Tables Diagram 1 The present regulation and its coverage 8 Figure 1 Epidemic curve with hypothetical points of action 16 Table 1 Cost of the case study E. coli (STEC) outbreak of 400 cases 17 Table 2 Costs and Benefits of Regulatory Option 19 Table 3 Issues raised during the initial consultation 23 Table 4 Issues raised during the Consultation RIS stage 27 Table 5 Red Meat – 2011 Production in Australia 35 6 Cattle and sheep by state in 2011 (in millions) 35 Table 7 Annual Production Volumes and Indicative Value of Minor Meats 36 Table 8 Australia’s Exports in 2011/12 37 Table 9 Beef and Live Cattle Export Destinations 2011/12 37 Table 10 Mutton, Lamb and Live Sheep Export Destinations 2011/12 38 EXECUTIVE SUMMARY This regulation impact statement (RIS) examines the impacts of amending Standard 4.2.3 (Production and Processing Standard for Meat) of the Australia New Zealand Food Standards Code to include primary production requirements for traceability, inputs and management of waste for the major and minor meat species e.g. cattle, sheep, goats, pigs, buffalo, camels, alpacas, llamas, deer, horses, donkeys, rabbits, crocodiles, ostrich and emu (the Proposal). Currently, food regulatory powers in the meat sector are limited to processing environments. The draft variation to Standard 4.2.3 provides food safety regulators with the legislative power to investigate throughout the entire meat supply chain, should a food safety incident or potential for an incident arise.
Cost-benefit analysis Current controls along the meat supply chain are working well and questioned the cost-benefit of introducing additional regulatory measures for producers and processors. The potential increase in regulatory burden and impact on the viability of the kangaroo meat industry was raised noting that there are existing regulatory requirements for processing. The preferred option proposes no additional regulatory requirements for processing i.e. retain the current Australian Standard. In regard to kangaroos, the existing Australian Standard AS 4464:2007 - Hygienic Production of Wild Game Meat for Human Consumption contains requirements for managing inputs and traceability at the primary production stage such as the sourcing of wild game animals and identification of field harvester and place of harvest. Section 3.2.5 addresses the cost-benefit analysis. Mechanism to review Existing Australian Standards Supported a mechanism for review and to ensure currency of the existing Australian Standards for processing. The jurisdictions are progressing this issue. Maintenance of non-food safety issues in the existing Australian Standards The on-going maintenance of animal welfare and quality aspects in the existing Australian Standards. are addressed in the current Australian Standards for processing. The preferred option is to retain these Australian Standards for processing. Traceability The need for minimum requirements for traceability of minor meat species and wild game products to assist with foodborne illness investigations and the recall of food. The Australian Standard for the Hygienic Production of Wild Game Meat for Human Consumption (AS4464-2007) contains requirements for ensuring carcases have approved tags and accurate records kept of product received (Clauses 9.2 – 9.3); maintaining identification system and records to identify product to the processing premise (Clause 11.12) and that wild game meat businesses have a documented system that provides for the accurate identification, and the ability to trace and recall meat and meat products (Clauses 12.1 – 12.9). In regard to the minor species, the relevant Australian Standard contains requirements for meat businesses to
Production Volume – species The volume of meat produced from minor species is much lower than that of the major meat species. A summary of industry is provided in the following tables. These figures were sourced directly from industry participants. 7: Annual Production Volumes and Indicative Value of Minor Meats Meat Species Total annual production (tonnes) Export volume (tonnes) Domestic volume (tonnes) Retail Kangaroo 21,000 (for humans) 15,000 6,000 $6 Rabbit 260 0 260 $14.50 Deer 288 200 88 $35.00 - $65.00 Ostrich 30 29.3 0.3 $16.50 $30.00(premium fillets) Buffalo 35 8 27 $2.70 (manufacturing carcass) $3.60 - $4.00 (restaurant carcass) Camel 250 250 Crocodile 100 60 40 $10.00 - $20.00 Emu 88.7 18.6 70.1 $5 - $30 Exports Australia’s meat industry is heavily dependent on exports, which account for around 65 per cent of the country’s beef, 45 per cent of lamb and 80 per cent of mutton production. Export markets are very sensitive to food safety issues. Between 2010–11 and 2015–16, beef production is projected to increase by around 10 per cent, sheep meat production by 12 per cent and pig meat production by 7 per cent. Table 8: Australia’s Exports in 2011‒12 Meat Weight/numbers ($m) Beef & veal 948 kt 4,466 Mutton 89 kt 362 Lamb 174 kt 1,061 Live animals 2.562 million 345 Cattle 0.579 million 412 The main destinations of Australia’s beef, veal and live cattle exports in 2011/12 are displayed in Table 9. Table 9: Beef, Veal and Live Cattle Export Destinations 2011‒12 Meat Exports Destination Volume (kt) USA 205
Schedule 3 – Consultation with Government Agencies Questions NSW Vic Qld SA AGRICULTURE A General Questions 1 (a) What issues if any have been raised at abattoir level regarding matters that should be addressed on farm (ie. incorrect completion on NVDs)? The following issues have been raised during abattoir audit: • NVDs being completed incorrectly • Lost or missing ear tags on cattle • In - correct details for non-vendor bred animals All abattoirs have contacts with LHPA and DPI compliance officers to investigate with these issues. Incidental amount of incorrectly completed Vendor Declarations (ovine), Misread or missing NLIS Tags (Cattle). Yes – Incomplete NVDs Instances of with NLIS Smaller plants failed to have the provisions for NLIS Incorrect completion of NVDs including, traceability (use of depots), withholding periods and sourcing location to prevent residue breaches. Animal welfare issues regarding fit to load. 1(b) Indicate the numbers or percentages affected? NSW Food Authority would not be able to provide exact percentage Low in percentage too low to approximate for ovine. For NLIS Tags on cattle compliance is around 99% accuracy. Less than 5% noncompliance in this area NVD issues have been picked up at a random audit and treated as systemic issues and address by both industry and Agriculture. Animal welfare issues are raised directly to the appropriate state authority.
2. How and to what extent will the requirements for producers in the draft Standard make things easier for the abattoirs? If it will allow NSWFA to take action against primary producers and/or sale yards for breaches which cause issues at abattoir, this may have most benefit to abattoirs. No change, than have potential to include all required information in one declaration etc. May assist in identifying the problems about stock being farmed on contaminated areas. E.g Dee River – Coal Seam Gas etc Ensures that the responsibility for provision of animals meeting the requirements can be enforced by state and territory jurisdictions. Agriculture require the abattoir to source appropriately to meet the requirements. 3. Can this be expressed in monetary terms? NSW Food authority would not be able to provide this information No No Unknown monetary advantage. B Costs 1 (a) Will the adoption of the draft Standard impose any compliance costs on Producers? No as it formalises what producers should currently be doing to comply with Primary Industry requirements There will be some costs to the individual producers who have not already installed appropriate on farm management practices. No additional costs No Producers are not in Agriculture’s jurisdiction 1 (b) Will the adoption of the Standard impose any compliance costs on a processor? Processor already licensed and paying levies to industry and Government. No further costs No. Processors already have substantial requirements in place for identifying the place of purchase of animals (refer to A 2 above) Status Quo No Agriculture does not expect any addition compliance costs 2. Will jurisdictions incur additional costs (excluding responses to food incidents) If it is used for on-going non compliances (instead of current DPI/LHPA system), then yes. If excluding incidents, then no. Not anticipated. This should provide greater efficiencies “through chain” No Agriculture does not expect any addition compliance costs
F. In the of a major food safety incident, will the draft Standard adequately empower jurisdictions to respond effectively? Powers reside under individual food acts and should be sufficient. No difference (refer to C/D/E above). Yes – We will be able to go back on farm Yes Producers are not in Agriculture’s jurisdiction, standard potentially allows state and territory jurisdiction to additional provisions to manage/trace food incidents at the producer level.
Waste disposal: solid and liquid waste generated during primary production such as sewage, waste water, animal carcasses and garbage. Traceability: Animals are identified in accordance with State animal identification systems, and systems are in place that allow animals to be traced from the holding of origin and to the holding of consignment. Slaughter and processing of animals State and Territory laws govern meat processors whose activities involve the slaughter and processing of animals for human consumption, including of animals in the wild and the preparation, packing, transportation, or storage of meat or meat products. These laws require persons involved in such activities to comply with specified Australian Standards. Compliance requirement - Industry Monitoring requirements - Government Current Industry arrangements An individual, business, enterprise or activity undertaking slaughtering of animals must be approved by the competent state/territory regulatory authority to undertake such activity. All individuals, business, enterprises or activities undertaking slaughtering of all animals covered by the Primary Production and Processing Standard for Meat and Meat Products must comply with the following Australian Standards: - AS4466:1998 Hygienic Production of Rabbit Meat for Human Consumption - AS4467:1998 Hygienic Production of Crocodile Meat for Consumption - AS4696: 2007 Hygienic Production and Transportation of Meat and Meat Products for Human Consumption - AS5008: 2007 Hygienic rendering of animal products - AS5010: 2001 Hygienic Production of Ratite Meat for Human Consumption - AS5011: 2011 Hygienic productions of natural casings for human consumption. - AS4464:2007 Hygienic Production of Wild Game Meat for Human Consumption. Regulator to continue with current monitoring arrangements. e.g. may include inspection or audit, or other monitoring arrangement depending on regulator’s legislation. The frequency of monitoring will be based on risk and performance. Check business’s evidence to confirm that animals received or supplied for processing are traceable, as well as meat and/or meat products produced by the business. Confirming compliance using: - LPA program (livestock production assurance), - NVD (National Vendor Declaration), - Pigpass, - NORM (National organochlorine residue monitoring), - NARM (National antibacterial residue monitoring), - START (Sheep targeted antibacterial residue testing). - TART (targeted antibacterial residue testing). - NLIS (National Livestock Identification Scheme).