Trevor Domaschenz
Vice President
Victorian Yabby Growers Association
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Email 1
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Requires four licences to grow yabbies.
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Under FSANZ will require licence for all other products.
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Unviable under PrimeSafe and Fisheries licensing structures to continue to grow yabbies without FSANZ intervention.
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Will end up with 20 licences.
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Yabbies have been assessed by FSANZ as the safest seafood which makes live yabbies near to nil risk. FSANZ philosophy clearly states nil risk nil regulation.
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Any practical food safety issues are addressed by the standard means of cooking for 5 minutes after they reach boiling point.
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Yabbies can aestivate for many years out of water as longs as their gills are kept moist thus storage and transport of yabbies has no detrimental effect on yabbies or on food safety.
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Yabbies cannot tolerate pesticides
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The yabby industry cannot afford Primesafe style audits.
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In Victoria live finfish are exempted but not live yabbies. Eels and fish are often caught in the same water bodies as yabbies.
Email 2
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Levels of cadmium and mercury in inland waters are lower than in the sea as shown in the National Residue Surveys.
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AQIS have no concerns with yabbies.
Email 3
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Has been told to expect 3-4 audits annually.
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Has calculated the cost to be $855 per visit, including costs for hourly rate of $140, plus audit travelling time $175; plus time on farm 4 hours $560; his time at $20 per hour for four hours; plus time preparing paper trail at $40.
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Average yabby grower in Victoria last year earned less than $1000.
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Have run at a loss for the past 8 years.
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Other costs that are hard to pin down are the compliance costs for sheds and potable water.
Email 4
‘Risk Assessment of Pesticides for Yabby Farmers’ April 2004, Fisheries Victoria, Fisheries Victoria Research Report Series No. 12.
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Study assessed the risk posed to the food quality of yabbies grown in farm dams as a result of normal farm practices.
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The model integrated land use practices with application methods and properties of pesticides, as well as combining the effects of several applications of multiple pesticides during the course of a growing season.
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A model that provided a qualitative ‘indicator’ which evaluated potential impact was considered the most appropriate for this study.
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To verify the results from the model, samples of yabbies from selected dams were submitted for chemical analysis.
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Farmers were also asked to answer a questionnaire on their pesticide use. Nineteen out of 49 responded. Only five stated that pesticides were used in the dam catchment area where the yabbies are grown. Ten did not use pesticides. Four were no longer farming yabbies.
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The information from the growers who applied agricultural chemicals to their farmland was used in the mathematical model to assess environmental risk of the pesticide to the yabbies.
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Respondents also asked about distance of septic tanks. In all cases, septic tanks were further than 100m from dams and therefore the risk of contamination from pathogens from this source was considered minimal.
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Study revealed there was a low risk of contamination by agricultural chemicals for yabbies grown in farm dams.
Email 5
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Original email that was responded to by FSANZ and redirected to Margaret Darton.
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Very concerned about new regulations being applied to live yabbies.
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Has sold $2000 of live yabbies for human consumption in the last five years and is expected to pay at least $800 annually for a very low risk product.
Email 6
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Correspondence with Jayne Gallagher of SSA and Don Nicholls of WA.
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WA does not currently have FSP or audit requirements for yabbies in WA. Have developed a post-harvest COT that is available on the SQMI website.
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Have found that processors are putting in place a requirement for his or an internally developed COP.
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Agrees with assessment of risk.
Attached also two-page fax from PrimeSafe detailing the licensing requirements from 1 July 2004 for yabby farmers plus a reminder letter to renew application for a licence.
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All seafood businesses involved in the harvesting of yabbies for human consumption will be required to be licensed by Primesafe form 1 July 2004.
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Prescribed application fee is $200 for up to 15 tonnes
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Yabbies need to comply with the requirements of the Code.
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Live seafood is required to be transported a licensed vehicle.
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All seafood businesses need to develop food safety plans and have audits. Audits will not be required until after 1 July 2005. PrimeSafe staff will conduct inspections until this time.
Attached one-page fax from NSW Fisheries with physiological information on yabbies, confirming that they can survive many years out of water in a state of suspended animation (aestivation) provided their gills are kept moist.
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