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: firstname.lastname@example.org
15 September 2006
Animal Biosecurity Secretariat
GPO BOX 858
CANBERRA ACT 2601
By: Email email@example.com
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
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.
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