Independent observers

Independent observer deployment policy (revised)

We have published a revised Independent observer deployment policy. It takes effect from 1 July 2026. Until then, the observer deployment information on this page continues to apply.

If you have difficulty accessing this file, contact us for help.

 

Overview

Observers play an assurance role within our regulatory system. They monitor, review and/or audit exporter arrangements on-board livestock export vessels.

Their focus is to verify and report on the:

  • implementation of individual exporter arrangements. This includes its approved arrangement (AA) and approved export program.
  • activities undertaken by the on-board accredited veterinarian (AAV) or accredited stockperson.
  • exporters effectiveness at managing animal health and welfare. This includes meeting the Australian Standards for the Export of Livestock (ASEL).

Observers do not take an active role in animal management during the voyage.

Further information on the roles and responsibilities of exporters, AAVs, accredited stockpersons, master of the vessel and observer can be found on the accredited veterinarians page.

We deploy observers in accordance with our regulatory framework.

We also publish recent independent observer reports.

Independent observer program objectives 

In response to the Inspector-General of Animal Welfare and Live Animal Exports’ review of the Independent Observer program, we have published the program objectives below:

  • To provide the department with independent data collection and reporting relevant to the management of animal health and welfare during livestock export voyages to support effective regulation of the live animal export industry. 
  • To assess exporters’ compliance with ASEL and relevant federal legislation, through verifying and reporting on the implementation and effectiveness of individual exporter systems, including their approved arrangements (AA), approved export programs (AEP) and management plans.
  • To provide assurance and transparency to the government, department, industry and the broader community regarding the health and welfare of live animals on export vessels. 
  • To verify and report on the activities undertaken by the on-board AAV or accredited stockperson.
  • To support exporters to take corrective action during and following a voyage, based on independent observer observations.

Information for exporters

You should prepare for an observer to accompany a voyage when:

  • the voyage departs from ports south of latitude 26 degrees south and crossing the equator.
  • it is the first voyage undertaken by you following a notifiable mortality incident.
  • it is the first voyage of any new exporter or vessel.
  • the voyage is considered a long-haul voyage with any complex arrangements. This includes those with multiple ports of discharge, carrying buffalo or enacting management plans (e.g. heavy cattle).

We will take steps to deploy an observer where a voyage meets a criterion.

We may also direct an observer to accompany other voyages. We will notify you if we require this.

Extenuating circumstances

If there are extenuating circumstances that may prevent an observer accompanying a particular consignment, you must provide us with sufficient evidence for the delegate to decide it is appropriate to deviate from the deployment policy.

  • You need to tell us what actions you have taken to prepare for an observer, including discussions with shipping companies/vessel operators about accommodating the observer on the vessel.
  • You must provide supporting evidence that there are extenuating circumstances and a statutory declaration that the supporting evidence is true and accurate to the best of your knowledge.
  • Depending on the circumstances, supporting evidence may include but is not limited to:
    • Original advice from the vessel operator regarding crew numbers and accommodation spaces onboard the vessel.
    • Detailed reasoning for multiple reef pilots.
    • Recent vessel refurbishments that alter the number of accommodation spaces.
    • Crew contract periods.

If you vary a notice of intention (NOI) in a way that impacts an observer being deployed, or creates extenuating circumstances that may prevent an observer being accommodated, you must contact us at least 10 business days before departure.

Email IO.Reporting@aff.gov.au.

If we require an observer to accompany a vessel, export and vessel operations continue as normal. AAVs and Accredited Stockpersons should perform their normal duties.

Observers do not take an active role in animal management during the voyage.

AAVs or accredited stockpersons submit daily reports under ASEL. They provide detail on health and welfare issues during the voyage. You should take timely and appropriate action in response to issues identified in these reports. Do not wait for observer reports, or the publication of summary observer reports, to act.

There are fees and travel costs for having an observer accompany a vessel.

If a vessel has multiple exporters and consignments we will:

  • base fees on the number of head exported by each exporter
  • assign travel costs equally between all exporters.

Further information can be found in our charging guidelines.

Example scenario

An example of how we charge for an IO to accompany a voyage is provided here.

An IO departs Melbourne and arrives at Broome at 4pm on Monday 6 August for a 13-day voyage to Malaysia:

  • the voyage is estimated to depart at 11am on Tuesday 7 August
  • due to unforeseen circumstances, the voyage departure is delayed until Wednesday 8 August at 10am
  • the IO provides the standard 7 hours and 30 minutes audit service each day
  • the IO obtains audit support from Australia for a total of 18 x 15 minute units throughout the audit. This includes 10 x 15 minute units on weekdays and 4 x 30 minute units on weekends
  • the unloading of stock is not completed until 10pm on 20 August and the IO departs for Melbourne on the next available flight at midday on 21 August.

This is the breakdown for how the exporter is charged.

Table 1 example scenario charging breakdown
Chargeable eventItemised charges
Delay at Broome – Tuesday 7 August1 x weekday audit rate
13-day voyage 8 – 20 August9 x weekday audit rate
 4 x weekend audit rate
Audit support from Australia10 x weekday 15 minutes
 4 x weekend 30 minutes
International flight – Malaysia to MelbourneAirfares
Additional day travel to Australia1 x weekday audit rate