be conducted before or when the fillets are landed.

Therefore we ask that these rules be removed also.

Thank you for the opportunity to present our views on these subjects.

Please contact me if any further information is required.

Terry Fuller, Secretary, Australian Anglers Association, WA Division


We have received a reply from the Fisheries Minister as follows:-



Mr T Fuller, Secretary, Australian Anglers Association, P0 Box 2200, MARMION WA 6020

Dear Mr Fuller

Thank you for your letter of 31 July regarding the new management arrangements for recreational fishing.

With regard to your comments on the definition of whole fish and the ban on filleting at sea, I will answer your issues in the order raised.

Fish which have been gilled and gutted should be considered as whole fish.

Currently fish which have been gilled and gutted are considered to be whole fish and this arrangement will continue in the future.

Fish which have the head and or tail removed should be considered as whole fish.

For the purpose of the possession limit currently two pieces of fish are considered to equal one fish. I acknowledge that this creates a problem where someone removes the head and tail from two fish and is left with two whole trunks of fish which would be classified as one fish.

To rectify this situation for the purposes of the bag and possession limits I have approved an amendment to the regulations that will direct that once a fish has been landed, its head and tail may be removed, and the trunk is defined as a whole fish. If a fish is processed down into any smaller pieces they will fall under the weight restriction of 20kgs.

Fish which have been cut into multiple pieces should be considered as whole fish.

Allowing fish to be processed into a number of pieces and still called "whole fish" would make enforcing bag and possession limits very difficult and where people are sharing containers to store fish it would be virtually impossible. It is for these reasons that if a fish is filleted or processed down into a number of small pieces the fish will fall under the weight possession limit.

Filleting at sea should be allowed

The reasons you have outlined for allowing fish to be filleted at sea primarily relate to the ease and convenience associated with being able to process fish at sea. These issues were thoroughly discussed during the public review process for both the West Coast and Gascoyne Regions.

As you are aware minimum size limits are an important conservation measure designed to ensure adequate recruitment into the fishery. It is important that Fisheries Officers have the capacity to enforce these controls at the point of landing. Allowing people to fillet at sea simply because of the inconvenience of keeping fish whole would severely impact on the effectiveness of this important conservation control.

It should be noted that surveys clearly show angler return rates on undersize fish are very high for many species. The recent National survey on recreational fishing indicated that around 30-40% of the recreational catch is returned to the water. This highlights the importance of minimum legal size limits as an important conservation control.

An allowance has been made for mackerels, tunas and shark due to their excessive length. Mackerels and tunas may be filleted at sea on day trips provided each fillet is a whole side of the fish with the skin and pectoral fin attached. Likewise shark may be trunked. Processing these fish in this matter will enable Fisheries Officers to judge whether the fish were above the minimum legal size.

Also given that some people who are conducting extended trips or staying on islands may wish to process some of their catch a provision has been made to allow fish to be processed as long as the fillet length is greater than 30cm and the skin and scales are left on the fillet. Setting a minimum fillet length will help ensure undersize fish can't legally be processed. Once fish have been filleted at sea they will fall within the weight possession limit of 20kg of fillets or 10kg of fillets, plus one day's bag limit if people choose to keep some fish whole.

Setting the minimum fillet length at 30cm was essential to provide protection for a suite of larger demersal species. If Fisheries Officers are to have the capacity to enforce size limits the only alternative to not having a minimum fillet length is to require people to land fish in whole form regardless of the length of stay at sea.

Catch care and eating quality

I am advised that extensive research in the commercial marketing sector over the last 10 years has clearly shown that fish attain their optimum quality and shelf life if stored whole packed in ice or plunged into an ice slurry as soon as possible after capture. This method ensures that the core body temperature of the fish is rapidly reduced, slowing down the bacterial action that starts the moment the fish is killed, and which leads to the breakdown of tissue and gradual decay. Rapid chilling of whole fish, and filleting just before consumption, ensures a very high eating quality, with the texture and flavour of a recently caught fish. Fish chilled and packed whole in ice retain their quality for well over 10 days.

By contrast fish that are filleted begin to decay at the moment the flesh is exposed to the air, and bacterial action commences. Fillets stored on top of ice, even in a bag, do not reach a low enough temperature prevent rapid bacterial action, and if exposed will absorb water and become mushy and unpalatable in a short period of time.

The Department of Fisheries will be including more detailed information on the storing and handling of fish as part of the community education program associated with the implementation of the Gascoyne and West Coast reviews.

Disposal of offal

The issues you have raised in relation to the disposal of fish offal are not new, and were, I understand, thoroughly discussed by the regional review working groups. I am advised that in reality very few anglers process their catch prior to landing due to concerns about product quality, and the safety and hygiene issues associated with filleting in boats.

The landing of filleted fish has been prohibited for over a decade in the Ningaloo Marine Park and Shark Bay, and the issues you have raised have been well managed in these areas.

Many Shire Councils now provide fish cleaning stations and rubbish removal services at key boat ramps, and the Department of Fisheries will continue to encourage more of these facilities by providing advice and some supplementary grant funding.

In more remote areas anglers should dispose of their offal at sea either on a subsequent trip, or well away from camping and launching areas. Alternatively it should be bagged with other organic rubbish for proper disposal at a Shire tip site or other suitable location.

Thank you for your interest in this matter.

Yours sincerely

Kim Chance MLC


30 SEP 2003

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