View AFSA's entire submission here. 

The current review of the Model Code of Practice for the Welfare of Animals – Domestic Poultry offers the first opportunity in 15 years to improve the minimum welfare standards for domestic poultry in Australia. It provides the chance to modify Australian standards to reflect current animal welfare science and equivalent international developments.

The Proposed Draft is significantly more comprehensive than the previous welfare standards in the 4th Edition, as well as in other welfare codes for ostriches and emus, some of those standards dating back to mid-20th century management practices. We commend the collective and lateral efforts of the Animal Welfare Task Group (AWTG), the Stakeholder Advisory Group (SAG) and Animal Health 9 Australia (AHA), and welcome the opportunity to comment on the Draft during the 90 day public comment period.

It is necessary for Australia to lead a fundamental reshaping of animal welfare standards that meet international standards and community expectations, and that is based on scientific research and available data from Australian farms. Many farmers give ethical reasons for changing towards pastured poultry production methods because of the maximum animal welfare and provenance it offers if well managed.18

This submission aims to contribute on behalf of small-scale, pasture-based poultry producers so that best animal welfare standards can be achieved more readily and regulated appropriately.

In this submission, AFSA will primarily make comment relating to the standards and guidelines for domestic poultry due to scope of our representation of poultry farms extending to small producers of layers, broiler chickens and ducks. As principle, we support best animal welfare practices in the industry as a whole.

What the Proposed Draft means for Farmers- Farmers employing pasture-based practices will lose a once in a generation opportunity to be heard in the decision-making process relating to poultry welfare. Continued large-scale production of poultry will further dominate the market and drive small-scale farmers into ‘niche markets’.

What the Proposed Draft means for Eaters- It will turn a blind eye to popular demand for higher standards of welfare and eaters will continue to have low access to sustainably produced meat and/or eggs that positively impacts quality. Consumer quality perception when purchasing poultry will be informed by perceived standards of welfare and environmental factors that do not in fact meet their expectations.

What the Proposed Draft means for Poultry- Domestically raised poultry in conventional systems will continue to suffer from worse physical and mental states than those in countries with advanced animal welfare standards such as all nations of the EU, various states of the US, New Zealand and Canada.

What AFSA Members want- We demand that the Agriculture Ministers of all states and territories, Premiers and Local MPs support best examples of animal welfare standards using data relating to pasture-based systems. We urge that they back research into better solutions for livestock welfare to meet community expectations and public health interests. We support the development of a more inclusive, science-based system for setting animal welfare standards where an independent body monitors the animal welfare standards and investigates regulatory behaviour.

List of Recommendations

Recommendation 1: Phase out battery systems in the next 3 - 5 years and phase out all cage systems in the next 10 years. This should be done using a strategy to transition the industry such as that used in Austria (where battery cages were prohibited in 2009)19, and supporting long-term management of cage-free systems as done across the EU.

Recommendation 2: Transition poultry systems to free range over 10 years and during that transition reduce the maximum stocking density in barns or sheds (as they are phased out) for non-cage layer hens to 2 birds per metre squared and meat chickens 15kg per square metre. (Option E suggests reducing maximum stocking densities in barns or sheds for non-cage layer hens to 9 birds per m2 and meat chickens 30kg/m2)

Recommendation 3: Current practice of rearing poultry outdoors on pasture for egg and meat production be considered with the updated or new Regulatory Impact Statement and be added as a supporting paper to reflect the absent data on Australian poultry farms.

Recommendation 4: Establish an independent non-governmental body that oversees the development of animal welfare regulation and represents all relevant stakeholders including small-scale farm businesses.

Recommendation 5: Directly source data from Australian pasture-based farms and genuine free-range farms by visitation or by extended consultation in order to obtain correct information about the quality of alternative poultry production.

Recommendation 6: Explore research on alternative agricultural production occurring internationally in order to gain a more comprehensive understanding of the benefits of pasture-based poultry systems. Recommendation 7: Australia primarily sign the Universal Declaration of Animal Welfare.

View AFSA's entire submission here. 

The Codes for animal welfare for poultry are being reviewed for the first time in over 15 years.

The result will be one Australia-wide Code on animal welfare for poultry. Two main documents, along with an independent Farmed Bird Science Welfare Review and many supporting papers, have been released for public comment:

1. The Draft Standards and Guidelines; and
2. A Regulatory Impact Statement.

In total these documents stack up to over 700 pages. So we have condensed some of the basic information you need to know in a fact sheet.

We were deeply disappointed to see that, despite early expectations for the process, there was no mention of battery cages being banned.

If they go ahead, the proposed Draft Standard will make things worse for consumers, genuine free-range producers and birds raised on poultry farms.

AFSA’s vision is to enable regenerative farming businesses to thrive. We recognise that Australians want food that is grown locally and without damage to animal health and the environment. Food produced on small regenerative farms is in demand. We believe that it is critical that government heeds changing community expectations by supporting the growth and viability of regenerative agriculture while protecting the environment and human and animal health.

The reforms have been in progress since mid 2015. They were intended to reflect the latest science on animal welfare, recommended industry practices and community expectations. Instead, the integrity of the drafting process is being questioned after egg industry representatives were recently accused of engaging in ‘systemic collusion’ with the NSW Government to thwart moves to outlaw battery hens.

The outcome was that the banning of battery cages was kept out of the Draft Standards. With NSW having the highest production rates of caged eggs in the country, this collusion ought to have been expected.

For many reasons, such as there being over 10 million hens kept in conventional cages, false and misleading claims about egg-labelling and many others, AFSA is concerned for the future of genuine free-range systems for raising poultry on farms.

Australia should ban battery hens as in countries like Canada, New Zealand, Switzerland and Austria. We should follow the example of the ACT where the use of battery cages is prohibited.

Whether you’re a poultry farmer, egg or chicken consumer, chef or animal rights advocate, your views on the Draft Standards are crucial to the consultation process and to the future of poultry welfare in Australia.

We know that you care about animal welfare as much as we do. In 2016, nearly 10,000 consumers, farmers, retailers and advocacy groups provided input to the new national standards to define ‘free-range’.

The welfare reforms are just as important to secure the future of genuine free-range poultry farming in Australia and gives us a chance to reduce regulatory uncertainty faced by producers.

Make your own submission by 5pm Monday 26 February 2018. Alternatively, email us at admin@afsa.org.au with your concerns and we will include them in our submission.

In support of small-scale, regenerative farmers in Victoria, the following organisations have submitted responses to the Victorian Government's Planning for Sustainable Animal Industries Draft Planning Provisions.

• Australian Food Sovereignty Alliance
• Victorian Farmers Market Association
• Melbourne Farmers Market Association
• Regenerative​ ​Agriculture​ ​Industry​ ​Group​
• City of Whittlesea

The Australian Food Sovereignty Alliance (AFSA) has submitted a response to the Victorian Government's Planning for Sustainable Animal Industries Draft Planning Provisions. View the submission here.

The Victorian Government's current proposals will do serious damage to the regenerative and small-scale livestock farmers of Victoria. See AFSA's media release regarding the proposed changes here.

AFSA's Response to Planning for Sustainable Animal Industries Draft Planning Provisions

Summary of AFSA's recommendations:

• Recommendation 1: That the Government continue to allow low-risk, low impact grazing animals as an allowable use in the UGZ.
• Recommendation 2: That the trigger to judge a pastured pig farm a Section 2 use (streamlined process) be set at more than 25 SPU/Ha, subject to meeting minimum standards.
• Recommendation 3: That the trigger to judge a pastured poultry farm a Section 2 use (streamlined process) be set at more than 450 birds/Ha, subject to meeting minimum standards.
• Recommendation 4: Treat all pastured livestock systems with supplemental feeding the same in the land use definitions and graduated controls, subject to meeting minimum standards.
• Recommendation 5: That all pastured livestock are defined under ‘Grazing Animal Production’, but that the term be changed to ‘Pastured Animal Production’. We further recommend that where feeding infrastructure is mobile that the setback from waterways and environmentally sensitive areas be set at no more than 20m.
• Recommendation 6: Maintain the definition of ‘intensive’ as drafted in the new VPP, and include intensive pig and poultry farms in that nesting diagram.
• Recommendation 7: That the Government’s proposed Action 6 – to establish a panel of animal industries specialists to provide technical advice to local government – include representation from small-scale pastured pig and poultry
  farmers.
• Recommendation 8: Develop Codes of Practice in close consultation with small- scale pastured pig and poultry farmers. (See draft Code of Practice for Pastured Pig Production in Appendix C for what such codes might include.)
• Recommendation 9: That a regulatory impact statement be prepared urgently.