Live Animal Export Letter to Parliamentarians

June 20, 2012

Sentinet has written to parliamentarians across Australia, including the Prime Minster Julia Gillard, Tony Abbott, and the Minister and Shadow Minister for Agriculture asking for a review of the live export trade in light of the lack of significant penalties for the two exports found to be in breach of the new regulatory framework. We have also reiterated our call for the immediate introduction of preslaughter stunning and a move to a permanent ban on the trade. See attached the letter that was sent.



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


Dear Prime Mininster


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 infeasible.


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 Indonesia.


  • •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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