Ross Carter was reappointed as the Inspector-General of Live Animal Exports (IGLAE) commencing 11 December 2020. On 18 December Carter released a report on the Implementation of Moss Review recommendations..and despite much procedural jargon they are actually pretty damning. He found:
1. the department’s IT systems do not support efficient operations or provide for streamlined industry interaction. They also do not effectively support data and intelligence analytics to target regulatory effort and contribute to the body of knowledge on risk mitigation to animal health and welfare.
2. the dispersed functional model of the department presents a major challenge to delivering an integrated regulatory model.
3. the department needs to improve compliance monitoring and using a proportionate response model to address poor performance.
“The department appears to determine the severity of an individual non-compliance in isolation from other factors. This is a reductive approach that risks not correcting underlying and ongoing unacceptable performance.”
It should be noted that VALE used the June 2020 Al Kuwait exemptions to illustrate the importance in regulatory practice of considering broader community trust and confidence (minimal) in its submission. It was interesting that Ross Carter chose to also use this voyage for the same purpose.
"Mortality rates ..remain the primary indicator of animal health and welfare....but not an indicator of individual animal health and welfare across a consignment."
"Transparency and access to the results of research will help underpin the credibility" SO....where is the study on rumen loggers performed by Murdoch University and reported as completed by Norman in various Shipboard Performance reports??
"The inspector general has not been provided with evidence of improvements to the compliance monitoring approach" [re Moss Recommendation 7]...[this] does not provide confidence in its agility ...and casts doubt on the departments capacity..."
"Despite a long history of significant incidents and events..the department has not put in place and effective proportionate regulatory model that includes strong enforcement action"
"The inspector general is concerned that the full intent and potential of the Principal Regulatory Officer has been reduced from the department's original intent"
"The department has not provided rgulatory process mapping in response to data requests"
"The department should continue to look for opportunities to further increase transparency and accessibility" (7 applications and 6 months for VALE to get one FOI document that showed Dept cover-ups gives little evidence of improved transparency)
"The Awassi Express incident was viewed...as an egregious failure to ensure appropriate animal health and welfare outcomes during an export voyage"
Re regulation "the senior executive have chosen a largely functional structural model [whatever that is]....However, it is a model that best works where the regulatory schemes it supports are at a mature standard of practice. For livestock animal exports this is not the case."
"It appears that the department is not sufficiently agile to take the multidisciplinary approach required"
Re Al Kuwait exemption "The voyage recorded a low mortality rate but a significant number of sheep suffered from heat stress in the later stage."....."mortality rate of 0.08% (28 sheep) ... (noting a 155 negative head count discrepancy. The heat stress scores observed ..appear to confirm that exporting sheep to the Middle East during the northern summer prohibition period results in a poor animal health and welfare outcome for many of the animals despite the additional risk mitigations undertaken by the exporter"