The new Meat Regulations 285/13, amending O. Reg. 31/05, made under the FOOD SAFETY AND QUALITY ACT, 2001 were written by OMAF on October 23, 2013 then filed on October 25, 2013 then published on e-Laws as of October 25, 2013 and printed in The Ontario Gazette: November 9, 2013.
Small Flockers have been ignored, in spite of our dedicated campaign and the submission of our recommendations to improve the regulations as requested by OMAF (see here, here, and SFPFC's recommendations here).
As one of the last available avenues to seek redress with Ontario's government, I have used the Service Ontario Regulatory Registry to submit a complaint against the newly revised regulations.
My comments submitted are as follows:
ONTARIO REGULATION 285/13
made under the
FOOD SAFETY AND QUALITY ACT, 2001
Made: October 23, 2013
Filed: October 25, 2013
Published on e-Laws: October 25, 2013
Printed in The Ontario Gazette: November 9, 2013
Amending O. Reg. 31/05
Our complaint and comments are as follows:
a) remote regions of Ontario that have reasonable access or geographical proximity to neither Provincially or Federally licensed meat plants (especially small flock poultry farmers); and
b) to a lesser but still significant degree for all small flock poultry farmers in Ontario (and possibly others):
the above regulations as they apply to poultry (and possibly other meats) are ultra vires, unconstitutional, violate and infringe civil and common law and other rights, violate international law and treaties, and are arbitrary, excessive, un-necessarily subject the public to greater risks and costs than alternative methods, oppressive, not science based, not risk based, have no or inadequate objective evidence to support or justify their imposition, and are contrary to the public's needs and rights for safe, accessible, locally grown, affordable, sustainable, and nutritious meats and meat products.
I have requested a written response, and the standard commitment to this response request is for the relevant Ministry to answer within 15 business days.
We shall wait and see what OMAF says, but since this latest revision in Ontario's Meat Regulations took five years to germinate, and about 9 months to draft, I have no allusions about obtaining a speedy solution for Small Flockers from this semi-fossilized governmental bureaucracy.
If I am to be pleasantly surprised, please do so Premier Wynne.
If my future disappointment is again inevitable, we shall have to look at obtaining relief for our just cause through other avenues and means.