Inspector-General of Animal Welfare and Live Animal Exports

1. That the department develop a data quality and management strategy that:
   1. adopts the Australian Government’s quantitative data standards
   2. includes actions to develop detailed guidance and training resources for all qualitative data to reduce subjectivity
   3. uses co-design to develop electronic report formats that increase standardisation and support data upload for analysis
   4. supports clear, accurate and efficient reporting

• This recommendation remains open although the department has made significant steps to improve data quality and management.
• Guidance and Training: Co-designed training and guidance materials were developed, including developing Rejection Criteria Guidebooks with input from departmental and industry veterinarians and providing support for LiveCorp’s animal welfare indicators training.
• Electronic Reporting: Electronic report formats were co-designed to enhance standardisation. The department worked with LiveCorp to ensure LIVEXCollect aligns with ASEL reporting requirements, and developed digital tools for independent observers to capture voyage data and evidentiary media.
• Data Access and Integration: A centralised database was created to integrate multiple data sources for end-to-end supply chain visibility. Power BI was adopted to improve data visualisation and support decision-making.
• Given the substantial progress made, the department intends to close this recommendation.

2. That the department work with the Australian Maritime Safety Authority to require all vessels used in the live export trade to install automated:
   1. CCTV cameras to record representative pens on all decks and any pens that have been identified as problematic
   2. Wet and dry bulb temperature monitors at representative lockers on each deck and on the bridge
   3. Data loggers that can provide monitored data to those onboard in real time and that retain data records in a verifiable form for compliance purpose.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• The department has completed the following activities:
  • Mandated the use of automated wet bulb temperature data loggers on sheep voyages during the northern summer prohibition shoulder period
  • Conducted a CCTV trial and found the technology was currently not feasible to monitor compliance with ASEL.
  • To address technology gaps conducted a Business Research and Innovation Initiative technology challenge for remote automated monitoring of export livestock health and welfare
• As the department has addressed the components within its remit, the department intends to close this recommendation.

3. That the department increase the resourcing and capability of the Technical Analysis Team in both statistical analytical expertise and epidemiological expertise. This analytical capability should include expertise in identifying other areas of risk such as participant behaviour, drivers and asset performance (for example, vessels, decks and pens).

• An additional officer was recruited in 2021 with appropriate expertise.

4. That the department reframe approved arrangement for exporters to:
   1. Deliver the benefits of streamlined documentation and approval processes
   2. Incorporate characteristics and indicators of dynamic risk management as a requirement of exporters operating under their approved arrangements
   3. Ensure that demonstrating dynamic risk management by an exporter is an enforceable requirement
   4. Design and undertake unannounced and targeted regulatory projects aimed at detecting poor dynamic risk management.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• The department has completed an approved arrangement review, conducted a full consignment audit trial and a random document assessment trial to identify risks and areas of improvement for the approved arrangement framework.
• The department has assigned a low risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• The department is evaluating whether further activity is required to satisfy this recommendation, ahead of evaluating whether this recommendation can be closed.

5. That Independent Observers be deployed as part of a risk-based compliance monitoring program that includes:
   1. targeting of industry participants based on analysis, intelligence and the nature of voyages (with an element of random targeting)
   2. a proportion of Independent Observer deployment occur as part of integrated audit and inspection projects.

• This recommendation remains open as the department undertakes a dedicated consultation process to determine the policy settings for a revised independent observer deployment policy and the appropriate form of implementation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• The department is working to finalise the policy and proceed to close the recommendation following a detailed consultation process with industry.

6. That Independent Observer summary reports be published within a service-level commitment period after the conclusion of a voyage. Any matters under further investigation should be noted. Details of matters under investigation may be excluded, as appropriate, until the department’s course of action is determined. Once this is determined, the published report should be updated to explain the issue and the department’s response.

• The department now publishes Independent Observer summary reports quarterly.

7. That the department consider whether cost recovery of the Independent Observer program should be incorporated into the general cost of regulation.

• Cost recovery of the Independent Observer program was incorporated in the CRIS framework released in 2021.

8. That the department work with Live Corp and industry to update training for stockpersons, particularly in relation to monitoring and reporting. The department should consider the utility of establishing a stockperson network.

• The department worked with LiveCorp and industry to update stockpersons training including assisting the review of the LiveCorp Shipboard Stockperson Training Course and conducting industry education sessions on the Australian Standards for the Export of Livestock (ASEL) version 3.

9. That Australian Government accredited veterinarian (AAV) training, monitoring and reporting obligations be updated and clarified with improved guidance, support material and advice.

• In February 2022, an updated AAV training package was published on the Animal Health Australia website. Additional guidance material, training and engagement on obligations were provided, including ASEL guidebooks, regular teleconferences with the AAV forum and improved webpages.

10. That Australian accredited veterinarians are accessed as a professional group to contribute to industry co-design of relevant monitoring and reporting standards and formats.

• The department actively engages with the AAV Working Group.

11. That the department support Australian Government accredited veterinarian forums, in addition to debriefing individual veterinarians after voyages, that allow the exchange of information, knowledge and experience of effective approaches to managing onboard risks between veterinarians and the department.

• The department continues to hold regular teleconferences with the AAV Working Group as the primary forum to exchange information between AAVs and the department. The department also provides advice to AAVs on request.

12. That the department develop a risk-based compliance monitoring program for Australian Government accredited veterinarians, including a firm approach to escalating sanctions, to support good performance and a level playing field.

• The department has delivered numerous enhancements to the regulation of AAVs including delivering a conflict-of-interest policy, ongoing audit program, and a welcome pack to be provided to newly accredited veterinarians.

1. The department should change from a 3-year review of the Australian Standards for the Export of Livestock to an annual update of the standards. The review should address emerging issues and advances in scientific knowledge and technology associated with improved animal welfare outcomes.

• The department is committed to reviewing ASEL regularly and consulting with subject matter experts, including industry, to ensure latest developments are considered and changes are fit-for-purpose.

2. The department should ensure that the investment in improved IT infrastructure announced in the 2020–21 budget:
   1. delivers improved regulatory operations and knowledge on animal health and welfare through effective use of data and information analysis
   2. enables disparate parts of the department to work more effectively through real-time access to all relevant records, policy, guidance and procedures
   3. reduces delays and duplication for industry through streamlined application processes, decisions and reporting.

• The department has invested in foundational IT infrastructure. As resourcing permits, this will allow specific solutions for live animal exports to be built upon over time.

3. The department should ensure it has detailed business process maps for all live animal export regulatory processes to support improved regulatory effectiveness and efficiency, and to inform optimal IT investment in the systems that support these processes.

• A catalogue of business process maps was compiled in 2021.

4. That the department address the challenge that dispersed regulatory functions pose to improved regulatory practice. This could include:
   1. accelerating the expansion of the role of the Principal Regulatory Officer consistent with its original intent
   2. secondments and placements of staff from relevant functional regulatory areas into the Plant and Live Animal Exports Division
   3. instituting cross-functional multidisciplinary projects at strategic and operational levels as a business-as-usual approach to compliance monitoring.

• Many improvements have been made across the department as a whole and specifically in livestock export regulation.

1. In delivering the Australian Government’s Busting Congestion, Deregulation and Modernising Agricultural Trade budget reforms, the department should improve its business-facing systems and digitised services to streamline the efficiency of industry interactions and decision-making. These systems should:
   1. facilitate efficient submission of applications
   2. assist with the quality of applications, including facilitating compliance
   3. support efficient decision-making and access to information for departmental officers.

• The department has implemented a range of improvements to its business-facing systems and digitised services for livestock exporters. These included enhancements to the Tracking Animal Certification for Export (TRACE) system such as enhanced system usability, automated advice on documentation requirements, and automatic verification of information.
• Given the substantial updates made to the technical system supporting livestock exports that addresses the intent of this recommendation and the continuing investment in this digital system, the department intends to close this recommendation.

2. The department should update the Exporter Supply Chain Assurance System (ESCAS) animal welfare standards (Export Advisory Notice 2018–01) to be consistent with the World Organisation for Animal Health (OIE) Terrestrial Animal Health Code 2019.

• The department agreed in principle to this recommendation and noted that it would review the current ESCAS animal welfare standards (which are listed in Export Advisory Notice 2018-01) against the World Organisation for Animal Health code.
• The department has assigned a medium risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.

3. The department should use a risk-based approach to requiring the use of a visual recording devices and fixed radiofrequency identification (RFID) tag scanning in markets, or for specific exporters, where loss of control and traceability is a systemic problem.

• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

4. The department should undertake, and publish, a review of available technologies for accurate sheep and goat counting, and individual identification. The department should also undertake a cost-benefit analysis of requiring the use of improved counting and individual identification technology for sheep and goat exports. Depending on the outcome from the technology review, the department should consider requiring all sheep and goat exporters to utilise improved technology, or consider imposing this requirement on markets, or individual exporters, where counting inaccuracy and loss of control and traceability is systemic.

• This recommendation remains open due to the department undertaking dedicated consultation, research and analysis processes to determine the details and policy settings needed.
• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.

5. The department should monitor the performance of independent auditors and consider not accepting reports from auditors who do not detect issues that may have contributed to non-compliance or who provide poor quality audits.

• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

6. The department should change the required self-reporting period from 5 days to 'as soon as is practicable'.

• The department changed the relevant clause in approval instruments to state as soon as possible and not more than five working days of becoming aware or receiving information.

7. The department should report the range of detected non-compliance and the range and number of sanctions or other regulatory responses that resulted from the non-compliance. The department should record non-compliance to examine the performance of individual exporters over time and analyse and understand issues within each market.

• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

8. The department should review and update the Biosecurity guideline for management of non-compliance to incorporate the appropriate use of a proportionate response regulatory model that utilises the full range of sanctions and powers available under the Export Control Act 2020. The department should apply an escalating proportionate regulatory response model to improve compliance of exporters who continue to breach ESCAS.

• The department is undertaking its review of the ESCAS animal welfare standards as part of its broader ESCAS Review, at which point the department would seek to progress closing this recommendation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

1. The department should replace the TRACE system with a modern IT system that supports:
   1. streamlined application processes with automated verification of pre-existing approvals
   2. single point of truth for an applicant's documentation, decision and compliance history (for both applicants and departmental officers).

• The department has implemented a range of improvements to the TRACE system such as enhanced system usability, automated advice on documentation requirements, and automatic verification of information.
• In addition, exporters will shortly access TRACE via the department’s Export Service which will help them manage their agricultural export requirements in one place.
• The department is intending to close this recommendation based on the progress made against the recommendation to-date and on the basis that the activity is not currently supported by a funding measure or specifically provisioned within the industry Cost Recovery Impact Statement.

2. The department should streamline the notice of intention to export (NOI) assessment and decision-making process by:
   1. implementing a risk-based NOI assessment process to redirect its resources to higher risk consignments and provide faster decisions for lower risk consignments
   2. publishing updated policy guidelines that define thresholds that trigger the need for a variation to the NOI application to be submitted.

Point 1: Agreed

Point 2: Agreed in principle

• This recommendation remains open as the department considers the feasibility of implementation work in the light of benefits and resource requirements.
• The department has implemented a risk-based NOI assessment reducing the time for assessment actioning the first part of the recommendation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

3. The department should consider a single integrated application process to include notice of intention to export, export permits and health certificates.

• The department has improved the NOI assessment process and enhanced TRACE including improving usability and automating verification of information. The NOI assessment improvements reduced the average cost per NOI.

4. The department should review the Performance management and compliance guidelines – approved arrangements for livestock exporters, including the livestock export consignment reports ratings, the way in which audits are utilised, and how this relates to performance levels, and the utility of performance levels.

• This recommendation remains open due to the department requiring other activities to be progressed such as the randomised document assessment framework implementation and projects to digitally capture processes and assessments, are being progressed. The review and amendment of identified areas, including performance levels, of the guideline is dependent on these projects.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meetings its core regulatory responsibilities.

5. The department should implement a risk-targeted multidisciplinary audit process that is conducted during the notice of intention to export application and export permit inspection process (consistent with the Inspector General’s recommendation 4(d) of the review Monitoring and reporting during livestock export voyages, and Moss Review recommendation 7).

• The department completed a full consignment inspections pilot program in 2023. Findings have informed verification and assurance activities including the randomised document assessment trial which underpins the implementation of recommendation 4 of this report.
• Approval to close this recommendation is now being sought, based on the progress made against the recommendation.

6. The department should trial the use of body cameras for regional veterinary officers and auditors for use during inspections and onsite audits.

• This recommendation remains open due to legislative and administrative challenges preventing the practical implementation of this recommendation.
• The department will be further evaluating as to whether to close the recommendation on the basis that the activity is not able to be supported by legislation.

7. The department should continue to use its discretion in relation to the Fremantle model provided:
   1. that where a registered establishment is physically unable to fully comply with ASEL the occupier agrees to develop and submit a program of works that would enable the registered establishment to fully comply, and a schedule and time frame for implementation of those works
   2. if the works and the time frame are accepted by the department as being reasonably practicable, the department consider an enforceable undertaking to ensure that the works progress over the agreed time frame so that the exporters and registered establishments can be progressively brought into full compliance.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• Amendments to registered establishment (RE) ASEL requirements (commenced in 2024) allow for greater flexibility regarding timing of marking and removal of rejected livestock, balancing the best animal health and welfare outcomes with the management practices and infrastructure constraints at some registered establishments. This now means strategies other than a program of works as described may also be used.
• Approval to close this recommendation is now being sought, based on the progress made against the recommendation.

1. The department should conduct a holistic risk analysis of the livestock export framework to identify risks, and the critical control points for these risks in the department’s business processes. Once identified the department should examine the effectiveness of the controls in place and undertake treatments to address any shortcomings.

• This recommendation remains open as it considers a consultancy report it commissioned to review the department’s workflow processes and identify potential improvements. The department continues to assess the current regulatory framework and relevant steps to develop and implement changes.
• The department has assigned a low risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

2. The department should prescribe a range of documents that are currently part of approved arrangements such as standard export plans, approved export programs, vendor, spay and pregnancy declarations, health declarations, and elements of management plans.

• This recommendation remains open due to the department undertaking with industry a dedicated development process to determine the policy and most appropriate form of implementation of prescribed standard export plans and approved export programs.
• The department has assigned a low risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

3. The department should change the approach to livestock export approved arrangements to one that is more aligned to the approach taken with meat export approved arrangements. This includes reviewing the performance indicators to improve clarity and including performance tests and targets that are directly linked to legislation and standards.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• Departmental staff from meat exports and live animal exports (LAE) met in 2022 to identify opportunities for improving LAE approved arrangements. Opportunities for learning from their model have been recorded and are being considered in reform activities, including the review of the LAE performance and compliance framework.
• The department has assigned a low risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

4. The department should develop options to provide a more accessible regulatory powers and sanctions regime, linked to clear and enforceable requirements in export licences and approved arrangements. If there are options that are within the power of the secretary, they should be implemented. If there are options that require legislative change, these should be provided to the minister for consideration.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• A Regulatory Practice Statement was adopted in 2023 by the department, which forms part of the department’s regulatory practice framework.
• The department also released its formal Compliance Policy in 2023.
• The Regulatory Assurance Strategy was released in December 2024, to improve decision making, increase confidence to stakeholders, improve regulatory maturity and demonstrate a proportionate and adaptive approach to the level of risk.
• Given the substantial progress made, the department intends to close this recommendation.

1. The department should increase meetings or workshops with stakeholders to ensure that those who are time constrained from providing formal submissions can be heard. This should target stakeholder segments to ensure that regional differences are identified, and so that stakeholders with widely disparate positions are heard separately.

• This recommendation remains open as the department considers the feasibility of implementation in the light of benefits and resource requirements.
• The department has assigned a low risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• The department is evaluating the structure and purpose of the committees with industry, with a view to making changes soon.

2. When the department undertakes a formal consultation process the subsequent decision should include a ‘response to submissions’ to inform stakeholders who made submissions of how their concerns were considered.

• This recommendation remains open as the department considers the feasibility of implementation in the light of benefits and resource requirements.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• The department has several consultation processes underway and will look to fulfill this recommendation at their conclusion.

3. The department should develop an annual regulatory activity report and publish it on its website.

• The department generates 6-monthly reports for the Australian Parliament, and summaries are published on the department’s website.
• A new annual regulatory activity webpage has been published that provides reporting against annual regulatory actions taken. The webpage will be updated annually.

4. The department should reformat summary independent observer reports to become outcome reports. The reports need to include all non-compliance against ASEL, observed and verified mortalities, exporter mitigating actions and departmental regulatory actions.

• The department undertook a legislative amendment process to allow publication of full summaries. This is now completed. The Voyage Management team are actively considering appropriate changes for development and implementation.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• Given the amendments to the summary report, the department intends to close this recommendation.

5. The department should be consistent in its reports with naming of entities, scheduling publication, and inclusion of non-compliance and regulatory action taken information. In this regard, the department should consider whether integration and rationalisation of reporting would be beneficial to make information more easily accessible to stakeholders.

• The department has considered the feasibility of mandating consistency across its reports. Where legislatively possible, alignment has been implemented. However, some obligations including Parliamentary obligations in reporting structure and timing has meant full consistency is not feasible.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.
• Given the progress against the intent of this recommendation and action to date, the department intends to close this recommendation.

6. The department develop and publish a service level commitment for the provision of IO observational data to exporters, and for the publication of all of its live animal export reports.

• The department is now publishing quarterly IO summary reports that were finalised in the previous quarter.
• The department is considering closing this recommendation based on the progress made against the recommendation.

1. The department should reinstate the biannual meetings for the senior executives to review the status of Inspector General recommendations. Updates from these meetings should be provided to the Inspector General.

• The department has re-introduced a governance forum to discuss and monitor the status of recommendations.

2. The department should create implementation plans for all open and future Inspector General recommendations. Implementation plans should include an evaluation plan.

• This recommendation remains open although the department has finalised implementation plans for all recommendations agreed to in 2024. Implementation plans are being developed for recommendations as closure processes progress.
• The department has assigned a low-risk rating to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

3. The Inspector General recommends that the department commit to a shorter timeframe for implementing all inspector general recommendations.

• The department is committed to the implementation of agreed recommendations as soon as practicable, and in accordance with assessment with assessment of risk.
• The department has assigned a low-risk rating to its response to this recommendation remaining open due to it not directly inhibiting the department meeting its core regulatory responsibilities.

4. The department should publicly report on progress in implementing Inspector General recommendations and provide a summary of reasons to support closed recommendations.

• This webpage reporting is the department’s response to this recommendation.
• This webpage will be updated regularly with progress against each recommendation.

1. The department should implement its revised deployment policy to enable it to enforce the deployment of at least one independent observer per exporter per year regardless of their risk status.

• This recommendation remains open as the department undertakes a dedicated consultation, development and analysis process to determine the policy settings and appropriate implementation of the revised policy.
• The department has assigned a medium-risk rating to the matters raised by this recommendation due to the department able to prescribe additional reporting requirements in lieu of deployments.

2. The department should develop an ongoing evaluation program to assess whether the IO program is achieving its objectives.

• This recommendation remains open as the department undertakes a dedicated consultation, development and analysis process to determine the policy settings and appropriate implementation of the revised policy.
• The department has assigned a medium-risk rating to the matters raised by this recommendation due to the department able to prescribe additional reporting requirements in lieu of deployments.

3. As a high priority, the department should clearly define the measurements and parameters used to assess animal health and welfare with the intention of providing a basis to test the capability of modern technologies to supplement existing regulatory tools for livestock voyages.

• This recommendation remains open although the department has made significant steps to address this recommendation.
• The department has adopted the use of technology to assist in providing regulatory assurance. This includes requiring the deployment of data loggers on sheep export voyages and the use of the LIVEXCollect reporting system. LIVEXCollect includes a range of specific animal welfare indicators.
• The department supported the external project “Smart technology delivering animal welfare and supply chain efficiency, for remote automated monitoring of export livestock health and welfare”.
• The investment and installation of technology on-board livestock vessels is a commercial matter.
• Given the substantial progress made, the department intends to close this recommendation.