VALE Opposes LGAP: Open Letter

28/1/2016

Jan 28th 2016
VALE opposes industry proposal to dilute regulation of animal welfare standards in live export
Open letter from Vets Against Live Export (VALE) to Alison Penfold, Chief Executive Officer of the Australian Livestock Exporters Council (ALEC), PO Box 5552, Kingston ACT 2604

Dear Ms Penfold,
I write on behalf of Vets Against Live Export (VALE) concerning proposals by the live export industry to change the standards governing the welfare of animals exported from Australia (Livestock Global Assurance Program; LGAP). You have expressed the opinion that you would welcome a submission on this matter from VALE.
As a preliminary matter, we note that the form which you have posted on the relevant website is entirely prescriptive, requiring comment on defined paragraphs of LGAP. VALE is not interested in making a submission in this prescriptive fashion.
The substantive point, so far as VALE is concerned, is that it is a fundamental principle of animal welfare that animals used for food should be slaughtered as close to their source as possible. Live export of animals from Australia is inconsistent with this principle, particularly where animals are transported aboard ships for long durations, in overcrowded conditions, exposed to extremes of weather and other conditions inconsistent with maintenance of good animal welfare.
It is equally evident that live export is also unacceptable to the Australian public because of the treatment of animals in overseas destinations. Consistent with this view, our recent survey, conducted as an independent poll by UMR Strategic Research, demonstrates that the majority of people polled want to see live export stopped. In our opinion, seeking to improve the treatment of animals in importing countries which have no culture of animal welfare is nothing more than an unrealistic aspiration.
We know that Australian animals continue to suffer unacceptably both on live export voyages and during transport and slaughter in overseas countries.
We regard your present proposal to put regulation of welfare into the hands of the owners and operators of overseas facilities as nothing more than a cynical exercise by those who stand to profit from this unacceptable and unethical trade. The intention is clearly to make life easier and more profitable for those with a vested interest. VALE does not support such a proposal.
Yours sincerely

Dr Sue Foster BVSc MVetClinStud FANZCVS
VALE Spokesperson
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1 Comment

Alison Penfold

28/1/2016 09:36:22 pm

Dear Dr Foster

Thank you for your letter of 28 January 2016 advising of your decision, on behalf of Vets Against Live Export (VALE), not to provide comments on the Livestock Global Assurance Program (LGAP) Standards in accordance with the process determined by the LGAP Standards Committee.

As I am not a member of the Standards Committee and ALEC has no role in the outcome of the Standards Committee process, I have forwarded your letter to the LGAP Standards Committee for their consideration. Despite what you have written, I ask you to reconsider and take the opportunity to provide formal comments on the Standards.

By way of background the development of the LGAP is currently an ongoing research project of the industry and as such, no decision has yet been taken to move to implementation. The concept of a welfare assurance program covering the post-export supply chain stems from the 2011 Farmer Review commissioned by Australian Government which recommended that industry develop and implement a through-chain QA system to complement government regulation compliance programs.

The research project commenced in July 2014 with a project team that includes subject matter experts, specialising in the areas of project management, the live export industry, animal welfare, husbandry and behaviour, development and internationalisation of standards and conformity assessment programs; and the development and application of technology solutions.

In accordance with an earlier scoping research project, the research project was to develop a certification program, applicable to any market and designed to provide assurances that animals continue to be treated in accordance with international guidelines (the Exporter Supply
Chain Assurance System (ESCAS) standards for Australian livestock) up to and including the point of slaughter. As with any conformity assessment program, the Program is required to be governed by a set of Rules and a Standard or Standards.

Furthermore, as the Program is to operate outside of Australia and across international borders, the development of the Program overall, as well as the Standards and Rules, is intended to follow international guidelines including the OIE Code, guidelines and standards published by ISO; and guidelines published by the WTO.

In order to be internationally applicable, the standards development process has followed:
• AABSDO: Requirements for the Accreditation of a Standards Development Organisation, Version 1_1 (2014).
• ISO/IEC 17007:2009: Conformity assessment - Guidance for drafting normative documents suitable for use for conformity assessment.
• ISO/IEC Guide 59:1994: Code of good practice for standardization.
• Standards Australia: Standardisation Guide 006 - Rules for the structure and drafting of Australian Standards. Version 2.6 (2012).
• WTO: Agreement on Technical Barriers to Trade, Annex 3: Code of Good Practice for the Preparation, Adoption and Application of Standards.
These guidelines specify the expectations of any organisation setting standards and the standards development process.

I would like to now correct a number of your statements about LGAP in your letter.

The form provided for comment on the Standards has been designed to enable comment and input on the specific content of each element of the Standards and is not intended to prescribe an outcome. I am disappointed that you hold the latter view.

The development of LGAP is far from a cynical exercise and I am disappointed that you have been blinded by your opposition to the trade and rejected objective and constructive input into this process. The letter inviting VALE to participate was a genuine invitation respecting your organisation’s interest in the livestock export trade – regardless of your policy position. LGAP is being designed not just for Australian exported livestock. Any facility anywhere in the world could be certified under the program regardless of country of origin as long as the Program Standards are met. The development of auditable animal welfare standards for livestock anywhere in the world in a program that will provide a pathway to higher levels of welfare certification, we had hoped would be of genuine interest to VALE.

LGAP will not dilute ESCAS. ESCAS is a regulatory framework for Australian exported livestock covering animal welfare to the point of slaughter. This does not change under LGAP and indeed LGAP has been developed to strengthen oversight and management of welfare along the supply chain through operators (exporters and importers) and facilities (feedlots, farms and abattoirs). It will, if implemented, provide for a better demonstration of ESCAS compliance, more immediate and thorough management of non-conformances and potentially a scope for facilities and operators which seek to perform over and above ESCAS standards.

In addition, the research project does not propose any regulatory changes for the pre

Your comment will be posted after it is approved.

VALE Opposes LGAP: Open Letter

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