Live Animal Export Letter to Parliament

June 2, 2012


In honour of the one year anniversary since ABC's Four Corners program documented horrific practices associated with the live cattle export trade to Indonesia, Sentient has written to the Prime Minister Julia Gillard, Tony Abbott, all the Senators and the Shadow Minister for Agriculture asking for the live export trade to be reviewed in the light of the poor adherence to penalty allocation for the two exporters found to be breaching the new regulatory framework. We have also called for the immediate introduction of pre-slaughter stunning and a move towards  a permanent end of live export. See below for the details of this letter.


The Hon. Julia Gillard, MP Prime Minister of Australia,


Dear Prime Minister


Sentient, The Veterinary Institute for Animal Ethics, holds grave

concerns about ongoing animal welfare abuses in our live export

markets. We appeal to the Australian Government to initiate a renewed

debate and public inquiry into the trade. We also wish to express our

disappointment with the recommendations of the 2011 Senate Inquiry and

Farmer Reviews. Having submitted to both, our professional opinion is

that the Government’s subsequent reforms have failed to raise and

maintain animal welfare standards to acceptable levels and that

options for phasing out the trade should have been considered.


Exactly one year ago today, on May 30th 2011, ABC’s Four Corners

program broadcast footage of inhumane animal handling and slaughter

practices in Indonesian abattoirs. In February 2012, ABC’s Lateline

program broadcast footage of ongoing cruelty, with four abattoirs in

Indonesia being identified. Two of these were later confirmed to be

part of the approved Exporter Supply Chain Assurance System (ESCAS).

It is alarming that this issue has been exposed by the combined

efforts of an animal welfare charity (Animals Australia) and the

media, rather than being detected by the Government’s independent

auditing process and made publicly available.


The Department of Agriculture, Fisheries and Forestry (DAFF) has taken

three months to investigate the complaint without having suspended the

trade to Indonesia, which we submit would be the most fitting course

of action in the face of these cruelty allegations, particularly given

such an extended response time. Their investigations concluded that in

both abattoirs, two Australian exporters (International Livestock

Exports and North Australian Cattle Company) had ‘reduced control

within this supply chain against the regulatory framework’. Although

the abattoirs in question were removed from the exporters’ approved

supply chains, the exporters did not face serious penalties such as

fines or loss of license. This was despite committing 37 breaches of

animal welfare standards, such as failing to confirm that animals were

dead before cutting them up. The penalty imposed on the exporters, of

increased auditing and the presence of an industry-paid animal welfare

officer during slaughter, does not represent a sufficiently strong

response by a Government committed to ensuring welfare standards and

is unlikely to act as a deterrent against further breaches.


These recent events have confirmed our view that despite the best of

intentions, the Australian Government cannot ensure the welfare of

animals involved in the live export trade, whether they are sent to

Indonesia, the Middle East, North Africa or any other destination.

Firstly, there is the issue of the proven incompetence of industry

bodies. Transcripts from last year’s inquiries provide ample evidence

that MLA and LiveCorp were aware of serious animal welfare problems in

the Indonesian market. The Senate committee admitted that this

situation “casts a cloud over the efforts of peak bodies to facilitate

improved welfare outcomes”. It appears highly inconsistent that,

despite its findings, the Senate committee recommended Australia’s

ongoing involvement as an "agent of change" in the live export trade,

and that the Government has again entrusted those same industry bodies

with the role of protecting the welfare of our exported livestock.


Secondly, we wish to challenge the view that Australia’s involvement

allows us to significantly raise animal welfare standards in export

destinations. For the last thirty years, inhumane handling and

slaughter techniques have been perpetuated, with increasingly frequent

exposure by animal welfare organisations and the media. There are

entrenched reasons for this failure. The Senate committee acknowledged

the significant challenges to improving animal welfare in Indonesia

due to “the prevalence of traditional slaughter practices and the lack

of an educated workforce, limited understanding of animal handling

techniques and the great variability in the availability of both

capital and infrastructure”. MLA have themselves identified that "due

to the enormous turnover of people in the slaughter teams and their

relatively low social status, it is not a good strategy to invest in

training personnel in animal handling practices at this level.” The

committee was also advised by DAFF in 2011 that the more humane Mark

IV boxes for restraint during slaughter could not be installed in many

areas of Indonesia due to the lack of powered mechanisms such as

hydraulics. DAFF’s recent investigation into the Indonesian abattoirs

found that even where Mark IV boxes are used, lack of head and neck

restraint in some boxes, along with problematic operational procedures

and lack of training, have led to poor animal welfare outcomes.


This raises a broader problem – how can we instil a fundamental

appreciation of animal welfare or enforce compliance with World

Organisation for Animal Health (OIE) or any other guidelines when

dealing with nations that lack animal welfare legislation? And should

the burden of this role really be inflicted upon Australian livestock?

Furthermore, there are serious limitations to the OIE standards the

Government has proposed to ensure animal welfare in Indonesia and

other destinations. These standards are voluntary and fall far below

Australian standards for the slaughter of animals, having been written

for developing countries. They allow the use of leg restraints such as

rope casting for cattle and permit slaughter without stunning.

Pre-slaughter stunning is the most basic welfare safeguard for animals

being slaughtered because it renders them unconscious to pain before

throat cutting and bleeding. To date, approximately 90 percent of

cattle slaughtered in Indonesia are not stunned. This is inconsistent

with The Australian Model Codes of Practice and raises the question of

how we can insist upon humane standards for our animals on Australian

shores, yet knowingly expose them to brutal treatment in their

countries of destination.


The Australian Government’s failure to mandate pre-slaughter stunning

as a requirement for the resumption of trade with Indonesia was

extremely disappointing. We acknowledge the Government’s plan to

increase the use of stunning by raising the issue for inclusion in the

OIE guidelines and supporting industry efforts to include stunning in

voluntary codes of conduct. Unfortunately, there is too much evidence

that these strategies will have minimal impact. The review panel of a

recent independent study of animal welfare in Indonesia concluded that

“stunning delivered the single biggest animal welfare benefit”, but

noted the adoption of the required technology in most facilities is



A welfare issue that received less attention in last year’s review was

the plight of animals on board export ships. One of the key

recommendations of the Keniry Report (2003) was for the presence of

‘third party’ veterinarians on board the ships to monitor livestock

welfare, yet this was never implemented. As a veterinary science based

organisation, we believe the Government’s recent reforms have not

sufficiently addressed the ongoing conflict of interest whereby

exporters continue to contract AQIS-accredited veterinarians, despite

evidence of veterinarians being coerced after reporting animal welfare

concerns. Farmer’s recommendation that veterinarians submit their

reports directly to AQIS at the same time as to the exporter does not

go far enough to protect neutrality of reporting.


Likewise, we are concerned that the Government’s requirement for

ongoing assessment of the supply chain by independent third party

auditors does not constitute a truly external auditing system; if such

audits are paid for by the exporter, this represents just another

example of industry self-regulation. Furthermore, the use of a

checklist developed by DAFF to assess compliance with OIE standards

appears somewhat circular given DAFF’s past performance in monitoring

animal welfare standards. And yet the matter is crucial, for as the

Senate committee note, insufficient monitoring has made it impossible

to determine whether the historically incremental approach has

achieved sustained change. In their own view, the changes appear

minimal “given the significant investment of both financial and

physical resources by the Australian Government and peak industry

bodies over a considerable period of time”. Even if the new auditing

system does detect welfare problems, we would question the openness of

importing nations to follow-up reviews, given that in 2011 the

Australian Chief Veterinary Officer was forced to base his independent

review of Mark 1 and IV restraint boxes on video footage, having been

denied access to the abattoirs.

Sentient therefore calls upon the Australian Government to pass

legislation to permanently end our live animal export trade to all

destinations and to immediately enforce pre-slaughter stunning as a

minimum welfare requirement in the interim. Furthermore, we request

that the Government reopens last year’s public inquiry, this time with

terms of reference that include solutions for phasing out the trade

without creating further hardship to livestock and with adequate

compensation for Australian producers whose livelihood will be

affected. Our specific recommendations for strategies are as follows:


• Opening a feasibility study on the use of pre-slaughter stunning in

Indonesia and other export destinations and suspending trade until

stunning can be enforced.

• Opening a public inquiry into the independent auditing system, which

failed to expose serious animal welfare breaches of the Government's

new Exporter Supply Chain Assurance System at two abattoirs in


• Suspending the export of livestock to Indonesia while the above

matter is being investigated.

• Raising the Greens’ Live Animal Export (Slaughter) Prohibition Bill

2012 for debate in parliament.

• Opening an independent scientific analysis of animal welfare issues

on board export ships, as well as in export destinations.

• Replacing the existing system of exporters contracting

AQIS-accredited veterinarians with the appointment of independent

veterinarians who are not answerable to exporters.

• Inviting independent veterinarians and representatives from animal

welfare organisations to participate both in this suggested scientific

review and in the current auditing process.

• Opening an inquiry by the Productivity Commission into the benefits

of chilled meat versus live exports.

• Opening a review into solutions to make northern Australian cattle

production less dependent on live export.


Thank you for your time and attention to our concerns. We look forward

to your reply and welcome the opportunity to discuss our concerns

further and provide assistance with implementing the above



Yours faithfully,


The Sentient Executive

Katherine van Ekert, President

Adele Lloyd, Vice-President

Rosemary Elliott, Secretary

Matthew Lloyd, Public Officer

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