Feed Ingredients and Additives Association of Australia Inc

The Feed Ingredient & Additives Association of Australia is a new association representing manufacturers and distributors of feed ingredients & additives.

FIAAA wishes to comment on the following items raised in your Discussion Paper:

1. Risk frameworks- we support the concept of aligning level of assessment with risk.
   
   
2. Lodging Applications- we support initiatives to streamline the application process by defining a pre-registration process
   
   
3. Low risk assessments- Recent work by APVMA of horse electrolytes is a clear example of low risk products requiring lower level of assessment. There are many other examples where there is little risk for the food chain and we welcome judicious review of such products to streamline the work needed in gaining registration.
   
   
4. Assessment timeframes- we welcome the concept of an accelerated assessment. Applications are notoriously slow perhaps compromised by un-necessary detail for low risk applications. We trust your review will address the expeditious processing of applications.
   
   
5. Re-registrations- Where re-registrations occur, the process should also be automatically simplified, especially if there are no changes to the existing permit. We welcome your suggested tiered approach in streamlining the process.
   
   
6. Review- These should also take into account the risk profile, lower risk items requiring less frequent review?
   
   
7. Use of overseas data- we support the concept regarding acceptance of scientific data especially those used or generated for overseas jurisdictions. We support change in legislation to reflect this outcome.
   
   
8. Scientific panel- we support appointment of a panel of scientists and use of a scientific panel in overseeing APVMA review. We however do not support a change in the broad stakeholder representation in the APVMA Advisory  Board.
   
   
9. Appeal process- Australian legal system adopts “innocent until proven guilty” so care must be applied in any forced market withdrawal pending investigation. Perhaps such issues might be assessed by the expert scientific panel (as proposed) if market withdrawal is deemed appropriate by APVMA officers.
   
   
10. Compliance- we support the introduction of a graduated compliance regime including use of product risk profiles in defining the graduated scale.

While the issue of cost and APVMA financial liability is highlighted as a key objective, we are unable to identify in your reforms any issue which addresses any proposed changes. Many of our members find costs can be exorbitant especially for low risk products.

We look forward to the opportunity for further consultation on the reforms as you proceed.

Yours faithfully

John Aird
Executive Manager