The Productivity Commission has been accused of ignoring significant industry and Government efforts to achieve world-leading animal welfare standards in Australian agriculture, and favouring skewed welfare group policies to solve problems that don’t actually exist.
The comments come from the Red Meat Advisory Council in the wake of yesterday’s release of the final Productivity Commission report into the regulation of Australian Agriculture.
As its draft report released in July 2016 highlighted, the Productivity Commission’s final report recommends Australia create a single statutory agency responsible for developing national farm animal welfare standards.
The move has been warmly received by the RSPCA which has accused Australian agriculture of lacking leadership on farm animal welfare policy.
However RMAC, speaking on behalf of the grassfed and grainfed cattle sectors, as well as live exporters, processors, and sheepmeat and goat producers, says the Productivity Commission’s report goes against its core objective of increasing agricultural productivity, and will only add further red tape and cost with no welfare gain.
Productivity Commission findings
In its report the Productivity Commission said Australians generally accept the rearing of animals for commercial purposes, evidenced by their consumption of animals as food or in other products.
They also place a value on farm animal welfare and benefit from knowing animals are being treated humanely.
The report acknowledges that good animal management practices align with increased productivity and profitability of livestock operations, giving producers an incentive to improve animal welfare to meet changing consumer demands for higher welfare products.
It says the current process for setting standards for farm animal welfare does not adequately value the benefits of animal welfare to the community.
In the commission’s view, standards and guidelines for farm animals need to be more evidence-based, and should draw on the existing body of evidence on animal welfare science and research on community views of animal welfare.
The PC says a statutory agency should be created, responsible for developing national farm animal welfare standards using rigorous science and evidence of community values for farm animal welfare.
“The Commission maintains the view that the most effective approach would be to establish an independent statutory agency — the Australian Commission for Animal Welfare (ACAW) — with responsibility for developing the national standards — the standards would be implemented and enforced by state and territory governments,” the report states.
“ACAW would be responsible for managing the RIA process for the proposed standards, and would include science and community ethics advisory committees to provide independent and rigorous evidence on animal welfare science and community values.
“ACAW would also disseminate information to the community on best-practice farm animal husbandry practices and contemporary animal welfare science, including through the development and publication of standards and guidelines.
“ACAW would be able to offer assured scientific guidance (often missing in debates about animal welfare) which would help facilitate a more proactive, rather than reactive, response to community concerns about animal welfare.
“ACAW would not result in a duplication of current regulatory processes or necessarily result in an increase in regulation (a concern that was raised by some industry participants).
“ACAW would replace (and improve upon) the national structure that is already in place for developing standards and guidelines. Importantly, ACAW would be an advisory body, not a regulatory body, and comprise a small number of members with specified skills and experience.”
The Commission also says there should be more independence in the standards development process so that outcomes are not overly influenced by the views of any one group, either industry or animal welfare groups.
Judgments made to balance conflicting views should be transparent and apply rigorous scientific principles. Surveys of community values for animal welfare should be statistically robust and transparent.
As an example of disproportionate industry influence in Regulation Impact Assessment processes, the Productivity Commission pointed to an assessment in the newly endorsed sheep standards and guidelines that the net incremental benefits provided by pain relief for mulesing did not justify the additional compliance costs to industry.
“This assessment was based on the views of a reference group, which comprised representatives of 11 national livestock industry organisations, representatives from the eight state and territory relevant government departments, and the Australian Government, two animal welfare organisations and the Australian Veterinary Association.”
RSPCA welcomes proposed Australian Commission for Animal Welfare
The RSPCA said the report provides a clear vision for the future of animal welfare policy governance in Australia.
RSPCA Australia Senior Policy Officer Dr Jed Goodfellow said the findings justified many of the RSPCA’s concerns about a lack of national leadership on farm animal welfare policy.
‘The report identifies the failure of our current standard-setting processes to properly consider independent scientific advice and community expectations regarding key animal welfare issues in livestock industries,” Dr Goodfellow said.
“It also details widely-held concerns about the lack of transparency and conflicts of interest in the decision-making process.
“By establishing a more independent framework, these proposals would also go some way to de-politicising the current animal welfare policy process, something a lot of stakeholders would greatly appreciate.
The RSPCA said the Productivity Commission report also highlighted the need for greater openness and transparency in farm animal welfare monitoring and enforcement activities, as well as greater separation between agricultural policy matters and the monitoring and enforcement functions at the state level.
RMAC: “More red tape with no welfare gain”
Red Meat Advisory Council (RMAC) chairman Don Mackay said the final report had over-reached with regard to animal welfare.
“Australian producers and other supply chain stakeholders are proud of their hard-earned reputation as world leaders in livestock welfare standards and are committed to demonstrating to the community we are continuously improving standards and practices,” Mr Mackay said.
“RMAC’s Meat Industry Strategic Plan (MISP2020) confirms our industry’s absolute commitment to improved animal health and welfare, while more effectively engaging with the public regarding supply chain initiatives which align industry practice with community expectations. Furthermore, industry has committed to working with Government to better communicate to the community the significant work being done.
“But more red-tape and bureaucratic processes won’t help improve the welfare of livestock on farms or in our supply chains, it will merely create further administrative costs for the red meat industry and do not reflect the Federal governments approach to unlocking growth in the Australian red meat and livestock sector.”
Mr Mackay said the red meat industry’s concerns regarding a lack of balance which arose from the PC’s draft report, released in July last year, had not been allayed by the release of the Productivity Commission’s final report.
“At a time when Australia’s competitiveness and global market access is already being tested by our high operational costs, the Productivity Commission report’s animal welfare recommendations do not reflect the practical, commercially viable policies embraced by industry and supported by the Federal Government,” he said.
“It would seem that not only does the recommendation to establish an Australian Commission for Animal Welfare actually goes against the core objective of the report – to find ways to increase agricultural productivity in Australia by cutting red tape – it also adopts skewed animal welfare lobby policies to solve a problem that doesn’t actually exist, putting at risk thousands of Australian jobs.”
“It would appear significant industry and government efforts to drive and uphold the world’s best animal welfare outcomes have been overlooked in this report. Through industry direction, industry research and development bodies such as Meat & Livestock Australia, LiveCorp and Australian Meat Processors’ Corporation have spent millions in researching best-practice methods and enabling stakeholders to upskill and adopt new standards throughout the supply chain.
Mr Mackay said Australia’s red meat and livestock industry contributes approximately $7 billion to Australia’s gross domestic product.
“Our red meat processing sector has an annual turnover in excess of $16 billion, making it the largest trade-exposed manufacturing industry in Australia,” he said.
“The industry is also Australia’s largest food manufacturer and a significant employer in rural and regional areas, directly employing some 200,000 Australians on-farm across the supply chain, while supporting thousands of other jobs indirectly.”
More points from the PC report:
The Commission found that Australian farm businesses are subject to a vast and complex array of regulations, and the cumulative burden on farmers is substantial.
It notes that Australian farmers want better, or less burdensome regulation.
Some regulations lacking sound policy justification it identified included:
- Restrictions on the use of land held under pastoral lease arrangements
- State bans on cultivating genetically modified crops
- Barriers to entry for foreign shipping providers
- Mandatory labeling of genetically modified foods
In other cases, the Commission said regulation is the wrong policy tool. As an example, it says regulatory changes to address community concerns about foreign investment in agriculture are costly and likely to be ineffective. “A better informed conversation about foreign investment is needed”.
The PC report says other regulations and regulatory systems need to be reformed so they can more fully achieve their objectives:
- Native vegetation and biodiversity conservation regulations need fundamental change so that risks and impacts are considered at a relevant landscape-wide scale. Environmental regulatory decisions also need to take into account economic and social factors.
- International evidence could be put to greater use in assessing agricultural and veterinary (agvet) chemicals, reducing the time and cost taken to grant registration.
- Road access arrangements for heavy vehicles should be streamlined and simplified.
- Inconsistent regulatory requirements across and within jurisdictions make it difficult for farmers to understand their obligations and add to the cost of doing business. A more consistent approach would improve outcomes in the areas of heavy vehicle regulation and road access, and the use of agvet chemicals.
Governments could also reduce the regulatory burden on farm businesses by:
- improving their consultation and engagement practices. There is scope to better support landholders to understand environmental regulations, and to reduce duplicative and unnecessary information gathering regarding water management by farm businesses
- doing more to coordinate their actions, both between agencies and between governments
- ensuring that good regulatory impact assessment processes are used as an analytical tool to support quality regulation making, not as a legitimising tool or compliance exercise.
Not all regulation is bad – for example biosecurity and food safety regulations were highlighted as providing clear benefits to Australian farmers.
Live export regulation is costly but has led to some improvements
The Productivity Commission report said the introduction of the Exporter Supply Chain Assurance System in Australia’s livestock export industry has led to some improvements in welfare outcomes for Australian livestock in some overseas export supply chains.
For example, it said, the rate of pre-slaughter stunning has increased in Indonesia, as has awareness of international welfare standards in some overseas countries.
“The livestock export industry has made substantial investments in infrastructure, training and systems to meet ESCAS requirements.
“However, industry is concerned about the administrative burden of the ESCAS.
“The regulatory burden on exporters could be reduced through greater cooperation between exporters, including the sharing of audits and implementing an industry quality assurance program.
“Whether an industry-developed quality assurance program could be used by exporters to demonstrate compliance with the requirements of the ESCAS depends on whether it can be shown to assure the welfare of Australian live exports, in line with the Australian community’s expectations.
“It is critical that the community has confidence in the system used to regulate live exports. Incidents of mistreatment of animals in facilities that are within the purview of the ESCAS, and that are overseen by the Australian livestock industry, reduce community confidence in the trade and the regulator’s effectiveness.
“Focusing government resources ($8.3 million has been announced) on the implementation of an industry quality assurance program (the Livestock Global Assurance Program) should not be at the expense of continual review and refinement of the ESCAS.
“The performance of the ESCAS should be reviewed on a regular basis (including to identify opportunities for reform to improve its efficiency and effectiveness). Regular, independent reviews will help to address any perceived or actual conflict of interest in livestock export regulatory arrangements, and ultimately help to further improve the welfare of Australian livestock exports.
“If, as is probable, ACAW is not established in time to review livestock export regulations by 2017, then the Australian Government should appoint an independent expert or committee to undertake the first review.”