The Department of Agriculture (the department) has extended the prohibition on live sheep exports to, or through, the Middle East to 22 September 2019.
This decision relates to 2019 only with future regulation of live sheep exports to, or through, the Middle East to be decided following a Regulation Impact Statement (RIS) process.
Evidence indicates that the risk of an animal welfare incident relating to heat stress for voyages departing in the first 3 weeks of September is comparable to, or higher than, June. The risk in October is more aligned to May. The department consulted publicly from 12 to 22 July on three options for arrangements for live sheep exports during September and October 2019.
The department has taken the interests of the industry, animal welfare and the government’s policy into account.
We considered the best available science and evidence, and feedback from public consultation before making a final decision.
Once trade resumes, shipments to the Middle East must comply with the same conditions that applied in May including a requirement for the collection and reporting to the department of automated environmental data.
Arrangements for September and October 2019 aim to support the sustainability of the live sheep trade to, or through, the Middle East by maintaining industry’s social licence through improved animal welfare outcomes.
|Explanatory note – Rationale for the September-October 2019 decision PDF|
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What conditions will apply to live sheep exports this northern hemisphere summer?
Exports to and through the Middle East will be prohibited until 22 September 2019. Shipments to the region will be able to depart from 23 September.
When trade resumes, the current conditions as per the Australian Meat and Live-stock Industry (Export of Sheep by Sea to Middle East) Order 2018 will continue to apply. This includes:
- verification of the ship’s pen air turnover,
- a heat stress management plan to be in place, and
- stocking of sheep in accordance with an allometric formula or the heat stress risk assessment model depending on whichever provides more space per animal.
In addition, there will be a requirement that export vessels be equipped with automated environmental data (wet bulb temperature) logging equipment and for the data collected during export voyages to be reported to the regulator.
Why was public consultation open for only 10 days?
In April when the department announced the prohibition for June-August, it indicated that a decision would need to be made for September and October.
In subsequent discussions with industry and welfare bodies, the department had committed to making the decision by the end of July to provide certainty to exporters. Activities to prepare for a voyage usually take at least a month.
The department used the period between April and July to undertake further analysis and to receive historical weather data from the Bureau of Meteorology to analyse. In this time, the department was also able to consider reports from voyages undertaken in May.
The timing of the consultation period allowed the department to consider the information provided by stakeholders before making a decision.
The issue of heat stress in sheep has been well canvassed in recent consultations with two separate consultations on the Heat Stress Risk Assessment review and a previous consultation on condition for May–August 2019.
Why is the department extending the prohibition on live sheep exports to or through the Middle East for part of September?
Under the framework established under the Export Control Act 1982 and Australian Meat and Live-stock Industry Act 1997, the department’s role, as regulator, includes responsibility for setting operating rules for exports.
Analysis of the best available science and evidence indicates that the risk of an adverse animal welfare incident relating to heat stress for exports in September is comparable with, or greater than June.
Conditions in June, along with July and August have already been determined independently by the department and industry to be too hot for sheep exports as demonstrated by the department’s prohibition on trade during these months in 2019 and the similar industry moratorium on trade in 2019.
In addition, sheep departing Australia during early to mid- September are acclimatised to cool Australian temperatures and are therefore less heat tolerant than sheep departing Australia in summer and autumn.
A prohibition on sheep exports departing Australia for the majority of September to the Middle East is therefore reasonable to support animal welfare outcomes.
Travelling times to the Middle East were considered by the department in reaching conclusions about resumption of trade.
Why does the final decision not reflect one of the options?
The final decision considered the best available science and evidence, and feedback from public consultation.
The final decision also reflects revised data analysed by the Bureau of Meteorology. The Bureau of Meteorology re-analysed the data using an alternative (but more complex) method for calculating wet bulb temperatures.
The Bureau advised that this method is likely to be better suited to estimating high-end wet bulb temperatures.
The intention of the Bureau to re-analyse the data was not known to the department until the re-analysis was received on Friday 26 July.
The revised analysis shows that wet bulb temperature estimates using the original method differ from the alternative by, on average, 0.2 to 0.6°C. The original method tended to overestimate wet bulb temperature in higher wet bulb temperature conditions and underestimate them in low wet bulb temperature conditions.
The result of this was to lower the estimates of wet bulb temperatures across the Middle East such that the timing of late summer cooling moved earlier in the year by about a week. The exception to this was the Bab al Mandab Strait into the Red Sea and the central Red Sea which were only marginally impacted.
Why did the department use temperatures from near Qatar when considering conditions for September and October 2019 live sheep exports?
The department reviewed temperature data analysed by the Bureau of Meteorology for several locations in the Persian Gulf including Dubai, Kuwait, Bahrain onshore, Doha onshore and Doha offshore in considering possible regulatory settings for September and October. These considered conditions at destinations and those that may be experienced en route.
The department received feedback during the consultation process that the temperature data may not be representative of conditions experienced on ships. In response, the department obtained additional analysis from the Bureau from sites in mapped shipping routes through the Persian Gulf and the Red Sea. Data for the new sites did not materially differ from data for the original locations.
Heat stress risk assessment is about assessing environmental conditions experienced during journeys from port of loading to port of discharge and not just the destination ports. To reach Kuwait, ships must pass through the whole Gulf, so conditions in more central regions of the Persian Gulf are an important consideration.
What information did you use to make a decision?
The science and evidence for the conditions came from analysis by Bureau of Meteorology of historic temperatures and regional climatological analysis, the Heat Stress Risk Assessment (HSRA) review and submissions, industry research, voyage reports and independent observer reports.
Why did the department conduct analysis on mortality rates?
The department did not use the data to indicate future expected mortality rates but to consider relative risk across months of the year.
The department undertook an analysis of relative monthly risk based mortality data from voyages to and through the Middle East from 2013 to 2017. Data from 2018 and 2019 were analysed separately to keep the trend analysis consistent with underlying regulatory conditions such as pen space allowances.
In submissions, there was some concern that the mortality analysis was unrepresentative given voyages during this period were conducted under different regulatory conditions in place since 2018.
Why did the Government not make this decision when they prohibited trade in June, July and August?
The department elected to make the decision about sheep exports during September and October 2019 at a later time than the decision regarding May to August 2019 to allow for completion of the heat stress risk assessment (HSRA) review
This also enabled the department to get climatological analysis from the Bureau of Meteorology and to analyse data from the May voyages.
The need for a future decision about September and October was flagged to industry and other stakeholders at the time of the earlier decision.
Why does the decision not use the heat stress threshold of 28°C?
The HSRA draft report recommended using the heat stress thresholds (HSTs) built into industry’s HotStuff model. The HSTs used in the model vary depending on animal factors such as weight, acclimatisation, fat score and coat type.
The HSRA panel noted the HST of 28°C for a standardised ‘shipper’ sheep (56 kg adult Merino wether, body condition score 3, zone 3, winter acclimatised, recently shorn) to demonstrate an example of an HST. As such, the 28°C threshold only applies to this specific type of sheep at a specific time of year.
Sheep travelling at different times of year (ie autumn, summer, spring) will have different acclimatisation and therefore a different heat stress (usually higher) threshold. Many sheep which are exported now are lighter and therefore have a different, higher HST. Awassi sheep are different to Merinos and have a different, higher threshold. Heavier sheep or young lambs generally have a lower threshold. These numbers are already built into HotStuff.
Why is the department conducting a Regulation Impact Statement?
The department is required to undertake a RIS to inform a decision on its regulatory approach for live sheep exports from 2020 onwards to maintain a viable trade supported by high animal welfare outcomes.
While the HSRA review was based on available scientific evidence, the RIS will also consider the potential economic and regulatory impact of a range of regulatory options on individuals, businesses and communities involved in the live sheep export trade.
The development of the RIS will involve two rounds of public consultation. The first will follow the release of a discussion paper and the HSRA report, and a second round of consultation based on the release of a draft RIS. Stakeholder feedback will be considered on the possible impact of the options before a final decision is made.