Live Export

Groups battle over future livex welfare rules

James Nason, 02/02/2016

Anti-live export groups have accused livestock exporters of trying to water down Government regulation of welfare standards in their industry.

It comes as the livestock export industry considers a proposal to change the way Australian Government approved animal welfare standards are complied with in foreign markets.


This image highlights some of the key differences between ESCAS and LGAP. Click on picture to view in larger format.

In recent months the public has been invited to comment on draft new animal welfare standards that would underpin the proposed Livestock Global Assurance Program (LGAP), if the program is adopted by industry.

LGAP would require the same animal welfare requirements as the Australian Government-administered Exporter Supply Chain Assurance System (ESCAS), but would spread responsibility for upholding welfare standards across all stakeholders in the supply chain, not just on exporters as ESCAS does.

Under the existing draft, the program would be overseen by a member-based company with a board of directors that would be independent of industry and Government.

This model is intended to ensure the program operates at arm’s length from industry, to avoid perceptions that it merely amounts to exporters “marking their own homework”, and also to overcome the impression of sovereign imposition that has prevented significant markets such as Saudi Arabia accepting ESCAS. Some countries view ESCAS as being told what to do on their own soil by the Government of another country.

However the Australian Government will remain as the regulator of the Australian livestock export trade if LGAP is implemented.

The 60-day period for public comment on the draft program closed last Friday.

At the same time a number of groups including the RSPCA, Vets Against Live Exports (VALE) and the Humane Society International released statement accusing exporters of attempting to water down Government control and regulation of the livestock export industry.

LGAP will lead to self-regulation: RSPCA

The RSPCA said it lodged a submission to the LGAP consultation process warning that the program would lead to self-regulation and less government oversight of “an industry which has seen shocking breaches in animal welfare”.

RSPCA Australia senior policy officer Dr Jed Goodfellow said RSPCA’s submission to the Committee raised deep concerns over the implications of the “government hands-off” proposals from the industry.

“The LGAP process is industry-driven and funded. It has been promoted on the basis that it is ‘independent of government’ and may appease foreign markets that have opposed the current Exporter Supply Chain Assurance System (ESCAS),” said Dr Goodfellow.

“The industry needs to answer some crucial questions; what does ‘independent of government’ mean, if not self-regulation, and why is this program expected to open markets that have opposed the ESCAS, like Saudi Arabia, if it does not remove Australian Government regulation from the process?”

RSPCA will object strongly to any proposals to remove strong government oversight and regulation of the industry.

“This industry has proven itself to be utterly incapable of effective self-regulation. History has shown that when the industry is left to its own devices, animal welfare is neglected and cruelty ensues,” said Dr Goodfellow.

“The industry does not have the confidence of the Australian community to self-regulate.

“LGAP also seeks to shift the responsibility for the humane treatment of exported animals, from exporters to the abattoirs and feedlots in foreign jurisdictions.

“While we welcome further quality assurance focus on these facilities, Australian exporters must continue to bear ultimate responsibility for the welfare of animals sent into these markets.

“Reducing this responsibility will reduce their incentive to ensure their supply chains are able to comply with animal welfare standards before animals are sent to them,” said Dr Goodfellow.

‘Cynical grab for greater profits’: VALE

Instead of lodging a submission to the review, Vets Against Live Exports released an open letter stating its concerns about LGAP to the public.

VALE’s view is that LGAP places the regulation of welfare into the hands of owners and operators of foreign supply chain facilities and functions as nothing more than “a cynical exercise by those who stand to profit from this unacceptable and unethical trade”.

“The intention is clearly to make life easier and more profitable for those with a vested interest,” VALE spokesperson Dr Sue Foster wrote.

VALE said it preferred to air its concerns about LGAP via an open letter rather than via a submission to the public consultation process, because it said submitters were required to comment only on defined paragraphs of LGAP, which it said was too prescriptive.

Industry responds

The Chair of the LGAP project Standards Committee Dr David Kennedy issued an open letter to respondents to the public consultation process on Friday afternoon.

Australian Livestock Exporters’ Council CEO Alison Penfold said the Farmer Review in 2011 recommended the industry research a welfare conformance and assurance system.

“LGAP is a research project and we thank RSPCA for their contribution. The live trade expects to face effective regulation, even RSPCA would agree with that,” Ms Penfold said.

“So it is prudent that industry research the option of a welfare conformance and assurance system as recommended by the 2011 Farmer Review and noting the outcomes of the 2015 ESCAS review.

“That is what the industry is doing.  No decision has been made to implement until industry has considered the research report.  I also expect the Government will consider the report in the context of its regulatory obligations, LGAP’s ability to meet these obligations and the policy of red tape reduction.

‘Despite their commentary, RSPCA knows more than to suggest this is an effort for self-regulation’

“RSPCA has participated in several discussions on LGAP and despite their public commentary, they know more about the proposed program than to suggest this is an effort for industry self-regulation.”

The Australian Government would remain the regulator of the Australian livestock export trade if LGAP is implemented, she said.

LGAP would not change in the regulatory framework but would develop assurance and conformance processes that enable exporters to demonstrate compliance with ESCAS that reflects more typical conformance programs.

The role of auditors and accredited audit bodies was an example.

“There is strong merit in developing a system that can be recognised and utilised by any government anywhere in the world – a truly international animal welfare assurance system that is auditable and credible – and one that is not seen as an extension of Australian sovereignty as ESCAS currently is.

“This is the heart of why Saudi Arabia does not accept ESCAS and why LGAP may be acceptable to them.

“To be clearer, LGAP could be recognised by the Australian Government as demonstrating and fulfilling the requirements of ESCAS compliance but in a Saudi context it could be seen by the Saudi government as Saudi facilities participating in a welfare conformance program that is not run by the Australian government.

“We believe sharing responsibility for animal welfare with facilities is a better approach to ensuring the welfare of livestock.  Under LGAP this includes requirements for internal audits and the introduction of management systems over welfare requirements and related standards.”

“The trade has never self-regulated and any move to LGAP will continue to involve the Australian government.”

Management of non-conformance under LGAP

Ms Penfold said LGAP had been developed with “a nonconformity management process”.

The process proposed under the Program follows what typically occurs in other conformity assessment programs based on international guidelines and natural justice principles.

Under the Program Rules, nonconformities can be identified either through internal and external audits or feedback or complaints.  In a departure from ESCAS, the Approved Certification Body and Approved Auditor for the Facility (ie feedlot, farm or abattoir) or Operator (ie exporter or importer) would take responsibility for the nonconformity management through corrective action, escalation and ultimately suspension or certification withdrawal.


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