Review of the Exporter Supply Chain Assurance System

Review of the Exporter Supply Chain Assurance System From the Australian Veterinary Association Ltd 9 July 2014 Contact: Marcia Balzer, National Public Affairs Manager, marcia.balzer@ava.com.au 02 9431 5060, 0430 175310 The Australian Veterinary Association (AVA) is the national organisation representing veterinarians in Australia. Our 8500 members come from all fields within the veterinary profession. Clinical practitioners work with companion animals, horses, farm animals, such as cattle and sheep, and wildlife. Government veterinarians work with our animal health, public health and quarantine systems while other members work in industry for pharmaceutical and other commercial enterprises. We have members who work in research and teaching in a range of scientific disciplines. Veterinary students are also members of the Association. Summary AVA supports the Exporter Supply Chain Assurance System (ESCAS) as an important safeguard for the welfare of exported animals after arrival at their destination and to the point of slaughter. It has been effective in prompting significant advances in animal welfare in market countries, and AVA supports the extension of ESCAS to all Australia s livestock export markets. The AVA is aware of the costs to industry imposed by ESCAS, but we see it as a means of assuring the Australian community that appropriate animal welfare standards are being met. ESCAS must continue, and any changes as a result of the review should not water down the regulatory controls currently in place. The AVA believes that there is a significant national interest in ESCAS in the context of animal welfare and in national returns on exports. We are aware that lower returns to industry minimise resources that can be allocated to animal welfare. So effort must be made to improve the efficiency of the export supervision process generally and the operation of ESCAS in particular. The refinement of ESCAS procedures is possible and there is a case for public funding for those aspects of the scheme that return a benefit to the national interest. These aspects include staff policy and advice time, responses to freedom of information requests, investigations, appearances before parliamentary committees and inquiries, and representations to overseas countries. There are divisions within the community and within the veterinary profession itself on whether live animals should be exported from Australia The position statement of the AVA reflects these diversities of opinion by focussing on the animal welfare

considerations that must be regulated and enforced rather than whether the industry itself should or should not exist (see Appendix A). Recommendations ESCAS should continue and be extended to all livestock export markets. ESCAS should be reviewed and refined to ensure maximum efficiency and minimum costs. Exporters should be given on-going approval for each ESCAS and related supply chain. Approval could be withdrawn at any time for non-compliance. There should be greater emphasis on training for all involved in the export process, including veterinarians, industry, auditors, Department of Agriculture staff, overseas trainers and importers, and abattoir staff. The national interest elements of ESCAS need to be identified and those costs met from appropriations rather than recovered from industry. Independent audits should inform change and regulatory action. Any changes as a result of this review should not water down current animal welfare regulatory controls. There should be a review of regulations in relation to diagnosing and exporting pregnant animals to ensure the results are linked to the individual animals involved and to the veterinarians performing them and to assess the success of current controls. The pregnancy status of animals for export should only be determined by a registered veterinarian. Veterinarians accompanying livestock export shipments should not be employed by exporters or shipping companies as this may lead to conflicts of interest and compromises in animal welfare standards. Ideally they should be employed by the federal government on a cost-recovery basis from industry. Why ESCAS must continue ESCAS has achieved significant animal welfare improvements in market countries. It has complemented the investment by the industry in training local workers in more humane handling and slaughter techniques, while also raising general awareness of animal welfare considerations. ESCAS is influencing foreign governments to address their own domestic animal welfare standards and has focused international attention on the issue. With ESCAS came the need for individual identification of cattle, and flock identification of sheep destined for export, and the AVA considers this an important step forward. With individual identification comes the ability to more accurately trace movements, diagnostic tests and procedures. This allows a stronger focus both on animal welfare considerations and tracking in the event of a disease outbreak or animal welfare or public health incident. The independent audit reports mandated by ESCAS have provided useful information on systemic issues and enabled them to be addressed. Australian Veterinary Association 2

ESCAS requires the minimum standards set out in the OIE s Terrestrial Animal Health Code. While OIE does not require pre-slaughter stunning, the introduction of ESCAS has brought about changes in destination countries that have resulted in a very high percentage of animals, including many local animals, being stunned before slaughter. For example, in Indonesia from a base of about 6% more than 85% of imported cattle and many local animals are now pre-stunned. This is an outcome that is welcomed by Australia s veterinarians. The AVA s policy on humane slaughter strongly advocates that all animals should be humanely rendered unconscious before being killed (see Appendix B). This is the standard the live export industry should aspire to in the future if it seeks to continue and thrive. ESCAS provides important feedback to regulators which allows them to understand what is happening throughout the supply chain. This is ensures more effective regulation of the industry, and timely responses to breaches. For all these reasons, the AVA believes that ESCAS must continue. How ESCAS can improve Extending ESCAS to all markets is likely to continue the valuable contribution the scheme is making to animal welfare for Australian animals exported for slaughter. There have been criticisms by livestock export opponents that breaches of ESCAS are more often reported by these external critics than the scheme participants. We are sympathetic to these concerns, and would welcome improvements in reporting and transparency to address them. The AVA urges the government to avoid watering down the requirements in the interests of reducing costs. At the same time, costs should not escalate out of control to a point where the industry is forced to cut corners with animal welfare. The current costs of ESCAS should be reviewed with the aim of streamlining and simplifying regulatory requirements and ensuring the costs to industry only reflect the direct costs of ESCAS. The costs of running a government department and associated activities should be supported with government funding. For example, staff policy and advice time, responses to freedom of information requests, investigations, appearances before parliamentary committees and inquiries, and representations to overseas countries should all be funded by the Australian Government and not by industry. Valuable resources of government and industry are invested in re-approval for each shipment of the supply chain and ESCAS. Exporters should be given on-going approval for each particular enterprise for ESCAS and related supply chain. The exporter would still need to enter a Consignment Risk Management Plan (CRMP) and use the Hot Stuff space /temperature model and meet all ASEL requirements. Approval could be withdrawn at any time in the event of non-compliance. The independent audit would inform decision making. This approach would minimise costly delays, focus government staff on duties critical to animal welfare, and reduce expense. Australian Veterinary Association 3

Stock handling and commercial operations are skilled tasks. There should be greater emphasis on training for all involved, including veterinarians, auditors, Department of Agriculture staff, overseas trainers and importers, and abattoir staff. It is only through a strong, transparent and accountable regulatory regime, with independent audit, that the live export industry will be able to continue with due regard to animal welfare. There are very real risks both to animal welfare and the future of the industry should there be an escalation in breaches, and perceptions of inadequate controls on the activities of exporters. Role of veterinarians The role of veterinarians in the industry is primarily in the phases prior to arrival in the destination country. However, these roles often have implications further down the supply chain, especially in relation to cattle pregnancy testing. For example, there have been instances where cows that calved on board or shortly after arrival were certified as not pregnant before shipment. This has caused some importing country authorities to question the integrity of Australia s certification as well as being a significant animal welfare concern. In response to complaints on this issue in relation to a cattle shipment to Mauritius, the Department issued Export Advisory Notice 2013-01 in June 2013. This notice strengthened the requirements around identification of individual cattle, the veterinarian / person who made the diagnosis, certification and reporting. This was a very appropriate and timely response by the Department. The accuracy of pregnancy diagnoses has been called into question by these incidents, and this reflects our members experiences of widely varying accuracy in the cattle pregnancy diagnosis services currently available in Australia. To ensure a high standard of accuracy, the AVA established the National Cattle Pregnancy Diagnosis Scheme, a national program that accredits registered veterinarians who can provide extremely accurate diagnosis. Given that there are significant animal welfare and potential international trade impacts of inaccurate pregnancy diagnoses of exported cattle, the AVA recommends that all diagnosis should be carried out by a registered veterinarian, and preferably one accredited under the National Cattle Pregnancy Diagnosis Scheme. Veterinarians also have an important role on board live export ships. They assess the physical wellbeing of animals and appropriate treatments when required in order to present the animals in the best possible condition on arrival. Accurate reporting of onboard events enables corrective and regulatory action, monitoring and research. Government veterinary officers and private veterinarians are equally important in the export process and in the training of operatives in importing countries. Private practitioners play important roles in on-farm preparation of stock as well as on board ships. Government veterinary officers contribute along the entire supply chain and in international negotiation and activities. Australian Veterinary Association 4

The AVA strongly believes that veterinarians accompanying shipments must be independent and not employed by either the exporting company or the shipping company. To have a robust and independent regulatory regime, we must ensure there is no conflict of interest for the veterinarian accompanying the shipment. Our preference is for on-board veterinarians to be employed by the federal government with the costs recovered from industry to ensure true independence and an appropriate priority is given to animal welfare concerns. Appendix A Position statement on live animal export There must be strict adherence to the following requirements to protect the health and welfare of animals when they are exported to provide food or genetic material. Importing countries should be members of the World Organization for Animal Health (OIE) and have a legislative commitment to ongoing monitoring and enforcement of animal welfare standards. Animal health and welfare should be protected from farm gate to slaughter through a whole-of-chain enforcement of the OIE Terrestrial Animal Health Code chapter 7 at a minimum. The AVA policy on humane slaughter for all species states When animals are to be slaughtered they must be humanely rendered unconscious until death. This equates to use of stunning for the species involved in live export. Australian exporters and authorities must work to promote these standards in importing countries. The Australian Standards for the Export of Livestock (ASEL) and Australian Maritime Safety Authority requirements must be enforced by the Australian Government and regularly reviewed and updated. There must be an effective and enforceable dispute resolution process agreed between governments prior to export approval being granted. Contingency plans must be in place to ensure that the welfare of exported animals is protected if they cannot be unloaded at the designated port. There needs to be continued research and development into the health and welfare of livestock at all stages of the export process. Every live export shipment must be accompanied by an Australian registered shipboard veterinarian. Veterinarians accompanying shipments must be independent and not be employed by either the exporting company or the shipping company where the entities are different. All measures must be implemented to ensure there is no conflict of interest for the veterinarian accompanying the shipment. Australian Veterinary Association 5

Appendix B Policy on humane slaughter Slaughter of animals must be carried out in a humane manner. Animals must be humanely rendered unconscious until death. Background The slaughtering of animals is usually to provide food, although animal slaughter can also be used for population control and disease eradication. Arrangements should be in place so that animals are spared unnecessary excitement, pain, stress or suffering during movement, restraint, stunning and slaughter. Regardless of religion or cultural beliefs, animals must be humanely rendered unconscious prior to exsanguination. A sheep can remain conscious for 7 to 20 seconds after its throat is cut, while loss of consciousness in cattle under similar circumstances can take up to two minutes. There are species-specific Australian guidelines on how to slaughter animals humanely. These are outlined in the animal welfare model codes of practice as well as in industry standards. Australian Veterinary Association 6