Thursday, August 7, 2014

Weedy wanderings

Oxalis sp. Clover like leaves, lemony flavour. This much maligned weed is a refreshing garnish anywhere you'd like a lemon flavour. Around Tasmania you'll find species with white, yellow or pink flowers, and green or maroon leaves. 

One of the very best things about what we do here is community. There are loads of incredible, knowledgeable, like minded people about. Every one of them brings their own gifts, skills, knowledge, energy, philosophy, and every one of them is open, generous and wonderful to be around soaking up the sweet energy of shared ideals.

One such energetic, knowledgeable and all round nice gal is Hannah Maloney of Good Life Permaculture. Hannah is an experienced and vibrant permaculture designer and educator. On Sunday I had the pleasure of showing a group of Hannah's students around our plot and talking about the weeds that grow here and how we use them. It was heaps of fun to be around a group so interested in the functions of plants in a landscape and open to thinking about them in different ways. We have a tendency to want to label things as good, bad, edible, weedy, native...when many plants are far more than just one thing. Taking the time to think and chat about this stuff probably raises more questions than answers, but for me the questions are often more exciting and important than answers. Questions motivate you to think and research, which in turn gives you the opportunity to see something as mundane as a weed through the spectrum of its natural history, botanical detail, nutritional values and cultural significance.

Before the advent of modern vegetables many 'weeds' were important and nutritious foods. In seeking efficiency of harvest, bigger yields, consistent productivity and milder flavours, many of these plants have fallen out of favour. But many still hold significant cultural value. Traditional meals that celebrate the seasons can be found in many cultures. Pistic from Italy, Horta in Greece and Nanakusa-no-sekku in Japan. Below is a run down of what we looked at with Hannah's students on Sunday.

Before you use any of this info though please be aware that a little bit of knowledge can be a dangerous thing. It is all to easy to misidentify something and, while most plants are harmless, there are others that can upset your stomach, cause allergic reactions, burn the inside of your mouth, make you sensitive to sunlight and many other unpleasant outcomes. Some may not affect you negatively but could have adverse impacts on people who are young, pregnant or have compromised health. Please read the warnings below before you make yourself a meal.

ASTERACEAE, Daisy Family
Spear thistle, Cirsium vulgare
Spear thistle, Cirsium vulgare Edible leaves, flowerbuds, and root. Dried flowers used as rennet, seed roasted. Great compost plant.

California thistle, Cirsium arvense 

California thistle, Cirsium arvense Perennial thistle, spreads by rhizomes as well as seed. Edible root, harvested in the first year, leaves and stems. Leaves can be used as curdling agent. This species has both purple and white flower forms. This turned up in our paddock last summer and I'll be doing my best to get rid of it this spring. Being perennial and spreading via rhizomes I think it would be more difficult to control than the odd spear thistle.

Sow thistle, Sonchus oleraceus
Sow thistle, Sonchus oleraceus Young, spring leaves are a tasty salad green. Older leaves can be cooked. Apparently Maori people used the sap as gum, although the medical use of the sap to soften warts makes me curious about the advisability of this.

Dandelion, Taraxacum officinale Edible root, leaf and flower. Addictively bitter spring leaves are wonderful to stimulate digestion. Flowers can be battered and fried or made into ‘wine’.

Out of interest, I found an obscure one while checking dandelion species in Tasmania. It’s interesting to think of how many agrigultural enterprises based on unusual plants have been tried here.
From the Utas Dicot Key: “Taraxacum kok-saghyz (Russian Dandelion) is an uncommon weed species, found near Cressy where it was once cultivated for rubber production. It resembles the much more common dandelion (T. officinale), although smaller.” PFAF database “The root is a source of a high quality latex, used in making rubber[1, 46, 61, 110]. Yields between 150 and 500 kilos per hectare are possible[110, 171]. The roots are harvested in the autumn, before any hard frosts which can destroy some of the latex. They are then macerated to extract the latex. The root is rich in the starch inulin. After the latex has been extracted, this inulin can be converted to alcohol and used as a fuel.”

CARYOPHYLLACEAE, Carnation family
Chickweed, Stellaria media
Chickweed, Stellaria media Winter active weed, grows through the cooler months. Excellent people and animal food, medicinal and great winter groundcover.

Corn spurrey, Spergula arvensis Young leaves as a salad green, or if you've got a lot of time on your hands, the tiny seed is edible too.

Petty spurge, Euphorbia peplus Common annual weed, used to remove sunspots, but use with caution as it’s irritating to some people and keep away from eyes.

Shepherds purse, Capsella bursa-pastoris.

Shepherds purse, Capsella bursa-pastoris Peppery, tasty winter weed. Thrives in infertile soil. Young leaves raw, older leaves cooked. Flower tops make tasty, peppery garnish.

Hairy bittercress, Cardamine flexuosa There are several native, and introduced Cardamine species, all are peppery and edible.

RUBIACEAE Coffee family
Cleavers/Stickyweed, Galium aparine Young, tender shoots eaten cooked. Use roasted seeds as coffee substitute and leaves as a tea. Tangles of this plant are used as sieves for milk.

Acetosella vulgaris syn Rumex acetosella Sheeps Sorrel 
Acetosella vulgaris syn Rumex acetosella Sheeps Sorrel Rhizomatous weed, thrives in compacted, acidic soil. Lemon flavoured leaves, in small quantities or cooked, as they contain oxalic acid, used in salads or pottage. Reported to be used as a milk curdling agent.
Dock, Rumex crispus
Dock, Rumex crispus Thrives in compacted, poorly drained soil. Young leaves are great in pottage, slippery and a little astringent when eaten raw.

Other useful plants:
Nettle, Urtica diocea
Nettle, Urtica diocea Delicious and nutritious edible when cooked to break down stinging hairs. Can be brewed into a fertiliser tea and hosts the larvae of Australin Admiral butterflies and lots of ladybirds here last summer.

Fennel Foeniculum vulgare Ubiquitous and delicious weed. We cather the fronds and leaf bases in spring, the stems for throwing on a fire and adding fragrant smoke to barbeques, the pollen as a flavouring (just cut a big bunch of flowers, brush off any insects and hang upside down in a paper bag to dry) and the seeds in curries.

Mallow, Malva spp Edible leaves, immature seed pods and flowers. Leaves will thicken weed pies and soothe the digestive tract. 

Fat hen, Chenopodium album Wonderful summer weed. Closely related to quinoa it makes a great salad ingredient when really young and a spinach substitute when mature. The seed is edible, but tiny and coated with saponins that must be washed off before consumption.
Native Fireweeds, Senecio minimus also S. linearifolius, S. quadridentatis  and other native speciesGreat colonisers (Mother Nature's band aid!) of disturbed ground and poor soil, fast growing and useful to cut for composting. Senecio linearifolius is easy to strike from cuttings and makes excellent, fast growing habitat. Not edible, but very useful plants.

My thoughts on eating weeds.

Only eat it if you know exactly what it is. Plants can be superficially similar, making it easy to misidentify edibles. Make sure you are absolutely confident with your identification before making a meal. You don’t know what you don’t know. I've seen hemlock harvested by someone who thought it was a wild parsnip, a seaside daisy, probably harmless but containing small amounts of alkaloids, misidentified as sea celery and a fungi gathered for consumption in the wild in Tasmania labelled as a species that doesn't even occur here. Get to know the characteristics of plant families and use these as your guide. Use books, referenced websites and experienced people to guide you, and if you have any doubts leave it out.

Only take what you need and gather from multiple plants.  Generally this rule would only apply to native plants. The plants we forage from provide a number of environmental services. They provide food and habitat for other species, they prevent erosion and protect and stimulate soil life and they propagate themselves. Denude a plant and you remove all of the benefits it provides for its local environment.

PLEASE! Watch where you step. Many coastal plants are edible, and they also can conceal the nests of shorebirds. Species like hooded plovers are under threat, partly due to human activity in their habitat and it is far too easy to tread on a clutch of tiny, sand-coloured eggs and not even know you’ve done it. I’ve also seen shearwater burrows collapse under the weight of a person putting the birds that use those burrows at risk and making the dune susceptible to erosion. This applies to all plants on all habitats. Many species of native orchids are difficult to see and easily trampled. And for your own safety in the warm months keep an eye out for snakes and jack jumpers.

Consider the history of the site you’re foraging on. Pollution can affect the safety of food plants you gather in many differing ways. Nitrogenous fertilisers used in conventional agriculture can cause nitrates to build up to toxic levels in thistles and other weed species that are normally edible and nutritious. Old industrial areas or orchards may have heavy metal or other toxic residues that can accumulate in plant tissue. Roadsides, gardens, parks and farmland may have been treated with herbicides, unless you know the area is clean avoid it! Other reasons to gather carefully and wash what you gather are pollution from traffic, dog urine, septic runoff and a multitude of other pollutants.

Don’t spread weeds or soil borne diseases. Make sure your boots, secateurs and collecting gear are free of soil and weed seeds. If you’re collecting things like fennel seed try to get all of it in your collecting bag and don’t allow it to scatter while you’re cleaning or threshing it. Keep Phytophthora in mind and avoid moving through affected areas.

Try not to break the law. It is illegal to take plant material from reserves (although careful harvest of invasive species may be beneficial). Always seek permission from landholders before foraging on private land. And don’t eat any threatened species.

Damsels with damsons. In any old farming area in Tasmania you are likely to come across damsons and sloes or other wild plums. Every May we take a trip to the back roads of the Derwent Valley and gather damsons to make a tart, rich jam and a thick, spicy sauce with our chillies. While we're there we gather fennel seed for curries and rosehips for tea.


Identification keys, and photos of a lot of the plants that occur in Tasmania.

This is helpful if you want to determine if a particular plant is recorded as being naturalized in Tasmania.

Notes on edibility, medicinal and other uses of thousands of species of plants.


Wild Food Plants of Australia, Tim Lowe

Wild Food in Australia, Cribb

Weeds of the Southeast, FJ Richardson, RG Richardson, RCH Shepherd

Tasmania’s Natural Flora,

Weed Forager’s Handbook, Adam Grubb, Annia Raser-Rowland

Paulette Whitney, 2014

Sunday, April 6, 2014

Three Sisters

Painted Mountain corn, Uchiki Kuri winter squash and Lazy Housewife beans.

This post is a litany of good intentions, naive stupidity and learning from mistakes. You are completely excused for groaning at my ineptitude, or my missing of the bleeding obvious, but, to give me a little credit, although I make a lot of mistakes I'm (sometimes) good at learning from them, and I'm sharing them here so that you can learn from them too.

The Three Sisters is a planting method based on a traditional American technique of which I have only a very tenuous understanding. Native American gardens are complex and are based upon values including nutrition, flavour, stewardship of land and soil, and the spiritual significance of specific varieties of plants and parts of plants. The commonly understood Three Sisters planting includes squash (or pumpkins), corn and climbing beans grown on mounds together, but has countless variations depending on the climate, soil or the gardener. The theory behind the method is that the beans fix nitrogen for the corn and squash, the squash suppresses weeds and provides ground cover, and the corn supports the climbing beans. 

Here at Provenance Growers we're super keen on polyculture. Growing more than one crop in the same bed can be a really efficient use of space. Some crops can be complimentary to each other's needs as in the scenario above, others just get along well enough that we can increase our yield from a bed by sowing faster growing crops amongst slower ones, others involve planting a new crop among one that is almost finished (right now I'm planning to sow broad bean seed under our tomato plants, when we're done with the tomatoes I'll cut them off at ground level and our beans will take off). Tomatillos self seeded amongst our oca and they both seem happy together, the frost that signals the oca harvest will conveniently kill the tomatillos. Every season sees us trying something new, sometimes failing, others succeeding, always learning.

We made our first three sisters mistake at sowing time. I've now learned that you should establish your corn seedlings first, then the beans, and the squash a fair distance away from the other two. Both climbing beans and squash grow fast, the beans need the corn to climb up, and squash will swamp any nearby plants pretty quickly. The second mistake came at planting time, something went terrible awry, we were racing to get our new irrigation system installed and somehow neglected to plant enough pumpkins....zucchini took their place in one bed, volunteer potatoes performed really well in another.

The third, and perhaps most vital mistake was in our variety selection. We planted the plants we always have, with the notable exception of the beautiful grinding corn, Painted Mountain, in these pictures. Our friend Fraser from Old Mill Road Bio Farm quickly recognised that you'd be a dill if you grew things that needed regular picking, like those zucchini (oops!) and green beans (oh dear!) or sweetcorn (bugger!) because the close planting makes getting in to harvest regularly pretty difficult. But we did kick goals with this Painted Mountain, some Uchiki Kuri squash and those volunteer spuds. We also broke the formula by planting in rows rather than the traditional mounds simply because it seems to be the most efficient use of our drip irrigation system. We did make the mistake of planting different varieties in each row, which meant they tasseled at different times, so pollination wasn't as good as it would have been if we'd planted in blocks.

Lessons learned, we will get into it again next year with drying beans, winter squash and pumpkins, grinding or popping corn, perhaps potatoes, and, not being one to stick with a winning formula, I might have a go at interspersing some millet or grain amaranth too, along with whichever other whims strike during our cold Tasmanian winter where we huddle by the fire and dream up plans for next springs gardening adventures whilst quietly cursing the quarantine restrictions that mean we're limited to only a few varieties of corn. *Note: We do value greatly the work Quarantine Tasmania do protecting our state from the scourges of pests like fruit fly, we just sometimes get intense seed catalogue lust, which, sadly, must remain unsated.

Next season I'm hoping to embark upon these shenanigans on a grand scale. I'm keen to work on growing what is traditionally a cheap commodity, grinding or popping corn, and sharing it with some keen locals who will hopefully enjoy the unique flavours and properties that different strains provide, and the differences in flavour that a locally grown and freshly milled crop can provide, enough to make it a commercially viable adventure. Because if these things aren't commercially sustainable then they're sadly not sustainable at all, no matter how delicious or beautiful they are. And we're hoping to supply seedlings of the plants you'll need to embark on your own Three Sisters adventure next spring, or you can just pop down and see us at market and enjoy the fruits of our experiments.

We've kept the husks for tamale wrappers, although they may have to be tiny tamales...

Thursday, March 13, 2014

An 11th hour plea!

I began this letter months ago, but sowing kale, keeping up with animals and weeding has kept me busy. It's our Tasmanian state election this Saturday, and whilst there are so many important issues to be covered, these are the ones that directly impact on our family business.

Any politicians that have something to say will be loudly congratulated!

Dear Politician,

I am writing to you seeking your position prior to the upcoming state election.

Together with my husband I run a small mixed farm growing specialty herbs and vegetables for local restaurants and vegetable seedlings, vegetables and eggs for the Hobart farmer’s market.

The Federal Egg Act is due to become enforceable in November. As far as I understand, following community action, Tasmania’s conditions are under review to better reflect the practicalities of enforcement on producers after confusion and misinformation previously, that lead to media interest in the issue and a petition being presented to Minister Green.

I would love to hear how you and your party intend to offer support for small primary production enterprises.

Our production system is diverse to allow for resilience in the face of fluctuating seasons and markets. This diversity enables us to offer a good range of local, fresh, nutritious food to our customers and also is integral to our land management systems. We currently use poultry to cultivate, control pests, create manure and clean up spent crops. We sell the eggs to cover the cost of their feed and as another income stream on our farmers market stall. Our eight-year-old daughter has grown and sold radishes to raise capital to run quail as her first business venture. She hopes to care for the birds and sell the eggs on our farmer’s market stall, but with limitations on the number of birds as it stands this would prevent her from undertaking this entrepreneurial initiative.

I have been encouraged to hear that all parties intend to support rural Tasmania, and I would love to see this focus not only on large scale agribusiness, but supportive of small scale, family based enterprises as well.

Our business is unique and has followers all over the world on social media. Our brand is intrinsically linked with Tasmania and adds weight to the boutique food angle of Tasmania’s tourism branding. Businesses like ours provide authenticity, depth and faces for the image of Tasmania as a place rich in quality, sustainably produced food.

My husband Matt is a qualified chef, and it would greatly increase the viability of our business if we were able to utilise excess produce to make pickles, jams and other low risk products to sell in the cooler months when produce is more scarce. This is a traditional method that small, family scale farms have used to maintain income streams. The difficulty we face with the current regulations is economy of scale. Because of the diversity that makes our business resilient in the face of the vagaries of weather and markets, we cannot afford to invest a lot of capital in any one aspect of our enterprise, so to access a commercial kitchen would make it to expensive for us to grow, process and market the small quantities we would be producing.

We would applaud a bureaucratic culture that sought to enable family enterprises like ours.

Thank you for your time and consideration.

Warm regards,

Paulette Whitney

The reason we do what we do.
We want our kids to enjoy value in hard work,
good access to a wide variety of clean, fresh food,
cohesive, supportive communities,
a beautiful environment
and successful, happy family life.

Thursday, January 2, 2014

A call to arms!

This post was written earlier this year when draft legislation threatened, in theory, to make it illegal to sell eggs without submitting to regulation that would incur costs that make it impossible for small producers to bring eggs to market at a reasonable price. Our friends from Our Mate's Farm gathered 9000 signatures on their petition to the then Labour Primary Industries Minister, Bryan Green and received positive feedback. Since then we have had a change of leadership and we're holding an egg day, this Sunday, the 24th of August at Farm Gate Market hoping to begin a conversation with our new Liberal ministers about how they can support our small businesses and the wider Tasmanian community. 

Please come along, invite your local member or media personality, sign our petition and chat about the future of small agricultural and horticultural enterprise in Tasmania.

(*the following is out of date, submissions into the review have closed, but please write to your local politician in support of safe, well raised food! ) Submissions are due into the Tasmanian Government's draft legislation Primary Produce Safety Act (Egg) Regulations 2013 by the 10th of January 2014. We'd love your support for safe, local food. Even if you only have the time to pen a few lines, every voice will help to demonstrate the demand to buy food produced on small farms (I've included a copy of my submission at the bottom of this post). Written submissions can be sent to:
Email: or
Post to: Senior Policy Officer Compliance
Biosecurity & Product Integrity Division
Department of Primary Industries, Parks, Water and Environment
GPO Box 44, Hobart, TAS, 7001

As the Tasmanian draft regulations stand, initial accreditation for those with more than 20 hens will cost approximately $525. Plus annual fees (to DPIPWE) which depend on the number of employees, but start at $260, and an annual audit (to a private auditor) costs between $300 and $600. Fees alone would add at least $3.70 per dozen eggs to the cost of production in the first year for flock of just over 20 birds (which would be the situation we would find ourselves in as we gradually increase our flock size as the garden expands). If we add cost of legally required new cartons, feed and costs associated with bringing eggs to market, stall fees, fuel and insurance, it would cost us about $7.98 to sell a carton of eggs. A flock of 50 birds would spread the fees out further but in the first year fees alone would add $1.58 to the price of a carton of eggs. This doesn't take into account any amendments we might be forced to make to our egg packing area (our family kitchen) or the birds housing (a mobile a frame built for us by a friend).  There would also be added labour due to additional administration requirements. I have heard a rumour that there may be other options, but in the absence of them being officially spelled out these are the figures we have to write our submissions from.

As small producers, running a small number of poultry as part of our market garden system, we have a strong concern about the effect these regulations will have on our business as we slowly expand. Small, mixed enterprises like ours are a wonderful, low debt family business that provide us with meaningful, healthy work, in a enterprise that enriches our local community and provides you with access to local, fresh nutritious food, placed into your hands by the hands that grew it.

We would love to see laws drafted and enacted in a manner that recognises the limitations of small, mixed businesses and seeks to support us in producing and marketing safe, fresh food, and communicates clearly, and in a way that is easy for busy farmers to understand. Throughout this process there have been people suggesting selling under the counter, selling eggs as pet food or looking for loopholes, but this is not the way we'd like to do business. We want to run a professional, transparent, ethical enterprise, pay tax, and fees where necessary, and to have the support of the Government to do so.

I love the idea of my children learning the value of hard work and caring for livestock by running small flocks of their own to earn money toward university, a gap year, a guitar... We should enable young, or old, entrepreneurs and provide them with knowledge in how to produce safe food, not price them out of the market.

We are not flippant about the risks involved with egg production. Salmonella is a serious health issue, particularly for those in the community with health problems, the main aim of our enterprise is to provide people with food that is safe, clean and nutritious. We believe that due to the short (nonexistent!) supply chain that our eggs take to get to market, the intimacy we have with hygiene and welfare of our small flock of hens, and the freshness of our product, that our eggs are a safe food. Other states, namely Victoria and New South Wales have higher limits on birds before fees and compulsory stamping kicks in, and they both provide supportive, clear information for producers on how to handle eggs safely.

A few like minded, and hard working egg lovers have come together and written some suggestions that you could use if you'd like to add your voice and support our push to be allowed to use chickens as part of a mixed small holding, and cover their costs by selling eggs. Thank you so much for reading this far, and I promise to write about the garden or a plant next time! Please find our pointers below.

Hi There,

You may be aware that in response to enacted national egg safety legislation, the Tassie Government has put out for comment draft legislation "Primary Produce Safety (Egg) Regulations 2013".  The proposed changes in a nutshell:

Number of egg laying birds

How eggs are used

What am I required to do?
Fewer than 20 egg laying birdsFor home purposes only (including eggs given away to family or friends)Nothing. Producers in this category are not required to stamp their product, nor is an audited food safety plan required.
Fewer than 20 egg laying birdsHome purposes plus some sold at markets, roadside stalls, and to friends, colleagues etcAll eggs sold must be individually marked with a unique identifying mark or code. This can be done with a hand stamper provided to egg producers in this category on registration of their details with DPIPWE. No accreditation is required, however producers in this category are not exempt from the requirements of the Food Standards CodeYou are now leaving our site. DPIPWE is not responsible for the content of the web site to which you are going. The link does not constitute any form of endorsement in respect to eggs for intended sale.
More than 20 egg laying birdsMainly soldAll eggs sold must be individually marked with a unique identifying code. Producers in this category require accreditation and an approved and audited food safety program (this requirement is already in place for producers in this category under the Egg Industry Act 2002You are now leaving our site. DPIPWE is not responsible for the content of the web site to which you are going. The link does not constitute any form of endorsement).

Note: Accreditation and auditing for those with more than 20 birds was already required (but not enforced) under the Egg Industry Act 2002, so the only new requirement for people who sell their eggs on roadsides, at their farm gate, market stalls etc is the stamping. What has also changed is the enforcement of the auditing and food safety program.

Initial accreditation for those with more than 20 hens will cost approximately $525. Annual fees (to DPIPWE) depend on the number of employees but start at $260, and an annual audit (to a private auditor) costs between $300 and $600.

Suggested issues/questions

Will stamping the eggs (traceability) of small to medium sized egg producers (those who sell directly to the consumer or to a single retailer) lower the incidence of salmonella poisoning in Tasmania? 
What information and help can DPIPWE provide to small producers to lower the incidence of salmonella poisoning in Tasmania? (I really like these documents from the Victorian and NSW Governments.)
How many egg laying birds do you currently have? If you have more than 20 birds how do the accreditation fees impact your business? 
Should the 20 bird threshold be raised to take into account the increasing number of small to medium sized producers who raise hens as part of a mixed holding or integrated farming system? If so, what number of laying hens would define a small to medium sized producer? (As a guide, the threshold in NSW is 20 dozen eggs per week, and in Victoria it is 50 laying birds). Please click here for links to the act and to find out where to send your submission. 

Provenance Growers submission for the review of the Tasmanian Primary Produce Safety (Egg) Regulations

Provenance Growers is a small, mixed market garden and edible plant nursery. We sell our produce to some of Tasmania’s leading restaurants and direct to domestic consumers at Farm Gate Market in Hobart.

We feel the Tasmanian Primary Produce Safety (Egg) Regulations fail to recognise the limitations of smallholders to achieve compliance in a cost effective manner.

It is the primary goal of our business to financially support our family whilst providing nutritious and, above all, safe food to our customers. We would love to see compliance and food safety issues addressed in an environment where small enterprises are nurtured by a bureaucracy that has an interest in the success of our enterprises, not just in our compliance.

Our eggs are only sold direct to customers at Farm Gate Market for domestic use. Currently we maintain a flock of 18 laying hens and only sell a few dozen eggs each week. We sell our eggs in new cartons with a label outlining our methods of production, our contact details and date of lay and best before date. We know each customer who buys our eggs, and they know us. Traceability, in our situation is not an issue.

Our flock are an integral part of our production system. We feed them spent crops and weeds, which they convert to manure that we then use in our composting system. They cultivate growing areas between crops, removing weeds and cleaning up insects and spoilt fruit thus eliminating the need for us to use agricultural chemical inputs and therefore increasing the marketability of our produce.

We sell the eggs to cover the cost of supplementary feed for the birds, and also because we want to offer a wide range of produce to our customers.

Our business is expanding as demand for our produce increases and we had planned to increase the size of our flock accordingly. The eggs on our market stall sell out within the first 5 minutes of the market opening for trade and we are asked throughout the trading period for more.

We retail the eggs for $7 a dozen. We feel that after costs this provides a reasonable return for our labour, caring for birds, packaging and bringing eggs to market. The new fee structure would add a minimum of $3.70 per dozen in fees in the first year as we build our flock. We hatch chicks under broody hens so we anticipate the growth of our flock to progress slowly. The lack of a sliding scale in the fee structure does not allow for this, as it begins as soon as you increase beyond 20 laying hens. We calculate our cost of production, packaging and market fees for 21 laying hens to be $4.25 per dozen eggs so when the first year fees are added our break even for a dozen eggs would be $7.95.

As well as the financial impost, we are concerned at the time it would take us to achieve compliance, and also at any infrastructure changes that may be required following auditing. Our poultry housing structures are made from recycled materials and our packing area is our domestic kitchen.

The definition of an egg laying bird is also of concern to us. The draft defines this as “a female bird that has reached a stage of growth where the bird is capable of laying eggs.” In our current flock we maintain older hens who lay irregularly but are valuable to us as broody hens. We also maintain a strain of Rhode Island Reds as meat birds for personal use but they share housing with our laying birds. If these birds are included in the flock number allowable, and should we choose to operate with fewer than 20 birds, this places us at a distinct financial disadvantage to producers who run flocks of commercial hybrids and cull spent fowls.

Implementation of a food safety scheme and making time for inspections will prove logistically difficult for us. Eggs from our 18 birds provide about 2% of gross farm income and a small increase in flock size, to above the threshold, will not increase this percentage greatly. The administrative burden to achieve compliance would render it impossible for us to increase our flock size and remain efficient in terms of time use in relation to income.Refer to Part 2, 13 of the act.

What we would like to see:

·      A charter that producers can fill in with a checklist of risks involved with the small scale production, handling and sale of eggs and clear guidelines on how these can be implemented. This example from NSW is a workable and useful document. WordTM version for customising   

·      A review into the allowable flock size. We feel that in our mixed enterprise we can safely handle, and sell directly to domestic consumers, the eggs from 100 birds and a flock of this size will prove invaluable from a weed management and soil fertility perspective as the scale of our business increases. Our children have expressed interest in raising birds as a source of income and legislation should be written to allow for the reality of family businesses and to foster entrepreneurs by giving them safe guidelines to work under. Victoria and NSW both allow for larger flocks than Tasmania.

·      Recognition that small, mixed holdings do not have the administrative capacity of large, industrial egg producers. In the case of our business there are two full time operators. It has taken at least 24 hours of work time to read, interpret and collate our input for this submission. This is a critical expense for a small, fledgling business.

·      A review into the definition of ‘Laying Bird’ to allow for older hens, broody hens, domestic flocks on mixed holdings and breeding stock.

·      We question the role of stamping as a method of reducing the incidence of food borne illnesses. The incidence of salmonellosis in Tasmania has remained relatively static, from 204 in 1991 to 232 in 2013 (the number of cases peaked at 302 in 2005). Queensland introduced egg stamping as a means of tracing the source of salmonella in 2007. The incidence of salmonellosis in Queensland rose from 2363 in 2007 to 3092 in 2013 (Australian Government Dept of Health, 2013) We advocate for an educative path for small producers and consumers in the safe handling of eggs and egg products. Producers who sell fresh eggs into the local domestic market will not create the same traceability issues as large producers who store, ship, wholesale and /or process eggs.

·      We would also like to see evidence of the risk posed by clean, used egg cartons.  To reduce costs and lessen the environmental impacts of our business reusing cartons would be of great benefit. Labelling issues are easily addressed by removing old labels from cartons. We also question the requirement for our business address to be printed on cartons. As we would be registered with the Department this would negate the need for small, domestic producers addresses to be shown, and allow privacy for us as operators who live with our families on the site of their business, we are happy to provide our phone numbers and email address.

·      Recognition of the value of small mixed holdings, or small poultry enterprises as a low debt business for people wishing to contribute to the Tasmanian economy. Legislation should be drafted in such a way that it enhances food safety and the viability of small business.