Australian Food Sovereignty Alliance

Fair food for all Australians

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

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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