We love our chooks, and we want more!
Submissions are due into the Tasmanian Government's draft legislation Primary Produce Safety Act (Egg) Regulations 2013 by the 10th of January. 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: Egg.Review@dpipwe.tas.gov.au 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.