RIS for Queensland Biosecurity Act

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GregH
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17 Nov 2014, 23:26

Please read and critically evaluate my Regulatory Impact Statement for the Biosecurity Act at viewtopic.php?f=65&t=17374&p=156163#p156163. I'ts due 5PM on November 21
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Lee 62
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18 Nov 2014, 10:33

Won't let me read it
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finchbreeder
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18 Nov 2014, 11:15

Tells me I am not Authorised to read this.
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18 Nov 2014, 15:16

Oops i put it in the Moderators forum so only they can see it. I offer my apologies So here is the RIS:



I am after any help for my Regulatory Impact Statement. Please resound ASAP as the the document but be received by 5 PM on November 21. Sorry about the format tin shown her (it looks better in MS Words)
____________________________________________________________________
To:
Office of Best Practice Regulation
Queensland Competition Authority
http://www.qca.org.au/Submissions

Biosecurity Regulation—draft Regulatory Impact Statement
Biosecurity Queensland
Department of Agriculture, Fisheries and Forestry

GPO Box 46
Brisbane Qld 4001
CC. Mark Lightowler ([email protected])

This document represents the regulatory impact response from a range of Queensland aviculturists to the Biosecurity Act 2014, hereafter referred to as “the Act”. This report is in addition to submissions made using the electronic RIS survey (https://www.getinvolved.qld.gov.au/gi/c ... /view.html). We have submitted this longer, more detailed response as we found that the survey shepherded responses and offered limited opportunity to address the issues that are to be regulated by the Act.

Executive Summary
It is expected that the regulatory impact of the Queensland Biosecurity Act 2014 on aviculturists keeping aviary birds would have a significant negative impact on the avicultural sector if it were to be enforced. It is however likely that in practice impact will be minimal because the Act will be ignored unless it is significantly amended and in all probability is not going to be enforced. The number of regulations required to make the legislation workable is large because the Act includes all bird species regardless of their natural and necessary diet and the lack of proper risk analysis conducted by DAFF on the diseases expected to be encountered, the susceptibility of the various bird species to these diseases and the cultural practices used in Australia to maintain captive populations. The expected outcome of a reduction in legislative burden for aviculturists cannot be demonstrated because not only does it place additional requirements on bird keepers (Nature Conservation Act 1992 and Nature Conservation (Wildlife Management) Regulation 2006) but this new legislation also is in direct conflict with existing obligations under the Animal Welfare and Protection Act 2001.
Background
I am a long time bird breeder who has recently moved to Queensland and am not a current member of any bird club however I am a moderator of the on-line community, Aussie Finch Forum (http://aussiefinchforum.net). As such I have exposure to a wide range of views on aviculture and am acting with the knowledge and support of AFFs Queensland members but this is not to be construed as the view of the owners of AFF. I hold a PhD in in Botany from the University of Melbourne and worked for many years as a scientist in NSW’ Department of Primary Industries and the International Rice Research Institute. My background as an agricultural scientist and my avicultural interests allows me to offer informed insight into many aspects of Australian Aviculture in light of the new Act.
Aviculturists are responsible members of the Australian community and acknowledge the need to control avian and zoonotic diseases in our aviaries and in the human food production chain. My own and the experience of the AFF members is largely in the area of aviary birds so our response will highlight this area of specialisation. I would implore readers of this RIS response to consider an evidence-based approach to control rather than take at face value the unfounded proscriptive regulation that has been drawn into the Act by DAFF regulators.
As it stands, we do not believe that the Act is able to deliver the intended biosecurity benefits or demonstrate a reduction in legislative burden for the Avicultural Sector. In our communications with DAFF, our reading of the Act and the background documents available from the Parliamentary website we find a lack of understanding and consultation by DAFF has led to resentment and doubts over the competence of DAFF to regulate aviculture through the Act. It is likely that most aviculturist will ignore the Act as it stands rather than risk their stock while DAFF and the Act catch up.
Aviculture is extremely diverse, encompassing all aspects of the care and maintenance of all captive bird species including commercial poultry in addition to the public bird exhibits maintained for education or entertainment, the collections of private hobbyists right down to pet owners that may keep a single caged companion bird in their own homes. With rare exceptions birds are not exclusively herbivorous, most are omnivorous (eg honeyeaters, wrens, bower birds, finches, parrots) and many taxa (eg raptors, egrets, kingfishers, crows, flycatchers) are obligate carnivores/insectivores. Even species that the public might think of as seed eaters such as finches or parrots normally procure animal protein in the wild to supplement their diet particularly when breeding. In order to maintain captive populations of birds an appropriate diet and environmental enrichment practices for each species must be provided and this means that essential animal matter must be provided to them.

A diverse array of captive birds has been legally kept in Queensland since colonization. If because of existing, emerging or purely theoretical biosecurity threats posed by captive birds is now considered by DAFF that the prohibition on feeding animal matter was necessary then it should have declared the possession of birds requiring such matter to be illegal unless there is a reasonable way to reduce the risk. The immediate enforcement of vegetarian diets on all captive birds regardless of their natural and necessary dietary requirements will cause the death of many, if not most, captive bird species. We contend that DAFF has exaggerated the risk in order to regulate the sector. Possibly DAFF could have worked with manufacturers, over multiple generations, to prove that the now legislated dietary restrictions were sustainable. Short-lived birds like finches have little capacity to buffer their population and a few years without successful breeding would drive them to extinction in captivity but longer-lived bird species like parrots or pigeons might survive the development phase of new diets. The reasoning behind the prohibition of animal matter in avian diets shows not only a poor understanding of the dietary requirements of captive birds but little understanding of food preparation & storage or the diseases that can reasonably be prevented by such laws, DAFFs feeding rules may present an opportunity for the creation of artificial media however manufactures were not consulted and many of the currently available supplements contain animal matter or are unproven.
Understanding and Analysis of the Legislative Processes.
It is our understanding that the DAFF sought to regulate the Avicultural Sector through the Act because it believed that the sector was largely unregulated and as such represented a threat to Queensland biosecurity and animal welfare. We dispute these assumptions and contend that DAFF did not thoroughly research the avicultural sector and should have provided proof that the regulation of the Avicultural sector through the Act offers significant benefit to the community, animal production systems, the environment and the avicultural sector. We believe that the Australian Veterinary Association was unaware of the existence of the Biosecurity Bill (later to become the Act) until just before the close of the public consultation and that major research organisations (CSIROs Biosecurity Flagship and University of Queensland’s school of Veterinary Science) and animal food distributers, retailers and manufacturers were also not informed of the Act until after it had been passed. Given that the Act was drafted over a number of years it should been incumbent on DAFF to thoroughly investigate all stakeholder groups – especially ones that that it believed were being regulated de novo.
The lack of consultation with the avicultural sector by DAFF regulators drafting the Biosecurity Act has resulted in illogical feeding provisions which if enforced will lead to the extinction of the majority of captive bird species held in Queensland. If through regulation the feeding of animal matter is allowed then the status quo would be maintained making the Acts feeding provisions pointless. Even if the Act were to specify that avian diets could include “uncontaminated or regulated animal matter” there is no doubt that this is already the case and that DAFF lacks the resources to ensure that such foodstuffs are given as many aviculturists prepare their own food so any such provision is unenforceable. We believe that the redirection of public funds or funds taken from other stakeholders amounts to a misplacement and misuse of resources and could alienate the all stakeholders. If enforced the Act will result in the local extinction of many species currently kept securely in the state and which are the source of many of the birds species held in public exhibits.
DAFF has shown that it has little understanding of the nutritional requirements of birds, is very selective in its understanding of avian diseases and has ignored independent expert advice regarding aviculture from the Australian Veterinary Association. Other Queensland based biosecurity stakeholders such as CSIROs Biosecurity Flagship or the University of Queensland’s School of Veterinary Science were not consulted on the need for or appropriate way to regulate the avicultural sector. In drafting the Act to regulate aviculture DAFF failed to engage with it or with its suppliers or the manufacturers of feedstuffs used to support it and for these reasons the Act will receive little support from the avicultural sector. Additional resources needed to enforce the Act would amount to a waste of public funds as it is doubtful the Act actually increases biosecurity protection for the state. By their own admission DAFF's "proactive" approach to biosecurity regulation goes beyond any other state or Federal law by seeking regulate all captive birds without regard to demonstrated risk or resource prioritization.
The state government through the Office of Best Practice Regulation (OBPR) within the Queensland Competition Authority has assured Queenslanders that it will roll back red-tape to reduce legislative burden. It was disappointing to see that the only measure of a reduction in legislative burden mentioned by the Minister when commending the Act to the parliament this year, was that it contained fewer words than the collective Acts it replaced – no actual mention was made of how it actually reduced the legislative burden of affected stakeholders was given. There appears to be a systemic failure within Australian bureaucracies in their management of public displeasure to report on the “efficiency” of the process rather than actually addressing concerns raised (see http://www.ombudsman.gov.au/files/Compl ... t_2014.pdf). The assures Queenslanders that it is “important for regulation to be subjected to a systematic process that ensures, in the first instance, that the regulation is necessary, and that if it is, that it is efficient and effective in achieving policy objectives without imposing unnecessary burdens on Queensland business, community and government”. From the point of view of aviculturists, veterinarians, avian and avian disease researchers it appears that the Act fails the objectives set by the OBPR.
Understanding and Analysis of the Act
The Act encompasses regulations for many classes of designated animals, assets or activities that are unrelated to aviculture so I will restrict my response to those areas that affect aviculture. Specifically the parts of the Act that affect aviculture are:
Schedule 5 Dictionary, What is captive bird, p512
We interpret this to mean all domesticated or captive birds however clarification may be need to make it clear if free-ranging domestic poultry or other free-ranging domesticated species like domestic or racing-pigeons or peacocks are covered by the Act.
Chapter 2, Part 4 Other Offences: Section 46 Designated animals feeding on animal matter
Aviculturists would like assurance that feeding uncontaminated animal matter to birds is not offence under the Act because it is reasonable and therefore legally permissible to do so. Following from this if it is reasonable to do so then why have a feeding prohibition in the Act? The growing public demand for free-range poultry and eggs in Australia presents a far greater risk to biosecurity than do aviary birds primarily because they come into contact with wild birds, are kept in far greater numbers and are part of the human food chain and of course they can and do consume any animal matter they come across.
Aviculturists would like to know under what circumstance is it necessary and lawful to feed the same species back to itself as this presents the highest risk of disease transmission and amplification.
Birds are not considered to be Show Animals as they are not exhibited raptors which are exempt from the prohibition on feeding animal matter. This ignores the fact that raptors are not the only group of birds that have an obligate need for animal matter in their diet in order to survive and express their natural behaviour. Birds other than raptors a long history of public exhibition in Queensland in events and institutions. To single out raptors in Zoos and Circuses shows a narrow and illogical focus. For example Brisbane’s agricultural show, the EKKA, boasts it has exhibited poultry and aviary birds for over one hundred years (http://www.ekka.com.au/animals/animal-b ... ilion.aspx). The Act appear to ignore the fact that bringing designated animals together at agricultural or bird shows and allowing them to disperse afterwards represents a greater biosecutity risk than allowing them to consume animal matter.
Wildlife rehabilitators have limited funds for veterinary care and will seek exemption from the requirement to engage the services of a veterinarian in order to feed appropriate animal-matter to birds under their care.
Chapter 5 Codes of practice and guidelines
We are pleased that before the making of a code of practice that the Governor in Council, the chief executive must consult with relevant entities. We only wish this had occurred during the Acts development phase.
Manufacturers of bird feeds and supplements cannot retrospectively commit to providing animal-matter free products and so existing feeding practices must be made legal. Short-lived birds like finches have little capacity to buffer their population and four years without successful breeding may be acceptable for many parrots or pigeons but most finch and soft-bill populations would not survive the development phase for novel foods. If DAFF wants to enforce vegetarian diets on all birds regardless of their natural and necessary dietary requirements then it should have worked with manufacturers, over multiple generations, to prove that their legislated dietary restrictions were sustainable.
A code of practice for aviculture already exists which was developed by DEAHP in consultation aviculturists. In the absence of any attempt by DAFF to communicate or enforce the 1986 amendment to the Stock Act 1915 (http://www.legislation.qld.gov.au/LEGIS ... 6AC004.pdf) to include all captive birds rather than just commercial poultry, aviculturists have been able to keep and feed a range of native and exotic bird species. The keeping of native birds has been regulated up until now solely by the Department of Environment and Heritage Protection (DEAHP) without restriction on numbers of birds held. Captive native birds must be descended from captive bred stock and registered if they are a regulated species.
DEAHP recognize the necessity of animal matter in the diet of captive birds as part of the obligations of the Animal Welfare and Protection Act 2001 (https://www.legislation.qld.gov.au/LEGI ... aPrA01.pdf). DEAHP clearly state in their Avicultural Code of Practice (http://www.legislation.qld.gov.au/LEGIS ... aPrA01.pdf) that the feeding of live insects and other animal matter is needed for avian welfare and to maintain the population of captive birds. Thus there exist a conflict between the Biosecurity Act 2014 and the Animal Welfare and Protection Act 2001. Aviculturists will choose to follow the Animal Welfare and Protection Act because it makes reasonable assumptions about the diet of captive birds without ascribing arbitrary risk to the feeding of animal matter. The Act itself (Chapter 5, Part 1 Codes of Practice & Guidelines, Provision 105 Consultation about codes of practice) promises consultation with relevant groups will be used to formulate Codes of Practice & Guidelines. Adoption of the existing DEAHP Avicultural Code of practice would be our preference.
Chapter 7 Section 135 What is a special designated animal

Birds are not Special Designated Animals and so are:
1. Not required to be fitted with individual identification devices.
2. Not considered to be show animals and so are not exempted from the prohibition on feeding animal matter
3. Can be brought together for sales, auctions and shows without applying to do so except during designated biosecurity emergencies.

Chapter 7 Section 137 What is the threshold number of designated animals
In regard to the registration of biosecurity entities, that is owners holding 100 or more birds, it is doubtful that such aviculturists will volunteer to register because:
1. The threshold number is purely arbitrary and at this level will affect the normal breeding and selection of shorter-lived species especially low-cost exhibition species like zebra-finches.
2. The Act fails to offer any advantage to the aviculturists or the community through this control
3. The Act States that the register will be published and this places the registrant and their birds at risk from thieves and possibly has implications for insurance of the collection.
4. DAFF lacks the resources to enforce the requirement.

Our conclusions should not be surprising because the Stock Act 1915 was amended in 1986 to expand the poultry provision to include all captive birds under regulated animals with the obligation to register if 100 or more birds were held. The response of aviculturists to comply with this requirement was close to zero so rolling the requirement over from the Stock Act 1915 (amended 1986) to the Biosecurity Act 2014 is unlikely to increase compliance rates. Had aviculturists been consulted and shown that there were demonstrated benefits to aviculturists, animal welfare or to the community then compliance rates may have been larger. The Stock Act 1915 was amended in response to hysteria surrounding an avian influenza in NSW and the new Biosecurity Act 2014 has carried this over without any serious attempt to quantify the risk posed by the various bird taxa, the method of housing or the diseases likely to be encountered or controlled. Realistic epidemiological models for plausible diseases threats incorporating threshold numbers in addition to risks associated with actual taxon, housing and cultural practices are needed to make a convincing case the need for regulation.
Chapter 7 Part 2 Section 145 Registrable biosecurity entity must apply for registration
The majority of aviculturists will likely not register because they believe they have a reasonable excuse to do so.
Chapter 7 Part 2 Section 146 Approval for registrable biosecurity entity to remain unregistered
It is stated that exemption is possible if the biosecurity entity (owner of > 99 birds) can prove they do not pose any biosecurity risk. This is an impossible hurdle so its inclusion is unnecessary a more reasonable threshold risk needs to be set in place. Having captive birds isolated in aviaries that exclude the entry of wild birds should be sufficient. Further risk reduction would be if the aviary is fully roofed and that the collection is not normally open to the public would make the biosecurity risk negligible.

Chapter 7 Part 2 Section 155 Registration Fees

The majority of aviculturists should be exempt from fees as it is our hobby not a business.

Chapter 7 Part 2 Sections 172-3 Biosecurity Register

Aviculturists place themselves and their birds at risk from theft or the actions of animal activists if their names and locations become a matter of public record. We strongly object to the publication of the register or release of the register to anyone upon payment of a fee.
Endnote 4 List of legislation
The Act is not proclaimed until legislation is in place to regulate the Act and these must be in place before 1 July 2016 or will be deemed to be in place on that day even if unregulated.
Disease susceptibility of aviary birds
It is significant that, with the exception of poultry and domestic pigeons - both of which regularly come in direct contact with wild birds, that aviary birds have been free of significant diseases which might endanger the biosecurity of Queensland’s commercial and native avifauna. While all birds are susceptible to commercially damaging diseases like avian influenza and Newcastles disease there is very little chance that aviary birds will come into contact with such disease as outbreaks originate in wild birds and enter commercial poultry flocks whose housing allows entry of wild birds (free-range being the most at risk). There have been no instances in Australia or overseas where aviary birds contracted or retransmitted influenza and even if this did occur then it would burn itself out within the aviary before it was retransmitted. The Australian Veterinary Emergency Plan (http://www.animalhealthaustralia.com.au ... 1Jun11.pdf) makes it clear that it is exposure to wild birds presents the highest risk for disease entry into domestic bird populations. Birds housed in aviaries are of least concern because their confinement isolates them from wild birds. As was stated by the Australian Veterinary Associations' submission to DAFF to exempt captive (aviary) birds from the Act (http://www.parliament.qld.gov.au/docume ... iation.pdf); resources would be better directed to ensuring that the food & water sources of commercial poultry were protected from contamination by wild birds and that aviary birds be exempted from registration.
Food Standards Australia New Zealand (http://www.foodstandards.gov.au/Pages/default.aspx) does not prohibit the consumption of animal matter by humans yet the risk in consuming animal matter is considered by DAFF to be so great that they have prohibited it’s consumption by an entire order of vertebrates. The assumptions behind the prohibition on the feeding animal matter are at the extreme end of plausibility. The fact that viable influenza virus can be isolated from raw duck meat in China is not a reason to prohibit all animal matter from the diets of all birds in Australia. It is a reasonable assumption that such infected meat would not be permitted to enter Australia and if it was to enter that only raptors might be given it in a raw state (yet they are exempted from the requirement).

Conclusion
In drafting the Act, DAFF has made a number of assumptions are not supported by evidence or informed expert opinion:
1 Greater biosecurity to the community and captive bird populations is guaranteed by restricting all captive birds to vegetarian diets.
i. Prohibiting the consumption of the natural food of an entire class of vertebrate is reasonable and necessary.
ii. Birds that are not slaughtered and consumed represent the same risk for epizootic transmission than those that are.
iii. Feeding animal matter derived from the same species to which it will be fed is necessary if done under the guidance of a Veterinarian and undertaken on the same property where it was produced.
2 A threshold number of birds (100 units) is of more importance to epizootic occurrence than any other factor. This implies that:
i. A strong augment for this number was derived and tested in numerous epidemiological models before it was incorporated by the Act
ii. There is no relationship between the potential to generate inoculum and size of the infected bird
iii. All avian taxa have the same susceptibility to all diseases
iv. Owners of birds wishing to remain under a threshold and unregistered will not prematurely dispose of progeny to ensure they remain under that threshold; and that this will not affect the health and susceptibility of these birds to disease
3 The most significant risk of contracting disease in captive birds is:
i. Unrelated to their exposure to wild birds or to domestic poultry
ii. The way in which birds are kept has no bearing on entry and retransmission of diseases in captive population. We contend that aviaries provide two way protection from disease, firstly preventing entry then preventing the exporting of a disease by isolating the inhabitants from external vectors
4 All diseases represent the same level of threat to the biosecurity of Australia’s human and animal population regardless of:
i. The disease causing agent or pathotype already being endemic within Australia
ii. The disease being protected against being purely hypothetical
5 Birds raised in sterile environments are hardier than those where some pathogens are present
6 The Act attempts to manage risk, for which the consequences of failure are of such magnitude that the probability of occurrence is irrelevant
7 The Act does not increase the Legislative burden on Aviculturists
8 Provisions under Act were justified using documented evidence and expert consensus from Veterinary Science, Epidemiology or Stakeholders groups (primary producers, hobbyists, feed manufacturers, retailers, quarantine facility managers and risk analysis engineers etc).
9 The Act imposes proportionate restrictions on activities identified as of highest biosecurity risk such as the keeping of free-range and organic poultry

Recommendations
1. Aviary birds should be exempt from the Act. Aviary birds are defined as any bird/s securely housed in such a way that they are not only confined but wild birds are excluded from the enclosure
2. If birds are to be included in the Act then access to the proposed register should be restricted to DAFF officers or police and the register should not be available to the public.
3. Consumption of essential animal matter should be permitted for any bird species requiring it. Deliberately procuring or producing contaminated animal matter for feeding to birds should be prohibited
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matcho
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18 Nov 2014, 22:19

Wow Gary,

Well done. Heaps of research and well presented. Obviously commonsense never came into the equation when considering the passing of the bill.

One thing though, in reference to Chapter 2 Part 4 "Other Offences" spelling mistake "grater" as opposed to "greater". Never trust spell check.

Once again

well done

Ken.
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Diane
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19 Nov 2014, 07:37

I know the change of format may be responsible for some of these spacing errors
A few other suggestions............

Biosecurity Regulation—draft Regulatory Impact Statement
Biosecurity Queensland
Department of Agriculture, Fisheries and Forestry


Background
As such I have exposure to a wide range of views on aviculture and I'm acting with the knowledge and support of AFFs Queensland members

A diverse array of captive birds has been legally kept in Queensland since colonization. If because of existing, emerging or purely theoretical biosecurity threats posed by captive birds is now considered by DAFF to be so great, then this should be demonstrated by DAFF and their possession declared illegal unless there is a reasonable way to reduce the risk.

This doesnt read quite right to me, I feel it needs something where the dots are but Im not sure what you would want to say.....
The enforcement of vegetarian diets on all captive birds regardless of their natural and necessary dietary requirements ............... then it should declare their possession illegal. have worked with manufacturers, over multiple generations, to prove that the now legislated dietary restrictions were sustainable.

We believe that the redirection of public funds or funds taken from other stakeholders amounts to a misplacement and misuse of resources and could alienate the all stakeholders. If enforced the Act will result in the local extinction of many species currently kept securely in the state. and which are the source of many of the birds species held in public exhibits.


The OBPR assures Queenslanders that it is“important for regulation to be subjected
Diane
The difference between Genius and Stupidity is, Genius has it’s limits
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GregH
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19 Nov 2014, 08:28

Thanks for the feedback I've included your changes.

Should I list the required animal matter utilised in aviculture and it's potential disease risk risk? If for example insects fought in a light trap might carry parasitic worms is that a reason to ban them or to worm your birds when symptoms appear?

Eited this again so I've put in this:

Animal Matter in the diets of captive birds
As previously stated the diets of birds are extremely varied – far more than the insects and worms suggested by DAFF as possible exemptions. The range of captive birds kept in Australia and Queensland require a full range of animal-matter derived foods and supplements derived from nearly all zoological taxa. We can not comment with authority on the requirements of all bird taxa and perhaps a submission and review process for novel animal matter needs to be included as part of the Act. The greatest risk to birds comes from the consumption of raw infected avian meat and eggs or from contamination by avian fecal material in the food and water sources. Aviculturists using meat and eggs source these from the human food supply chain that is carefully regulated and tested by Food Standards Australia New Zealand. I have consulted with FSANZ and they confirm that animal matter is for human consumption is not prohibited and is considered safe if produced under sanitary conditions and is not subjected to spoilage from inappropriate handling. Aviculturists are unlikely to source avian carrion, sick or dying birds as food sources even by those keeping or rehabilitating raptors as a matter of best practice management because of the inherent disease risk – the use of such material could be prohibited in a code of practice. The act itself actually exempts the feeding of animal matter derived from the same species back to itself - if done under the instruction of a veterinarian. This exception is actually the most risky practice and should be prohibited.

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