On 21 November 2012, South East Asian Livestock Services Pty Ltd (SEALS) self reported possible non-compliances with the Australian Standard for the Export of Livestock (ASEL) to the Department of Agriculture (the department) in relation to the export of a consignment of 2061 slaughter cattle to Mauritius. The consignment departed Australia on 4 October 2012 and arrived in Mauritius on 19 October 2012.
The investigation concluded that three ASEL Standards were not met:
- 1.9 – which requires female slaughter/feeder cattle to be pregnancy tested within 30 days of export and certified in writing not detectably pregnant
- 5.1 – which requires an accredited stockman to remain on board until discharge is complete
- 5.13 – which requires accurate end of voyage reports to be provided to the department.
The department issued the exporter with a show cause notice. The exporter took corrective actions and the matter was closed. The department also issued an Exporter Advisory Notice (EAN 2013-1) to improve the quality and accuracy of pregnancy declarations.
This consignment was not subject to Exporter Supply Chain Assurance System (ESCAS) requirements. ESCAS came into effect on 1 January 2013 for slaughter and feeder livestock exported to Mauritius.
1. The report from the exporter
On 4 October 2012, a consignment of 2061 slaughter cattle was exported from Geraldton, Australia to Port Louis, Mauritius by South East Asian Livestock Services (SEALS). The consignment arrived in Mauritius on 19 October 2012. This was the first consignment of slaughter cattle exported to Mauritius by SEALS. Mauritius is a small but regular market for Australian slaughter cattle and sheep with between one and six consignments exported each year.
On 21 November 2012, SEALS reported to the Department of Agriculture (the department) that non compliances with the Australian Standards for the Export of Livestock (ASEL) may have occurred during the export of this consignment of cattle, in relation to the following:
- pregnancy status of the cattle exported and the provision of an outdated pregnancy test report to the department
- the provision of an inaccurate end of voyage report to the department
- the activities of the LiveCorp accredited stockman, including not remaining on board until all livestock had been unloaded.
2. Complaints from non-government organisations and the importer
In addition to the information received from the exporter, the department received letters of complaint from the Royal Society for the Prevention of Cruelty to Animals (RSPCA) on 5 December 2012 and Animals Australia on 10 December 2012 about the consignment. Additionally, a complaint from the importer was received on 21 December 2012. The complaints contend:
- pregnant animals were included in the shipment
- mortality levels reported were incorrect
- the voyage was deliberately delayed
- insufficient antibiotics were loaded on the vessel.
3. Conduct of the investigation
On receipt of the report from the exporter, the department assessed the information and commenced an investigation. The focus of the investigation was to:
1. review the self reported ASEL non-compliances relating to export of pregnant cattle, end of voyage report and the LiveCorp accredited stockman
2. determine if non-compliance with any other regulatory requirements occurred
3. determine if any regulatory action should be taken.
4. Investigation findings
It is a requirement of the ASEL that all female livestock exported for feeder and slaughter purposes are either:
Spayed (desexed by removal of the ovaries), or
pregnancy tested within 30 days of export and found to be not detectably pregnant.
Pregnancy testing for cattle is carried out by manual palpation by a veterinarian or accredited pregnancy tester. Cattle are pregnant for 272-293 days and pregnancy can be detected by manual palpation from approximately 40 days.
The exporter provided pregnancy testing certificates and declarations from registered veterinarians to the department. One of the certificates provided was found to be six days out of date. ASEL Standard 1.9(c)(i) requires that cattle sourced for slaughter purposes must have been pregnancy tested during the 30 day period before departure.
The ASEL states an accredited stockman is responsible for providing appropriate care and management of livestock on board the vessel during the voyage. That is, from the time the first animal is loaded on board the vessel until the last animal is unloaded at the destination port.
The exporter engaged an accredited stockman to accompany the voyage in accordance with ASEL Standard 5. The stockman stated he got off the vessel at 6:30 pm on the final day of unloading. He was later informed by a member of the ship’s crew that unloading was completed at 12:30am the following morning. At no stage did the exporter direct the stockman to leave the vessel prior to the completion of unloading of the livestock. The discharge completion time on the end of voyage report is noted as 8:12pm on 20 October 2012. However, the stockman has stated the discharge completion time recorded on the end of voyage report was inaccurate.
The stockman completed daily reports for the voyage. It was noted on days 13 and 14 of the voyage that two calves were born. The calves were euthanised prior to arrival in Mauritius. The two births were not recorded on the end of voyage report. The stockman has stated that an oversight on his behalf caused him to not record the births in the end of voyage report.
4.1 Was there non-compliance with any other regulatory requirements?
The investigation did not find evidence of other non-compliance with regulatory requirements.
The department investigated the claim that insufficient antibiotics were loaded on the vessel. The volume of antibiotics loaded onto the vessel met the requirements in the ASEL. The antibiotics were used throughout the voyage to treat injured or sick animals. The antibiotic supply was exhausted two days before arrival in Mauritius.
The department investigated the claim that the voyage was purposefully delayed. The anticipated voyage duration, indicated on the notice of intention to export submitted to the department, was 14 days. The actual voyage duration was 15 days which is not significantly longer than anticipated.
The department also investigated the claim that the mortality count reported to the department was inaccurate. The department received a report from the stockman and from the master of the vessel that both reported a mortality count of 18. The investigation did not find any information to support the claim that the mortality count was inaccurate.
5. Actions taken by the exporter in Mauritius
In November 2012, SEALS received information from the importer in Mauritius that two heifers had given birth and four others aborted pregnancies whilst in the feedlot in Mauritius.
A representative of SEALS and a registered veterinarian flew to Mauritius in November 2012. The purpose of their visit was to assess the cattle and determine if any more of the animals were pregnant. The veterinarian pregnancy tested 260 animals and found that 15 were pregnant. Of those, the veterinarian found nine that should have been detectably pregnant prior to export from Australia.
6. Investigation conclusions
The investigation found that three ASEL Standards were not met.
The exporter provided a pregnancy declaration from a registered veterinarian stating that the cattle tested were not pregnant prior to export. The certificate was out of date, that is the cattle were pregnancy tested more than 30 days before export, which is in contravention of ASEL Standard 1.9.
Two calves were born on route to Mauritius and nine animals in Mauritius were found to be in calf that should have been detectably pregnant prior to export. There are a number of factors that may have contributed to pregnant cattle being loaded on the vessel. These include inadequate animal identification and record keeping on the part of the exporter and inaccurate pregnancy testing by some of the registered veterinarians.The stockman departed the vessel before the discharge of livestock was complete, this action is not compliant with ASEL Standard 5.1. Additionally, there were inaccuracies in the end of voyage report including failure to mention the two calves born during the voyage and an incorrect discharge time.
7. Regulatory action taken
The department issued SEALS with a notice to show cause under the Australian Meat and Livestock Industry Act 1997 (AMLI Act), section 23 on 10 April 2013. SEALS responded to the notice on 26 April 2013 and detailed the corrective actions they had put in place. There was no further regulatory action taken.
The exporter has put in place systems to ensure pregnancy certificates are cross checked with vessel loading dates to ensure the 30 day standard is upheld. Additionally, all female cattle are re-tested at the registered premise to ensure no pregnant animals are loaded onto vessels for export.
The exporter has amended the written instructions given to stockman when they are engaged to ensure the stockman remains on board the vessel until unloading is completed at the final port.
The exporter has also revised their end of voyage report template to include the requirement to report any births that occur during a voyage.
8. Other actions taken by the department
The declarations provided to the department by SEALS did not include the individual identities of the animals that were pregnancy tested or spayed. Many of the declarations only listed the number of animals pregnancy tested and the outcome of the testing. Following consultation with the live export industry and the Australian Veterinary Association, the department issued an Export Advisory Notice (EAN 2013–01) in relation to pregnancy and spay declarations on 26 June 2013.
EAN 2013-01 advises exporters that female cattle presented for export must be individually identified and must be listed on the pregnancy or spay declaration. The EAN is available on the department’s website.
On board stockman are accredited by LiveCorp and the training program covers the need for stockman to stay on board the vessel until discharge of all livestock has been completed. This report has been provided to LiveCorp for their information.