Australian Food Sovereignty Alliance

Fair food for all Australians

Farmers Markets are an Essential Service – Keep them open!

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MEDIA RELEASE: 26 March 2020

Farmers’ Markets are an Essential Service – Keep them open!

The Australian Food Sovereignty Alliance (AFSA) is working to assert and secure everyone's right to access nutritious food grown and distributed in ethical and ecologically-sound ways.

Farmers' markets are excellent sources of this food grown by Australia's small-scale farmers, and play a critical role in ensuring food security for Australians, while also ensuring the ongoing viability of small-scale farmers and food producers.

AFSA has received information from farmers and eaters around the country of the threat of closures of their local markets during the COVID-19 pandemic, while supermarkets, butcher shops, and bakers have permission to trade with safety protocols in place – as they should.

We assert that all farmers' markets should be allowed to remain open as an essential service, just as other venues that sell food for household consumption, with all precautions taken for community safety. Farmers’ markets are, by virtue of being outdoors, inherently lower risk for disease transmission than their indoor retail food market counterparts.

Markets around the country are continuing to trade responsibly, by only allowing produce stalls to remain open (no non-essential consumer items), with strict rules around social distancing, including no more than one shopper at each stall, no handling of produce, and provision of hand sanitising facilities.

We are calling on all levels of government to protect our farmers, and the community's right to access safe, nutritious, ethical, and ecologically-sound produce through this unprecedented crisis.

If you are a farmer or eater in need of support to advocate your right to hold or attend a local farmers’ market, with strict safety guidelines in place, please contact us on admin@afsa.org.au.

Contact: Tammi Jonas, President                       

0422 429 362                                                                                          

president@afsa.org.au

2019 President’s Report

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What a delicious year of growing and eating and winning and celebrating it’s been for AFSA! And yet while the food sovereignty movement has had many successes, I’d like to acknowledge the very real struggles farmers across Australia, especially in the east, are facing in the worst climate-change-affected areas. The past year has seen the loss of countless farms as the rains simply haven’t come, dams and water allocations have dried up, and grain stores run out. Australian dairy farms are in crisis, as are pig and poultry farms reliant on grain inputs that have had astronomical price rises, and horticulture farms reliant on rain that hasn’t fallen or water stolen further upstream by big irrigators with the support of corrupt government policies. AFSA is committed to supporting farmers in climate-proofing their farms and business models with agroecological and degrowth practices to ensure a future of radical abundance is possible for all.

This time last year we saw the introduction of simplified guidelines for pastured pig and poultry farms in Victoria. It was a hard-won result after three years of working closely with the Victorian government to achieve acknowledgement of the low risk small-scale pastured pig and poultry farms pose to community amenity and ecosystems.

Meanwhile, we were also working hard on AFSA’s second book Farming Democracy: Radically transforming the food system from the ground up – launched in March 2019. Farming Democracy is the story of eight diverse and fascinating small-scale regenerative farmers from around Australia. In telling their stories each farm identifies and illustrates many of the issues they have faced in their quest to establish a fair, democratic, sustainable and resilient food system on their farm.

The farms in the book are as diverse as the food they produce, some with full or partial control of their supply chains, with varying levels of diversity and integration in their models, and at different places in their thinking about the role of growth in their businesses, all thoughtful in their approaches. They opened their hearts, their farms, and even their books to show what it costs (and earns) to grow and distribute food in ethical and ecologically-sound ways.

We launched the book at Farm Day Out at Jonai Farms in the central highlands of Victoria, a region that is an epicentre of the small-scale regenerative and agroecological farming movement. While the event itself was not a successful fundraiser for AFSA as intended, it was a joyful day of like-minded people working towards a food sovereign future fuelled by good tunes, great vibes, and excellent food. Important lessons about the way we try to fundraise for the food sovereignty movement were learned.

In April, we welcomed the visit by the UN’s High Level Panel of Experts to Canberra, where they explained their newest report on agroecology and ‘other innovations’ for sustainable agriculture, and noted with dismay the stark difference in the CSIRO’s understanding of and demonstrable lack of support for agroecology, a position we’ve witnessed regularly in the Australian government’s participation in international meetings of various governing bodies of the UN.

AFSA happily accepted an invitation to become a member of the newly constituted Regenerative Agriculture Alliance established at Southern Cross University (SCU). Together with new and old comrades from across all scales of the regenerative farming movement, we’re working to influence policy at all levels to support the management of healthy soils to repair Australia’s degraded landscapes and assure a prosperous and long future for Australian agriculture.

Many AFSA members and Committee members attended the fifth annual Deep Winter Agrarian gathering at Willunga in South Australia, renewing and striking new friendships and camaraderie with the movement of small-scale regenerative and agroecological farmers and our allies. We issued a declaration calling for recognition of the long experience and deep traditional knowledge of the Traditional Owners’ food production and care for land, increased attention to our critically endangered soils using holistic management and regenerative practices in agriculture, and for increased farmer and community control of the means of production – supply chain infrastructure such as abattoirs, boning rooms, grain mills, and the like.

AFSA are part of a global movement opposing the introduction of GMOs into the food chain without adequate regulation and scant consideration for human health. In solidarity with other organisations and individuals working to stop the de-regulation of GMO in Australia and globally, we have written to politicians and attended meetings advocating for safe regulation and labelling of GMO. New moves to de-regulate ‘new breeding techniques’ put all of us at risk of eating untested, unlabelled genetically modified (GM) foods – including animals. Powerful scientific evidence shows that new GM techniques such as CRISPR pose risks that require expert assessment and management. It’s vital that gene edited organisms are assessed for safety before being released into our environment and supermarkets.

While we reluctantly farewelled the exuberant Sarah de Wit, our excellent inaugural AFSA Legal Defence Fund paralegal, it was with great pleasure that we hired Airlie Morris, a lawyer with 20 years’ experience, to build on Sarah’s foundational work supporting and advocating for small-scale farmers, food producers, and eaters in Australia.

It was another busy year writing government submissions advocating for small-scale farmers and everyone’s right to nutritious and delicious food. Amongst a number of other submissions around the regulation of veterinary and agri-chemicals, protection of valuable agricultural land around Melbourne, animal welfare standards, and the impact of animal rights activists on livestock farmers, we put a strong case against FSANZ’s proposal to require a licence to sell lettuce, which we cautiously believe looks unlikely to proceed.

Our international work (funded by the Food & Agriculture Organisation (FAO) of the UN) has remained strong, with participation at the UN Commission on Genetic Resources for Food and Agriculture (CGRFA) as sub-regional members of the International Planning Committee for Food Sovereignty (IPC), where the first Report on the State of the World’s Biodiversity for Food & Agriculture was launched. The world is losing biodiversity at an alarming rate, and the UN is under no illusions that industrial agriculture is playing a significant part in the problem, while agroecology can play a major part in the solutions. We were honoured to be part of seed sovereignty meetings in northern Italy and learn some of the ways communities of farmers are wresting back control of seeds from the handful of multinational corporations who control the global seed supply.

Two of our farmer members of the National Committee attended the annual regional conference of La Via Campesina in Japan, and another the regional women’s conference in Thailand, working with our comrades from across South East and East Asia to shine the light on the negative impacts of multinational corporations controlling the food system and promoting the rights of peasants and Indigenous Peoples to collectively determine their own food and agriculture systems.

AFSA Secretary Ruth Gaha-Morris was selected for the sub-regional role on the Coordinating Committee of the Civil Society Mechanism (CSM), which articulates to the UN World Committee for Food Security (CFS), and joins us at this year’s Food Sovereignty Convergence directly from meetings in Rome.

Scanning the horizon, AFSA have our sights set on legalising sales of raw milk from the farm gate as one means of saving Australia’s dying dairy industry while giving people the choice to consume unprocessed foods from a safely regulated industry. We’re also closely monitoring the rise of false solutions to the problems of industrial agriculture such as the corporate-controlled rise of mass-produced vegetable-based protein patties and lab meat. We reject all ‘solutions’ that simply maintain corporate control of the food system in an undemocratic capitalist economy.

I’d like to thank the 2019 National Committee and staff for your work and commitment to the food sovereignty movement locally and globally, as well as your camaraderie and many shared feasts over the year. To those who are leaving us to focus on fertile grounds at home and in your local communities – Anna Treasure, Fraser Bayley, Kat Munksgaard, and Jess Brugmans – a special thank you and fare thee well!

We fight for what we eat, we eat what we fight for!

Viva la revolución!

Tammi Jonas, President

22 October 2019

The Willunga Agrarian Declaration

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For 60,000 years Indigenous Australians have eaten food as their medicine, and yet today Australia, like most of the world, has a disease industry largely caused by a highly industrialised food system.

Over two days in June 2019, 150 small- and medium-scale, mostly young farmers, farm and food workers, educators, and other allies came together from across Australia to meet on the traditional lands of the Kaurna people, who have cared for this land and maintained biodiversity through careful observation, cultivation, and judicious use of fire since long before and after Invasion.

At the fifth annual Deep Winter Agrarians gathering in Willunga, South Australia, we celebrated the opportunity to meet each other to continue weaving relationships, alliances, and solidarity. We strengthened our commitment to grow and distribute food in ethical and ecologically-sound ways, and to assert our collective right to democratically participate in food and agriculture systems.

The weekend was rightly framed and founded on considerations of soil and climate, with a stirring address from climate scientist and soil microbiologist Walter Jehne, who declared that promises of 5% reductions in emissions are political obfuscation. Walter called for a dramatic draw down of carbon – and assured us we can do that simply and naturally by fostering the fungi in our soils that digest carbon. Only with rapid transitions away from the destructive practices of over-tilling, over-grazing, and feckless application of agrichemicals can we regenerate the wasteland we have created.

Healthy soils are the primary reservoirs for Australia’s scarce water resources, with the potential to hold far more water than they currently do. The solution is to build the soil carbon sponge – we must urgently increase the carbon in our soils to improve its capacity to hold water, and the most obvious and clear pathway to that solution is through agroecological practices.

Agricultural producers spend millions of dollars and hours of labour killing things that want to live and growing things that want to die. A weed though, is simply a plant that doesn’t fit our dogma. Weeds are just pioneers that make room for succession. By killing them we constantly recreate the conditions that allow them to prosper – and worse, we kill ourselves while weeds thrive. Ultimately, we agreed that if you can’t beat it, eat it.

There is a paucity of nutritional integrity in food grown in what are essentially hydroponic conditions – fast-growing annuals in tilled soil with regular application of fertilisers. Methods of growing food without tilling are not commonly understood nor practiced. The agrarians in Willunga assert our interest and aims to work to reduce tillage and maintain biomass and healthy mycorrhizal fungi that nurture the roots and ultimately the nutritional integrity of the food we grow.

Farmers have largely lost control of the means of production, and small- and medium-scale farmers are the most vulnerable. Lost access to local abattoirs, grain mills, dairy processing plants, refrigerated storage, and the other infrastructure necessary to transform the produce they grow into saleable products threatens the viability of small and medium-scale producers. Leaders of the emerging grains movement in Australia spoke about their collaborative efforts to localize grain economies, grow heritage grains, and mill them into flour to bake artisanal, nutrient-dense breads.

Some farmers at Deep Winter have already experienced the extremities of our changing climate, suffering such severe water scarcity that they can no longer farm. We re-affirm our commitment to draw down carbon and strengthen the soil carbon sponge on our farms to both mitigate and adapt to climate change, and canvassed ideas to diversify business models and focus on growing biodiverse and resilient species and breeds of plants and animals.

While soil was the foundation of all discussions, we also debated what is the appropriate scale of farming and food businesses focused on feeding people in ethical and ecologically sound ways that are also economically viable. Acknowledging the diversity of scales appropriate to different regions, climates, soils, produce, and production methods, there was consensus that ‘scaling up’ is not inherently good, and should be considered with care for land, animals, farmers, and communities. We acknowledge the strength in collaborative networks of small-scale agroecological farmers and our allies to build diverse and resilient local food economies.

We live in challenging times, and the need for action on climate change has never been more urgent. The ever-growing movement of agroecological farmers embedded in the communities we feed is up to this challenge, and we need everyone to support our efforts to farm responsibly. We call on all of you to pledge to act – one simple action everyone can take is to buy one thing from a farm with a face this week and every week.

Viva la vía campesina! Viva la revolución!

Willunga, South Australia

23 June 2019

Agroecology and ‘Other Innovations’ – Australia on the wrong side of history

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In April, AFSA attended a seminar hosted by the CSIRO in Canberra, giving the High Level Panel of Experts on Food Security and Nutrition (HLPE) a chance to share their current work on Agroecology and Other Innovations for Sustainable Food Systems with the Australian public and policymakers. The HLPE is an expert panel created within the UN Committee on World Food Security (CFS) to facilitate policy debates and inform policy making with independent research.

What is the CFS HLPE report?

The UN Committee on World Food Security (CFS) will launch its High Level Panel of Experts (HLPE) report on "Agroecological and other innovative approaches for sustainable agriculture and food systems that enhance food security and nutrition” on July 3 in Rome. This report is the outcome of a consultation process where participants in the Civil Society and Indigenous People's Mechanism (CSM) have fought hard to distinguish agroecology as a practice, science, and politics from other "industrial" innovations such as so-called "sustainable intensification", biotechnology, and biofortification.

The next step - already agreed-upon by governments - is to use the report to guide a policy negotiation process at the CFS Plenary 46 in October 2019. The work ahead is to advocate for governments to commit to developing and implementing policies needed to address the root causes of hunger, malnutrition, and food insecurity. The CFS policy process, despite its many challenges, is a political tool we can use to push governments to realise the right to food for all, respect and protect local regenerative agriculture and indigenous food systems and strengthen biodiversity through an inclusive, bottom-up political process.

Read on for AFSA president Tammi Jonas' assessment of the Canberra seminar, put together by the CFS HLPE and CSIRO...and the challenges still to come.

Find out more about the CFS and CSM: www.csm4cfs.org

Read about our involvement in the Agroecology policy process and read the HLPE summary:  http://www.csm4cfs.org/working-groups/agroecology/

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The seminar was not particularly well advertised amongst farmers and their representative bodies, and I believe AFSA was the only representative organisation for farmers who attended. In fact, I learned about the seminar from activists and FAO staff in Rome – not through any local channels. Conversely, Bayer was there – the world’s largest supplier of seed and agri-chemicals after last year’s merger with Monsanto – they now control about 25% of the seed & pesticide market globally.

The event started out promisingly enough, with assertions that it used to be ‘agriculture versus the environment’ but that ‘that time is over,’ and repeated assurances that we are beyond the time for business-as-usual approaches given the urgency of the need for radically different agricultural practices in the face of a rapidly changing climate.

The Chair of the HLPE Steering Committee Patrick Caron gave an insightful overview of the context of the report on agroecology and ‘other innovations’, in which he pointed out that ‘when people talk about agroecology, sustainable intensification, precision agriculture – they have very different things in mind…’. Caron explained that this report’s role is to understand disagreements and to shape the international agenda.

He was followed by Fergus Lloyd Sinclair of the Agroforestry Institute in Nairobi, the HLPE Project Team Leader, who presented a very encouraging update on their work on the report to date. He first candidly shared what a ‘schizophrenic terms of reference’ the HLPE was given by the CFS, pointing out that ‘agroecology’ and ‘other innovations’ can be distinguished on the basis of principles. Sinclair asserted that ‘agroecology is a dynamic space, with many actors… not prescribed… locally defined in different ways by the people who are practicing it…’ and that there is a ‘strong connection between indigenous knowledge, traditional agriculture systems, and science.’

He went on to explain that agroecology as an innovation is easily distinguished from other approaches such as ‘sustainable intensification’ (and ‘climate smart agriculture’, ‘nutrient sensitive agriculture’, because agroecology (which may broadly include aspects of organic agriculture, agroforestry, silvopastoralism, and permaculture) is labour intensive rather than capital intensive. It relies on the humans in its system for knowledge and labour rather than capital intensive technological innovations that seek to largely replace human labour and often even knowledge.

Sinclair also explained the HLPE’s pitch to include ‘agency’ as a fifth pillar of food security – a concept already fundamental to food sovereignty, which asserts everyone’s right to collectively participate in food and agriculture systems.

After this rousing start, we watched as the CSIRO took to the podium. After thanking her colleagues from the HLPE and agreeing that we cannot continue with ‘business as usual’ approaches, the Acting Deputy Director of Food and Agriculture gave a 20-minute presentation on business as usual. She started with some stats:

  • Australia is 6th largest land size country in world and 55th largest population
  • Major exports: wheat, beef, wool, dairy, wine – mostly to China, USA, and Japan
  • Farmers are 2.5% of total workforce
  • 90% of our population lives on .2% of our land
  • Australian ag workforce: 82% live in regional areas, 73% work full time, 32% female (more likely to try non business as usual approaches, more likely to earn off farm income), 1% indigenous
  • Change areas for Australian ag: increasing competition, Asia’s growth, evolving consumer, biosecurity & provenance, resource scarcity, climate change, digital ag, energy disruption

She then asserted that ongoing innovations are needed to protect our natural resources as well as agriculture, requiring new forms of surveillance. Wait, what? Next, regarding upcoming innovations, she said, ‘I aspire for a future where Australian ag is a price-setter in the global market.’ Okay, but what about agroecology?

Here’s a list of some of the non-business-as-usual innovations cited by the CSIRO at this seminar on agroeocology and other innovations:

  • yield maps
  • canola yield based on average rainfall
  • nitrogen application impact
  • virtual fencing (‘quite happy cows with their lovely collars on’)
  • genetic engineering for broad-spectrum disease resistance, novel oils, nitrogen fixing plants, fixing heterosis through apomixes, pest-resistant legumes, boosting photosynthesis, and biofortified foods
  • New grains for human health – engineering health outcomes into food people eat such as barley and wheat. High amylose wheat, BARLEYmax, novel fibre wheat, gluten-free cereals, thick aleurone cereals
  • Leaf oils – ‘game changer for global oil production’ – a seed output as well as a leaf output

I guess the CSIRO is more in the ‘other innovations’ camp. (In fact when a like-minded colleague asked the CSIRO speaker between sessions why she didn’t speak about agroecology, she responded that she was ‘instructed not to.’ Let that sink in for a minute.)

Our mates from Bayer were the first question off the rank after the opening speakers, revisiting a point Sinclair made about an ‘increasing moralisation around food.’ The Bayer rep asked Sinclair how he believes the ‘moralisation of food’ impacts on equity. It is a tried and true rhetorical trick from industrial ag proponents, who often seek to establish their own moral position with appeals to equal access and the role of (presumed but not always proven) cheap technologies (that they own) to ‘feed the masses.’ They may as well exclaim, ‘Let them eat cake!’ and be done with it. Whether posed as a question or an assertion, this device always wilfully ignores earlier expert points that hunger is not caused by scarcity of food, but rather by failures in governance and distribution.

During the break I was introduced to another CSIRO senior staffer as the president of the Australian Food Sovereignty Alliance. His response was to raise his eyebrows and yelp, ‘Food sovereignty? That raises alarm bells with policy people!’ To which I calmly responded, ‘Really? Policymakers are alarmed by peoples’ right to democratically participate in the food and agriculture system?’ ‘Yes!’ he intoned, ‘Internationally it impedes trade!’

I think that rather than bore you with the rest of what we heard from the CSIRO at the seminar, all of which is in line with what’s cited above and demonstrates their slavish devotion to free trade in capitalist global markets to the detriment of most farmers and eaters everywhere, I’ll leave you with some more interesting input from the HLPE.

Agroecology and Other Innovations - Summary of the HLPE Draft Report

Caron gave a summation of the status of the current report on agroecology and ‘other innovations’, which has passed Version 0 and a period of public consultation, with draft Version 1 due to be released soon.

Part one of the report asks: What has changed in past 20 years regarding food security & nutrition (FSN)?

  1. Acknowledgement through different definitions of FSN of the right to food. FSN until creation of FAO in 1945 was a national issue, became a global issue in second half of the century. Increasingly realised that sufficient supply doesn’t ensure FSN.
  2. In 80s and 90s we were talking about starvation, and now we talk about 800mil suffering hunger & starvation – mostly rural poor.
  3. We are mainly focusing on yield improvement when we are wasting a third of production.
  4. Hunger is not decreasing quickly enough and overweight & obesity are increasing rapidly – well beyond infectious diseases – and are the number one problem in public health.

Part two of the report examines the ways in which food systems are changing, and reminds us that the question is not how to feed 9 billion people, it’s how to feed them in a sustainable way while providing decent livelihoods for producers. We can use the food system as a lever to address all the Sustainable Development Goals (SDGs). ‘We thought that improving supply and access to markets would help everyone but we were wrong.’

The third part of the draft report has the much-anticipated draft recommendations - what’s needed to make food systems sustainable? The answers warm a food sovereignty activist’s heart. How to improve food supply? It could be through investing in knowledge and technology, reducing food waste, internalizing externalities – they’re all possibilities. It must be through strengthening resilience – investing in small-scale ag, securing land and tenure rights, securing social equity and responsibility with social protection systems, supporting women and youth, creating decent jobs in agriculture, through investing in education for all.

The HLPE reminds us we can’t forget the need to change consumption habits, and that to do so we need to change the food environment – advertisements, subsidies, and banning some types of food like we have with alcohol and tobacco. The CFS is supposed to draft voluntary guidelines to be agreed in 2020.

Caron insists that we must improve governance of food systems and the capacity of stakeholders to participate. He says that the changes will be knowledge intensive and we have to invest in knowledge – the answers are not the ones already on the shelves. We must design new governance of food systems at all levels – including national levels.

Before closing we had a final opportunity for questions or comments, so I took the opportunity to express concern at the CSIRO’s focus over the course of the day on exports, growth, and increasing yield in spite of the obvious environmental degradation witnessed up Australia’s eastern coast over the past two years due to extreme levels of drought in a changing climate, and also in spite of the expert position presented here and for decades now that we don’t need to grow more food, we need to make food systems more democratic. The response from the CSIRO was, ‘we’re an independent science research body – we can’t take sides.’

Well AFSA can, and we choose a habitable planet for generations to come. By not joining the heavy weight of evidence showing the changes needed in our food and agriculture systems, CSIRO are taking a side too – commonly known as the wrong side of history.

Tammi Jonas

President, Australian Food Sovereignty Alliance

 

 

FSANZ proposes ‘licence to sell lettuce’ – AFSA says NO

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On 3 May 2019, Food Standards Australia New Zealand (FSANZ) released an information paper on its proposed approach to a review of food safety standards in the Food Standards Code (the Review).

The intention is to create a consistent and up-to-date approach to food safety management with regard to so-called “high-risk horticulture,” which includes a list of leafy green vegetables, melons, berries, sprouts, and ready-to-eat minimally processed fruits and vegetables. In light of the 2018 listeria outbreak in rockmelons produced at Rombola Family Farms in Nericon NSW, the timing of the Review is unsurprising. However, reactive regulation is often ineffective at achieving its stated aims, and can create a spiral of perverse outcomes as many caught up in new regulations are not the intended targets.

A variety of food safety measures are already in place to mitigate the risks of listeria, salmonella, campylobacter and other pathogens, and all Australian producers identified as responsible for the outbreaks used as justification for the proposed Review have quality assurance (QA) and traceability arrangements in place.1 In FSANZ’s 2011 Review, the question was posed as to whether existing industry programs are sufficient to manage food safety risks or whether regulation may be more appropriate.

FSANZ abandoned its earlier pursuit of increased regulation in 2014, stating: ‘Microbiological data available from Australian surveys suggests a low level of contamination of fruits and vegetables in the Australian supply chain, although infrequent contamination with pathogenic microorganisms can occur. The available evidence provides a high degree of confidence that Australians have access to safe fresh produce.’ (FSANZ, Abandonment – Proposal P1015, 21/02/14) [...]

However, in spite of the 2014 findings and assurances of public safety from Australian horticulture, ‘FSANZ has now been asked to reconsider that finding and to investigate whether the non-regulatory efforts of industry and regulators require supplementation through regulation that adds to the basic requirement that food for sale must be safe and suitable.’

Strengthening consistency in food safety management and traceability throughout the food supply chain is the stated objective of this Review. Appropriate controls may be better found by asking the right questions, including but not limited to:

  • Are there weaknesses in the QA programs that audit produce sold through the supermarkets where contaminated produce has been sold?
  • Will a national, mandatory regime for food safety effectively achieve a better result than current Freshcare and other supermarket food quality regimes?
  • What are the links between pathogens and large-scale industrial farms or monocultures?
  • What are the links between pathogens and small-scale agroecological farms?
  • What proportion of those people affected by outbreaks have been immunocompromised or in a similar high risk demographic? What other public health measures can be implemented to prevent foodborne illness in vulnerable populations?

While it is currently beyond the scope of this proposed Review, how many people are made ill by fresh produce as compared with highly processed foods, allergens in foods, food additives, or chemical or active constituent residues? Is the risk of salmonella and campylobacter from fresh horticultural products the highest priority for better protection of public health?

From what can be compiled via publicly available FSANZ Food Incidents and Food Recalls websites, it is apparent that neither contains any incidents or recalls connected to small-scale agroecological farms. Our submission seeks to demystify the source and true cause of food safety management failures with a view to determine the correct regulatory approach (if any) necessary to resolve the failures. Our submission further seeks to put this Review in the scheme of the broader context of food sovereignty, which asserts everyone’s right to access culturally-appropriate and nutritious food produced and distributed in ethical and ecologically-sound ways, and our right to democratically participate in the food and agriculture system.

The Information Paper rings alarm bells for Australia’s many small-scale market gardeners. These small, diversified farms that are typically reliant on very few (if any) chemical inputs are vital to localised markets and urban, regional food bowls. (For more information about regulating for resilient, equitable food systems and food bowls, FSANZ should refer to the work of FoodPrint Melbourne.) The key concern for them is whether increased regulation of large-scale industrial horticulture would also apply to their low-risk farming systems, most of which have traceability built into their direct-to-consumer sales models.

The proposed Primary Production and Processing Standard (the Proposed Standard) would appear to also amount to prohibitions on food sharing arrangements such as non-commercial farm-to-farm produce swaps. Further, such a standard would threaten the viability of small-scale farms while industrial-scale horticulture farms will continue business-as-usual under existing food safety QA programs.

More broadly, the Foodborne Illness Reduction Strategy 2018-21+ (the Strategy) relevant to the Review did not recommend pursuing the earlier proposal to increase regulation of high-risk horticulture products, but instead focused on the much higher risks in poultry and eggs. This leaves us wondering what triggered the renewed focus on horticulture instead of poultry and eggs?

The way in which finalised food standards become law under the FSANZ Act precludes consultation to one isolated step of the process. Afterwards, only government agencies, the applicant, FSANZ Board, Forum Members and finally Ministers are able to influence decisions. The newly adopted UN Declaration on the Rights of Peasants and Other People Working in Rural Areas asserts the right of small-scale farmers to participate in ‘decision-making processes on food and agriculture policy’ (UNDROP, Article 15.4). As stakeholders and representatives of farmers and eaters, we seek further engagement in the making of new standards or major variations which can become law.

Recommendation 1

The development of a mandatory Primary Production and Processing Standard for “high-risk” horticulture (the Proposed Standard) is unacceptable. This process should be halted and substituted by an engaging, transparent and participatory approach which identifies the current priority needs of horticulture farmers, and which uses measures already available in the food regulatory system to prevent outbreaks.

Recommendation 2

Any risk-management measures considered should target the known source of outbreaks, namely large-scale, intensive operations and sections of the processing industry engaged in the export and import of horticultural products. Appropriate assessments of relationship between scale, production methods, and risk should be a priority.

Recommendation 3

The Office of the Commissioner for Better Regulation (OCBR), including the Red Tape Unit, and similar commissioners or authorities of all States and Territories should be notified of this Review to provide practical advice and support to the Government on the impacts of regulatory burden on agriculture. This can be done through the Regulatory Impact Assessment (RIS) and Legislative Impact Assessment (LIA) processes.

Recommendation 4

FSANZ’s rushed attempt to commence a major assessment procedure by mid-2019 should be slowed to set a measured pace to allow for a comprehensive and effective regulatory response, inclusive of broad consultation with farmers at all scales and their representative bodies.

Recommendation 5

That the drafting stage of such a Review be put on hold until the required steps are taken to:

  1. Consult with producers with regard to the cost and administrative impact of any of FZANZ’s proposals;
  2. Identify and improve any current regulatory and non-regulatory measures that can be improved, rather than adding more costly and burdensome steps for producers and processors;
  3. Provide the expected assurances to low-risk producers that there will be exemptions that apply to them should any new regulatory measures be put in place.

Read AFSA's full submission to FSANZ here: 190530_AFSASubmission_FSANZfoodsafety.

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