The Commercial Egg Producers' Association of Western by ybg79195

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									The Commercial Egg Producers’
Association of Western Australia (Inc)
Phone:             08 9486 2100                                                          PO Box 6291 EAST PERTH WA 6892
Fax:               08 9361 3544                                                          Thorogood St BURSWOOD WA 6100
President:         John Simpson                                                          ABN: 56 449 013 149
Executive Officer: Lucy Beckwith                                                         Email: lucybeckwith@wafarmers.org.au



                                                                                                    SUBMISSION
              15 September 2006




              Animal Biosecurity Secretariat
              Biosecurity Australia
              GPO BOX 858
              CANBERRA ACT 2601
              By: Email animalbiosecurity@daff.gov.au



              DRAFT GENERIC IMPORT RISK ANALYSIS REPORT FOR CHICKEN MEAT

              On behalf of our commercial egg producing entitles in Western Australia I would like to
              thank you for the opportunity to comment on appropriateness of uncooked chickens being
              imported into Australia from anywhere in the world based on an Import Risk Analysis.

              1. Australian Biosecurity must not be compromised to any degree. Federal Government
                 must take into consideration the economical consequences to commercial egg
                 producers in the event that an exotic disease enters through uncooked chicken meat.

              2. We do not support the importation of uncooked chicken meat into Australia from any
                 country.

              3. We believe that the only chicken meat to enter Australia must be cooked.

              4. Commercial egg producers have stringent biosecurity protocols set in place to ensure
                 that their bird flocks are free from any pests or diseases. However, due to de-regulation
                 and consumer pressures, many producers have had to change their management
                 practices from an intensive in-shed set up to barn and free ranging systems. With any
                 free-range system the possibility of introducing a pest or disease into a flock increases.
                 We agree that in general, biosecurity for free-range poultry is low and hence at a higher
                 risk of exposure.

               5. The documents explain that in order to allow the importation of chicken meat into
                   Australia, the Government has a responsibility of reducing the risks to an acceptable
                   level. What is this acceptable level? Who determines what an acceptable level is?
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              6. We are concerned that although there is State and Federal Cost sharing arrangements
                 between Industry and Government, the Federal Government must realise that in the
                 event of a disease incursion, it will be industry not government paying the price of
                 eradication, compensation or management of the problem. Both Government and
                 Industry have worked hard in placing protocols in place ensuring that the health of
                 poultry and hence, industry is not jeopardised. Allowing the importation of uncooked
                 meat from overseas may do just that.

              7. We have some concern in that one member on each of the working group who has
                 specific technical expertise in that particular disease/virus etc. is from an overseas
                 country, some from countries that wish to export raw chicken meat into Australia.

              8. We believe that any chicken meat which may be considered for importation into
                 Australia must be produced under conditions at least equivalent to those set out in the
                 two relevant standards:

                   •    Australian Standard for Construction of Premises and Hygienic Production of
                        Poultry Meat for Human Consumption.

                   •    Australian Standards for the Hygienic Production and Transportation of Meat and
                        Meat Products for Human Consumption.

                   The question is, who will police the above to make sure that it is carried out? And who
                   will pay for this service?

              9. We agree that with the increase of volume of raw chicken meat being imported there is
                 an increased chance of the diseases entering Australian shores.

              10. Should the disease status of the Australian chicken industry be compromised it will
                  have detrimental effect on the export opportunities.

              11. Current IRA allows the importation of fresh product to be processed on site. Therefore,
                  it is possible that disease infected product may come into Australia prior to the disease
                  being recognised in a zone or imported chicken meat pay originate from birds infected
                  with the disease without showing any symptoms (depending what incubation stage the
                  disease is at.)

              12. Disease free zones depend on credible quality standards in farming and integration,
                  addressing disease transmission risk in addition to laboratory back-up to conduct any
                  necessary testing. Australia has very highly credible institutions that can undertake this
                  activity. The IRA does not address the issue of standards of these institutions overseas
                  in terms of their testing standards to be comparable and as high as Australia.




              13. We believe that the control of risk-reducing measures on and off shore must be retained
                  by Australia. The Association believes that:
                      i. AQIS should certify all processing plats.
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                        ii. On-shore and Off-shore processing should be under “quarantine supervision”
                       iii. Disease-free status of countries and zones should be established to the
                            satisfaction of the Australian Government authorities.

                   If the above is to be undertaken, then it is the exporting country that must meet all costs
                   associated with the activity of exporting chicken meat into Australia.

              14. There must be farming, processing and testing standards developed which are
                  appropriate to the risk and not attributed to the poultry produced in Australia. These
                  are different to FSANZ standards and need to be considered separately for each
                  exporting zone as a generic assessment process is not appropriate.

              Once again, thank you for the opportunity to make comment on the draft proposal.


              Kindest regards


              Lucy Beckwith
              Lucy Beckwith
              EXECUTIVE OFFICER




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