Calculating the costs that will be faced by the industry is difficult as there has been little consultation and even less solid information on exactly how the auditing and verification processes will be carried out and what costs the industry will incur. The basic licence structure is a pay per volume arrangement with large processors paying the lion’s share. However yabby Growers are in the same baseline category under the Victorian Scheme as the abalone industry one which makes far more profit per Kg produces for more product and has different and understandable food safety risks and sustainability issues. All but o few of the 60 – 70 Victorian licensed yabby growers last year made less than $1000 from the sale of product for human consumption. Adding in other sales such as bate and pets a good year in the last 8 for an average grower is overly estimated at around $4000. It is not hard to see the serious nature of regulatory burden that is now being faced by the industry.
The industry, through a small and largely inadequate consultation process with Primesafe has been told to expect 3-4 audits annually, especially in the first year in order to bring the industry up to a standard of compliance Primesafe says will protect the public from the associated food safety risks posed by this industry.
The industry was visited by representatives of Primesafe pre-1 July 04 to explain the changes that have to be made and given a year to comply. If anything has changed since then there has been no consultation.
Therefore the industry assumes on a viable farm of average size 80 acres compliance costs are estimated thus:
3-4 hr 3rd party audit. We have been quoted an hourly rate of $140.
Travelling time has not been ruled out in writing by Primesafe so as farms are in the country 1 ½ hrs is not an unreasonable time say approx $175
Time on farm 4 hrs $560
Growers time while Audit takes place audits can’t proceed without the licence holder being present $80 at 20 hr
Time preparing paper trail would assume if they are here 4 hrs at least 2 hours paperwork at some stage $40
Therefore even conservatively it is estimated that in addition to annual licence fees it will cost a conservative minimum of $855 per visit at Audits times 3-4 times per year for a reasonable sized and therefore viable farm.
The actuality of this figure is seen by experienced industry growers on smaller viable farms to be more in the region of 1500-$2000 annually.
This envisaged cost burden is completely unacceptable to the Australian Fresh Water Crayfish Growers Association Vic and is seen by stakeholders as threatening their livelihood and that of the industry total.
