Australian Food Sovereignty Alliance

Fair food for all Australians

Submission to the Senate Inquiry on regulation of farming practices impacting the Great Barrier Reef

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New regulations under the Environmental Protection (Great Barrier Reef Protection Measures) and Other Legislation Amendment Bill 2019 will require more documentation of agricultural practices and permits for changes to cropping and land use.

While strongly supporting measures to protect water quality in the Reef, AFSA has highlighted the difference in ecological impacts between small-scale, regenerative farms and large industrial producers in the region, calling for greater support and incentives for farmers to adopt regenerative practices which will improve water quality outcomes. The submission also called for scale-appropriate regulations to allow farms to shift to regenerative practices, and avoid barriers to entry or excessive admin burdens for small-scale farmers.

See the full submission here.

Local Laws submission to defend the right to common resources

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Last week AFSA made a submission to the Hepburn Shire Council to defend residents' rights to forage, collect firewood, have more than 20 chooks, and salvage materials from the tip and roadside without need for a permit.

We were concerned that these laws originated from overzealous risk management policies rather than residents' interests. Further, they were proposed without transparent community consultation, and would hinder sustainable public use of public goods.

You can see the full submission here.

Local council laws have significant potential to facilitate or limit democratic community control of local food systems and common resources, so it's important to speak up to make sure councils get it right!

If your council is doing good things, or you'd like to see them do things differently - let us know over at the Ideal Councils Survey so we can tell councils what our members want to see to improve food sovereignty support in local regulations.

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.

NSW Fresh Food Pricing Parliamentary Inquiry Hearing

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On Friday 22 June 2018, AFSA attended the NSW Fresh Food Pricing Parliamentary Inquiry Hearing at Parliament House in Sydney. AFSA was selected and recognised as a key stakeholder in the food system by the parliamentary members in this Upper House inquiry. Tammi Jonas, president of AFSA, and our paralegal Sarah de Wit were welcomed to present evidence because of the strength of our submission to the Inquiry lodged in May this year. AFSA was one of nine stakeholders invited to attend sessions and questioning at the Hearing, chaired by Reverend the Hon Fred Nile, MLC and members from the Liberal Party, the Greens and the Australian Labour Party.

The below are the highlights, lowlights and summary of AFSA's experience at the FFPI Hearing. Read our full submission HERE.

Highlights

Chair Revd Nile asked about Fair Food Farmers United, a branch of AFSA set up in 2014 to provide a balanced voice to protect small-scale agro-ecological farmers. The Chair was interested to know whether our members are being ripped off by supermarkets. Our response that most AFSA members effectively circumvent the duopoly by engaging in direct sales models interested LC Member Courtney Houssos of the ALP. Ms Houssos and Mick Veitch of the ALP (substituting for Adam Searle) expressed keen interest in and asked many questions about the operation of Jonai Farms and how the Community Supported Agriculture (CSA) model operates.

Due to this interest, our evidence gave members an introduction to the democratic participation and farmer-led decision-making about costs involved in CSA models. Ms Houssos told us that the case studies we gave would provide “movement and colour” to their final report.

Tammi gave evidence based on the meetings of the Food and Agricultural Organisation (FAO) of the United Nations in Fiji at the Asia-Pacific regional conference. As a result, the Parliamentary members are now aware of the effect of exports on fresh food access in Fiji, where 50% of food comes from countries like Australia, leading to a preponderance of highly processed foods with low nutritional value that are a leading cause of Fiji and other Pacific islands’ high obesity rates.

The ALP questioned AFSA about our proposed solutions to protect NSW’s peri-urban farming and expressed interest in our submission’s reference to foodsheds. We gave the members information about successful case studies in Victoria, NSW and in Colorado, where Boulder’s local government have an ‘open spaces’ tax that funds the purchase of peri-urban land as it comes up for sale to be maintained for agriculture.

Taylor Martin of the Liberal Party commended us for a “particularly good submission” and asked us about examples of where the Right to Food is being implemented and whether we’ve seen downsides. Emphasising first and foremost that we’ve never heard of any downsides of ensuring the Right to Food, we cited the example of Belo Horizonte in Brazil, where a zero-hunger program was enacted in the 1980s as referred to in our submission. We referred to Beginning to End Hunger by M. Jahi Chappell, a newly released book that details the case study of Belo Horizonte and the way it achieved the Right to Food.

Tammi gave the Liberal Party members an insight into the “culturally appropriate” element of food sovereignty when asked to explain it. Scott Farlow was interested in the membership and networks of AFSA and whether AFSA would support AmazonFresh. In reply, we asserted the importance of direct sales models and the need to shorten supply chains in order to overcome the “grow more for less” model. We agreed with the Liberal party member that there has been a loss of skills and literacy, but also taste for preparing fresh food. Justin Field, representing the Greens, took the opportunity to encourage the other members to try a homegrown carrot. He then queried AFSA whether CSAs could “feed Australia”. To this Tammi responded that already 70% of the world's food is produced by small-scale growers and fed into direct systems.

AFSA was scheduled in a session after The NSW Council of Social Service (NCOSS), preceded by the NSW Farmers’ Association, the Cancer Council and the Public Health Association. This meant that questions asked by the Members related to their submissions. This also gave AFSA the opportunity to call out the Farmers’ Association’s phrase "paddock to port" as a rather cynical phrase to describe export-oriented supply chains that will not feed local communities.

The Greens member then asked us to speak to some of the barriers around access to land. We mentioned the issue of the average age of farmers but also of the many young people wanting to farm in systems AFSA promotes. We alerted them to the work of Cultivate Farms, which is working to connect would-be farmers with the land and finances they need to grow ethical and ecologically-sound food.

Key message

We drove home the message that pricing is not the key trigger to a better food system. Food system problems like hunger must be solved at the point of production and worked through along the supply chain.

As Tammi stated, “We do not start with hunger as the problem, we start with how we are producing and making food available to people or not available to people. We know that globally we produce far more food than we need and yet we still have millions and millions of people who are hungry. So it is not an availability problem, it is accessibility and it is problems of distribution and governance of food.”

Lowlights

 No questions from the National Party. National Party member Richard Colless (substituted for the Hon Ben Franklin) was absent for the Hearing session.

 Summary

At the Inquiry Hearing we were asked to respond to the NSW Farmers Association’s proposal for “a state-based commissioner or advocate for the farming sector to address issues” relating to fresh food pricing. The Association made this proposal in their submission. We didn't have a position on the proposal but took it on notice to consult with the AFSA Committee.

NSW Farmers Assoc. believe that a Commissioner could address unequal bargaining power within food supply chains, market competition and abuse of market power. They suggested a NSW Ag Commissioner could focus on:

  • code compliance on unfair payment terms;
  • advocacy on behalf of the farming sector on competition and abuse of power matters; and
  • analysis and monitoring of farm-gate and retail prices on a basket of goods to assess the competiveness within supply chains.

After the Hearing, the AFSA Committee discussed its views on the pros and cons of this proposal. We considered what an Agriculture Commissioner’s role might be and came to the conclusion that we do not support the proposal. Such an initiative would simply be incapable of examining all externalised costs associated with food production accruing to all levels, including the consumer level. The question of who would fund the Commissioner and what powers they would be allocated remains unanswered. Whether such an individual would be capable of genuinely representing the diverse interests of the sector and its many interrelated networks of suppliers and distributors also remains to be explained.

While AFSA notes that having an independent Red Tape Commissioner in Victoria has assisted in efforts to reduce regulatory burden in the state, we believe it would be impossible to create a role that genuinely is responsive to all scales of farming, as well as wholesalers, retailers and consumers effectively and independently. We are of the view that the NSW Farmers’ Association’s submission made starkly clear their emphasis on scaling up "paddock to port" infrastructure and increasing expenditure on export channels for monocrops.  In making such intentions explicit, their submission blatantly missed the intent of the Inquiry by undermining fresh food access to NSW residents. We see their suggestion of establishing a food hub neighbouring the airport a hollow attempt at supporting domestic food exchange, as the area is inaccessible and impedes the Right to Food. In that regard, we believe the proposal will not serve NSW residents better access to fresh food, and nor will it better support democratic participation in the food system.

Other questions (NOT a question on notice)

Should governments be more involved in Food Pricing

 In general, AFSA does not believe government has a strong role to play in food pricing. However, where there are low-income communities in need of support to access nutritious, fresh, local food, government can play a role by paying local producers full price for their produce and then subsidising the sale of this food to low-income households, whether directly through models such as community-supported agriculture (CSA), or through local greengrocers or independent grocery stores, and/or through cooked meals at dedicated venues (similar to Belo Horizonte’s ‘popular restaurants’, where lunch is $1 no matter who is buying it).

 Final remarks

Overall, the Hearing was a success for AFSA. Not only did we manage to get the word “delicious” into the NSW Parliament Hansard, we considered it an opportunity to advocate for CSAs, for NSW small-scale agro-ecological farmers who want to engage in direct sales models and for eaters in NSW losing access to fresh, local produce due to the lack of protection for peri-urban farmland and foodsheds.

Read AFSA's submission to the NSW FFPI HERE.

Response to the Proposed Draft Australian Animal Welfare Standards and Guidelines for Poultry

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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. 

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