Government correspondence
On this page is VALE's correspondence to and from the Australian Government Department of Agriculture appearing as various names and acronyms (DAFF, DAWE, DAWR and Department of Agriculture).
March 2025: VALE notes Dept's approval of live exports to Israel and alerts Dept to escalating Houthi attacks
On 12 Mar 2025, at 10:42 am, Vets Against Live Export <[email protected]> wrote:
Dear Mr Young,
Thank you for your response.
VALE does not believe this is a matter for exporters and their contingency plans. No contingency plan, other than avoiding Israel shipments (a Departmental decision), could prevent a Houthi attack in the Red or Mediterranean Seas on live export ships. If it is too dangerous to place independent observers on these ships, it is too dangerous for the animals.
On 12 Mar 2025, at 7:41 am, Live Stock Exports <[email protected]> wrote:
OFFICIAL
Thank you for your email.
The department continues to monitor the security situation as it relates to the safety of shipping to ports in the conflict zone. Although we cannot comment on specific consignments, we can assure you that all applications to export livestock are assessed on their own merits, against legislative requirements, which includes animal welfare.
As a matter of policy since 2 April 2024, for consignments destined for ports in the Red Sea or any port in Israel, exporters must submit their contingency plan to the department for assessment, to support their application for export.
Regards
Richard Young, Plant and Live Animal Exports, Welfare & Regulation Division
From: Vets Against Live Export <[email protected]>
Sent: Tuesday, 11 March 2025 9:02 AM
To: Live Stock Exports <[email protected]>
Cc: Inspector-General of Animal Welfare and Live Animal Exports (IGAWLAE) <[email protected]>
Subject: Houthi Alert
Dear Livestock Exports,
Although, there was no public announcement of the trade resumption, VALE has been tracking ships and it is evident that Dept has again approved live exports from Australia to Israel (see MV Gelbray Express shipping data below).
Consistent with that, the MV Bahijah has finally left Haifa on track to Australia no doubt to resume live export to Israel.
Given the previous unpreparedness of the Dept for the seriousness of Houthi attacks (MV Bahijah voyage incident in 2024), VALE wishes to alert the Department to the current Houthi situation:
https://splash247.com/houthis-warn-attacks-on-merchant-ships-could-resume-tomorrow/
VALE does not believe that with the current conflict, Australia should be approving live export to Israel by any route (noting that the MV Shorthorn Express came under attack entering Haifa from the Mediterranean Sea in 2024:https://www.aljazeera.com/news/2024/6/23/yemens-houthis-claim-joint-raid-on-israeli-ships-with-iraqi-militia).
On 12 Mar 2025, at 10:42 am, Vets Against Live Export <[email protected]> wrote:
Dear Mr Young,
Thank you for your response.
VALE does not believe this is a matter for exporters and their contingency plans. No contingency plan, other than avoiding Israel shipments (a Departmental decision), could prevent a Houthi attack in the Red or Mediterranean Seas on live export ships. If it is too dangerous to place independent observers on these ships, it is too dangerous for the animals.
On 12 Mar 2025, at 7:41 am, Live Stock Exports <[email protected]> wrote:
OFFICIAL
Thank you for your email.
The department continues to monitor the security situation as it relates to the safety of shipping to ports in the conflict zone. Although we cannot comment on specific consignments, we can assure you that all applications to export livestock are assessed on their own merits, against legislative requirements, which includes animal welfare.
As a matter of policy since 2 April 2024, for consignments destined for ports in the Red Sea or any port in Israel, exporters must submit their contingency plan to the department for assessment, to support their application for export.
Regards
Richard Young, Plant and Live Animal Exports, Welfare & Regulation Division
From: Vets Against Live Export <[email protected]>
Sent: Tuesday, 11 March 2025 9:02 AM
To: Live Stock Exports <[email protected]>
Cc: Inspector-General of Animal Welfare and Live Animal Exports (IGAWLAE) <[email protected]>
Subject: Houthi Alert
Dear Livestock Exports,
Although, there was no public announcement of the trade resumption, VALE has been tracking ships and it is evident that Dept has again approved live exports from Australia to Israel (see MV Gelbray Express shipping data below).
Consistent with that, the MV Bahijah has finally left Haifa on track to Australia no doubt to resume live export to Israel.
Given the previous unpreparedness of the Dept for the seriousness of Houthi attacks (MV Bahijah voyage incident in 2024), VALE wishes to alert the Department to the current Houthi situation:
https://splash247.com/houthis-warn-attacks-on-merchant-ships-could-resume-tomorrow/
VALE does not believe that with the current conflict, Australia should be approving live export to Israel by any route (noting that the MV Shorthorn Express came under attack entering Haifa from the Mediterranean Sea in 2024:https://www.aljazeera.com/news/2024/6/23/yemens-houthis-claim-joint-raid-on-israeli-ships-with-iraqi-militia).
20.2.2025 VALE questions Dept of Ag on sending pregnant Victoria dairy cows to calve in the extreme conditions of a Northern Hemisphere summer
It has come to VALE’s attention that ... both consignments are almost certainly pregnant dairy cattle. If that is the case, then these southern Victorian diary cattle will be calving mid-summer ...
Could you confirm if the Department has indeed authorised the carriage of pregnant animals to either or both of these destinations and if confirmed, indicate what Australian supervision will there be for calving in NHS summer in these locations. VALE notes that historically, .. has had a poor animal welfare record with dairy cattle, with at least one export company voluntarily ceasing supply of dairy cattle there in the past.
[Note: specific vessels and destinations redacted for legal reasons]
21.2.2025 Dept of Ag deflects to ASEL - ASEL doesnt cover end destination
The information you have requested is classified as protected information under our legislation and, as such, cannot be disclosed.
However, I can provide some general information regarding the relevant regulatory requirements. As you would be aware, under ASEL, there are numerous requirements pertaining to pregnant cattle, including gestation, pen space and shipboard personnel. Although there are no regulatory requirements for breeder animals post-arrival, exporters generally have extensive in-market support for their animals as part of their commercial arrangements to ensure the health and welfare of their livestock is maintained.
25.02.20 VALE Requests whether Dept would consent to transport of pregnant dairy cows to calve in NHS summer
As you would be well aware, this question was not about ASEL or the regulation of shipboard transport by ASEL.
Given that the requested information is regarded as classified, VALE wishes to rephrase the question:
1) would the Dept of Ag approve shipments of pregnant southern Victorian dairy cattle to a hot northern Hemisphere summer destination (Middle East or Pakistan for example) at this time of the year knowing that calving will occur in the Northern Hemisphere summer in a third world/developing country with no welfare regulations?
2) if indeed approval is given, is there consideration of the end-destination conditions for calving.
Evidence-based analysis over 20 years shows that exporters have rarely had commercial arrangements to ensure the health and welfare of their livestock at end destination. If they had, the Australian Government would not have had to formulate ESCAS and continued ESCAS non-compliance would not be occurring. In addition, and specifically for pregnant dairy cattle, the evidence from the shipments to Qatar [confidential] and previously to [confidential] would also refute the assertion.
It has come to VALE’s attention that ... both consignments are almost certainly pregnant dairy cattle. If that is the case, then these southern Victorian diary cattle will be calving mid-summer ...
Could you confirm if the Department has indeed authorised the carriage of pregnant animals to either or both of these destinations and if confirmed, indicate what Australian supervision will there be for calving in NHS summer in these locations. VALE notes that historically, .. has had a poor animal welfare record with dairy cattle, with at least one export company voluntarily ceasing supply of dairy cattle there in the past.
[Note: specific vessels and destinations redacted for legal reasons]
21.2.2025 Dept of Ag deflects to ASEL - ASEL doesnt cover end destination
The information you have requested is classified as protected information under our legislation and, as such, cannot be disclosed.
However, I can provide some general information regarding the relevant regulatory requirements. As you would be aware, under ASEL, there are numerous requirements pertaining to pregnant cattle, including gestation, pen space and shipboard personnel. Although there are no regulatory requirements for breeder animals post-arrival, exporters generally have extensive in-market support for their animals as part of their commercial arrangements to ensure the health and welfare of their livestock is maintained.
25.02.20 VALE Requests whether Dept would consent to transport of pregnant dairy cows to calve in NHS summer
As you would be well aware, this question was not about ASEL or the regulation of shipboard transport by ASEL.
Given that the requested information is regarded as classified, VALE wishes to rephrase the question:
1) would the Dept of Ag approve shipments of pregnant southern Victorian dairy cattle to a hot northern Hemisphere summer destination (Middle East or Pakistan for example) at this time of the year knowing that calving will occur in the Northern Hemisphere summer in a third world/developing country with no welfare regulations?
2) if indeed approval is given, is there consideration of the end-destination conditions for calving.
Evidence-based analysis over 20 years shows that exporters have rarely had commercial arrangements to ensure the health and welfare of their livestock at end destination. If they had, the Australian Government would not have had to formulate ESCAS and continued ESCAS non-compliance would not be occurring. In addition, and specifically for pregnant dairy cattle, the evidence from the shipments to Qatar [confidential] and previously to [confidential] would also refute the assertion.
25.01.17 VALE Questions IO Program
VALE wants to urgently discuss the Independent Observer (IO) Program from April 2023 to
present.
In this 20-month time period:
1) there have been only 9 independent observers employed, indicating a program
which is no longer statistically viable for data capture;
2) one report from September 2023 (15 months ago) has not been completed;
3) the Department has reported only one action against non-compliance despite most
voyages having reported non-compliance; in that one instance (see point 4), no
information is provided as to why action was required;
4) the one “Department Action” noted (IO Summary 236) provides no information as to the reason why it was taken. This ship historically has had discrepant livestock
counts (e.g., High Mortality Voyage 65 in 2016 and IO Summary 2 in 2018). This is
evidence for repeated non-compliance re discrepant livestock counts but there
appear to be no sanctions by the Department despite the repeat nature of the noncompliance;
5) the Department made the extraordinary statement on one report that Bovine
Respiratory Disease (a disease, by definition) has no effect on animal health;
6) one voyage had 5% sheep non-compliance with wool length exceeding ASEL noted
prior to departure but these sheep were allowed to sail in May despite being on the
edge of the Northern Hemisphere Summer prohibition period. May is a month of high
heat stress risk in sheep as assessed by the Australian Veterinary Association in
their 2018 Submission. 1
Details are provided in Appendix 1 with non-compliance noted in red font.
[Redacted confidential information] It is understandable that, almost universally in VALE’s
experience, AAVs are as concerned about the Department as they are about the exporters.
In summary, this very small snapshot of the last 20 months is a major concern. The IO
program is now dysfunctional and, if the IO information that is available is representative, the
Department has failed to implement sanctions or even direct changes for future voyages
since the program started. It is thus not surprising that exporter breaches are ongoing as
exporters are seemingly protected by the Department regardless of non-compliance. The
incoming Inspector General (IGLAE) Dr Clift perceptively asked VALE if anything had
improved as a result of the Independent Observer reports. VALE’s answer was that one of
the aims had been transparency for an industry that needed social licence and that that
outcome had been partially met. The summaries demonstrate how many repeatable
problems occur on the voyages seemingly with no proactive responses by exporters. The
summaries also demonstrate how ineffective or complicit the Department was, and is, in
addressing the repetitive animal welfare issues on ships. VALE informed the IGLAE that the
program has not improved animal welfare due to the Department’s consistent failure to
effectively respond to repeated issues and non-compliance.
No response. VALE wrote again in 25.02.14
Response: Meeting still to be scheduled and a letter from the Assistant Secretary sent in the interim
See letter
VALE wants to urgently discuss the Independent Observer (IO) Program from April 2023 to
present.
In this 20-month time period:
1) there have been only 9 independent observers employed, indicating a program
which is no longer statistically viable for data capture;
2) one report from September 2023 (15 months ago) has not been completed;
3) the Department has reported only one action against non-compliance despite most
voyages having reported non-compliance; in that one instance (see point 4), no
information is provided as to why action was required;
4) the one “Department Action” noted (IO Summary 236) provides no information as to the reason why it was taken. This ship historically has had discrepant livestock
counts (e.g., High Mortality Voyage 65 in 2016 and IO Summary 2 in 2018). This is
evidence for repeated non-compliance re discrepant livestock counts but there
appear to be no sanctions by the Department despite the repeat nature of the noncompliance;
5) the Department made the extraordinary statement on one report that Bovine
Respiratory Disease (a disease, by definition) has no effect on animal health;
6) one voyage had 5% sheep non-compliance with wool length exceeding ASEL noted
prior to departure but these sheep were allowed to sail in May despite being on the
edge of the Northern Hemisphere Summer prohibition period. May is a month of high
heat stress risk in sheep as assessed by the Australian Veterinary Association in
their 2018 Submission. 1
Details are provided in Appendix 1 with non-compliance noted in red font.
[Redacted confidential information] It is understandable that, almost universally in VALE’s
experience, AAVs are as concerned about the Department as they are about the exporters.
In summary, this very small snapshot of the last 20 months is a major concern. The IO
program is now dysfunctional and, if the IO information that is available is representative, the
Department has failed to implement sanctions or even direct changes for future voyages
since the program started. It is thus not surprising that exporter breaches are ongoing as
exporters are seemingly protected by the Department regardless of non-compliance. The
incoming Inspector General (IGLAE) Dr Clift perceptively asked VALE if anything had
improved as a result of the Independent Observer reports. VALE’s answer was that one of
the aims had been transparency for an industry that needed social licence and that that
outcome had been partially met. The summaries demonstrate how many repeatable
problems occur on the voyages seemingly with no proactive responses by exporters. The
summaries also demonstrate how ineffective or complicit the Department was, and is, in
addressing the repetitive animal welfare issues on ships. VALE informed the IGLAE that the
program has not improved animal welfare due to the Department’s consistent failure to
effectively respond to repeated issues and non-compliance.
No response. VALE wrote again in 25.02.14
Response: Meeting still to be scheduled and a letter from the Assistant Secretary sent in the interim
See letter
24.03.22 Andrew McDonald to VALE re questions on selection of veterinarians for inspection and wool length
I write to respond to your further correspondence.
1. The department approached veterinarians who had experience with livestock, were available in WA and who were not tied of the specific exporter. The department requested the veterinarians to undertake an assessment of the welfare of the livestock on the vessel. This assessment provided advice to the department as a separate, one-off activity and was in addition to the on-board veterinarian’s daily assessments and reports.
2. ASEL (ASEL-version-3.3.pdf (agriculture.gov.au)) provides that sheep sourced for export must have wool no longer than 25mm in length at the time of loading for transport, unless otherwise provided in a Northern Hemisphere winter sheep shearing management plan that is approved in writing by the department. Without going into the specifics, we worked with the exporter in question to ensure they met this ASEL standard for this particular consignment.
3. Exporters are obliged under federal legislation (the Export Control Act 2020, Export Control (Animals) Rules 2021 and the Australian Standards for the Export of Livestock) to record, monitor and report on key aspects of the voyage, including environmental conditions, animals’ health and welfare, heat stress and animal morbidities and mortalities. They must supply a range of data and reports, including daily and end of voyage reports (completed by the onboard accredited veterinarian or accredited stockperson).
4. Additional reporting may be required where an independent observer cannot be deployed. The key elements of additional reporting include:
· confirming livestock are loaded onto vessels in accordance with the load plan,
· information regarding the daily livestock husbandry routine,
· information regarding feed, water, bedding and the identification and treatment of sick livestock, and
· date and time-stamped photos and video footage.
Additionally, data collected and stored by environmental data recording devices that have been tested against the standards of an internationally recognised standards organisation may be required.
24.03.12 VALE further questions the Dept of Ag re exemption from ASEL wool length compliance on the Bahijah.
Dear Mr McDonald,
Further to VALE’s email correspondence on 1 March 2024, VALE reviewed all available footage of the sheep trucked to Fremantle Port to be loaded onto the MV Bahijah. The footage confirmed the earlier information we had been given that these sheep were not shorn before re-loading.
I have attached VALE’s letter of concern regarding the wool length of the sheep loaded onto the MV Bahijah in March 2024.
VALE is also awaiting a response to our concerns about the selection of independent veterinarians (19 Feb 2024).
Yours sincerely
Dr Sue Foster
VALE Spokesperson
0423 783 689
I write to respond to your further correspondence.
1. The department approached veterinarians who had experience with livestock, were available in WA and who were not tied of the specific exporter. The department requested the veterinarians to undertake an assessment of the welfare of the livestock on the vessel. This assessment provided advice to the department as a separate, one-off activity and was in addition to the on-board veterinarian’s daily assessments and reports.
2. ASEL (ASEL-version-3.3.pdf (agriculture.gov.au)) provides that sheep sourced for export must have wool no longer than 25mm in length at the time of loading for transport, unless otherwise provided in a Northern Hemisphere winter sheep shearing management plan that is approved in writing by the department. Without going into the specifics, we worked with the exporter in question to ensure they met this ASEL standard for this particular consignment.
3. Exporters are obliged under federal legislation (the Export Control Act 2020, Export Control (Animals) Rules 2021 and the Australian Standards for the Export of Livestock) to record, monitor and report on key aspects of the voyage, including environmental conditions, animals’ health and welfare, heat stress and animal morbidities and mortalities. They must supply a range of data and reports, including daily and end of voyage reports (completed by the onboard accredited veterinarian or accredited stockperson).
4. Additional reporting may be required where an independent observer cannot be deployed. The key elements of additional reporting include:
· confirming livestock are loaded onto vessels in accordance with the load plan,
· information regarding the daily livestock husbandry routine,
· information regarding feed, water, bedding and the identification and treatment of sick livestock, and
· date and time-stamped photos and video footage.
Additionally, data collected and stored by environmental data recording devices that have been tested against the standards of an internationally recognised standards organisation may be required.
24.03.12 VALE further questions the Dept of Ag re exemption from ASEL wool length compliance on the Bahijah.
Dear Mr McDonald,
Further to VALE’s email correspondence on 1 March 2024, VALE reviewed all available footage of the sheep trucked to Fremantle Port to be loaded onto the MV Bahijah. The footage confirmed the earlier information we had been given that these sheep were not shorn before re-loading.
I have attached VALE’s letter of concern regarding the wool length of the sheep loaded onto the MV Bahijah in March 2024.
VALE is also awaiting a response to our concerns about the selection of independent veterinarians (19 Feb 2024).
Yours sincerely
Dr Sue Foster
VALE Spokesperson
0423 783 689
| vale_letter_mcdonald_24.03.12.pdf |
24.03.01 VALE questions the Dept of Ag re wool length compliance on sheep to be loaded onto the MV Bahijah and receives a reply.
From: Vets Against Live Export <[email protected]>
Sent: Friday, March 1, 2024 7:27 PM
To: Sheridan, Carol <[email protected]>
Cc: McDonald, Andrew <[email protected]>
Subject: MV Bahijah sheep wool status
Dear Carol,
VALE has been provided credible information that the sheep from the MV Bahijah currently at feedlot, and due to reload, have not been shorn. VALE hopes that this information is incorrect as wool length will have increased since the first pre-export period in December 2023/January 2024.
VALE was concerned when Mr McDonald did not consider wool length important in his MV Bahijah decision. ASEL mandates for appropriate wool length to reduce heat stress. Woolly sheep are the most vulnerable to heat stress on routine long haul voyages. There is clear evidence from the MV Al Kuwait voyage in June 2020 that woolly animals suffered most (IO 219). Other independent observers (IO 86 and 220) made similar observations.
It should be noted that in IO Report 193, 14,000 head of sheep with non-compliant fleece slipped past an “accredited observer" at Fremantle Port which highlights the necessity for a truly independent observer at Fremantle Port for the loading of the MV Bahijah.
VALE requests that all animals reloading onto the MV Bahijah are examined by independent veterinarians/observers for ASEL compliance and that any sheep with non-compliant wool length are rejected.
On 1 Mar 2024, at 4:39 pm, McDonald, Andrew <[email protected]> wrote:
Dear Dr Foster
I wish to acknowledge your correspondence.
While I cannot go into specifics, I can advise all decisions have been made in accordance with the requirements of the Export Control Act 2020.
Kind regards
Andrew
Andrew McDonald
A/ First Assistant Secretary
Department of Agriculture, Fisheries and Forestry
Plant and Live Animal Exports, Welfare and Regulation Division
Agriculture House, 70 Northbourne Ave, Canberra ACT 2601 Australia
GPO Box 858 Canberra ACT 2601 Australia
From: Vets Against Live Export <[email protected]>
Sent: Friday, March 1, 2024 7:27 PM
To: Sheridan, Carol <[email protected]>
Cc: McDonald, Andrew <[email protected]>
Subject: MV Bahijah sheep wool status
Dear Carol,
VALE has been provided credible information that the sheep from the MV Bahijah currently at feedlot, and due to reload, have not been shorn. VALE hopes that this information is incorrect as wool length will have increased since the first pre-export period in December 2023/January 2024.
VALE was concerned when Mr McDonald did not consider wool length important in his MV Bahijah decision. ASEL mandates for appropriate wool length to reduce heat stress. Woolly sheep are the most vulnerable to heat stress on routine long haul voyages. There is clear evidence from the MV Al Kuwait voyage in June 2020 that woolly animals suffered most (IO 219). Other independent observers (IO 86 and 220) made similar observations.
It should be noted that in IO Report 193, 14,000 head of sheep with non-compliant fleece slipped past an “accredited observer" at Fremantle Port which highlights the necessity for a truly independent observer at Fremantle Port for the loading of the MV Bahijah.
VALE requests that all animals reloading onto the MV Bahijah are examined by independent veterinarians/observers for ASEL compliance and that any sheep with non-compliant wool length are rejected.
On 1 Mar 2024, at 4:39 pm, McDonald, Andrew <[email protected]> wrote:
Dear Dr Foster
I wish to acknowledge your correspondence.
While I cannot go into specifics, I can advise all decisions have been made in accordance with the requirements of the Export Control Act 2020.
Kind regards
Andrew
Andrew McDonald
A/ First Assistant Secretary
Department of Agriculture, Fisheries and Forestry
Plant and Live Animal Exports, Welfare and Regulation Division
Agriculture House, 70 Northbourne Ave, Canberra ACT 2601 Australia
GPO Box 858 Canberra ACT 2601 Australia
23.09.08 VALE alerts Chief Veterinary Officer and Deputy Chief Veterinary Officer to the inadequate food requirements for dairy cattle
Dear Dr Schipp,VALE has recently checked ASEL requirements for cattle fodder: ASEL v 3.2 (3.4.1). The specified food provision of 2.5% bodyweight is inadequate for acceptable energy and protein requirements of Holstein dairy heifers of the weight often exported (eg 7-10 months old, 200- 290kg).....
See: Letter
Response:
See letter...a review is apparently required to increase the ASEL food requirements BUT without any review, and definitely without any science, the Department actually reduces the ASEL food requirement in cattle >250kg from 2.5% to 2%.
See: Letter
So VALE wrote again to Beth Cookson, now CVO on 31 Oct 2023...
Dear Dr Cookson,
This is a very serious issue, not just in terms of animal welfare risks but also reputational risk of both the industry and the government.
In the past we have contacted Dr Schipp only where there was a clear failure of the Department to act in response of a matter of extreme veterinary importance.
VALE considers this matter of extreme veterinary importance.
VALE wrote to you as Acting Chief Veterinary Officer because we wanted this assessed by the CVO and not the Department. The Department have ignored concerns raised by AAVs just as they have ignored VALE’s recommendations for ASEL 3.3.
VALE notes that in response to our concerns the Department, in contradiction to MLA’s own recommendations of >2.5% (Willis 2011) per animal, has actually reduced the required fodder ever further for most classes of cattle to 2%. The number of days of fodder reserve required has also been decreased for voyages up to 15 days. This amounts to a 33% decrease in fodder reserve and a 25% decrease in fodder/beast/day. With 63% of voyages under-estimated (the Departments own figure), this drastic reduction in fodder onboard will be catastrophic. Starvation was identified as a repetitive issue by VALE in our peer-reviewed paper (Hing et al 2021) using descriptions and reports from the Independent Observers. In addition, one ship, the Gulf Livestock 1 has already sunk because it ran out of cattle feed and was then forced to sail through a typhoon rather than going around (too many days in a ship with no food).
Could we please organise a Zoom meeting as a matter of urgency.
RESPONSE: Zilch.
Dear Dr Schipp,VALE has recently checked ASEL requirements for cattle fodder: ASEL v 3.2 (3.4.1). The specified food provision of 2.5% bodyweight is inadequate for acceptable energy and protein requirements of Holstein dairy heifers of the weight often exported (eg 7-10 months old, 200- 290kg).....
See: Letter
Response:
See letter...a review is apparently required to increase the ASEL food requirements BUT without any review, and definitely without any science, the Department actually reduces the ASEL food requirement in cattle >250kg from 2.5% to 2%.
See: Letter
So VALE wrote again to Beth Cookson, now CVO on 31 Oct 2023...
Dear Dr Cookson,
This is a very serious issue, not just in terms of animal welfare risks but also reputational risk of both the industry and the government.
In the past we have contacted Dr Schipp only where there was a clear failure of the Department to act in response of a matter of extreme veterinary importance.
VALE considers this matter of extreme veterinary importance.
VALE wrote to you as Acting Chief Veterinary Officer because we wanted this assessed by the CVO and not the Department. The Department have ignored concerns raised by AAVs just as they have ignored VALE’s recommendations for ASEL 3.3.
VALE notes that in response to our concerns the Department, in contradiction to MLA’s own recommendations of >2.5% (Willis 2011) per animal, has actually reduced the required fodder ever further for most classes of cattle to 2%. The number of days of fodder reserve required has also been decreased for voyages up to 15 days. This amounts to a 33% decrease in fodder reserve and a 25% decrease in fodder/beast/day. With 63% of voyages under-estimated (the Departments own figure), this drastic reduction in fodder onboard will be catastrophic. Starvation was identified as a repetitive issue by VALE in our peer-reviewed paper (Hing et al 2021) using descriptions and reports from the Independent Observers. In addition, one ship, the Gulf Livestock 1 has already sunk because it ran out of cattle feed and was then forced to sail through a typhoon rather than going around (too many days in a ship with no food).
Could we please organise a Zoom meeting as a matter of urgency.
RESPONSE: Zilch.
VALE requests information on Indonesian animal welfare and biosecurity with FMD outbreak
19th August 2022: written response from Tina Hutchinson to VALE
Thank you again for your email of 18 July. Indonesia represents Australia’s largest cattle export market, which is part of a longstanding and significant bilateral relationship between the two countries. In addition, Indonesia relies on Australia to supply beef cattle which cannot currently be produced domestically to address its food security needs. Outbreak of serious disease is deeply concerning to both countries. The Australia Government continues to cooperate with Indonesia to combat the outbreak of foot and mouth disease, including through advice from Australian technical experts, supply of vaccines and offers of financial support. This is in addition to assistance already being provided to combat lumpy skin disease, that was detected in Sumatra. Furthermore, the Australian Government has co-funded a project with Meat and Livestock Australia to coordinate support from Australian industry for the Indonesian feedlot sector’s emergency response to these diseases and to support Indonesian feedlots to access FMD vaccine.
In direct support of protecting the health of exported Australian livestock, and supporting Indonesian importers and feedlots manage the impact and spread of FMD, Meat and Livestock Australia has made funding available for a vaccine project to support importers to vaccinate Australian cattle entering Indonesian feedlots. This is in addition to over 40 000 vaccinations that have already been administered across Indonesian feedlots, with another 450 000 doses on order and expected within weeks.
In relation to your questions about livestock vessels and their crew, Australia has long standing biosecurity arrangements in place for international vessels, and these have recently been enhanced for livestock vessels. Specifically:
15th August 2022: two phone call follow-ups to say response coming and that response has been delayed; BUT still no actual response
18th July 2022 VALE to TIna Hutchinson 18th July 2022:
VALE is very concerned about the current export of cattle from Australia to Indonesia from the perspectives of Australian cattle welfare and Australian farm biosecurity. VALE would like to know:
1. why our FMD naive cattle are being exported to a country with an FMD epidemic - this is a serious animal welfare issue, especially given the limited animal health and care options in a Third World Country with a disease that has up to 100% morbidity.
2. what biosecurity measures are in place for difficult-to-disinfect cattle ships returning back from Indonesia.
3. what biosecurity measures are in place for the ship crew (eg returning Australian stockpersons and vet, ship's crew etc) when they disembark and what of Australian stevedores and stockpersons etc who will be on and off the ship when it reloads in Australia. We have not seen any EANs providing any extra instructions re ship disinfection, crew movements, quarantine orders etc relating to the Indonesian export trade and likewise have seen no specific EANs for procedures in Indonesia, where usually there is only a footbath of disinfectant (often muddy and easily stepped over) at the end of the gangway but nothing in place on the cattle ramps, a major entry and exit point for personnel.
On both animal welfare and biosecurity grounds, VALE believes that there should be trade suspension to Indonesia whilst the FMD epidemic is out of control. Boxed meat is an alternative that should be considered at this time.
Thank you again for your email of 18 July. Indonesia represents Australia’s largest cattle export market, which is part of a longstanding and significant bilateral relationship between the two countries. In addition, Indonesia relies on Australia to supply beef cattle which cannot currently be produced domestically to address its food security needs. Outbreak of serious disease is deeply concerning to both countries. The Australia Government continues to cooperate with Indonesia to combat the outbreak of foot and mouth disease, including through advice from Australian technical experts, supply of vaccines and offers of financial support. This is in addition to assistance already being provided to combat lumpy skin disease, that was detected in Sumatra. Furthermore, the Australian Government has co-funded a project with Meat and Livestock Australia to coordinate support from Australian industry for the Indonesian feedlot sector’s emergency response to these diseases and to support Indonesian feedlots to access FMD vaccine.
In direct support of protecting the health of exported Australian livestock, and supporting Indonesian importers and feedlots manage the impact and spread of FMD, Meat and Livestock Australia has made funding available for a vaccine project to support importers to vaccinate Australian cattle entering Indonesian feedlots. This is in addition to over 40 000 vaccinations that have already been administered across Indonesian feedlots, with another 450 000 doses on order and expected within weeks.
In relation to your questions about livestock vessels and their crew, Australia has long standing biosecurity arrangements in place for international vessels, and these have recently been enhanced for livestock vessels. Specifically:
- all vessels entering Australian waters, including returning livestock vessels, become subject to biosecurity control and must therefore comply with Australia’s strict biosecurity requirements.
- all livestock vessels, including those returning from Indonesia, are subject to heightened surveillance due to Indonesia’s changed FMD status. This surveillance is in addition to the existing cleaning, disinsection and inspection requirements for livestock vessel that must be completed prior to or upon arrival in Australia and before the vessel is permitted to load livestock.
- all operational staff, including biosecurity officers who oversee returning livestock vessels have been provided refresher information about the risks posed by FMD;
- livestock vessels are required to enforce the use of footbaths at all times whilst vessels are in port in Australia including an additional second footbath at the top of the gangway on the vessel;
- biosecurity officers who perform biosecurity clearances of livestock vessel crews, including any accredited stockmen who return on the vessel, pay particular attention to any food, tools, foot wear and clothing given the biosecurity risks associated with these items;
- a publicly available industry advice notice (IIAN 117-2022) was published on 8 July 2022 setting out additional requirements for livestock vessels to manage the risks posed by FMD/LSD;
- furthermore, all international travellers, including accredited stockmen, accredited veterinarians and the crew of livestock vessels returning from Indonesia that enter Australia are not permitted to bring food products that may present an FMD risk – these products must be declared for inspection on arrival.
15th August 2022: two phone call follow-ups to say response coming and that response has been delayed; BUT still no actual response
18th July 2022 VALE to TIna Hutchinson 18th July 2022:
VALE is very concerned about the current export of cattle from Australia to Indonesia from the perspectives of Australian cattle welfare and Australian farm biosecurity. VALE would like to know:
1. why our FMD naive cattle are being exported to a country with an FMD epidemic - this is a serious animal welfare issue, especially given the limited animal health and care options in a Third World Country with a disease that has up to 100% morbidity.
2. what biosecurity measures are in place for difficult-to-disinfect cattle ships returning back from Indonesia.
3. what biosecurity measures are in place for the ship crew (eg returning Australian stockpersons and vet, ship's crew etc) when they disembark and what of Australian stevedores and stockpersons etc who will be on and off the ship when it reloads in Australia. We have not seen any EANs providing any extra instructions re ship disinfection, crew movements, quarantine orders etc relating to the Indonesian export trade and likewise have seen no specific EANs for procedures in Indonesia, where usually there is only a footbath of disinfectant (often muddy and easily stepped over) at the end of the gangway but nothing in place on the cattle ramps, a major entry and exit point for personnel.
On both animal welfare and biosecurity grounds, VALE believes that there should be trade suspension to Indonesia whilst the FMD epidemic is out of control. Boxed meat is an alternative that should be considered at this time.
INADEQUACY AND INACCURACY OF GOVERNMENT INDEPENDENT OBSERVER SUMMARY 197
2 Nov 2022: call from Acacia Pyner offering to meet up in WA with short notice - not possible for VALE but in a follow up call on 9 Nov 2022, a meeting set up for 11 Nov 2022. Dept confirms verbally that they did notify AMSA of fire risk and MO 43 concerns but will clarify dates of email at meeting on 11 Nov 2022.
October 31 2022: with no further Department analysis and information forthcoming, VALE resorted to another FOI for voyage documents to enable independent analysis
Sept 2022: call to request meeting in WA with short notice - not possible but Dr Joffrid Mackett confirmed that the Dept were still working through VALE's complaint
14th August 2022: NO UPDATE
6 Jul 2022, at 5:51 am, Joffrid Mackett to VALE
Just a quick email to follow up on the phone message I left with you the other day.As I mentioned in my message, and as indicated by Tina in her discussion with you, once we have gone through the document you provided we will be in touch to arrange a time to discuss it in detail. In the interim, should you wish to discuss this further I have included my phone number below in case it wasn’t clear in my phone message. Please note I will be out of the office until next Wednesday (13 July), and will only have intermittent access to phone and email until I return.
17th June 2022: VALE to Dept
I have attached VALE’s comparison of the initial IO Report, the final IO Report and the Department’s IO Summary for IO 197. VALE believe that any member of the public and any objective independent analyser would consider the IO Summary to be a misrepresentation of this voyage. The animal welfare issues were downplayed or excluded, personnel issues were excluded, the ship faults were not detailed and the fire risk omitted. VALE alerted AMSA to the fire risk situation on this ship which had undergone an extensive fire assessment after previously burning in Fremantle Port.
Yours sincerely,
October 31 2022: with no further Department analysis and information forthcoming, VALE resorted to another FOI for voyage documents to enable independent analysis
Sept 2022: call to request meeting in WA with short notice - not possible but Dr Joffrid Mackett confirmed that the Dept were still working through VALE's complaint
14th August 2022: NO UPDATE
6 Jul 2022, at 5:51 am, Joffrid Mackett to VALE
Just a quick email to follow up on the phone message I left with you the other day.As I mentioned in my message, and as indicated by Tina in her discussion with you, once we have gone through the document you provided we will be in touch to arrange a time to discuss it in detail. In the interim, should you wish to discuss this further I have included my phone number below in case it wasn’t clear in my phone message. Please note I will be out of the office until next Wednesday (13 July), and will only have intermittent access to phone and email until I return.
17th June 2022: VALE to Dept
I have attached VALE’s comparison of the initial IO Report, the final IO Report and the Department’s IO Summary for IO 197. VALE believe that any member of the public and any objective independent analyser would consider the IO Summary to be a misrepresentation of this voyage. The animal welfare issues were downplayed or excluded, personnel issues were excluded, the ship faults were not detailed and the fire risk omitted. VALE alerted AMSA to the fire risk situation on this ship which had undergone an extensive fire assessment after previously burning in Fremantle Port.
Yours sincerely,
What is happening to the MV Dareen: April 2022: Issue resolved satisfactorily
16th June 2022:satisfactory verbal communications and explanation from Tina Hutchinson.
29th April: Tina Hutchinson contacts VALE to discuss. VALE agrees to a discussion in June as VALE unavailable to meet until June
25th April NO RESPONSE FROM DAWE
14th April 8:02 am WST VALE to Joffrid Mackett. Still no answer to the question.
Email: "6 days and 5 emails later, VALE has still not had a straight answer to the question posed on Friday 8th April:Were there cattle on the MV Dareen when it left Qinhuangdao Port for Shanghai Port?
Could you please provide an answer to this question."
13th April 11:33 am WST VALE to Joffrid Mackett requesting clarification as to which port he was referring.
Thank you for that information. I assume you are referring to the port of Qinhuandao and not the port Shanghai ie that the cattle consignment was discharged at Qinhuangdao?
13th April 11:29 am WST Joffrid Mackett to VALE seemingly after complaint to Inspector General
I can confirm the consignment was discharged at the port.
13th April 10:13 WST From VALE to Inspector General
Letter of complaint about lack of Dept transparency.
13th April 10:03 WST From VALE to Joffrid Mackett and Animal Welfare
Thank you for your email. It is encouraging that the department has no animal health or welfare concerns with this consignment but I would also note that the Department is not always privy to conditions on board live export ships - as per the Awassi Express experience and the subsequent installation of Independent Observers onboard livestock vessels, a practice that was halted with the pandemic and has not been resumed.
As such, and as per my request, could you please confirm whether there were cattle on this ship when it left Qinhuangdao?
13th April 9:34 WST from Joffrid Mackett to VALE, excluding Inspector General, avoiding the question
Thank you for your email.
The department monitors the progress of consignments of livestock exported by sea. For voyages such as the one you have enquired about, exporters must ensure a daily report on the health and welfare of the livestock and conditions on board is provided to the department. These reports are monitored by LAE Branch officers and where concerns or issues are identified the department takes appropriate action. In addition, exporters must notify the department within 12 hours of a notifiable incident occurring. Such notifiable incidents include vessels that are having or are likely to have a shortage of feed.
I can confirm that the department had no animal health or welfare concerns with this consignment.
13th April 8:34 WST to Tina Hutchison and Animal Welfare Inbox, cc Inspector General
There has been no response to VALE’s email from 8 April 2022.
VALE note as of this morning that the MV Dareen is now moored in Shanghai but, if satellite information correct, alongside another another ship ie would not be able to unload cattle (but could perhaps take on food). Lack of priority berthing has been noted in previous IO reports of Australian livestock voyages to China and is a recurrent theme in the NZ live export trade using the same ships on the same routes (as per recent documents obtained under FOI - see below).
Would you be able to update us as to the status of this ship - loaded vs empty.
8th April 12:11 WST to Animal Welfare Section and Tina Hutchison
VALE has noted that the MV Dareen, which left Portland on 11 March 2022 is now sitting at anchorage in Shanghai port after spending some days at Qinhuangdao Anchorage and Port between 27 Mar and 2 April 2022.
Unless all the Portland cattle were unloaded at Qinhuangdao (unlikely if it then proceeded to Shanghai), there will be cattle onboard this ship, 28-30 days after being loaded at Portland (approximately 2 days of loading time). As you would know Shanghai is under very strict Covid lockdown measures. This is reflected in the unprecedented number of ships in Shanghai Anchorage, unable to enter port to be loaded/unloaded.
VALE has no information about how many days of extra provisions are on board the MV Dareen but 28-30 days would likely exceed the usual ASEL requirements of 3 days over the predicted time for China voyages. VALE also does not know if there is the possibility of loading extra fodder at Qinhuangdao but from analysis of China voyages (Hing et al 2021), it is evident that this would not be routine so it follows that it is likely unfeasible.
Could the Department please confirm the status of this ship - loaded with cattle vs empty- and inform VALE of what measures are in place to ensure that any cattle on this vessel have adequate food and water provisions necessary for the remaining number of days until unloading
_____________
29th April: Tina Hutchinson contacts VALE to discuss. VALE agrees to a discussion in June as VALE unavailable to meet until June
25th April NO RESPONSE FROM DAWE
14th April 8:02 am WST VALE to Joffrid Mackett. Still no answer to the question.
Email: "6 days and 5 emails later, VALE has still not had a straight answer to the question posed on Friday 8th April:Were there cattle on the MV Dareen when it left Qinhuangdao Port for Shanghai Port?
Could you please provide an answer to this question."
13th April 11:33 am WST VALE to Joffrid Mackett requesting clarification as to which port he was referring.
Thank you for that information. I assume you are referring to the port of Qinhuandao and not the port Shanghai ie that the cattle consignment was discharged at Qinhuangdao?
13th April 11:29 am WST Joffrid Mackett to VALE seemingly after complaint to Inspector General
I can confirm the consignment was discharged at the port.
13th April 10:13 WST From VALE to Inspector General
Letter of complaint about lack of Dept transparency.
13th April 10:03 WST From VALE to Joffrid Mackett and Animal Welfare
Thank you for your email. It is encouraging that the department has no animal health or welfare concerns with this consignment but I would also note that the Department is not always privy to conditions on board live export ships - as per the Awassi Express experience and the subsequent installation of Independent Observers onboard livestock vessels, a practice that was halted with the pandemic and has not been resumed.
As such, and as per my request, could you please confirm whether there were cattle on this ship when it left Qinhuangdao?
13th April 9:34 WST from Joffrid Mackett to VALE, excluding Inspector General, avoiding the question
Thank you for your email.
The department monitors the progress of consignments of livestock exported by sea. For voyages such as the one you have enquired about, exporters must ensure a daily report on the health and welfare of the livestock and conditions on board is provided to the department. These reports are monitored by LAE Branch officers and where concerns or issues are identified the department takes appropriate action. In addition, exporters must notify the department within 12 hours of a notifiable incident occurring. Such notifiable incidents include vessels that are having or are likely to have a shortage of feed.
I can confirm that the department had no animal health or welfare concerns with this consignment.
13th April 8:34 WST to Tina Hutchison and Animal Welfare Inbox, cc Inspector General
There has been no response to VALE’s email from 8 April 2022.
VALE note as of this morning that the MV Dareen is now moored in Shanghai but, if satellite information correct, alongside another another ship ie would not be able to unload cattle (but could perhaps take on food). Lack of priority berthing has been noted in previous IO reports of Australian livestock voyages to China and is a recurrent theme in the NZ live export trade using the same ships on the same routes (as per recent documents obtained under FOI - see below).
Would you be able to update us as to the status of this ship - loaded vs empty.
8th April 12:11 WST to Animal Welfare Section and Tina Hutchison
VALE has noted that the MV Dareen, which left Portland on 11 March 2022 is now sitting at anchorage in Shanghai port after spending some days at Qinhuangdao Anchorage and Port between 27 Mar and 2 April 2022.
Unless all the Portland cattle were unloaded at Qinhuangdao (unlikely if it then proceeded to Shanghai), there will be cattle onboard this ship, 28-30 days after being loaded at Portland (approximately 2 days of loading time). As you would know Shanghai is under very strict Covid lockdown measures. This is reflected in the unprecedented number of ships in Shanghai Anchorage, unable to enter port to be loaded/unloaded.
VALE has no information about how many days of extra provisions are on board the MV Dareen but 28-30 days would likely exceed the usual ASEL requirements of 3 days over the predicted time for China voyages. VALE also does not know if there is the possibility of loading extra fodder at Qinhuangdao but from analysis of China voyages (Hing et al 2021), it is evident that this would not be routine so it follows that it is likely unfeasible.
Could the Department please confirm the status of this ship - loaded with cattle vs empty- and inform VALE of what measures are in place to ensure that any cattle on this vessel have adequate food and water provisions necessary for the remaining number of days until unloading
_____________
Dept strings VALE out on an FOI request: May to August 2020
4 August 2020: FOI request finally accepted. Yep....exporters can have an exemption to a Govt order overturned in under a week but it takes VALE, 2 requests, 6 revisions and 3 months to request documents that we should be able to access in a democracy. Now lets wait and see how much it is redacted
30 July 2020: Revision No 6
| foi_vale_revised_2020.07.30.pdf |
30 July 2020: still no luck - DEPT to VALE
Thank you for your revised FOI request. We wish to clarify that the attachments are part of the final draft report and not the first draft report. Accordingly, excluding the attachments from the first draft report will not alter the documents within the scope of your request. On this basis, do you wish to exclude the attachments from the final draft report?
We note that today is the last day of the consultation period. However, the department would be open to extending the consultation period if you consider it is necessary. If you wish to extend the consultation period, please let us know today.
Thank you for your revised FOI request. We wish to clarify that the attachments are part of the final draft report and not the first draft report. Accordingly, excluding the attachments from the first draft report will not alter the documents within the scope of your request. On this basis, do you wish to exclude the attachments from the final draft report?
We note that today is the last day of the consultation period. However, the department would be open to extending the consultation period if you consider it is necessary. If you wish to extend the consultation period, please let us know today.
28 July 2020: we try yet again - VALE to Dept:
It is difficult to understand how an attachment to the first draft could be so large when we have excluded photographs and videos from our request. However, as per your advice, please see the 5th revision of our request (attached) excluding the attachment.
It is difficult to understand how an attachment to the first draft could be so large when we have excluded photographs and videos from our request. However, as per your advice, please see the 5th revision of our request (attached) excluding the attachment.
| foi_vale_revised_2020.07.23.pdf |
22 July 2020: still no luck
Thank you for your revised Freedom of Information (FOI) request. We have made some further enquires, and your revised request is likely to still be too big for the department to process. This is largely due to the size of the attachment to the report and the number of third parties the department would need to consult.
If you were to revise your FOI request to exclude the attachment to the report then this may help us to process the request....
Thank you for your revised Freedom of Information (FOI) request. We have made some further enquires, and your revised request is likely to still be too big for the department to process. This is largely due to the size of the attachment to the report and the number of third parties the department would need to consult.
If you were to revise your FOI request to exclude the attachment to the report then this may help us to process the request....
18 July 2020: we try again
Dear FOI Team, In response to your advice (LEX-4467-24AA) that our current FOI request will be refused unless revised, VALE has revised the request, scaling it back to the bare miminum (see attached)....
Dear FOI Team, In response to your advice (LEX-4467-24AA) that our current FOI request will be refused unless revised, VALE has revised the request, scaling it back to the bare miminum (see attached)....
| foi_vale_revised_2020.07.18.pdf |
16 July 2020: Advised request too large again
| lex-4467_-_24aa_notice.pdf |
29 June 2020: FOI request resubmitted by VALE removing one voyage
| vale_foi_request_29.06.20.pdf |
18 June 2020: FOI request refused after revision
| lex-4226_-_decision_-_signed.pdf |
29 May 2020: refusal with offer for a scaled request:
| lex-4226_consultation_notice.pdf |
18 May 2020: requested two voyages with IO reports that appeared to have Dept sanitisation
| foi_two_voyages_vale_may_2020.pdf |
17 June 2020: VALE follows up request and get a response re Al Kuwait exemption voyage:
VALE has not received your reply despite the assurance below. It may interest you that despite the intense spotlight and public interest, there were certainly sheep on the trucks going to Fremantle Port yesterday that had wool length >20mm (http://www.vale.org.au/blog/good-to-see-conditions-being-observed).
In addition to observing sheep with >20mm wool length, I observed the excellent body condition of the majority of the sheep. Prolonged feedlotting is likely to reduce inanition/salmonellosis but the flipside is that A class wethers are often the highest risk sheep during a heat stress event due to their fat cover.
The combination of greater wool length than the original shipment due to 2 week loading delay (ie wool continues to grow so this would be abnormally long for any routine shipment at loading), sheep with >20mm wool length, A class wethers and a Govt acknowledged high risk time of year makes it imperative that VALE’s request for an independent observer and publicly available CCTV footage is granted.
VALE has not received your reply despite the assurance below. It may interest you that despite the intense spotlight and public interest, there were certainly sheep on the trucks going to Fremantle Port yesterday that had wool length >20mm (http://www.vale.org.au/blog/good-to-see-conditions-being-observed).
In addition to observing sheep with >20mm wool length, I observed the excellent body condition of the majority of the sheep. Prolonged feedlotting is likely to reduce inanition/salmonellosis but the flipside is that A class wethers are often the highest risk sheep during a heat stress event due to their fat cover.
The combination of greater wool length than the original shipment due to 2 week loading delay (ie wool continues to grow so this would be abnormally long for any routine shipment at loading), sheep with >20mm wool length, A class wethers and a Govt acknowledged high risk time of year makes it imperative that VALE’s request for an independent observer and publicly available CCTV footage is granted.
| letter_from_deputy_secretary_david_hazlehurst.pdf |
13 June 2020: VALE requests Dept apply conditions to their Al Kuwait decision
| vale_letter_to_dept_secretary_13_june_2020.pdf |
5 March 2020: Dept replies taking umbrage at the suggestion of IO report sanitisation!
Thank you for your email. We are aware of the issues with the vessels as identified by the independent observers, and work closely with AMSA on matters that cross over into their responsibilities. The department is analysing the information obtained through IO reports, as you suggest. I would note that I don't agree with your characterisation that IO reports are sanitised.
The department is continuing to work on the IO program, including consistency of information capture and reporting, with temperature recording and reporting being an example of one area of focus. Thank you for your suggested approach to managing issues such as ventilation, hot spots and drainage - there are a number of ways we follow up on these issues; directly with specific exporters, generally with all exporters and with AMSA and vessel operators. There are multiple ways some of these issues can be addressed, and the department follows up with targeted observations to review any strategies put in place.
As I mentioned, we continue to work on both the program and our reporting on the program, and will continue to utilise the information gained from IO observations in policy review and development of standards for the regulation of the industry.
Thank you for your email. We are aware of the issues with the vessels as identified by the independent observers, and work closely with AMSA on matters that cross over into their responsibilities. The department is analysing the information obtained through IO reports, as you suggest. I would note that I don't agree with your characterisation that IO reports are sanitised.
The department is continuing to work on the IO program, including consistency of information capture and reporting, with temperature recording and reporting being an example of one area of focus. Thank you for your suggested approach to managing issues such as ventilation, hot spots and drainage - there are a number of ways we follow up on these issues; directly with specific exporters, generally with all exporters and with AMSA and vessel operators. There are multiple ways some of these issues can be addressed, and the department follows up with targeted observations to review any strategies put in place.
As I mentioned, we continue to work on both the program and our reporting on the program, and will continue to utilise the information gained from IO observations in policy review and development of standards for the regulation of the industry.
4 March 2020: VALE raises concerns about repetitive issues on voyages
Analysing the Independent Observer (IO) reports closely, it is very obvious that particular vessels, or particular areas in certain vessels have issues that are noted repetitively. For example, MV Yangtze Fortune has had repeated reports of water infrastructure issues such as clip on domestic hose fittings dislodging or breaking with leaks, flooding and lack of water delivery in addition to troughs being easily displaced due to shape with the issue resulting in food and/or water deprivation and spillage. MV Ocean Drover has some drainage issues and has had these historically also. MV Gloucester Express has had exhaust fumes noted in some areas. MV Al Shuwaikh has significant heat issues in selected parts of the vessel as do many other vessels, usually in the areas closest to the engine room (eg Decks 4 and 5 on MV Greyman Express and Deck 4 on the MV Rahmeh (renamed Gulf LIvestock 1)). In addition, other management issues sometimes get reported repeatedly eg pilot sheep on the MV Maysora reported on a number of occasions to be deprived of food and water.
VALE could compile a list of these repetitive issues from the IO reports 2018 and 2019 but as you know, the IO reports available in the public domain are summarised, sanitised and variable in quality and quantity of data provided (eg even basic information such as maximum and minimum dry bulb temperature (DBT) are not routinely provided and maximum wet bulb temperature rarely; 11/35 available IO summaries for voyages to China have no maximum DBT or humidity provided and 21/35 have no minimum DBT provided - an issue for northern winter Chine voyages). Any compilation we did would thus be incomplete and would fail to capture all available data. The Dept is far better placed to accurately analyse which decks or pens are an issue for each ship and also which ships are repetitively problematic. The fact that some stand out even on the scarce data available eg the MV Yangtze Fortune is concerning and we believe all IO reports (original reports and summaries) from this vessel should be immediately analysed and forwarded to AMSA for assessment.
Until such time as a full audit is available, could we suggest that load plans are altered to avoid placing animals in any IO-documented areas of increased heat and humidity, poor ventilation or poor drainage for each vessel? This information should also be included as part of the routine HSRA and load planning for each vessel.
Analysing the Independent Observer (IO) reports closely, it is very obvious that particular vessels, or particular areas in certain vessels have issues that are noted repetitively. For example, MV Yangtze Fortune has had repeated reports of water infrastructure issues such as clip on domestic hose fittings dislodging or breaking with leaks, flooding and lack of water delivery in addition to troughs being easily displaced due to shape with the issue resulting in food and/or water deprivation and spillage. MV Ocean Drover has some drainage issues and has had these historically also. MV Gloucester Express has had exhaust fumes noted in some areas. MV Al Shuwaikh has significant heat issues in selected parts of the vessel as do many other vessels, usually in the areas closest to the engine room (eg Decks 4 and 5 on MV Greyman Express and Deck 4 on the MV Rahmeh (renamed Gulf LIvestock 1)). In addition, other management issues sometimes get reported repeatedly eg pilot sheep on the MV Maysora reported on a number of occasions to be deprived of food and water.
VALE could compile a list of these repetitive issues from the IO reports 2018 and 2019 but as you know, the IO reports available in the public domain are summarised, sanitised and variable in quality and quantity of data provided (eg even basic information such as maximum and minimum dry bulb temperature (DBT) are not routinely provided and maximum wet bulb temperature rarely; 11/35 available IO summaries for voyages to China have no maximum DBT or humidity provided and 21/35 have no minimum DBT provided - an issue for northern winter Chine voyages). Any compilation we did would thus be incomplete and would fail to capture all available data. The Dept is far better placed to accurately analyse which decks or pens are an issue for each ship and also which ships are repetitively problematic. The fact that some stand out even on the scarce data available eg the MV Yangtze Fortune is concerning and we believe all IO reports (original reports and summaries) from this vessel should be immediately analysed and forwarded to AMSA for assessment.
Until such time as a full audit is available, could we suggest that load plans are altered to avoid placing animals in any IO-documented areas of increased heat and humidity, poor ventilation or poor drainage for each vessel? This information should also be included as part of the routine HSRA and load planning for each vessel.
23 August 2018: VALE's offer to government rejected.
| hon_littleproud_to_vale.pdf |
11 April 2018: Letter to Minister David Littleproud re our offer of scientific veterinary assistance.
| vale_hon_d_littleproud_18.4.11.pdf |
3 April 2018: Letter to CVO Mark Schipp re Department heat stress thresholds not being supported by scientific and field data.
| vale_to_dr_mark_schipp.pdf |
5 February 2018: Letter to Mark Schipp re incorrect figures in high mortality voyage report. The investigation report was re-written to reflect correct figures but the figures were not changed in the Parliamentary report. Also below is the letter from Narelle Clegg that prompted our response.
|
| ||||
7 February 2018: More FOI docs obtained after querying their withholding.
|
| ||||
6 December 2017: Letter to the department seeking review of the decision to withhold two crucial reports under FOI.
| vale_foi_december_2017.pdf |
23 November 2017: Response from the department re FOI request.
| foi_access_decision.pdf |
23 October2017: Letter to Mark Schipp (DAFF) highlighting concerns about discrepancies in high mortality voyage report.
| 20171023_vale_letter_to_dr_mark_schipp.pdf |
Freedom of Information request regarding the July 2016 voyage of Emanuel Exports Pty Ltd with 4.35% sheep mortality (3027 deaths).
| 20170517_foi_request_high_mortality_voyage_.pdf |
14 August 2014: Letter to DAFF and analysis of information in the public domain re High Mortality Voyage 46 (MV Bader III) in September 2013
| 140814_letter_to_dr_mark_schipp.pdf |
| vale_analysis_of_voyage_46_14.8.13.pdf |
Response from DAFF
| 140814_response_to_vale_letter_of_14_aug_14.pdf |
14 December 2014: Follow-up letter to Dr Schipp with Addendum to initial analysis
| 141214_letter_to_dr_mark_schipp_14_december_2014.pdf |
| 141214_vale_addendum_voyage.pdf |
Subsequent email trail between VALE and Dr Schipp
Summary: no response despite two requests; still nothing as at 14 April 2015
Summary: no response despite two requests; still nothing as at 14 April 2015
| email_trail_to_mark_schipp.pdf |
12 May 2015: Response from Dr Schipp
| 150512_response_from_dr_schipp.pdf |
13 December 2013: Letter to DAFF requesting a "show cause notice" after LSS breaches. Still no response.
| 131213_paul_grimes.pdf |
24 December 2014: Letter from Phillip Glyde on behalf of Dr Grimes
| 131224_glyde_letter_to_vale.pdf |
Minster for Agriculture acknowledges that he is aware of the evidence presented in a Federal Court to demonstrate routine overstocking on LE voyages.
22 January 2014: House of Representatives question for the Minister for Agriculture
| 140122_questions_to_mr_joyce.pdf |
A sequence of letters and correspondence to and from DAFF regarding the substitution of vets for accredited stockpersons on live export voyages and contravention of ASEL requirements for such. It's taken 12 months to get the admission that it happens – now to see why the exporters weren't penalised for breaking the law.
(Reverse chronological order)
(Reverse chronological order)
16 April 2014
From: Tim Naylor
Re: Further questions re lack of accredited stockperson, Port Kembla to Madagascar voyage
Possibly qualifies as a response ... though a blank piece of paper would serve equally well.
From: Tim Naylor
Re: Further questions re lack of accredited stockperson, Port Kembla to Madagascar voyage
Possibly qualifies as a response ... though a blank piece of paper would serve equally well.
| 140416_daff_response.png |
17 March 2014
To: Jenny Cupit
Re: Further questions re lack of accredited stockperson, Port Kembla to Madagascar voyages
To: Jenny Cupit
Re: Further questions re lack of accredited stockperson, Port Kembla to Madagascar voyages
| 140317_stockperson_substitution.pdf |
3 March 2014
From: Jenny Cupit (DAFF)
Re: Further questions: Port Kembla to Madagascar voyage
DAFF explain their penalties are "outcome based" ie no penalty applied for breaking the law if no adverse outcome. Interesting. Would like to try that argument on a random breath test: "Yes officer Im drunk but I never caused a crash so you cant prosecute"!!!! And anyhow, when has a high mortality voyage NOT been an adverse outcome?
From: Jenny Cupit (DAFF)
Re: Further questions: Port Kembla to Madagascar voyage
DAFF explain their penalties are "outcome based" ie no penalty applied for breaking the law if no adverse outcome. Interesting. Would like to try that argument on a random breath test: "Yes officer Im drunk but I never caused a crash so you cant prosecute"!!!! And anyhow, when has a high mortality voyage NOT been an adverse outcome?
| 140303_stockperson_substitution.pdf |
1 February 2014
To: Rebecca Irwin (DAFF)
Re: Further questions: Port Kembla to Madagascar voyage
DAFF's misinformation about their licensing of the relevant exporter is pointed out and based on this, DAFF asked to explain the lack of penalties
To: Rebecca Irwin (DAFF)
Re: Further questions: Port Kembla to Madagascar voyage
DAFF's misinformation about their licensing of the relevant exporter is pointed out and based on this, DAFF asked to explain the lack of penalties
| 140201_stockperson_substitution.pdf |
12 December 2013
To: VALE
From: Rebecca Irwin (DAFF)
An admission from DAFF that there had been voyages without stockpersons with reasons as to why no penalties applied: exporter no longer holds a licence (WRONG).
Still no answer to our original question though!
To: VALE
From: Rebecca Irwin (DAFF)
An admission from DAFF that there had been voyages without stockpersons with reasons as to why no penalties applied: exporter no longer holds a licence (WRONG).
Still no answer to our original question though!
| 131212_stockperson_substitution.pdf |
24 April 2013
To: Jonathan Benyei (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
We ask again “How many occasions have exporters been allowed by your
department to waive the requirement for a stockperson to be on board a live
export ship, and on what legal basis has that waiver has been granted?”
We provide examples of suspected or known voyages that proceeded without a stockperson as requested by DAFF.
To: Jonathan Benyei (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
We ask again “How many occasions have exporters been allowed by your
department to waive the requirement for a stockperson to be on board a live
export ship, and on what legal basis has that waiver has been granted?”
We provide examples of suspected or known voyages that proceeded without a stockperson as requested by DAFF.
| 130424_third_vale_letter.pdf |
28 March 2013
To: VALE
From: Jonathan Benyei (DAFF)
To: VALE
From: Jonathan Benyei (DAFF)
| 130328_second_daff_response.pdf |
5 February 2013
To: Rebecca Irwin (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
To: Rebecca Irwin (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
| 130205_second_vale_letter.pdf |
5 February 2013
To: VALE
From: Rebecca Irwin (DAFF)
To: VALE
From: Rebecca Irwin (DAFF)
| 130205_first_daff_response.pdf |
5 December 2012
To: Rebecca Irwin (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
To: Rebecca Irwin (DAFF)
Re: Substitution of vets for accredited stockpersons on live export voyages
| 121205_stockperson_substitution.pdf |
Questions on ASEL breaches: more unanswered correspondence
6 March 2013
To: Rebecca Irwin
Re: Dr Lynn Simpson's submission to DAFF
NOTE: this is not in chronological order as the Substitution of Vets correspondence (preceding and post-dating this request) was collated together
To: Rebecca Irwin
Re: Dr Lynn Simpson's submission to DAFF
NOTE: this is not in chronological order as the Substitution of Vets correspondence (preceding and post-dating this request) was collated together
| 130306_dr_lynn_simpson_submission.pdf |
