Submissions
28 February 2005
Domestic Food Review Policy Group
New Zealand Food Safety Authority
PO Box 2835
WELLINGTON
Submission on the Domestic Food Review
1 Rural Women New Zealand welcomes the opportunity to comment on the New Zealand Food Safety Authority (NZFSA) review of domestic food regulation.
2 Rural Women New Zealand (RWNZ) is a voluntary organization whose primary aim is strengthening rural communities. RWNZ has over 300 branches spread throughout the rural communities of New Zealand .
3 RWNZ supports the efforts of NZFSA to maintain healthy food for New Zealanders.
4 This submission focuses on the impacts of the review on the voluntary sector in fundraising by means of food sales (cake stall, sausage sizzles etc) and the preparation of food on the farm for employees and farm stays.
5 There has been a saying around for many years “It will be a great day when schools receive all the money they need and the air force has to run a cake stall to buy a new plane”. Unfortunately this is still not the case and schools, sports clubs, rural hall committees etc all rely heavily on fundraising to operate. RWNZ also relies heavily on food based fund raising activities to raise money for a wide range of community projects.
6 There is widespread concern in the community that these traditional methods of fundraising will be threatened due to the need for costly regulation proposed by the review.
7 RWNZ supports Policy Principle 1 that Government involvement and imposed compliance costs to the food sector will be minimised, consistent with Government policies and the need for food to be safe and suitable.
8 Further to that principle RWNZ suggests that in considering the options for Government involvement, as per the diagram in Paper 2 (page 29), that the non-regulatory response of education and information is the appropriate level of involvement for “one-off” fundraising events.
9 RWNZ agrees with the Second Policy Principle in Paper 3 which requires that “persons” take responsibility for producing safe and suitable food. This is intended to underline the importance of safety and suitability being “built in” to individual businesses and Food Control Plans, rather than being the responsibility of others ie “persons” are not expected to rely on regulators to ensure they deliver safe food, but to take that responsibility themselves.
10 Education about food preparation and storage and the development of voluntary Codes of Practice are considered by RWNZ to be the appropriate tools for addressing the issue of food safety for voluntary food-based fundraising activities.
11 RWNZ considers the cost of any regulatory body to enforce compliance on farm activities such as feeding the shearers (as part of the employment contract), small scale farm stays would far outweigh any benefits. It is far better that the “persons” take responsibility for producing safe and suitable food. Therefore education and Codes of Practice would again be the most effective tool to address the issue. For farm stays perhaps there is the need for a maximum number of guests allowed per month without regulation.
12 There is personal responsibility in relation to food preparation and storage in the home. This is also an issue that would benefit from education and information. For example, ensuring the public are aware of the recent information about the average temperatures of domestic fridges will be of major benefit in reducing incidences of illness related to food hygiene.
Recommendation
The most effective means of ensuring voluntary food-based fund raising activities and small scale on farm activities observe safe food preparation and storage procedures is education and Codes of Practice or guidelines rather than regulation.
Yours faithfully,
Sherrill Dackers
National President
Rural Women New Zealand |
