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.