2011/19: Live animal export: are the new recommendations for the export and slaughter of Australian livestock adequate?


What they said...
'The government's live export reforms represent the most significant and wide reaching changes to the live export industry in almost a decade'
Department of Agriculture information brochure

'This review was an opportunity to properly protect animals at the point of slaughter but instead there is no recommendation on stunning and the government has made no commitment to require it'
Heather Neil, the chief executive of the RSPCA

The issue at a glance
On October 21, 2011, the Australian federal government announced that by the end of 2012 all livestock exporters will have to ensure that animals sent overseas are handled and processed according to internationally accepted welfare standards. To ensure these standards are met the livestock will be traced via independent verification and performance audits.
The changes do not guarantee that animals will be stunned before they are killed; however, the Australian Minister for Agriculture, Mr Joe Ludwig, has maintained that stunning will be strongly encouraged.
The Government has accepted all recommendations made by the Independent Review of Australia's Livestock Export Trade (the Farmer Review) and reports from the Cattle and Sheep Industry-Government Working Groups.

Background
(The following information has been abbreviated from the Wikipedia entry titled 'Live export'. The full entry can be found at http://en.wikipedia.org/wiki/Live_export)

Australia is the world's largest exporter of live sheep and cattle. According to a report by Meat and Livestock Australia, 4.2 million sheep and 572,799 cattle were exported to markets in Asia, the Middle East and other countries in 2005. Most of the livestock are for meat but there is also an active trade in breeding stock, including dairy cattle.
The major market for Australian cattle is Indonesia, which takes 80 percent of annual exports. Other key markets include Israel, Malaysia, Japan, Mexico and China.[9] The major markets for Australian sheep are Saudi Arabia, Kuwait and Jordan.[10] Other key markets are Bahrain, the UAE, Oman and Qatar. Australia's main market competitors are from China, South America and North Africa.
On 7 June 2011, Australia placed a temporary ban on live exports to Indonesia, following an investigation by an animal-rights group of Indonesian slaughterhouses that was relayed to the ABC and formed the basis of a subsequent Four Corners program. The public outcry following the program prompted the government to impose the temporary live export ban.
Opponents of Indonesian slaughter practices and those employed in some other nations importing livestock typically call for the adoption of humane handling practices and the general use of stunning before slaughter. There are also those who are calling for a permanent live export ban. The Australian Greens are opposed to the live export trade and have consistently placed pressure on the Australian government to outlaw the practice.
Those involved in the industry dispute the allegations of opponents of live animal export. They point to alternative investigations that indicate live export adds considerable value to both the Australian economy and the importers' economies. Additionally key indicators of animal welfare purport to show that live export has improved the herd health of the north Australian herd. It has also been claimed that mortality rates on livestock vessels sailing short-haul voyages are lower than those occurring during road transport. Mortality rates in the offshore feedlots are also said to be lower than those in Australian feedlots.

The Recommendations of the Independent Review of Australia's Livestock Export Trade (the Farmer Review
(The following is an abbreviation of the Farmer Review recommendations. The full text of the recommendations can be found at http://www.liveexports.gov.au/__data/assets/pdf_file/0016/2030380/independent-review-of-australias-livestock-export-trade.pdf)

Under the recommended framework, Australian exporters will need to ensure:
animals will be handled and processed at or better than the internationally accepted standards for animal welfare established by the World Organisation for Animal Health (OIE);
they have control of the movement of animals within their supply chain;
they can trace or account for animals through the supply chain;
and they conduct independent verification and performance audits of their supply chains against these new requirements.

The Standards set by the World Organization for Animal Health (OIE) for the movement and slaughter of animals
(The following is abbreviated from the OIE standards. The full text of the standards can be accessed at http://www.oie.int/en/international-standard-setting/terrestrial-code/access-online/)

1. Personnel
There should be a sufficient number of personnel, who should be patient, considerate, competent and familiar with OIE recommendations
Competence may be gained through formal training and/or practical experience. This competence should be demonstrated through a current certificate from the Competent Authority or from an independent body accredited by the Competent Authority.
The management of the slaughterhouse and the Veterinary Services should ensure that slaughterhouse staff are competent and carry out their tasks in accordance with the principles of animal welfare.

2. Animal behaviour
Animals which are likely to harm each other in a group situation should not be mixed at slaughterhouses. The desire of some animals to control their personal space should be taken into account in designing facilities.
Animal handlers should use the point of balance at the animal's shoulder to move animals, adopting a position behind the point of balance to move an animal forward and in front of the point of balance to move it backward.
Smells which cause fear or other negative responses should be taken into consideration when managing animals. Sensitivity to [fear-inducing] noises should also be taken into account when handling animals.

3. General considerations
Each slaughterhouse should have a dedicated plan for animal welfare. The purpose of such plan should be to maintain a good level of animal welfare at all stages of the handling of animals until they are killed. The plan should contain standard operating procedures for each step of animal handling as to ensure that animal welfare is properly implemented based on relevant indicators. It also should include specific corrective actions in case of specific risks, like power failures or other circumstances that could negatively affect the welfare of animals.
Animals should be transported to slaughter in a way that minimises adverse animal health and welfare outcomes, and the transport should be conducted in accordance with the OIE recommendations for the transportation of animals.

Internet information
On Monday May 30, 2011, the ABC aired a 'Four Corners' investigative report on Indonesian abattoirs and their methods of slaughtering cattle.
A full transcript of the program titled, 'A Bloody Business' can be accessed at http://www.abc.net.au/4corners/content/2011/s3230934.htm
The full Four Corners program together with links to relevant news reports and transcripts of interviews with experts and stakeholders can be accessed at http://www.abc.net.au/4corners/special_eds/20110530/cattle/

An Australian federal government online information page giving links to different aspects of its response to the live export issue can be accessed at http://www.liveexports.gov.au/government_action
It includes a summary of the Farmer Review; an outline of the government's response and a timeline for the implementation of the recommendations.

Meat and Livestock Australia (MLA) describes itself as 'a producer-owned company, working in partnership with industry and government to achieve a profitable and sustainable red meat and livestock (cattle, sheep and goats) industry in Australia.'
MLA is the authority cited by government and news media as having the ultimate responsibility for overseas abattoirs guidelines.
The MLA's Live Exports page makes no reference to standards for handling and slaughter. It gives sale statistics for live exports of sheep and lambs from Australia. This page can be accessed at http://www.mla.com.au/prices-and-markets/trends-and-analysis/sheepmeat-and-lamb/live-exports
The MLA's homepage can be found at http://www.mla.com.au/Home

The Western Australian Farmers' Federation sent a submission to the Farmer Review essentially defending current livestock handling practices. The full text of this submission can be found at
http://www.livestockexportreview.gov.au/submission_received/wa-farmers-federation

The Australian Veterinarian Association (AVA) sent a submission to the Farmer Review arguing for improved standards of animals management in the live export industry. Included in their recommendations is the general adoption of stunning.
The full text of the AVA submission can be found at http://www.livestockexportreview.gov.au/submission_received/australian_veterinary_association

The Australian Lot-feeders' Association also made a submission to the Farmer Review, supporting the live export industry but recognising the need for improved standards and greater oversight. The full text of the submission can be found at http://www.livestockexportreview.gov.au/submission_received/australian_lot_feeders_association

The Australian Livestock Exporters' Council also made a very detailed submission to the Farmer Review, acknowledge the need for reform and oversight but arguing that certain sorts of oversight are counterproductive. This is a long submission and it is recommended that careful use is made of its table of contents to take the reader to relevant material.
The full text of the submission can be found at http://www.livestockexportreview.gov.au/__data/assets/pdf_file/0008/1951442/aust-livestock-expalec.pdf

The Animals Australia describes itself as 'Australia's second largest and the most dynamic national animal protection organisation, representing some 40 member societies and thousands of individual supporters.' It was an Animals Australia investigator who supplied the footage of Indonesian cattle slaughter practices that formed the basis of the controversial Four Corners' report on the subject.
Animals Australia's response to live exports can be found at http://liveexport-indefensible.com/

Dr. Temple Grandin is a designer of livestock handling facilities and a Professor of Animal Science at Colorado State University. Facilities she has designed are located in the United States, Canada, Europe, Mexico, Australia, New Zealand, and other countries. Curved chute and race systems she has designed for cattle are used worldwide and her writings on the flight zone and other principles of grazing animal behaviour have helped many people to reduce stress on their animals during handling.
She has also developed an objective scoring system for assessing handling of cattle and pigs at meat plants. This scoring system is being used by many large corporations to improve animal welfare. Other areas of research include effective stunning methods for cattle and pigs at meat plants.
Her website site contains text, graphics and video. The site can be accessed at http://www.grandin.com/

On August 23, 2011, The Conversation published an opinion piece by Siobhan O'Sullivan, Research Fellow, School of Social and Political Sciences at University of Melbourne. Dr O'Sullivan argues that public disquiet about animal handling practices will ultimately end the live export trade. The full text of this comment can be found at http://theconversation.edu.au/live-animal-exports-and-australian-politics-more-than-a-case-of-conscience-2964

On August 23, 2011, On Line Opinion published an opinion piece by David Leyonhjelm titled 'Slaughtering Indonesia's cattle trust'. The piece argues that the ban on live cattle exports had seriously damaged Australian trading relations with Indonesia. The full text of this comment can be found at http://www.onlineopinion.com.au/view.asp?article=12508

On October 21, 2011, the Minister for Agriculture issued a media release outlining the government's response to the Farmer Review. The full text of the release detailing those recommendations the government will accept can be found at http://www.daff.gov.au/ludwig/media_office/media_releases/media_releases/2011/october/gillard-government-reforms-live-export-trade

Arguments in support of the new recommendations for the export and slaughter of Australian livestock
1. The new recommendations are a dramatic improvement on previous practice
The Australian Government and others supporting the new recommendations have claimed they are a major improvement over previous conditions. An Australian Government information brochure states, 'The government's live export reforms represent the most significant and wide reaching changes to the live export industry in almost a decade.'
The Government information brochure goes on to state, 'The reforms mean Australian livestock exported for slaughter will be traced or accounted for, and treated to international animal welfare requirements right through the supply chain.
The government's reforms will give animal welfare assurances to the Australian community, certainty to industry and livestock producers about the sector's future and confidence to importing countries that Australia is a reliable trading partner.'

2. Australia cannot mandate that stunning be employed in other countries
Supporters of the recommendations note that there is a limit to how far the Australian government can go in imposing stock-handling standards on other countries. While it is possible for these nations to source their cattle and sheep from other suppliers, Australia is not in a position to enforce all the treatment practices it would prefer.
If Australia's standards were to become too onerous, importing countries would simply look elsewhere for their cattle and sheep. Ultimately importing countries exercise control over what occurs within their territories. The best Australia can do is encourage and support improved practices by bearing much of the cost.
The executive director of the Northern Territory Cattlemen's Association, Luke Bowen, has stated, 'I haven't found one producer that doesn't agree with adoption of stunning. We also have to be sensible about it and understand that we can't mandate in another sovereign country.'
The Agricultural minister, Joe Ludwig, has stated, 'We don't ourselves require stunning domestically, so it's a bit hard to enforce that on other countries. What we will do though, in relation to stunning, we will certainly advocate strongly in markets that they should approach and utilise stunning.'

3. Over time it is likely that stunning will be adopted
The Minister for Agriculture, Senator Joe Ludwig, has claimed that over time the use of stunning is likely to increase in countries to which Australia exports livestock. In order to help bring about the increased use of stunning the Australian government has given a series of commitments.
The Government has pledged it will seek to increase the use of stunning in live export markets by promoting the inclusion of stunning in the World Organisation for Animal Health (OIE) guidelines through the formal OIE process. Australia has stated it will also promote the use of stunning through work instructions and improved processes and stunning training through regional OIE forums. The Australian Government will also pursue with Australia's trading partners bilateral agreements which include stunning. The government will also support industry efforts to develop and implement voluntary codes of conduct that raise standards above those of the OIE and which include stunning. Finally the government has said it will fund animal welfare improvements in importing countries with support from Australian industry.

4. The recommendations are a sensible compromise that protects livestock while allowing the export trade to resume
It has been claimed that the recommendations are a moderate, feasible response to the previous crisis which both meets animal welfare concerns and operates within the limits of what our overseas export markets are able to achieve. As such it supplies a framework which gives security to both exports and importers of Australian livestock.
The federal Minister for Agriculture, Senator Joe Ludwig, has stated, 'The Government is committed to the live export industry and these reforms will provide stability for the industry and thousands of regional jobs.'
The Senator stressed the collaborative process through which the recommendations had been arrived at, 'The Australian Government has worked closely with the livestock industry and State and Territory governments to develop the new regulatory framework. We have engaged extensively with our trading partners during the development of the reforms and will continue to work with them.'
Senator Ludwig further stated, 'The reforms give certainty to the community who made it clear they want better welfare standards, and certainty to industry and livestock producers who want an industry with a long term future.
Importantly, if animal welfare issues do arise in overseas markets in the future, the Australian Government will have the ability to address these issues without closing entire markets. This is important for delivering global food security.'

5. Whatever costs the exporters may have to bear are necessary if the industry is to continue
These reforms will increase costs for exporters and importers who are now required to provide animal welfare assurance in their supply chains. Initial experience with implementation of the regulatory framework for the live export trade to Indonesia indicates that the additional costs to industry are manageable.
Australian livestock exporters have acknowledged that though implementing the recommendations will be costly, the expenses involved will have to be met if the live export trade is to continue.
Lach MacKinnon, the head of the Australian Livestock Exporters Council has recognised that the home slaughter ban will affect sales, and that it will be costly to impose tracing across the entire live-export industry.
However, Mr MacKinnon has stated, 'The trade will come under pressure, for sure, because that is what they have done in the Middle East for 2000 years and obviously countries don't like being dictated to about how they will feed their people, also, there will be costs involved in implementing these new practices, but we are going to have to work with it.'
Industry chiefs have anticipated such changes, and Sheepmeat Council of Australia chief executive Ron Cullen has indicated that any loss of business due to better animal welfare standards is 'probably the price we have to pay'.
Mr Cullen stated, 'The short-term cost is a cost we have to wear to ensure the future of the industry.'
The Government has agreed to offer partial assistance to exporters in meeting the costs assisted with the new recommendations. The Government has made $5 million available over the next two years to support exporters to deliver improved supply chains. This funding will be available on a 3:1 investment ratio. The full details of this program will be settled in consultation with industry.

Arguments opposing the new recommendations for the export and slaughter of Australian livestock
1. The recommendations do not require stunning
Many opponents of the recommendations argue that they are inadequate because they do not require stunning. This opposition has come from both animal welfare spokespeople and from livestock producers.
The Royal Society for the Prevention of Cruelty to Animals (RSPCA) has welcomed the new protections but said it was 'profoundly disappointed' that slaughter of animals without stunning would continue.
The chief executive of the RSPCA, Heather Neil, has stated, 'This review was an opportunity to properly protect animals at the point of slaughter but instead there is no recommendation on stunning and the government has made no commitment to require it.'
The president of the Cattle Council of Australia, Greg Brown, has stated he was also disappointed the review had not recommended mandatory stunning.
Greens Senator, Lee Rhiannon, has claimed that the Government has failed to tackle animal cruelty. Senator Rhiannon has stated, 'What we do know is that when an animal is stunned, that in most cases ... cruelty diminishes enormously. I've been informed that cattle that have not been stunned can remain conscious for up to two minutes after their throats are cut. That's why we had to have pre-slaughter stunning made mandatory.'
The independent MP Andrew Wilkie has indicated that he would push ahead with a private member's bill to require the stunning of all animals before slaughter.

2. Importers would have adopted stunning if the Australian government had insisted
It has been claimed that the new recommendations are a failure of resolve on the part of the Australian government. The ban on the export of live cattle to Indonesia has resulted in a dramatic increase in the use of stunning within that country.
Critics of the new recommendations claim that if Australian livestock exporters had continued to refuse to supply their animals unless stunning was used prior to slaughter the practice would be likely to be adopted in more countries.
The chief executive of RSPCA Australia, Heather Neil, has argued, 'The fact that the number of Australian cattle that will be stunned in Indonesia is expected to grow from 8 per cent to around 90 per cent in just six months shows that it's entirely possible to overcome any perceived barriers when the incentive is there and that markets can respond quickly if the supply of Australian animals depends on it.'

3. The recommendations do not recognise the conflict of interest in having supervising vets employed by livestock exporters
It has been claimed that the new regulatory system is faulted because it is to be implemented by veterinarians would are employed by the livestock exporters. This is also the current situation and there have been reports of vets who lodge unfavourable reports being intimidated.
Critics claim that while the veterinarians are employed by livestock exporters many of them will be afraid to give a fair and unbiased assessment of the animal-handling practices they are supposed to be monitoring.
Animals Australia said the review had failed to address the conflict of interest faced by veterinarians on board live export vessels, despite hearing evidence of exporters bullying of vets who report negative findings.
The executive director of Animals Australia, Glenys Oogies, has stated, 'That this obvious failure in the system was not addressed is totally unacceptable and will continue to result in inaccurate reporting.'
There has also been criticism that the recommendations do not require that all vessels transporting livestock have a vet onboard.
The president of the Australian Veterinary Association, Dr Barry Smyth, has stated. 'It appears that there hasn't been a change to the current practice of short voyages not having veterinarians ... But we think that there should be a veterinarian on all voyages no matter how long they are. This is to ensure that animals are examined properly on a daily basis; that any abnormalities are detected early and any appropriate treatments delivered promptly.'

4. The recommendations could put the Australian live animal export trade at a competitive disadvantage
There are those who believe that the recommendations go too far and that having to meet the new requirements will make it more difficult and expensive to import Australian livestock. Critics claim that this will put Australian exporters at a competitive disadvantage compared to those livestock exporters that do not have to abide by such rigorous regulations.
The executive director of the Northern Territory Cattlemen's Association, Mr Luke Bowen, has expressed concern that the changes could place Australia at a disadvantage in relation to rival exporting nations. Mr Bowen has stated, 'There is a cost to industry to put a detailed, comprehensive regulatory process in place. We're certainly hoping that you know we're ... going to see competition from other countries that don't have to meet these standards...'
Luke Bowen has further suggested that if the loss of competitiveness were too great this could discourage exporters in other countries from adopting similar standards of animal welfare. It is also likely that if Australia lost its position in these overseas markets through too high a price structure, this would remove Australia's capacity to influence livestock-handling practices in these markets.
Mr Bowen has stated, 'Let's hope it doesn't disadvantage just in pure economics terms; let's hope it doesn't disadvantage Australians and then see the animal welfare improvements not happening in other countries because we're not in those markets.'

5. The recommendations will reduce the profitability of the Australian livestock export industry
It has also been claimed that much of the cost of the new regulations will have to be absorbed by the exporters and that this will reduce the profitability of the Australian livestock export industry.
It has further been claimed that in times of financial duress such as that which results from the long periods of drought which Australian sheep and cattle farmers have had to face, this reduction in profits could make the difference between survival and bankruptcy.
Ron Cullen, the chief executive officer of the Sheepmeat Council of Australia, has stated, 'It will knock a few dollars a head or whatever the amount will be and our members will be expected to absorb some of those costs - just how much I don't have a handle on because there is still a lot of work to be done.
Luke Bowen, the executive director of the Northern Territory Cattlemen's Association has also stated, 'There is a cost, and ultimately the producers end up paying the cost.'

Further implications
What has currently been achieved is a compromise unlikely to satisfy animal welfare groups and others who are seeking both the mandatory adoption of stunning and ultimately the banning of the live export trade.
On October 31, 2011, independent MP Andrew Wilkie introduced a private member's bill into Federal Parliament to make stunning mandatory for all Australian livestock exported for slaughter.
Mr Wilkie told Parliament, 'It is still my belief that Australia's live export industry should eventually be phased out.
But incremental reform is better than no reform, and it is to that end that I now propose to legislate stunning before slaughter in all of Australia's live export markets.'
Responding to the release of the Farmer review, Mr Wilkie said he was bitterly disappointed the Federal Government had shied away from mandatory stunning which would have ensured all Australian animals exported overseas were unconscious prior to slaughter.
Mr Wilkie stated, 'The Government's confirmation today that it will only encourage stunning says to the industry that it's OK for un-stunned slaughter, the cruellest aspect of live export, to continue.
My hope that the Government would show a greater interest in animal welfare and public opinion was misplaced. I now look forward to the Parliamentary debate on my Bill, which I'm confident has the support of millions of Australians.'
The extent of popular disquiet about Indonesian slaughtering practices is not, however, sufficient to determine the issue.
As Dr Siobhan O'Sullivan, Research Fellow, School of Social and Political Sciences at University of Melbourne has stated, 'An enormous number of Australians responded passionately to the Four Corners footage. But the issue of live animal exports is considerably different to other issues where MPs could vote according to the dictates of their conscience.
The key difference is the sizeable financial investments, and returns, tied up with the live animal export trade.'
Currently exporters believe that requiring importers of livestock to stun before slaughter is too great an imposition and they are not prepared to sacrifice the profitable live export trade in the name of popular discomfort about the details of animal slaughter.
Mr Wilkie's bill is likely to attract only the support of the Greens.

Newspaper items used in the compilation of this issue outline
The Australian:  October 1, 2011, page 22, comment (ref to vegetarianism) by Michael Kirby, `Animals deserve our protection'.
http://www.theaustralian.com.au/news/opinion/animals-deserve-our-protection/story-e6frg6zo-1226154340969

The Herald-Sun, October 6, page , comment (answers Kirby comment above) by Miranda Devine,  `Meat lover bites back'.
http://www.heraldsun.com.au/opinion/meat-lover-bites-back/story-e6frfhqf-1226159628737

The Australian:  October 12, 2011, page 8, news item by Milanda Rout, `PM faces vote after stunning backdown'.
http://www.theaustralian.com.au/national-affairs/pm-faces-vote-after-challenge-to-abbatoir-stunning-backdown/story-fn59niix-1226164299417

The Australian:  October 18, 2011, page 1, news item by Neales and Rout, `Cattle growers sweat on live-trade ruling'.
http://www.theaustralian.com.au/national-affairs/foreign-affairs/cattle-growers-sweat-on-live-trade-to-indonesia-ruling/story-fn59nm2j-1226169199232

The Australian:  October 18, 2011, page 2, news item by Milanda Rout, `"No value" in seeing Indon abattoirs'.
http://www.theaustralian.com.au/national-affairs/politics-news/no-value-in-seeing-indonesian-abattoirs/story-fn59nqld-1226169156878

The Australian:  October 15, 2011, page 3, news item by Milanda Rout, `Ludwig ignored live-cattle ban advice'.
http://www.theaustralian.com.au/national-affairs/ludwig-ignored-live-cattle-ban-advice/story-fn59niix-1226167121432

The Australian:  October 22, 2011, page 7, news item by Milanda Rout, `Live export changes to come with $15m bill'.
http://www.theaustralian.com.au/national-affairs/changes-to-live-animal-export-rules-to-come-with-15m-bill/story-fn59niix-1226173555414

The Age:  October 22, 2011, page 7, news item by Dan Harrison, `Export report criticised for no compulsory stunning'.
http://www.theage.com.au/national/export-report-criticised-for-no-compulsory-stunning-20111021-1mcg8.html

The Australian:  October 21, 2011, page 4, news item by Peter Alford, `Aussie rules "driving Indonesian change"' .
http://www.theaustralian.com.au/national-affairs/aussie-rules-driving-indonesian-abattoir-change/story-fn59niix-1226172301210

The Australian:  October 21, 2011, page 1, news item by Milanda Rout, `Tracking for all animal exports to end cruelty'.
http://www.theaustralian.com.au/national-affairs/tracking-for-all-animal-exports-to-end-cruelty-after-farmer-review/story-fn59niix-1226172348752

The Australian:  October 29, 2011, page 7, news item (ref to kosher, halal) by Sue Neales, `Religious abattoirs dodge stun law'. (online version is from the Weekly Times)
http://www.weeklytimesnow.com.au/article/2011/10/30/399951_latest-news.html