Dear sir,
The claimed purpose of the new standards is to replace old standards that “have not kept pace with community and trading partner expectations”. However, despite undeniable community expectations, relevant standards like the length of time free range hens should spend outdoors, the required minimum eight hours for outdoor access in normal weather specified in the national Model Code of Practice for the Welfare of Poultry (4th edition), was left out of the proposed new standards.
The introductions of new standards require a Regulation Impact Statement (RIS) and if this process is incomplete, vague and/or inaccurate, one of the cornerstones of the Australian Government justification for regulatory/standards change is adulterated.
Non-factual claims like higher safety of eggs derived from cages were presented in the RIS although a recent report to the Australian Egg Corporation explained that available data about salmonella prevalence in different layer housing systems is inconclusive. A comprehensive review in 2011 concluded that “there is no general consensus about the superior food safety/egg quality of one housing situation over others. (See goo.gl/5oUYua.) In repeated surveys in Queensland in 2014 and 2015 fewer free-range flocks than indoor flocks were found to harbour salmonella. A NSW Food Authority survey (2013), showed that the old single tier cage farms had the lowest salmonella prevalence (10 per cent), free-range farms with moveable sheds (34 per cent), barn based free-range farms (50 per cent), multi-tier cage and barns (100 per cent).
Public documents for discussion (standards, guidelines and the accompanied RIS) can serve their purpose only if the comparative information between different husbandry systems in the RIS is balanced and accurate.
Regardless of any emerging criticism of the RIS and possible costing inaccuracies, significant welfare improvements are bound to be associated with higher costs. The public is asked to provide feedback on various options proposed in the RIS, including the banning of conventional cages, reductions in stocking densities, provision of perches, litter and nests in cage and non-cage systems and banning routine use of hot blade beak trimming and allowing only one routine beak trimming procedure using infra-red equipment. The ability to respond accurately to various proposals would be affected by the accuracy of the information that was provided in the RIS and some issues like, for example, food safety, may engender more public emotions and self-preservation than others.
Apart from trying to judge the welfare aspects and being confronted with a web of pros and cons, as well as trying to grasp the thin line between mental and physical welfare impacts of various housing options, ultimately an important consideration for many is the cost and what we are prepared to pay to optimise the welfare of poultry.
According to the RIS, costings could range from $709m for the bare minimum proposed Standards and Guidelines to $1,125m for the option of phasing out conventional cages over a 20 year period or, $1,128 for the option requiring nests, perches and litter in cage and non-cage systems.
The difference between the cost of the proposed Standards and Guidelines ($709m) and some welfare friendly options in the RIS varies from approximately $118 to $415m extra costs over the proposed basic Standards. Indeed, significant sums of money that could influence attitudes to various welfare friendly proposals. However, what would community attitude be if a mere brass razoo depicting a lyrebird would pay for these welfare options?
Based on 2016/2017 egg production in Australia (459.2m dozen eggs/annum), 10 cents extra for every dozen eggs produced over the next 10 years would result in $459m intake and handsomely pay for the extra costs of options that were estimated by the RIS to be of higher welfare benefits than others.
10 cents per dozen eggs is all it takes to herald in significant welfare improvements!
Too simplistic, I hear economists shouting but perhaps more tangible to understand for those left confused by pros and cons lists and intimidated by six zero figures.
Would the broader community begrudge paying an extra 10 cents per dozen eggs in order to achieve optimal welfare standards for millions and millions of hens?
George Arzey
via email
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