Conclusion
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The Australian Freshwater Crayfish Growers Association asks FSANZ to dutifully consider the above submission in light of the low food safety risks associated with the Aquaculture of Yabbies and assist the industry with respect to the regulatory impost currently being imposed by the Victorian Government.
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It is also asked that the concerns raised in this submission be canvassed and considered by the Office of Regulatory Review and the Development and Implementation Subcommittee (DISC) and any other committees empowered to review regulatory burdens and Cost Benefit Ratios with respect to the mitigation of food safety risks through nationally enforceable food safety standards.
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Please see attachment 1 for further information pertaining to the indictment of the Victorian government with respect to this industry’s issues.
Attachment 1
Article explaining the situation of the Victorian Yabby Growers
Source: Grow fish, Gippsland Aquaculture Industry Network 23/06/2004
Title: ‘Victorian yabby growers pushed to the wall’
Main points mentioned:
Recent regulatory changes in Victoria, hiking up the Fisheries licence fees by up to 400% immediately and up to over 1000% over the next three years.
Victorian Govt claiming to be forced into its actions by forces beyond its control.
Fledgling industry feels betrayed by the very govt and agencies that should be encouraging their development and the increased sustainable use of on-farm resources.
Under policy of ‘cost recovery’ each supplier of yabbies to a multi-water licence holder must pay a $200 per annum licence fee in addition to the $125 commercial dam fee.
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Vic Govt claimed that fee hike was mandated by the Federal Govt's National Competition Policy and unless they apply the additional charges they will be fined millions of dollars.
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The Seafood Safety Act (Vic) 2003 has placed responsibility for the maintenance of seafood safety in Vic in the hands of the former Victorian Meat Authority – re-badged under the name PrimeSafe Victoria.
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The Act specifically exempts live finfish producers where the product is processed off site.
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The Act does not extend the same exemption to crustaceans such as yabbies that are sold live, kept live by the down stream purchaser and cooked immediately prior to consumption.
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There has been no food poisoning event with yabbies to the knowledge of the oldest industry hands.
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Traceability already exists in the yabby industry, as all produce must be labelled with its source.
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Southern Rural Water have recently advised the Gippsland Aquaculture Industry Network (GAIN) that yabby growers will have to pay licence fees on their dams. The new Farm Dam Rules incorporated in the Water Act (Vic) 1989 require farmers to register their dams prior to 30 June 2004 or else pay a registration fee.
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If dam owner stocks dam with juvenile yabbies an annual fee for a commercial dam of $125 will apply.
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A new dam or yabby farm will require and application and associated fee.
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Gippsland Yabby Growers’ Association estimate that more than 90% of existing growers will choose to leave the industry.
Mary Ferguson
Export and National Marketing
Springs Smoked Seafoods
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