In September 2012, the Royal Society for the Prevention of Cruelty to Animals (RSPCA) and two individuals made complaints to the Department of Agriculture, Fisheries and Forestry (DAFF) regarding sheep and cattle exported from Australia to a farm in Qatar. Specifically, they alleged that:
- livestock exported from Australia for breeding purposes, experienced conditions which resulted in adverse animal welfare outcomes, including deaths;
- pregnant cattle exported by air from Australia on 5 June 2012 by International Livestock Exports (ILE) were beyond the maximum period of gestation allowed under Standard 6.6 of the Australian Standards for the Export of Livestock (ASEL); and
- livestock exported from Australia were unsuitable for export and not properly accounted for.
Pictures of livestock in apparent distress were subsequently broadcast, together with excerpts from an interview with one of the complainants, on the ABC 7.30 program on 18 September 2012.
This was the first formal complaint of an incident involving Australian–sourced breeder animals in another country.
DAFF regulates the export of livestock under the Export Control Act 1982, the Australian Meat and Live–stock Industry Act 1997 and associated orders, regulations and standards including the ‘Australian Standards for the Export of Livestock (ASEL)’.
In order to receive approval to export a consignment of livestock, the holder of a licence to export livestock must show how they will comply with both the Commonwealth Government’s regulations and the importing country requirements.
Exporters intending to supply Australian–sourced livestock for slaughter or fattening (feeder) purposes must comply with Australia‘s new regulatory framework – the Exporter Supply Chain Assurance System (ESCAS).
In this particular case, the livestock were exported from Australia for breeding purposes.
Livestock exported from Australia for the purpose of breeding [rather than for slaughter or fattening (feeder) purposes] are not subject to Australian regulation after they have arrived in the importing country.
The only aspects of this complaint that are subject to regulatory control by DAFF are the alleged ASEL 6.6 breach and the condition of the livestock prior to export. This was the primary focus of the investigation.
Conduct of investigation
The investigation sought and/or considered information, including photographs, from:
- The two complainants
- DAFF animal health and welfare experts
- DAFF Export Standards Branch (Food Division)
- the Qatar Ministry of Agriculture
- DAFF Investigation & Enforcement Program
- Licensed Australian livestock exporters
- Victorian Department of Primary Industries
- Australian Cattle Veterinarians (part of the Australian Veterinary Association who administer the National Cattle Pregnancy Diagnosis Scheme).
Alleged ASEL Standard 6.6 breach
ASEL Standard 6.6 relates to the export of livestock by air and states:
‘Female livestock must only be sourced for export for breeding if they have been pregnancy tested (cattle using manual palpation, other species by ultrasound foetal measurement) within 30 days of export and certified, by written declaration, by a person able to demonstrate a suitable level of experience and skill, to be not more than the following maximum number of days pregnant at the scheduled date of departure:
Cattle and buffalo (used for breeding) maximum 250 days of gestation at scheduled date of departure
Note: These gestation periods were provided by the World Organisation for Animal Health (OIE) and adopted into IATA regulations for pregnant livestock transported by air.
For cattle and buffalo a declaration must be made in writing by a registered veterinarian who is a member of the Australian Cattle Veterinarians and an accredited tester under the National Cattle Pregnancy Diagnosis Scheme and who pregnancy tested the cattle or buffalo.’
The complainant alleged that calves were born full term earlier than would be expected if they had been a minimum of 250 days pregnant at the time of export.
According to the Australian Cattle Veterinarians, National Cattle Pregnancy Diagnosis Scheme, there is a two week margin of error acceptable for cattle up to approximately four months of gestation. This margin of error increases to 30 days for cattle greater than four months pregnant.
Saunders Comprehensive Veterinary Dictionary (2nd Edition, D.C. Blood and V.P. Studdert) records a cow‘s gestation period ranges from 272 – 293 days.
This means, an animal certified as 250 days pregnant at the time of export could actually legitimately be as many as 280 days pregnant and hence could have a full term calf anywhere from the day of arrival.
The complainant was only able to keep partial calving records and did not reference any specific criteria, e.g. whether or not teeth eruption had occurred, in order to verify that the calves were indeed full–term and not premature.
In the absence of detailed calving records and the inherent margin of error in late stage pregnancy diagnosis, there is insufficient evidence to substantiate a breach of ASEL 6.6.
Recommendation 6 of the Farmer Review (Independent Review into the Livestock Export Trade 2011) recommends that a comprehensive review of ASEL be undertaken. The maximum allowable number of days of pregnancy for exported livestock has been referred for further consideration by the ASEL review.
Selection and tracing of animals
The complainants and the RSPCA allege that some animals sourced for export to the farm were old and in poor general health and condition.
All livestock were inspected prior to export by accredited veterinarians. The veterinarians certified that any animals showing signs consistent with the rejection criteria laid out in the ASEL were excluded from the consignment. The condition of livestock can change rapidly in response to dietary and husbandry changes.
Additionally, one of the complainants obtained National Livestock Identification System (NLIS) ear tags from cattle in Qatar and subsequently obtained a report from the NLIS database to help trace the cattle. The complainants allege that some of the livestock were originally destined for domestic slaughter and that the NLIS database did not show that cattle had been exported from Australia.
The NLIS allows the traceability of livestock from property of birth to slaughter. It was introduced in 1999 to meet European Union requirements for cattle exports and has since expanded to sheep and goats.
The Property Identification Code (PIC) used by NLIS does not provide details of particular pen or paddock of origin. The complainants‘ allegation that cattle came from the ‘boner pen’ at a saleyard could not be substantiated.
Responsibilities for updating the NLIS database are laid out in State/Territory legislation. It is the responsibility of the owner of the property where animals are assembled prior to export to update the NLIS database to indicate when animals are exported.
State and territory governments continue to work with the livestock industry to try to ensure the database is properly maintained given its importance to the livestock industry. DAFF will continue to encourage state and territory government efforts to ensure compliance with the requirements of NLIS.
Conditions of breeder cattle in Qatar
Several consignments of livestock were exported to the Al Waab farm between June 2011 and June 2012, by two Australian licensed livestock exporters: Stock–Air and International Livestock Exports. It is therefore likely that the livestock in the pictures provided by the complainants and broadcast on the ABC’s 7.30, were of Australian origin.
However, as set out in the legislative framework section of this report, export of breeder cattle is regulated up until the point of disembarkation from the aircraft or vessel in the importing country. Breeders are not subject to Australian regulation after they have arrived in the importing country, in this case, Qatar.
As such, there is no regulatory basis to further assess the claims that animals experienced conditions which resulted in adverse animal welfare outcomes, including deaths.
At a government–to–government level, the Qatar Government has provided assurances to the Australian Government that there are no ongoing adverse animal outcomes at the farm in question.
The question of whether there should be any further regulation of breeder livestock was raised in the Farmer Review (Independent Review into the Livestock Export Trade 2011), Recommendation 14:
‘The Review recommends that the Australian Government should articulate an approach to the question whether there is a need for any additional conditions for the export trade in breeder livestock.’
In response to this recommendation, the government is considering whether the current regulatory framework for breeders is sufficient.
No breaches of Australian regulations were found to have occurred. Therefore no regulatory action will be taken in relation to this matter against Australian livestock exporters who supplied animals to the farm in Qatar.