SUBMISSION BY: THE RED MEAT INDUSTRY FORUM ( the Forum ) TO: THE PORTFOLIO COMMITTEE ON AGRICULTURE, FORESTRY AND FISHERIES ( the Committee )

Transcription

1 SUBMISSION BY: THE RED MEAT INDUSTRY FORUM ( the Forum ) TO: THE PORTFOLIO COMMITTEE ON AGRICULTURE, FORESTRY AND FISHERIES ( the Committee ) In respect of issues raised before the Committee during September and October TO: THE PORTFOLIO COMMITTEE ON AGRICULTURE, FORESTRY AND FISHERIES C/o Albertina Kakaza Secretary of the Committee akakaza@parliament.gov.za Phone: (021)

2 Page 2 TABLE OF CONTENTS INTRODUCTION 4 Synopsis of events that led to this presentation 4 The Department s recalcitrance to engage meaningfully with the Forum and the Forum s limited options to address the situation 9 SCHEDULE A 11 I. THE DEPARTMENT S CONTINUED FAILURE TO PROPERLY COMMUNICATE WITH STAKEHOLDERS 11 II. ABATTOIRS 12 Independent Meat Inspection Service 12 Current Status: Independent Meat Inspection Service 16 Current Status: NARS 18 Vacant Posts 18 Current Status: Vacant Posts 18 Registration of Abattoirs 19 Current Status: Registration of Abattoirs 19 III. MEAT IMPORTATION 20 The Current System 20 Current Status: Master Permits 21 The Orion Cold Storage Saga 21 Current Status: Orion 23 IV. BORDER CONTROL 24 Fences 24 Current Status: Fences 25 Lesotho Grazing Permits 25 Current Status: Lesotho Grazing Permits 25

3 Page 3 V. NAMIBIAN TRADE CONDUCT 28 Namibian Small Stock Marketing Scheme 28 Current Status: Namibian Small Stock Marketing Scheme 29 The Proposed Namibian Proposed Cattle Export Policy and Namibian Pig and Pork Import Policy 29 Current Status: New Namibian Trade Barriers 30 VI. ANIMAL HEALTH CONCERNS 30 Tuberculosis, Contagious Abortion and Disease Control 30 Current Status: TB and CA 31 VII. FURTHER ISSUES 33

4 Page 4 INTRODUCTION 1. The Portfolio Committee on Agriculture, Forestry and Fisheries ( the Committee ) has invited the Red Meat Industry Forum ( the Forum ) to give feedback to it on issues previously raised and to address it on challenges facing the red meat industry ( the industry ). This is the Forum s report. Synopsis of events that led to this presentation 2. On 13 September 2011, the Forum made a presentation to Committee (this initial presentation is henceforth referred to as the Forum s first presentation ). 3. On 3 October 2011, the Director-General of the Department of Agriculture, Forestry and Fisheries ( the Department ) submitted a response to the Forum s first representation to the Committee (henceforth referred to as the Department s first presentation ). 4. The Forum only obtained the Department s aforementioned response much later, but nonetheless replied thereto on 24 October 2011 ( the Forum s second presentation ). 5. On 25 October 2011, a further hearing was held before the Committee. At this meeting the chairperson directed the parties to engage on the issues raised by the Forum in its two presentations.

5 Page 5 6. Pursuant to the Committee s directions a workshop was held between the Department and the Forum on 23 November 2011 ( the November 2011 workshop ). 7. The November 2011 workshop was attended by members of the Department, including the Director General of the Department, Mr Zita, Drs Maja, Hlatswayo and Nzibanda, as well as a representatives of the Forum and various specialist presenters invited by the Forum. A detailed presentation 1 was also given highlighting the issues of concern and the reasons for the workshop. The purpose of the workshop was: To address the concerns expressed by the Red Meat Industry in a submission to the Portfolio Committee. To rectify the perception that the Red Meat Industry is a political adversary of the Department and to relieve strained relations. To agree on a workable communication structure that is recognized by both the Department and the Red Meat Industry as being representative. To engender an environment of co-operation to the good of a sustainable Red Meat Industry. To be able to formulate a progress report to [give] feedback to the Portfolio Committee In particular, some of the major concerns expressed by the Forum at the November 2011 workshop included the failure by the Department to successfully engage with industry on reports, the failure by the Department to respond to correspondence and the perception by the 1 2 Forum s Third Submission Bundle, page 33. Forum s Third Submission Bundle, page 35.

6 Page 6 Forum that current communication structures are no longer considered credible The meeting was considered very positive and various decisions were taken and undertakings made in respect of: 9.1 issues raised in respect of the Meat Safety Act (Act 40 of 2000) and more particularly in respect of an independent meat inspection service and the development of the National Abattoir Rating Scheme 4 ; 9.2 South Africa s Foot and Mouth Disease ( FMD ) free status reinstatement after 5 ; 9.3 the prevention, incidents and treatment of Tuberculosis ( TB ) and Contagious Abortion ( CA ) 6 ; 9.4 illegal red meat imports and livestock imports 7 ; 9.5 border fences 8 ; Forum s Third Submission Bundle, page 62; these notes were prepared from the discussions held at the workshop and thereafter distributed to all parties for comment. No further comments or corrections / complaints were received from any of the recipients, including the Department s representatives. Forum s Third Submission Bundle, page 63. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 66.

7 Page compensation under the Animal Disease Act 9 ; 9.7 the Lesotho grazing permits 10 ; 9.8 the Namibian small stock marketing scheme On 2 February 2012, Mr Dave Ford ( Ford ), the Chairperson of the Forum, addressed follow-up letter to the Director-General of the Department in respect of the issues raised and discussed at the November 2011 workshop. 12 This letter was unacknowledged and not responded to. 11. The only issue that was subsequently addressed was South Africa s FMD free status, in respect of which a rezoning application was submitted to the OIE during October To the knowledge of the Forum all other issues currently remain outstanding. 12. Given the lack of progress on the issues raised at the November 2011 workshop, the Forum instructed its attorneys in June 2012 to address Forum s Third Submission Bundle, page 67. Forum s Third Submission Bundle, page 67. Forum s Third Submission Bundle, page 68. Forum s Third Submission Bundle, page 70. Forum s Third Submission Bundle, page 73. The Forum expresses the wish that the Department will make the report to the OIE on the state of South Africa s veterinary services and the application for rezoning publicly available.

8 Page 8 formal correspondence to the Department requesting that the issues previously raised be addressed At the end of August 2012 the Acting Director General of the Department, Mr Sipho Ntombela, responded to the Forum s attorneys letter of 18 June As was the case with the Department s response to the Forum s first submission, the content and tenor of the Department s response was unfortunate as it was clearly aimed at exonerating and vindicating the Department instead of addressing what are clearly very real issues and problems. The Forum repeats that it is not interested in ascertaining where the blame lies, but rather to deal with the issues that are important to the long-term sustainability of the red meat industry ( the industry ) in a manner that recognises the partnership that must exist between the Forum and the Department. 14. The aforementioned response was clearly unsatisfactory and the Forum has been forced to once again, and finally, resort to the Committee to attempt to resolve the impasse Forum s Third Submission Bundle, page 82 and further. Forum s Third Submission Bundle, page 106 and further

9 Page 9 The Department s recalcitrance to engage meaningfully with the Forum and the Forum s limited options to address the situation 15. As is evident from what has been set out above (and further elaborated upon hereunder), there has been a significant, critical and highly detrimental failure of service delivery by the Department. 16. The Forum has exhausted all non-litigious avenues available to it and, despite two previous appearances before the Committee, the issues remain outstanding. 17. The red meat industry is the largest single component of the agricultural industry and has the best prospect of promoting jobs within the agricultural industry. 18. The dysfunctionality of the Department has had the effect that: 18.1 problems that should never be part of a functioning Department are arising; 18.2 attempts by the Forum and other industry role players to engage meaningfully and to co-operate with the Department have failed. 19. As long as the current situation is allowed to continue the industry will suffer. In particular, emergent farmers will be hardest hit as these farmers are characteristically resource poor and risk adverse.

10 Page Central to the issues raised by the Forum has been a failure in proper communication by the Department on all levels. 21. The Department s conduct set out above not only hampers development of the industry, but has also resulted in significant losses to the industry. (Some of these issues have previously been highlighted). 22. The Forum s more detailed report in respect of the remaining issues appear in Schedule A hereto. DATED AT CAPE TOWN ON 22 OCTOBER MR DAVE FORD Chairperson of the Red Meat Industry Forum

11 Page 11 SCHEDULE A I. THE DEPARTMENT S CONTINUED FAILURE TO PROPERLY COMMUNICATE WITH STAKEHOLDERS 23. As is evident from the manner in which the issues raised by the Forum have been dealt with: 23.1 the Department continues to fail to engage with industry on reports, given undertakings and communications; 23.2 the Department continues to fail to respond to correspondence addressed to it; and 23.3 the Forum s perception that the current communication structures are no longer to be considered credible has proven valid.

12 Page 12 II. ABATTOIRS Independent Meat Inspection Service 24. An independent meat inspection service was raised in the Forum s first presentation The Meat Safety Act makes independent meat inspection by all abattoirs peremptory and is the responsibility of the National Executive Officer The Meat Safety Act commenced on 1 November For all most twelve years to the day it has not been implemented This is a serious failure on the part of the Department. 25. At the November 2011 workshop the following decisions were taken in respect of an independent meat inspection service and the National Abattoir Rating System ( NARS ): 25.1 The Department agreed to the process recommended by the technical committee whereby consultative meetings would be held with the respective provinces in the three weeks that followed the November 2011 meeting in order: 16 Forum s First Submission, page 16, paragraph 19.

13 Page for the industry to provide feedback to provinces at meetings to be arranged by the technical committee on outstanding matters with regard to the Department s business plan for one assignee (with a time frame of two months) 17 ; for the provincial authorities to recommend proposed changes to the assignee model in order to meet specific requirements 18 ; to provide an opinion for the implementation of independent meat inspection services to the Minister by the latest 31 March ; 25.2 Feedback meetings between national, provincial and industry were to be held 20 ; 25.3 The Department was to communicate any alternative to the aforementioned model to the industry. Proposals were to be consolidated by 17 February ; Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65.

14 Page An opinion and proposal with full details and recommendations were to be forwarded to the Minister by 31 March ; 25.5 The Department was to follow up on progress of the NARS to the Minister Only the decision in paragraph above, which was to be undertaken by the Forum, has been given effect to. 27. On 22 February 2012, Ford addressed a letter to Dr Molefe, the Chairman of the Sub-Committee on independent meat inspection. 24 Therein Ford reiterated what was decided at the November 2011 workshop, recorded that the road shows to the provincial departments had been completed and recorded that an alternatively proposal should have been supplied to the industry by 17 February 2012 (if there was such an alternatively proposal), that no alternative proposal had been received and that it had been agreed that the proposals would be on the desk of the Minister for her consideration and approval at the latest on 31 March On 29 February 2012, a meeting was held with Dr Molefe. At this meeting Dr Molefe informed the industry that an alternative proposal was in the offing. Ford followed-up this meeting with an on 12 March 2012, confirming what was discussed at the meeting and again reiterating that Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 65. Forum s Third Submission Bundle, page 77.

15 Page 15 the proposals had to be on the Minister s desk at the latest on 31 March Once again this went unacknowledged and was also not responded to. 29. In the Department s August 2012 response, the following was stated: An independent meat inspection service: throughout the years, the state has been providing the service and where they were not able to, contracted a company to assist. The Abattoirs owners (sic) subsequently refused the service the state was offering despite the fact that they were being charged 45% of the actual cost to the state. The industry s strategy was to force the DAFF to appoint some companies as assignees. Since the lodging of the complaint by the RMIF, the Directorate Veterinary Public Health has been working on the possibilities of on (sic) implementation of Independent Meat Inspection Service. It has come to our attention that the approach that has been proposed by the RMIF on the assignee ship (sic), will not favour other industries like the poultry industry. As a result, the DAFF need (sic) to consult extensively to ensure that it is taking correct steps. During the roadshows undertaken by the DAFF team and some industry members, many of the provinces have indicated that they have capacity to offer meat inspection service (sic). This would in our opinion be the best form of independent meat inspection service. Therefore, despite the understanding of industry, The Minister (sic) may decide to keep meat inspection service within the state since this is a public health matter. 30. In respect of the Department s aforestated response the following: 30.1 The appointment of companies as assignees for purposes of meat inspections came about as a result of the poor service 25 Forum s Third Submission Bundle, page 79.

16 Page 16 that was being rendered in terms of meat inspection by the provinces. 26 The statement that abattoir owners refused the service is taken out of context - (the service was sub-standard and often not available) - and the statement that the industry s strategy was to force the DAFF to appoint some companies as assignees is simply incorrect. The fact of the matter is that IMQAS was appointed in consultation by all parties and has been operating successfully The current cost structure proposal for the independent meat inspection service proposed by the Forum excludes the poultry industry. It therefore has no effect on the Forum s current proposal The Forum disagrees that the provinces have the requisite capacity to perform this function. It is also unclear what the financial and budgetary implications of this mooted alternative proposal will be. Current Status: Independent Meat Inspection Service The Department s response is unacceptable. It offers an unjustifiable excuse. 26 Forum s Third Submission Bundle, page...

17 Page The fact remains that there is no independent meat inspection service currently in existence in South Africa. It is a breach of the peremptory statutory requirements of the Meat Safety Act The Forum carried out its undertaking to provide a business plan and budget for an independent meat inspection service To date there is no alternative proposal from the Department and/or any of the provinces to the industry for its input and/or consideration and no proposal of whatsoever nature has been submitted to the Minister to date This ongoing situation is untenable. The Forum requests the Committee to direct the following: (i) Department must present its alternative proposal to the Forum on or before 15 November (ii) The Forum will consider and respond to such a proposal by 30 November (iii) The Department must meet with the Forum s representatives on or before 14 December (iv) Any such proposal as may be agreed upon, alternatively, both parties proposals must be presented

18 Page 18 to the Minister for her consideration by no later than 31 January (v) Both parties must report to the Committee by no later than 31 January 2013 and exchange their proposals. Current Status: NARS 32. No progress whatsoever has been made in respect of the NARS, which remains outstanding for at least two years now. Vacant Posts 33. The high levels of vacant posts within the Department s veterinary services was raised in the Forum s first submission 27 and acknowledged by the Department in its response thereto 28. Current Status: Vacant Posts 34. Despite the acknowledgement of these concerns, the high levels of vacant posts within the Department s Veterinary Services (approximately 25%) persist and directly impact upon the Veterinary Services capacity Forum s First Submission, pages 28 to 29, paragraph 54. Department s First Response, page 12, ad paragraph 54, as read with Annexure B thereto.

19 Page 19 and ability to not only render services to the industry but also respond to crises. 29 Registration of Abattoirs 35. The failure to properly register abattoirs was raised in the Forum s first submission 30, and was noted by the Department 31. Current Status: Registration of Abattoirs 36. According to the statistics available to the Forum, there are still approximately 45 facilities in the Limpopo Province that operate as abattoirs without being properly registered and certified Forum s Third Submission Bundle, page 116. Forum s First Submission, pages 13 to 15, paragraphs 14 to 18.3 Department s First Response, page 4, add paragraphs 13 to 18.

20 Page 20 III. MEAT IMPORTATION The Current System 37. In the Forum s first presentation, the Forum highlighted, as issues that needed to be addressed, the current importation system 32 and the need to formulate South Africa s import policy with Africa 33. Both the aforementioned issues were caused by a lack of proper communication by the Department with industry role players. South Africa s import policy with Africa has subsequently been resolved. 38. At the November 2011 workshop the Forum expressed concern regarding both the issuing of master permits for 12 month periods and various instances of the illegal importation of meat. 39. At the November 2011 workshop the following decisions were also taken in respect of illegal red meat and live stock imports: 39.1 The issue would be presented to the security cluster of government 34 ; 39.2 Permits would be linked to the Department s imports substitution programme 35 ; Forum s First Submission, page 21, paragraphs 34 to 35. Forum s First Submission, page 28, paragraphs 53 to 64. Forum s Third Submission Bundle, page 66.

21 Page A working group would be established to look into illegal permits, which working group would include representatives of the Department, the South African Revenue Services, the Customs Department and the Department of Health 36. Current Status: Master Permits 40. The Forum is not aware of any presentation to the security cluster of government and to date open-ended master import permits are still being issued without reference to tonnage or product (cut). 37 Furthermore, no working group has been established to look into illegal permits. The Orion Cold Storage Saga 41. The defects in the current administration of the import permit system has been highlighted by the importation of pork hearts by Orion Cold Storage (Pty) Ltd during During November 2011, Forum, the South African Meat industry Company ( SAMIC ) and the South African National Halaal Authority Trust ( the Trust ) brought an application for an interdict against Orion Cold Storage (Pty) Ltd ( Orion ) Forum s Third Submission Bundle, page 66. Forum s Third Submission Bundle, page 66. Forum s Third Submission Bundle, page 130.

22 Page Orion had been marketing and selling certain of its products, including meats and dairy based powder, in a manner that was false and misleading. Particularly, the Forum, SAMIC and the Trust alleged inter alia that: 42.1 Orion had imported water buffalo meat from India which was then sold to Frey s Food Brands (Pty) Ltd ( Frey s ) as AB/Bgrade beef; 42.2 Orion had imported pork hearts from Belgium and Ireland, which was packed in cardboard containers, which cardboard containers were then re-labelled and sold to unsuspecting members of the trade as sheep or beef/veal hearts and even marked as halal/halaal; 42.3 Orion imported poultry from Spain, via the United Kingdom, which was then re-labelled and sold to unsuspecting members of the trade as halaal when the poultry was in fact not halaal; 42.4 Orion imported kangaroo meat from Australia, which kangaroo meat was then re-labelled as chuck and blade (which is a beef cut), re-packed and sold as locally produced chuck and blade to unsuspecting members of the trade; 42.5 Orion imported non-food grade milk powder, which milk powder as then re-labelled as skim milk powder fit for human

23 Page 23 consumption and sold as such to unsuspecting members of the trade. Current Status: Orion 43. Despite Orion s heinous conduct, the Department took no action against Orion and the same system and officials that allowed this type of situation to occur is still in operation.

24 Page 24 IV. BORDER CONTROL Fences 44. In the Forum s first presentation the Forum highlighted the deplorable state of sections of South Africa s international border fences in detail. 38 Section 18 of the Animal Diseases Act imposes the obligation on the Director of Animal Health to maintain the border fences. In its first response the Department tried to shy away from what was clearly the Director s responsibility. 39 In its second presentation the Forum contested the Department s representations The issue of the state of sections of South Africa s border fences was again raised in detail in a presentation by Mr Heslinga during the November 2011 workshop. 46. On 25 September 2012, the Forum received information from Dr Robertson, a veterinarian from Namibia, that he has spotted cattle grazing inside the Kruger National Park a clear indication that the fences were not operational as they should be. 41 This information was forwarded to the Department shortly thereafter Forum s First Submission, pages 23 and 24, paragraphs 36 to 39. Department s First Response, pages 10 and 11, ad paragraphs 36 to 39. Forum s Second Submission, page 29, paragraph 5.7. Forum s Third Submission Bundle, page 128.

25 Page 25 Current Status: Fences 47. To date nothing further has been done about this issue, which remains outstanding and critical. Lesotho Grazing Permits 48. At the November 2011 workshop the following decisions were taken in respect of the Lesotho grazing permits: 48.1 It was recorded that the Registrar in terms of the Animal Improvement Act (Act 62 of 1998), Mr Joel Mamabolo, agreed on 21 November 2011 to address the Forum s concerns and withdraw the issuing of animal improvement permits which were contrary to the Act; 48.2 The Director-General undertook to address these valid concerns and proposed that a team from the Forum, the Department and Free State Agriculture should work on a strategy on how to handle this issue, which is presently in contravention of the Animal Improvement Act. Current Status: Lesotho Grazing Permits 49. Despite the aforementioned assurances, permits are still being issued by the Department, but now by the Directorate of Animal Health: Import-

26 Page 26 Export Policy Unit in terms of the Animal Diseases Act. 42 The Forum views the issuing of these permits (for grazing purposes) under the Animal Diseases Act as improper. It also directly contradicts the assurances given and recorded at the November 2011 workshop. 50. The issue surrounding the permits for grazing for cattle from Lesotho is critical in that: 50.1 the lack of proper marking and control of the cattle brought in from Lesotho facilitates livestock theft; 50.2 there is no valid reason for these cattle to be brought into South Africa, which threatens the grazing reserves in the area to the detriment of South African farmers and particularly emergent farmers in the region; 50.3 the permits that are now being issued under the Animal Diseases Act are open ended and perpetuate the same deficiencies and lack of proper control complained of by the forum in respect of import permits in general; 50.4 the perpetuation of the situation by the Department has inflamed relations between South African farmers on the border with Lesotho and Lesotho cattle owners. This situation has 42 Forum s Third Submission Bundle, page 130.

27 Page 27 escalated dramatically of late and is caused directly by the issuing of the grazing permits.

28 Page 28 V. NAMIBIAN TRADE CONDUCT Namibian Small Stock Marketing Scheme 51. The Namibian Small Stock Marketing Scheme is in contravention of the Namibia s obligations as a member of the WTO, the SADC Protocol on Trade and the SACU Agreement It was raised as an issue in the Forum s first submission to the Committee 44 and noted by the Department in its response At the November 2011 workshop the following decisions were taken in respect of the Namibian Small Stock Marketing Scheme: 53.1 the Director-General took note of the Forum s concerns that the scheme was in contravention of the provisions of the World Trade Organisation and the bi-lateral international agreements between South Africa and Namibia 46 ; 53.2 the Director-General undertook to investigate the matter through his counterparts in the Department of Trade and Industry and the Namibian Government Forum s First Submission, Annexure F. Forum s First Submission, pages 38 to 39, paragraphs 73 to 77. The Department s first response, page 15, ad paragraphs 73 to 77. Forum s Third Submission Bundle, page 70. Forum s Third Submission Bundle, page 71.

29 Page 29 Current Status: Namibian Small Stock Marketing Scheme 54. To date nothing further has been done by the Department about this. 55. There was a quantative restriction on the export of live sheep. (It was initially 3 slaughtered domestically for each one exported. This has been changed to a present ration of 6:1.) The Namibian government is now proposing a levy with a range of between 15 30%. The Proposed Namibian Cattle Export Policy and Namibian Pig and Pork Import Policy 56. The Namibian government now also intends implementing two further schemes that will affect the South African red meat industry detrimentally, namely: 56.1 a cattle export policy, which will impose trade barriers to the exportation of cattle to South Africa by limiting the amount of cattle that can be imported into South Africa and which will have a significant impact on the South African market. At this stage South Africa imports approximately 200,000 head of cattle a year from Namibia. The Namibian government would reduced it to 120,000 head per year. Moreover, there is currently a levy of 30% on cattle weighing more than 450kg.

30 Page 30 The Namibian government proposes to reduce this threshold to 380kg 48 ; and 56.2 a pig and pork import policy, which will impose trade barriers in respect of the importation of pork products and pigs from South Africa and which will have a significant impact on South African pork producers that export pork products and pigs to Namibia. Current Status: New Namibian Trade Barriers 57. Both the aforementioned proposed new policies constitute unlawful trade barriers, detrimentally impact upon the Forum s members, have been brought to the Department s attention and are currently unaddressed by the Department and the South African government at large. VI. ANIMAL HEALTH CONCERNS Tuberculosis, Contagious Abortion and Disease Control 58. At the November 2011 workshop the following decisions were taken in respect of Tuberculosis ( TB ) and Contagious Abortion ( CA ): 58.1 The Department was to provide a biosecurity plan for farmers on how to prevent an outbreak and also how to deal with one 48 Forum s Third Submission Bundle, page 134.

31 Page 31 on their farm. The Forum offered to finance the publishing of such information in weekly farmer magazines 49 ; 58.2 The occurrence of these diseases would be verified and updated 50 ; 58.3 An industry representative veterinarian was invited to attend a meeting with the Department to discuss policies on the aforementioned two diseases (the Forum s chairman would supply the name of veterinarian to the Director of animal health s office) 51 ; 58.4 A transparent evaluation according to OIE standards and the performance of veterinary services would be done to assure the industry that veterinary services is equipped to control with any disease outbreak 52. Current Status: TB and CA 59. Only paragraph 58.4 above was complied with (as part of the application to the OIE in respect of South Africa s FMD free status). A meeting was held with a veterinarian delegated by the Forum, Dr Schultheiss, on 1 December 2011, but nothing further came of this Forum s Third Submission Bundle, page 66. Forum s Third Submission Bundle, page 66. Forum s Third Submission Bundle, page 66. Forum s Third Submission Bundle, page 66.

32 Page None of the other decisions have been followed through on and outstanding and remain of concern to the Forum. 61. The control of animal diseases and the provision and control of vaccines (which falls within the definition of agricultural remedies as referred to in the Fertilizer, Farm Feeds, Agricultural Remedies and Stock Remedies Act, Act 36 of 1947, as amended) is of great concern to the Forum. As well as the instances of TB and CA mentioned above, the Department has also failed to act against Dr Daan Goosen who, though entities controlled by him, has been manufacturing and selling various vaccines whilst unregistered to do so in terms of the aforementioned Act. 53 Goosens conduct is not only illegal, but also a direct threat to the industry. 53 Forum s Third Submission Bundle, page 135.

33 Page 33 VII. FURTHER ISSUES 62. Compensation. 63. Proposed Fertilizer and Feed Bill. 64. Dispute resolution measures under the Meat Safety Act and Animal Diseases Act.