1/ Applied for a Primesafe Licence to sell yabbies for human consumption. Did not support the requirement to purge since this is not required by NSW or SA food authorities. Also not required by AQIS. Licence application was rejected. See Moora…… document. 2/ Went to VCAT won my argument resulting in no requirement to purge. See VCAT…… document. 3/ Primesafe added new conditions to licence requirements. These conditions are extremely costly and not required by other states. There is no correlation between purging yabbies and water and yabby testing. You can purge yabbies in river water which is not required to be tested. Nothing is achieved. See Post VCAT…… document. Regards, Stephen Chara

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3. What are the requirements that I must implement to be able to comply with a PrimeSafe licence for harvesting yabbies for human consumption? The key requirements are:

Develop a food safety plan that addresses the following requirements:

Gill washing – This is done immediately after harvesting to remove trapped mud and potential

contaminants in gills and is done by placing yabbies in clean water for at least one minute. The yabbies can then be graded prior to transporting to a holding and packing facility;

Purging – Yabbies are purged, normally at a central holding and packing shed by placing them

in clean water for around 48 hours. Sometimes salt is added to remove common parasites. Purging removes gut contents and muddy flavours. The water should be clean (i.e. tank water, reticulated water or clean river water). It is not required to be potable. The water is changed or suitably treated between batches of yabbies;

Packing – The yabbies are packed in a cool moist environment to maintain them alive. Then

they are transported to a retailer, restaurant or wholesale fish merchants;

Premises – The purging and packing process needs to be undertaken in a dedicated enclosed

shed with a floor that can be cleaned; and

Transport – Yabbies need to be maintained alive by transporting in a cool moist environment.

From: Brian Casey [mailto:caseyb@primesafe.vic.gov.au] Sent: Wednesday, 5 September 2012 9:00 AM To: Otway Yabbies Subject: RE: Please respond to the queries in red

Mr Chara, Your email below dated 3 September 2012 refers. In response, I again refer you to my letter of 31 July 2012 and reiterate that;

<!--[if !supportLists]--> <!--[endif]-->VCAT determined that a food safety plan was never properly developed by Moora Moora Pty Ltd.

<!--[if !supportLists]--> <!--[endif]-->In order for Moora Moora Pty Ltd to be licensed by PrimeSafe, a satisfactory food safety plan will need to be developed.

<!--[if !supportLists]--> <!--[endif]-->The matters which much be addressed in any food safety plan are set out on page 2 of my letter dated 31 July 2012.

<!--[if !supportLists]--> <!--[endif]-->It is for Moora Moora Pty Ltd to identify and satisfy PrimeSafe of the requisite quality of the water to be used for the purpose of harvesting yabbies intended for human consumption.

<!--[if !supportLists]--> <!--[endif]-->PrimeSafe will take no further action in relation to a proposed licence application from Moora Moora Pty Ltd until such time as a satisfactory food safety plan and annual fee payable are submitted.  Brian Casey Chief Executive

From: Otway Yabbies Sent: Monday, 3 September 2012 4:39 PM To: Brian Casey; Nathan Howard; Enquiries@primesafe.vic.gov.au Subject: Please respond to the queries in red

Hi Please respond to the queries in red in relation to yabby testing. Also I have just been informed that Silliker Australia Pty Ltd does not send their people outside of their laboratory. Regards, Stephen Chara 03 5266 1556 Manager

Otway Yabbies

From: Anne-Marie Colver Sent: Monday, 3 September 2012 3:55 PM To: Otway Yabbies Cc: Li Chua Subject: Re: Quote required.

Dear Stephen,

Thank you for speaking to me over the phone and the Primesafe document. I have gone through both the document and the Food Safety Australia and New Zealand (FSANZ) references and have found that the following tests apply to raw crustacea;

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Please note that GST is not included in the above fees. A $30.00 administration fee applies per invoice.

Please be aware that these are the expected methods to apply to your samples. At times, these methods may differ depending on your sample type and specifications and therefore the price may be altered.

Standard turn around times apply for microbiological analysis, please be advised that turn around time refers to a negative test result.

Chemistry turn around times (7-10 working days) may depend on the day and time samples arrive at the laboratory.

The tests highlighted above may be subcontracted to other NATA accredited laboratories; by submitting samples to Silliker you will be agreeing to these terms.

Sample Submission

A Sample Analysis Request Form (SARF) is attached; please complete the contact details, sample descriptions and indicate which tests you require and email the form back to me. Testing will not commence until these details have been received.

Payment Options

If you would like to set up an account with Silliker Australia please complete the attached credit application form. This process may take up to five working days, if you require testing before then we will seek credit card details.

If you do not wish to set up an account, Silliker will accept credit card (MasterCard or Visa) details before submitting samples to the laboratory. The estimated value for testing (including all fees and GST) will be reserved on your card when samples arrive at the laboratory and it is not until the analysis is complete and invoice created that the full charge will be processed. A credit card details form is attached, you can email or fax this to me.

You are deemed to have accepted the pricing and methodology presented above upon the acceptance of this quote, and/or the submission of samples. Further information on Silliker Australia's Terms and Conditions for the Supply of Services can be viewed by clicking the link.

Please contact me if you have any queries regarding payment or any other matter.

We look forward to assisting your business.

Kind Regards, Anne-Marie Colver Technical Sales Coordinator Silliker Australia Pty Ltd

www.merieuxnutrisciences.com

On 3 September 2012 10:43, Otway Yabbies > wrote:

Att: Anne Marie

Could you please supply a quote as per Primesafe requirements on page 2 an 3 in the attached. Please note quarterly tests and testing under the direct supervision of a NATA accredited laboratory. Regards, Stephen Chara

Manager Otway Yabbies