Proposed Australian Animal Welfare Standards and Guidelines for Livestock at Saleyards and Depots

 

 

General comments

 

We welcome the opportunity to contribute to the Public Consultation on the proposed Australian Animal Welfare Standards and Guidelines for Livestock in Saleyards.

 

Saleyards pose significant welfare risks as animals travel over long distances, often in harsh conditions; are exposed to unfamiliar surroundings and other animals; and are handled by people with various levels of animal handling skills.

 

Key areas to consider in the formation of this document are:

  • The condition of facilities: facilities must have appropriate stocking densities to allow animals to move freely; water must be available in all pens; they must provide shelter (e.g., shade sails) to protect from extremities; and the ground must be appropriate to prevent slipping, foot injuries, and permit adequate cleaning

  • The competency of staff: especially animal handling and in identification and response to sick/injured animals

  • The level of record keeping, including: compliance with access to food, water and rest during prolonged journeys; recording injuries when animals are offloaded from transport; and the number of animals humanely euthanased (including the timely nature of this)

  • Behaviour around animals, including: the reduction of excessive noise such as shouting; calm handling; not using prodders or excessive force

  • Strict adherence to specific classes/condition of animals that are NOT to be sold in saleyards, including: sick, injured, diseased, emaciated, or heavily pregnant; pigs; dairy breed calves weighing less than 60kg liveweight; lactating animals with dependent young; and unweaned animals without their mothers.

 

Throughout the document …’at the first reasonable opportunity’ should be replaced with ‘without delay’.

 

Specific comments

 

1.  Responsibilities and planning

 

We suggest adding Record Keeping as a sub section with standards describing the type and manner in which records are kept and communicated with other relevant parties. This is critical especially in order to demonstrate compliance with livestock transport standards relating to time off water and food and mandatory rest periods.

 

S1.1

 

  • Suggest adding a requirement for all personnel handling and managing stock to be suitably trained through nationally recognised programs.

 

  • Add Standard that an Animal Welfare Officer must be appointed and that a veterinarian is available on-call

 

 

2.       Livestock  handling, knowledge and skills

 

S2.1

 

  • Suggest amend to: “A person involved in any part of the sale yard process (including contractors) must have undergone the relevant animal welfare related inductions and must possess relevant nationally recognised accreditation to perform duties in compliance with relevant animal welfare regulation. Any persons without the relevant knowledge, skills, experience and accreditation must be directly supervised by a person with the required accreditations, and a written record of this must be made and retained by the sale yard.

 

  • Suggest including that transporters must be trained in the humane killing of livestock so that they can attend to urgent animal needs during unloading/loading, or where animals are dispatched after hours.

 

G2.1

 

  • More detail is required in this guideline about what determines an animal’s fitness for sale and fitness for the intended journey (e.g. a reference to the elements listed under S7.1).

 

3.  Saleyard facilities for handling livestock

 

S3.1

 

  • Suggest including a standard that requires all pens to be of a sufficient size to allow animals (or a single animal) to turn around and lie down with legs fully extended, and enable sufficient space between animals for in-pen assessments of animals' injuries or disease

 

  • Suggest including a standard that requires all holding and isolation pens to contain rubber matting (this substrate can be hosed down, provides insulation, and cushioning).

 

  • Suggest including a standard that requires all pens to be roofed.

 

  • vii) add “And all pens must have access to water to ensure that all animals have water available as required.”

 

S3.2

 

  • Bobby calves – being very young, vulnerable animals they should be consigned from farm directly to their final destination rather than through saleyards. If prohibition is not supported then they must be a minimum of 60kg body weight to be sent to saleyards.

 

  • Strongly recommend that pigs are not sent to saleyards but are consigned direct from farm to final destination

 

G3.35

 

  • Hospital pens should be mandatory, so recommend that this is a Standard, not a Guideline. An isolation pen should not be used as a hospital pen as both may be needed at the same time, i.e. isolation due to biosecurity risk and hospital due to injury or distressed condition.

 

G3.9

 

  • ALL sale yards should be fitted with sprinklers systems to enable cooling during hot days

 

4.  Handling and husbandry

 

S4.1

 

  • Add “minimises fear, stress, pain and injury”. Change “'minimise” to “avoid”/”prevent”

 

S4.1b v)

 

  • Livestock must NOT be thrown, dropped, punched, kicked or struck.

  • Livestock must NOT be released from a height EVER (remove "unless the animal can safely land on its feet").

 

S4.1b vii)

  • Must not drag animals which are unable to stand, except ADD IF THERE IS NO OTHER OPTION in an emergency to allow safe handling, lifting, treatment or humane killing.

 

S4.5

 

  • We strongly urge that electric prodders not be used on any livestock, given alternative and more humane alternatives are available for handling livestock. We are also concerned that applying a limit to ‘excessive’ use is unpractical, given the difficulty around auditing and enforcement. A compromise is changing the wording to to “unless other reasonable action to cause movement have failed and as a last resort. A maximum of three times must only be applied to an individual animal.”

 

S4.5

 

  • Suggest add section v) “more than three times on an animal that is unable to rise to its feet of its own volition.”

 

S4.8

 

  • Add to the sentence: “A person must not use a dog to move an animal that is diseased or distressed or that cannot stand of its own volition.”

S4.9

 

  • Amend to read: “A person in charge must ensure that an inspection of livestock is undertaken at the first opportunity and at least twice daily, including during the final hour that animals spend in discharge pens before their departure from the sale yard.”

 

S4.11

 

  • Add to the sentence: “Rubber matting must be provided.”

 

G4.13

 

  • This should be a Standard - Animals in advanced pregnancy or lactating with dependent young MUST not be consigned through saleyards.

 

G4.18

 

  • This should be a Standard - High pressure hoses should not be used to manually wash livestock; normal pressure can be used if necessary.

 

G4.22

 

  • This should be a Standard, and change to "livestock should MUST be examined for evidence of injury, and such injury must be attended to immediately, including humane euthanasia.

 

5.               Drafting and penning

 

S5.1

 

  • Insert stock density tables as an appendix and make reference to this appendix.

 

S5.2

 

  • Add section viii) to read “the animal’s mental state and stress levels.”

 

S5.3

 

  • Amend section iii) to read “level of aggression or distress.”

 

S5.4

 

  • The term “excessive” in relation to spinning of cattle is ambiguous – state that twice is maximum.

 

6.  Feed and water

 

  • Livestock at a saleyard or depot must be provided with reasonable access to water and space to lie down within 4 hours of arrival at the facility by the person in charge, or within the maximum time off water period applicable to the species and class of animal if this time is less than 24 hours as defined in the Land Transport Standards

 

S6.1

 

  • Livestock must have access to water at all times but may be denied water to meet transport curfews.

 

S6.3

 

  • Add to the sentence “This system should have a designated, independent body to audit these records. A formal, written record must be made of the time off water, the spell period and other relevant welfare details. A copy of this record must be passed onto the next ‘responsible’ person in the chain, and must be retained by the transport company and the sale yard.

 

S6.5

 

  • All livestock must be provided with feed no later than 24 hours of last feed unless stated less than this for specific classes, i.e. bobby calves.

 

S6.8

 

  • Bobby calves should not be consigned through saleyards. However if they are then add to the sentence: “A formal written record showing the time of each calf’s last feed must accompany calves through each link of the handling chain from property to sale yard to slaughterhouse.”

 

G6.1

 

  • Either make this a Standard or remove

 

G6.12

 

  • Water should be not located in an area that results in it being too hot to drink.

 

G6.12

 

  • Animals should not be without food for more than 24 hours including the time spent travelling and yarding. For immature animals the intervals between feeds should be considerably shorter - change to 'no more than 8 hours'

 

G6.16

  • Despite the bobby calf industry supply chain agreeing to a maximum 30 hours time-off-feed for bobby calves being transported for slaughter, if calves are consigned through saleyards, this must be reduced to a maximum of 12 hours due to the extra handling and stress involved. Note: This is less than the 18 hours stated under S6.8.

 

7.       Pre-sale livestock inspection, selection and care of weak, sick and injured animals

 

S7.1 ii)

 

  • The term “severely emaciated”, particularly as it relates to dairy cattle, requires further explanation in the Glossary, e.g. with a reference to an animal below condition score 3 as defined in the dairy industry’s scale from 1 to 8. For all other animals a BCS below 2 should be considered unacceptable. Animals in a severely emaciated state should be sent direct to their destination and not through a saleyard.

 

S7.2

 

  • Amend to “A person in charge must not present for sale a bobby calf unless the calf is a minimum of 60kg liveweight, and is in good health.”

 

S7.3

 

  • Change to “A person in charge must make the appropriate arrangements IMMEDIATELY for the separation of distressed, weak, sick or injured livestock for further assessment, rest and recovery, appropriate treatment or humane killing.”

 

G7.2 and G7.1

 

  • These should be Standards. Animals less than 60kg liveweight, which are not accompanied by their dam, MUST not be presented for sale.

 

8.       Pre-transport selection of livestock

 

S8.1

 

  • Add to section i) sentence: unable to walk more than a few steps of their own volition.

 

S8.1 ii)

 

  • The term “severely emaciated”, particularly as it relates to dairy cattle, requires further explanation in the Glossary, e.g. with a reference to an animal below condition score 3 as defined in the dairy industry’s scale from 1 to 8. For all other animals a BCS below 2 should be considered unacceptable. Animals in a severely emaciated state should be sent direct to their destination and not through a saleyard.

 

S8.2

 

  • Add to this sentence: “A written record of the veterinary advice must accompany the animal to its destination and must be signed by the responsible person at each stage of the handling chain until the animal reaches its destination. A copy of the record must be retained by each stage of the chain, and must be audited by an independent or government body.”

 

S8.4

 

  • Add to the sentence “A written record of the veterinary advice must be signed by the person loading the animals. A copy of this record must be passed onto the next link in the animal handling chain and must be retained for independent audit purposes.”

 

9.         Humane killing

 

S9.1

 

  • Add to sentence “Procedures to notify management of need for humane killing must be included in all sale yard employees/contractors inductions.”

 

S9.2

 

  • Add ‘nationally accredited’ designated person must be available during saleyard operating hours to ensure prompt euthanasia. The term available “within in reasonable time” is open to interpretation – we suggest changing this to  ‘without delay’ and that delays until end of sale are unacceptable.

 

S9.4

 

  • The killing method must ensure “immediate” rather than “rapid” loss of consciousness. Add another sentence: ”The responsible person must remain with the animal until death is confirmed.”

 

S9.5

 

  • Add: that the person killing the animal must possess nationally recognised accreditation for humane killing (a moratorium could be introduced whilst the industry develops and implements training & accreditation programs for this)

 

S9.6

 

  • Replace “take reasonable action” with a list of the vital signs that must be checked in order to confirm death.

 

S9.7

 

  • G9.4 should be a standard; G9.15 removed. It should not be permitted to kill a farm animal by a blow to the head – the method requires considerable skill for it to be successful at the first attempt and saleyards must be equipped with the appropriate equipment. The standard must require all livestock requiring euthanasia to be killed using either a firearm or captive bolt or anaesthetic overdose. There is no justification for a saleyard to have to use a blow to the head or throat cutting without prior stunning because management should be such that appropriate procedures, trained staff and equipment are available to ensure only acceptable humane methods are used. Add in the Guidelines that firearms and captive bolts be kept clean and operational.

 

G9.16

  • Animals must not have their throat cut while fully conscious. Delete the sentence “the use of bleeding out”

 

G9.3

 

  • Where livestock are able to walk, they should be handled in a race or crush. Animals requiring emergency killing should be humanely killed without moving them further than necessary to effect the killing. It may be necessary to carry out emergency killing on the transport vehicle. Animals with broken limb bones that are assessed as requiring euthanasia should be moved the minimum distance necessary to allow the humane killing in a safe and  effective manner - change to “animals with broken bones should always be euthanized”

 

 

Glossary

 

  • Under ‘Fit for Sale’, remove the word ‘severely’ emaciated and include BCS minimum, ie Score 2 for goats, sheep and cattle using score 1-5 and Score 3 for dairy cattle using score 1-8.

 

  •  Under ‘depot’ (p38) - amend the definition to read: Facilities or yards where livestock may be rested between journey(s) or holding facilities, including ports, in a particular region where livestock are delivered from farms or feedlots for assembly before a journey.

 

  • Under ‘fit for sale’ (p39) - add the word normally, to read: able to walk normally on their own by bearing weight on all legs.

 

  • Under ‘fit for the intended journey’ (p40) - the elements of fitness should be the same as those under ‘fit for sale’.

 

  • Add definition of ‘animal welfare officer’ - example of definition: A person inducted by the relevant sale yard who possesses nationally recognised accreditation in low stress livestock handling, animal welfare, humane killing and animal welfare record keeping.

 

 

Appendix 1 – Humane killing

 

Cattle

 

GA 1.1

  • Remove reference to blunt trauma of calves — change to firearms and captive bolt must only be used. Blunt trauma is not acceptable, given that saleyards should always have access to firearms and captive bolts.

GA 1.3

 

  • Remove as blunt trauma is not acceptable at a saleyard

 

GA1.3                                           

  • If necessary, use of blunt trauma on calves less than 24 hours old should be followed by bleeding-out or another technique while the animal is unconscious, to ensure death.

  • Similarly for other species, remove reference to blunt trauma as being acceptable for young animals.

 

Appendix 2 – AW incident report

 

  • Add Humane destruction – procedure not followed

 

  • Add under ‘For office use only’ 2 other categories Risk assessed & action taken for other animals AND corrective procedure to prevent future occurrence

 

Appendix 3 – Stock standstill

 

  • This does not appear to be included despite the document stating that it is.