Exporter Supply Chain Assurance System Regulatory Performance Report 1 June 2016 to 31 August 2016

​​​​​​​Incident report

The Exporter Supply Chain Assurance System (ESCAS) requires exporters’ to have commercial arrangements with supply chain partners (i.e. importers, feedlots, abattoirs) in importing countries to provide humane treatment and handling of livestock from arrival in the importing country up to the point of slaughter. ESCAS is underpinned by the following key principles – animal welfare, control and traceability – whereby the exporter must demonstrate, through a system of reporting and independent auditing:

  • animal handling and slaughter meets World Organisation for Animal Health (OIE) animal welfare standards (animal welfare)
  • the exporter has control of all supply chain arrangements (including having agreements in place with supply chain partners) for the transport, management and slaughter of livestock, and that all livestock remain in the supply chain (control)
  • the exporter can trace or account for all livestock through the supply chain (traceability).

If issues arise, ESCAS provides a mechanism to require exporters to address any non-compliance matters within their supply chains. This may be managed by undertaking additional steps at facilities (e.g. delivering training, upgrading infrastructure), by removing non-compliant facilities from a supply chain, or by not exporting any further livestock to a non-compliant supply chain.

Additionally, the ESCAS regulatory framework enables the Department of Agriculture and Water Resources to review and investigate reported non-compliance with ESCAS requirements and take regulatory action where appropriate. Reports are generally received through one of four pathways: third parties (for example, Animals Australia or private citizens in an importing country), industry, directly from exporters, or identified by the department itself. Reports are reviewed by the department using the Guideline for the management of non-compliance.

In response to an ESCAS non-compliance, the department may apply regulatory actions to an ESCAS supply chain or, in more serious instances, to an exporter or an entire market. This may include cancelling an ESCAS, varying an ESCAS to remove facilities or apply additional conditions (see section 3.2), cancelling or suspending an export licence, or reprimanding an exporter. Regulatory action is applied based on the nature of the non-compliance and level of associated risk, with any corrective actions implemented by the exporter to mitigate risks taken into consideration.

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Period summary: 1 June 2016 – 31 August 2016

From 1 June 2016 to 31 August 2016, more than 855,000 livestock (buffalo, cattle, goats and sheep) were exported in 175 consignments approved under ESCAS requirements from Australia to 16 markets (Table 1) by 18 exporters.

Table 1 - Markets for Australian Livestock exported under ESCAS - 1 June 2016 to 31 August 2016

Brunei DarussalamCambodiaChina
IndonesiaIsraelJordan
KuwaitLebanonMalaysia (including Sarawak)
OmanPhilippinesQatar
ThailandTurkeyUnited Arab Emirates
Vietnam

During this period, the department received reports of non-compliance with ESCAS requirements involving supply chains in Indonesia, Israel, Laos and Vietnam.

Eleven non-compliance investigations were completed and published by the department in eight reviews with 12 findings of non-compliance (Table 2). During this period, the department recorded two critical, seven major and three minor findings of non-compliance against ESCAS supply chains or facilities.

Table 2 Summary of findings of ESCAS non-compliance - reviews completed 1 June 2016 to 31 August 2016

Market

Reports

Finding

Critical

Major

Minor

No confirmed

No non-compliance

Indonesia

1

 

1

   

Kuwait

1

1

 1   

Malaysia

2

  

2

  

Oman

3

 

3

   

UAE

2

 

2

   

Turkey

1

1

    

Vietnam

1

  

1

  

Total

11

2

7

3

0

0

ESCAS non-compliance reviews

3.1 Overview of findings

An overview of findings for reviews completed in the period 1 June 2016 to 31 August 2016 is provided in Table 3. A detailed summary for each review is provided in Section 4 of this report.

Table 3 ESCAS regulatory performance reviews completed 1 June 2016 to 31 August 2016

#

Date

Type

Market

Species

Animals reportedly involved

Exporter

Non-compliance finding

79

September 2015

Animals Australia

Oman

Sheep

Over 360

Emanuel, LSS

Major

80

September 2015

Third Party

Malaysia

Sheep

7

Halleen

Minor

86

October 2015

Industry

Oman

Sheep

Over 1000

Emanuel, LSS

Major

87

October 2015

Third Party

Oman

Sheep

Over 500

Emanuel, LSS

Major

88

October 2015

Industry

United Arab Emirates

Sheep

At least 1

Emanuel, LSS

Major

89

October 2015

Animals Australia

United Arab Emirates

Sheep

Over 5200

Emanuel, LSS

Major

90

October 2015

Industry

Malaysia

Cattle

35

ILE

Minor

93

December 2015

Animals Australia

Kuwait

Sheep

Over 1200

Emanuel

Critical

94

December 2015

Audit

Turkey

Cattle

39

Otway

Critical

106

June 2016

Self Reported by Exporter

Vietnam

Cattle

1

ILE

Minor

107

July 2016

Audit

Indonesia

Cattle

Unknown

Wellard

Major

3.2 Actions taken in response to ESCAS non-compliance reports

The department and exporters have implemented a range of regulatory, corrective and preventative actions in response to confirmed non-compliance.
Regulatory action applied by the department this period included:

  • removing non-compliant facilities from ESCAS supply chains
  • raising the risk rating of facilities, requiring them to be audited more frequently
  • requiring the review of verification processes for ESCAS control and traceability requirements and provide a report to the department
  • requiring the development of exporter supply chain management plans to be developed and implemented, including systems for the high risk period over Eid al-Adha.

Corrective actions implemented by exporters this period included:

  • providing additional training to staff at facilities
  • suspending supply of livestock to a facility while an investigation was completed
  • revised processes and implemented improved control and traceability measures
  • appointing Animal Welfare Officers (AWOs) to oversee animal welfare and control and traceability requirements at facilities
  • liaising with importers and facilities to reiterate ESCAS requirements
  • performing assessments of supply chain traceability and completing an additional independent audit of facilities
  • ceasing supply to an entire market and closing an ESCAS
  • developing and implementing supply chain management plans
  • completing a risk gap analysis across the supply chain
  • appointing security and transport operators at facilities.

ESCAS Regulatory Performance Reviews

Markets

  • Indonesia
  • Kuwait
  • Malaysia
  • Oman
  • United Arab Emirates
  • Turkey
  • Vietnam

Exporters

Emanuel

Emanuel Exports Pty Ltd

EMS

EMS Rural Exports

Halleen

Halleen Australasian Livestock Traders

ILE

International Livestock Exports

LSS

Livestock Shipping Services

Otway

Otway Livestock Exports Pty Ltd

Wellard

Wellard Rural Exports

  

Acronyms and abbreviations

AA

Animals Australia

AWO

Animal Welfare Officer

Eid

Eid al-Adha

ESCAS

Exporter Supply Chain Assurance System

IPAR

Independent Performance Audit Report

MLA

Meat & Livestock Australia

NLIS

National Livestock Identification System

OIE

World Organisation for Animal Health

PIC

Property Identification Code

RFID

Radio Frequency Identification Device

SOP

Standard Operating Procedure

UAE

United Arab Emirates

Indonesia

Background

As at 31 August 2016, a total of 126 consignments of livestock were exported under ESCAS arrangements to Indonesia in 2016, including over 430 000 cattle making it the largest market for cattle by volume. There are currently seven Australian exporters with approved supply chains to export livestock to Indonesia.

The department has previously published reviews of ten reports relating to non-compliance in Indonesia. From these reports, seven findings of non-compliance have been recorded against exporter supply chains. These reviews can be found on the website.

As at 31 August 2016, there are no reports of non-compliance under investigation for Indonesia.

Report # 107: Cattle exported to Indonesia

Incident report:

On 27 June 2016, Wellard Rural Export Pty Ltd (Wellard) provided the department with Independent Performance Audit Reports (IPARs) for their Indonesia cattle supply chain. The audits were conducted between March and May 2016 for these medium risk facilities and identified a number of non-compliances related to ESCAS animal welfare and record keeping requirements at six abattoirs.

At Abattoir 1, the auditor observed processing of three animals and recorded the following non-compliances:

  • There were protrusions and sharp edges in cattle pens and gangways.
  • One animal was left in the restraining box for more than two minutes.
  • For two animals, the stun to stick interval was greater than the required timeframe of 20 seconds (intervals recorded were 21 seconds and 23 seconds).
  • Confirmation of death prior to processing and carcass dressing was not completed.
  • No records of equipment maintenance, feeding and inspection of cattle held over 12 hours were maintained.

At Abattoir 2, the auditor observed that an animal baulked in the raceway as a result of improper handling.

At Abattoir 3, the following non-compliances were recorded:

  • The Standard Operating Procedures (SOPs) to ensure facility staff work in accordance with the ESCAS animal welfare standards were not available.
  • Records of equipment maintenance were not retained.

At Abattoirs 4, 5 and 6 the auditor also observed that no records of daily inspection for cattle held over 12 hours and equipment maintenance were maintained.

Department assessment:

This was the first audit of these six facilities after the facilities were approved in the Wellard Indonesia cattle supply chain. The independent auditor identified several minor issues with ESCAS compliance at one abattoir, including checking for unconsciousness prior to dressing procedures and inadequate record keeping.  Inadequate record keeping was also identified at the other abattoirs, Clarification was sought from Wellard about when the audits were completed, why the non-compliances were not identified and reported and what corrective actions had been put in place.

Wellard advised that the IPARs were conducted between March and May 2016 and that these IPARs were provided to them by the auditor one week prior to their due date for submission (14 July 2016). They also stated that management of Abattoir 1 implemented corrective actions at the time the non-compliances were identified by the audit, as the Wellard local staff were advised of audit outcomes immediately.

Exporter action:

Wellard advised that at Abattoir 1 all three regular and experienced staff who perform stunning and slaughter operations were on leave and stand-in staff performed these procedures on the day of the performance audit. A new process has been implemented by Wellard to cover unplanned staff absences at facilities in the future.

The following corrective actions were implemented:

Abattoir 1

  • All staff re-training was conducted in relevant procedures for animal handling, stunning and slaughter operations.
  • Repairs were completed to remove protrusions and sharp edges in the gangway and pens.  Photographs of repairs were provided to the department.
  • New checklist for feeding, daily inspection of the animals held for more than 12 hours and restraining equipment maintenance were put in place.

Abattoir 2

  • All staff re-training was conducted in relevant procedures for animal handling, stunning and slaughter operations.

Abattoir 3

  • Copies of the relevant SOPs were provided.
  • Checklist for maintenance records of equipment used to restrain animals was put in place.

Abattoir 4, 5 and 6

  • The following checklists were put in place for
  • daily inspection of the animals held at the facilities for more than 12 hours
  • maintenance records of equipment used to restrain animals.

Department action:

The department contacted the exporter when the report was received and has raised the risk ratings for Abattoir 1 to high.  Abattoirs 2 to 6 will be maintained at medium requiring the facilities to be audited more frequently.

Department conclusions:

The audit reports identified non-compliance with ESCAS animal welfare and record keeping requirements. Wellard should have, but did not identify or report the non-compliances identified in these audit reports until the issues were raised with them by the department. Wellard’s actions with their in market staff and supply chain partners should address the problems identified in this supply chain.

In assessing this matter against the guidelines for management of non-compliance, the department recorded a major non-compliance with ESCAS animal welfare and record keeping requirements against the Wellard Indonesia cattle supply chain.

Kuwait

Background

As at 31 August 2016, a total of 20 consignments of livestock were exported under ESCAS arrangements to Kuwait in 2016, including 150 cattle and over 435 000 sheep making it the largest market for sheep by volume. There are currently four Australian exporters with approved supply chains to export livestock to Kuwait.

The department has previously published reviews of twelve reports relating to non-compliance in Kuwait. From these reports, ten findings of non-compliance have been recorded against exporter supply chains. These reviews can be found on the website.

As at 31 August 2016, there are no reports of non-compliance under investigation for Kuwait.

Report # 93: Sheep exported to Kuwait

Incident report:

On 8 December 2015, Animals Australia (AA) reported non-compliance with ESCAS control and traceability and animal welfare requirements observed in Kuwait. The report included video and photographs from an ESCAS approved abattoir and a list of ear tags from sheep observed outside approved supply chains.

AA reported that between 27 and 28 November 2015 they observed:

  • No less than 200 Australian sheep at each of the Al Rai and Kabd livestock markets. 
  • Unloading, handling, restraint and slaughter of Australian sheep at the abattoir which did not meet ESCAS animal welfare standards. The non-compliance observed included dragging, kicking, pushing and hitting of sheep, and dragging of conscious sheep immediately after the throat-cut.
  • Several trucks with no less than 800 Australian sheep arriving and unloading at the ESCAS approved abattoir, with a further 200 Australian sheep being held in outside pens at the Abattoir.

Some sheep had ear tags removed, however the majority had ear tags intact. A list of ear tags were provided for the sheep that were observed to have them, as well as the property identification code details relating to some of the ear tags.

Department assessment:

The department assessed the report and video provided to determine whether non-compliance with ESCAS control and traceability and animal welfare requirements had occurred.

The department determined that the sheep observed had typical characteristics associated with being of Australian origin with clearly identifiable Australian ear tags, and were outside the approved supply chain at the Al Rai and Kabd livestock markets.
The abattoir where the video was taken was confirmed to be an ESCAS approved facility in supply chains for International Livestock Exports (ILE), Livestock Shipping Service (LSS), Emanuel Exports (Emanuel) and EMS Rural Exports (EMS) with a capacity to process 2000 animals per day. The presence of Australian sheep being unloaded at the facility and their presence in the outside pens was not in breach of ESCAS requirements.

The video showed multiple examples of non-compliance with ESCAS handling and slaughter requirements including:

  • sheep were observed being dragged by front or back legs and being hit or kicked in an attempt to make them move
  • sheep being positioned for slaughter using their head and ears as hand holds
  • sheep having their throats cut and then being immediately pulled/dragged across the kill line. There are signs the animals are still conscious while being moved and the video showed that neck extension until unconscious is confirmed, was not performed.

The department contacted all exporters of sheep to Kuwait and requested property of origin lists for consignments discharged in Kuwait between 23 February 2015 and 24 November 2015. Exporters were also asked to provide details of their own investigations including findings, conclusions and corrective actions taken, reconciliation data and reasons for any identified non-compliance.

The department assessed the information and tag numbers provided in the report and determined:

  • Fifteen tags were National Livestock Identification System (NLIS) tags showing property identification codes (PICs) for 14 properties
  • nine PICs were exclusively linked to multiple Emanuel consignments
  • two PICs were linked to both Emanuel and LSS consignments
  • three PICs were not linked to any consignments exported at the time of the report
  • three tags were not traceable
  • no PICs were linked to ILE or EMS consignments

These findings confirmed that sheep were exclusively linked to the Emanuel supply chain. No sheep were exclusively linked to LSS. Two PICs were linked to both Emanuel and LSS consignments and as such cannot be exclusively linked to either exporter.  The exporters’ control and traceability systems did not identify that sheep were lost from their supply chains.

Exporter actions:

During November and December 2015, LSS and importer representatives worked with management of the abattoir to strengthen processes to achieve consistently compliant animal welfare outcomes. Three further visits in January, May and August 2016 continued this program and provided ongoing training.

LSS has also worked collaboratively with Emanuel and EMS using MLA Live Export Program consultants and in-market consultants to identify any issues at facilities that are co-used. This included control and traceability and animal handling training workshops. Training is focused on facility management supply chain personnel which can continue to train others in facilities. Maintenance and evaluation of training effectiveness is also being undertaken through in market consultants and industry.
Emanuel, ILE and EMS had their supply chain officers speak to abattoir management and staff and reiterated the correct processes for handling and movement of sheep. Since this incident three audits have been undertaken for each exporter with no non-compliance reported.

All exporters have implemented their Supply Chain Management Strategy to further strengthen animal welfare and handling of stock.

Department actions:

In response to the multiple reports received relating to Kuwait in 2015, the department raised the risk-rating for all Kuwait facilities to high in November 2015 requiring them to be audited four times a year. The abattoir shown in the video has been audited three times since this report with no non-compliances observed.

In addition, all exporters were directed to prepare a supply chain management strategy to manage the risk of loss of control and to include additional actions to be implemented for the high risk period over Eid al Adha. The plans have been reviewed and accepted by the department.

Department conclusions:

The department concluded that:

  • The sheep identified in the photographs and video were of Australian origin, were exported under ESCAS arrangements and were found outside approved supply chains.
  • Australian sheep were handled and slaughtered at an ESCAS approved facility in a manner that is not compliant with ESCAS animal welfare standards. This facility is approved in the supply chain of all exporters to Kuwait.
  • A small number of sheep were exclusively linked to consignments exported by Emanuel. Other sheep observed outside approved supply chains were also determined to be of Australian origin but could not be exclusively linked to any exporter.

In assessing this matter against the guidelines for management of non-compliance, the department has recorded a critical non-compliance against the abattoir identified in this report for non-compliance with ESCAS requirements. The department has also recorded a major non-compliance against Emanuel’s Kuwait sheep supply chain for non-compliance with ESCAS control and traceability requirements.

Malaysia

Background

As at 31 August 2016, a total of 197 consignments of livestock have been exported under ESCAS arrangements to Malaysia in 2016, including over 800 buffalo, 25 000 cattle, 31 000 goats and 46 000 sheep. This makes Malaysia the third smallest market for sheep and the largest for goats by volume. There are currently ten Australian exporters with approved supply chains to export livestock to Malaysia.

The department has previously published reviews of eight reports relating to non-compliance in Malaysia. From these reports, two findings of non-compliance have been recorded against exporter supply chains. The reviews can be found on the website.

As at 31 August 2016, there are two reports of non-compliance under investigation for Malaysia.

Report # 80: Sheep exported to Malaysia

Incident Report:

On 2 October 2015, Halleen Livestock Export Pty Ltd (Halleen) notified the department about possible non-compliance with Exporter Supply Chain Assurance System (ESCAS) control and traceability requirements in their Malaysia sheep supply chain. On 8 October 2015 Meat and Livestock Australia (MLA) provided photographs of five merino rams (with ear tags removed) and two damara sheep (with ear tags in place) ( Report #80). This ESCAS approved facility is part of another exporter’s supply chain who had not exported damara sheep for the previous six months.

Department assessment:

The department assessed the report and photographs and determined that the sheep were of Australian origin.

At the time of the report, seven exporters were approved to export sheep to Malaysia. Based on department records, Halleen was the only exporter to have exported damara sheep in the six months before this incident.

The department requested property of origin lists from Halleen for their consignments of damara sheep to Malaysia in the two months prior to the incident. Using the Department of Agriculture Western Australia Brand search facility, the department confirmed the two ear tags were from two properties that Halleen had sourced sheep for a consignment exported to Malaysia.

Although a number of exporters had sent merino and merino cross rams to Malaysia, the ear tags were removed, so it was not possible to trace these animals back to individual exporters.

Corrective actions taken by the exporter:

No corrective actions were taken by Halleen. While Halleen initially notified the department of possible non-compliance in their supply chain, the company decided there was no evidence of non-compliance as their reconciliations showed all sheep exported by the company remained in the supply chain until slaughtered. Halleen disputes the department’s conclusion that the two damara sheep are most likely from one of their consignments.

The facility where the damara sheep were seen has been visited by the exporter whose supply chain it is approved in. It is noted that the feedlot is not an exclusive ESCAS facility and receives animals from other sources. The exporter has reminded the feedlot operator of ESCAS requirements.

Regulatory action:

The department requested Halleen review their verification processes for ESCAS control and traceability in their Malaysia sheep and goat supply chain and provide a report to the department by 13 September 2016.  The exporter has not sent any further consignments to this supply chain since October 2015.

Department conclusions:

The department concluded that the damara and merino sheep identified in the photographs were exported under ESCAS and were outside approved supply chain/s.  The merino sheep were unable to be linked to any particular exporter as they had no ear tags. The two damara sheep were exclusively linked to a Halleen consignment. The feedlot on which the sheep were found was not included in the Halleen supply chain even though it is ESCAS approved.

In assessing this matter against the guidelines for management of non-compliance, the department recorded a minor non-compliance against the Halleen Malaysia sheep and goat supply chain for non-compliance with ESCAS control and traceability requirements. The damara sheep were found in ESCAS approved facilities; no animal welfare issues were reported.

Report # 90: Cattle exported to Malaysia

Incident report:

On 8 October 2015, the Department of Agriculture and Water Resources received an industry report from Meat and Livestock Australia (MLA) providing details of non-compliance with Exporter Supply Chain Assurance System (ESCAS) control and traceability requirements for cattle exported to Malaysia. The report provided the following information:

  • Thirty-two Australian bulls were observed in an ESCAS approved feedlot with ear tags removed.
  • Cattle were moved and processed outside the relevant approved supply chain.
  • The tethering of three Brahman bulls.
  • Ten images of cattle with ear tags removed and registered ear notches.

On 17 October 2015, International Livestock Export Pty Ltd (ILE) reported that MLA had provided photographs of cattle to them and that ear notches in the cattle were consistent with those supplied on one of their shipments to Malaysia.

ILE advised that Standard Operating Procedures (SOPs) were in place at the ESCAS approved feedlot where the cattle originated from. The SOPs state that animals are to be scanned in and out of the facility and that they can only be transferred to ESCAS approved abattoirs in the ILE supply chain. ILE stated that the feedlot owner was acting outside of the supply chain agreement and appears to have removed the ear tags to in order to supply facilities outside the commercial arrangement.

Department assessment:

Based on the information provided, the department determined that 32 cattle exported by ILE were observed at a feedlot not approved for the ILE Malaysia cattle supply chain. The cattle originated from an ESCAS approved feedlot in the ILE supply chain. Of the 32 cattle observed at the feedlot, 22 were processed at an abattoir which is an approved facility in the ILE Malaysia cattle supply chain (since 26 November 2014). The remaining 10 cattle (including the three tethered bulls) were processed at an abattoir which was approved in four other exporter supply chains at the time. The facility had previously been approved for ILE, however was removed in May 2015. The abattoir is currently approved in three exporter supply chains.

The department reviewed Independent Performance Audit Reports (IPARs) for facilities where the cattle were processed and confirmed that all facilities had been audited a number of times and found to be compliant with ESCAS animal welfare requirements. Based on audit outcomes, it is considered likely that livestock were handled and processed in accordance with ESCAS animal welfare requirements.

While tethering is not a breach of World Organisation for Animal Health (OIE) standards, Australian cattle are not accustomed to this practice and therefore it is considered to be inconsistent with optimal animal husbandry practices and a breach of ESCAS requirements. It was not known how long the bulls had been tethered however they did not appear distressed and had access to food and water.

Exporter actions:

The following actions were taken by ILE in response to this report:

  • In November 2015, ILE sent the owner of the feedlot who supplied the cattle a warning letter that any further non-compliance would not be tolerated.
  • A traceability assessment and reconciliation was completed by the supply chain officer at the feedlot and an additional independent audit was completed.
  • In February 2016, ILE held a meeting with the importer and feedlot to emphasise the importance of compliance with ESCAS.

Department actions:

In May 2016, once it was confirmed that no animals remained in the facility, the department removed the feedlot from the ILE Malaysia cattle supply chain so that no further animals exported by ILE could use the facility.

Department conclusions:

The department concluded that 32 animals exported by ILE were moved from an ILE approved feedlot and observed at another facility outside the ILE Malaysia cattle supply chain. Information available indicates that 22 of the animals were processed in a facility approved in the ILE Malaysia cattle supply chain and 10 animals were processed in a facility which at the time was approved in the supply chains of four other exporters, and remains in approved supply chains for three exporters. It is considered likely the animals were processed in accordance with ESCAS requirements.

In assessing this matter against the guidelines for management of non-compliance, the department recorded a minor non-compliance against the ILE Malaysia cattle supply chain.

Oman

Background

As at 31 August 2016, a total of 14 consignments of livestock have been exported under ESCAS arrangements to Oman in 2016, including over 87 000 sheep making it the sixth largest market for sheep by volume. There are currently three Australian exporters with approved supply chains to export livestock to Oman.

The department has previously published reviews of two reports relating to non-compliance in Oman. From these reports, one finding of non-compliance has been recorded against exporter supply chains. The reviews can be found on the website.

As at 31 August 2016, there are no reports of non-compliance under investigation for Oman.

Reports # 79, # 86 and # 87: Sheep exported to Oman

Incident report:

Between 22 September and 14 October 2015, the department received three reports relating to non-compliance with ESCAS control, traceability and animal welfare requirements in Oman.

Animals Australia provided initial notification on 22 September 2015, followed by an official complaint on 2 October 2015 reporting:

  • Australian sheep observed outside of approved supply chains with at least 360 seen at Sohar Livestock Market on 21 September 2015.
  • Sheep being sold from ESCAS approved facilities and street market stalls to the public for home slaughter.
  • Loss of traceability with ear tags removed.
  • Numerous other examples of non-compliance with ESCAS requirements relating to the handling and transportation of livestock, exposure of animals to adverse weather conditions, and slaughter and restraint methods.
  • Five ear tag numbers were provided.

On 6 October 2015 MLA notified the department by email reporting:

  • Australian sheep observed outside of approved supply chains with over 300 seen at Ibra Livestock Markets on 18 September 2015, and 700 seen at Sohar Livestock Markets and an unapproved abattoir on 22 September 2015.
  • At Ibra Livestock Markets, Australian sheep were seen trussed in the back of vehicles and being dragged by the hind leg.
  • Information obtained at Sohar Livestock Markets indicated that some sheep had come from the United Arab Emirates (UAE) (Al Ain Markets) indicating that unapproved cross-border movement had occurred.
  • 13 ear tag numbers were provided, which were collected over both locations.

On 14 October 2015 a third-party provided a post-Eid report:

  • Australian sheep observed outside of approved supply chains with over 300 at Ibra Livestock Markets, and over 200 an unapproved feedlot.
  • Numerous other examples of non-compliance with ESCAS requirements relating to handling, transport and restraint methods, inadequate supply of food and water, and public sales of sheep from both unapproved and ESCAS approved facilities for home slaughter.
  • Eight ear tag numbers were provided from an unapproved abattoir.

Department Assessment:

The department requested that each of the exporters to Oman and UAE supply their property of origin lists for checking against the ear tags provided in the reports. They were also asked to investigate the information in the reports and provide their findings to the department.

The department assessed the 26 ear tags provided and determined the following:

  • Two tags were not able to be traced back to a PIC.
  • Twenty four tags were National Livestock Identification System (NLIS) tags showing property identification codes (PICs) for 26 possible properties. Two of the tags provided presented a ‘Lazy’ letter alternative linked to a PIC.
  • For the 24 tag numbers provided which were able to be traced to a PIC:
  • twelve tags were exclusively linked to Emanuel consignments exported to Oman—two of these found at approved facilities and 10 found in unapproved facilities
  • two tags were exclusively linked to LSS consignments exported to the UAE
  • two tags were able to be linked to both LSS and Emanuel consignments—one of these tags could be linked to consignments that discharged in either the UAE or Oman, and the other was linked to consignments which discharged sheep only in the UAE
  • eight tags could not be linked to any consignments exported in the six months prior to the report.

These findings confirmed that sheep were lost from both the Emanuel-Oman and LSS-UAE supply chains, with 14 tags linked to their consignments found in locations which were not ESCAS approved facilities. The three tags linked to both LSS and Emanuel consignments that did not discharge animals in Oman, confirm unapproved cross-border movement from the UAE. The exporters’ control and traceability systems did not identify that sheep were lost from their supply chains.

Emanuel had stated in their report that they believed all of the facilities in which the sheep were seen were ESCAS approved, and that the market stall selling arrangements were ESCAS compliant in their supply chains. Despite informal discussions previously with the department regarding these arrangements, Independent Performance Audit Reports (IPARs) did not show that the market stalls had been audited or officially submitted to the department for approval.

LSS acknowledged that they had sourced animals from the four PICs linked to their consignments. They also advised they source from multiple vendors who also sell to other exporters and maintain that the match to POO lists is not confirmation that these animals were exported by LSS.

The department reviewed the video and photographs provided which confirmed handling and transport non-compliant with ESCAS requirements, and confirmed the reports of sheep being sold to the public for private slaughter from both unapproved and ESCAS approved facilities. The market selling arrangements associated with approved facilities and abattoirs was not demonstrated to be compliant, approved or audited.

Without ear tags to trace for the remaining sheep reported outside of approved supply chains, the department was unable to trace responsibility back to a particular exporter, however it is likely that the sheep observed were also of Australian origin based on their appearance and physical characteristics, indicating further loss of control and traceability from the approved supply chains.
No information was provided relating to the animal welfare outcomes for the animals discussed in the reports.

It could not be determined which of the ESCAS approved facilities were the source of the sheep in the markets.

Exporter actions:

No corrective actions were initiated at the time by either exporter.

Department actions:

In response the department implemented the following measures:

  • Raised the risk-rating for all facilities in Oman to high, requiring them to be audited four times a year.
  • Required all exporters to Oman to prepare a supply chain management plan. The plan must include additional actions for the high risk period over Eid al Adha.
  • The plans will be approved by the department and reviewed on an ongoing basis.
  • Compliance with the plan may be audited by the department.

Department conclusions:

The department concluded that the sheep identified in the reports were of Australian origin, were exported under ESCAS arrangements and were found outside approved supply chains. It is unlikely slaughter practices in these locations were compliant with ESCAS animal welfare requirements. The video and photographs provided demonstrated animal handling and transport non-compliant with ESCAS animal welfare requirements.

A small number of sheep were definitively linked to consignments exported to Oman by Emanuel and to UAE by LSS. It is likely that the other sheep observed in the market and being transported in private vehicles were also of Australian origin, indicating loss of control and traceability from the approved supply chains at a number of points.

In assessing this matter against the guidelines for management of non-compliance, the department has recorded a major non-compliance with ESCAS control and traceability and animal welfare requirements against the Emanuel supply chain to Oman.  The non-compliance with ESCAS control and traceability and animal welfare requirements identified for the LSS supply chain to the UAE has been recorded in report # 88 - 89 (Sheep exported to the UAE).

United Arab Emirates

Background

As at 31 August 2016, a total of 18 consignments of livestock have been exported under ESCAS arrangements to the United Arab Emirates in 2016, including 200 cattle, and over 5400 goats and 103 000 sheep making it the second largest market for goats and the fourth largest for sheep by volume. There are currently five Australian exporters with approved supply chains to export livestock to the United Arab Emirates.

The department has previously published reviews of two reports relating to non-compliance in the United Arab Emirates. From these reports, two findings of non-compliance have been recorded against exporter supply chains. The reviews can be found on the website.

As at 31 August 2016, there are no reports of non-compliance under investigation for the United Arab Emirates.

Reports # 88 and # 89: Sheep exported to United Arab Emirates

Incident report:

On 6 October 2015, Meat & Livestock Australia (MLA) notified the department of non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in the United Arab Emirates (UAE) (report # 88). The report stated:

  • on 23 September 2015 consultants observed failures in the process for transport from the market to abattoir at one ESCAS approved facility
  • on 25 September 2015 consultants observed a sheep being loaded into a private vehicle at an ESCAS approved facility.

On 7 and 9 October 2015, Animals Australia reported to the department that Australian sheep exported under ESCAS had been handled in a manner non-compliant with ESCAS requirements and offered for sale outside approved supply chains during Eid al Adha (Eid) (report # 89). The reports included ear tag numbers, photos and links to videos. The reports stated:

  • On 23 and 24 September 2015, no less than 3,200 Australian sheep were observed for sale outside approved supply chains at two livestock markets (Al Ain Livestock Complex and Dubai Municipal Livestock Complex). Non-compliant animal handling practices were witnessed in temperatures of 44 degree Celsius. Thirteen ear tag numbers were provided from Al Ain and 24 ear tag numbers from Dubai.
  • On 23 September 2015, no less than 2000 Australian sheep were observed for sale approximately 70 meters from the back of an ESCAS approved abattoir. Poor animal handling practices were witnessed in temperatures of 39 degree Celsius. Two images of ear tags were provided.

As the incident reports from Animals Australia and MLA were received around the same time and considered related, the two reports have been combined for assessment.

Department Assessment:

The department assessed the reports, photographs and video submitted by Animals Australia and MLA. The department determined that the sheep observed had typical characteristics associated with being of Australian origin.

The video showed multiple examples of Australian sheep outside the approved supply chain being handled and transported by methods non-compliant with ESCAS animal welfare requirements. The video showed:

  • sheep being dragged by a front or hind leg, wool and ears
  • sheep unloaded from a truck without a ramp
  • sheep being carried to and put into the boot and trays of private vehicles
  • sheep being trussed and placed in wheelbarrows
  • one animal in the boot of a private vehicle panting heavily.

The department’s records indicate that three exporters received approvals to export sheep to the UAE during the six months leading up to Eid in 2015:

  • Emanuel Exports (Emanuel)
  • EMS Rural Exports Pty Ltd (EMS), and
  • Livestock Shipping Services (LSS)

The department contacted the three exporters to UAE and requested property of origin lists for consignments exported to UAE during the seven months prior to September 2015 for checking against the tag numbers provided in the report. The department also asked exporters to respond to the Animals Australia report.

The department assessed the video footage, photographs of tags and tag numbers provided by Animals Australia and determined the following:

  • Twenty eight tags were National Livestock Identification System (NLIS) tags showing property identification codes (PICs) for twenty three properties
  • thirteen PICs were exclusively linked to Emanuel consignments
  • one PIC was exclusively linked to an LSS consignments
  • five NLIS tags and could not be exclusively linked to an exporter
  • four tags could not be linked to a consignment exported at the time of the report
  • nine tags could not be identified or were not NLIS tags and were not traceable.

EMS confirmed that none of the ear tags provided by Animals Australia corresponded to properties they had sourced sheep from during this period. EMS also stated it was not plausible that any sheep remained unprocessed in September given their consignment related to a June shipment.

LSS advised that there were four ear tags could be linked to properties from which LSS sourced sheep for consignments. LSS stated they had carried out an internal investigation in UAE and did not find any evidence of leakage from their supply chain. Further, their reconciliation data for the supply chain indicated no loss of traceability or control.

Emanuel stated that they had reviewed the ear tag lists provided by Animals Australia and found that 36 ear tags could be linked to properties from which Emanuel had sourced sheep for consignments. Emanuel advised that they have strict procedures in place and had no reason to suspect a loss of control, traceability or systemic failures.

Exporter actions:

Emanuel advised that their importer has received approval to build an abattoir facility at the feedlot in their supply chain. This facility will provide a closed loop system within the supply chain greatly reducing the risk of livestock moving outside the approved supply chain.

Emanuel have also implemented the following actions:

  • Employed a Supply Chain Manager and an Animal Welfare Officer whose responsibilities are to monitor/manage control and traceability and ensuring that all facilities and processes up to the point of slaughter are consistent with ESCAS animal welfare requirements.
  • Provided training to new supply chain management staff in February and June 2016.
  • Completed a risk and gap analysis across the UAE supply chain with outcomes from the analysis being used to assist in planning and resourcing activities for Eid 2016.
  • Met with importers senior management and Municipal Authorities to emphasise the importance of ESCAS compliance and prevention of leakage.

LSS advised that they have undertaken a risk assessment and developed a plan for Eid for their approved abattoirs and that they were reviewing the use of these facilities including:

  • implementing dedicated transport operators and a ticket system, to allow for a controlled and verifiable system for sheep delivery to approved slaughter points with appropriate handling if the facility is used over Eid in 2016
  • posting security at all exit points of the abattoir
  • importer staff selling and manning the holding pens will ensure sheep are sent directly from the holding pens to the slaughter point and transported appropriately using temporary raceways or trolleys.

Department actions:

The department raised the risk-rating for all UAE facilities to high in November 2015requiring them to be audited four times a year. The abattoirs shown in the video has been audited three times for each exporter since this report, with no non-compliances observed.

The department has required that all exporters to the market develop a supply chain management plan to be implemented in the market.

Department conclusions:

The department concluded that:

  • the sheep identified in the photographs and video were of Australian origin, were exported under ESCAS and were found outside approved supply chains
  • Australian sheep were handled in a manner that is was non-compliant with ESCAS animal welfare requirements and it is likely that animals outside the approved supply chain had adverse animal welfare outcomes
  • a small number of sheep were exclusively linked to consignments exported by Emanuel and LSS.

In assessing this matter against the guidelines for management of non-compliance, the department recorded a major non-compliance against the both the Emanuel and LSS UAE supply chains for non-compliance with ESCAS control, traceability and animal welfare requirements.

Turkey

Background

As at 31 August 2016, a total of 3 consignments of livestock have been exported under ESCAS arrangements to Turkey in 2016, including over 17 000 cattle making it the sixth largest market for cattle by volume. There is currently one Australian exporter with an approved supply chain to export livestock to Turkey.

The department has previously published reviews of one report relating to non-compliance in Turkey. From this report, no finding of non-compliance was recorded against exporter supply chains. The review can be found on the website.

As at 31 August 2016, there are no reports of non-compliance under investigation for Turkey.

Report # 94: Cattle exported to Turkey

Incident report:

On 4 December 2015, the Department of Agriculture and Water Resources identified non-compliance with ESCAS requirements in an independent performance audit report (IPAR) provided for the Otway Livestock Exports Pty Ltd – Turkey – Cattle supply chain. One consignment of 2295 cattle had been exported to the supply chain in December 2014.

The IPAR provided in July 2015 identified 39 cattle had been moved from four approved feedlots to two unapproved abattoirs.
Twenty head were slaughtered at two unapproved abattoirs using traditional slaughter techniques and 19 head were moved to unknown facilities with unknown animal welfare outcomes.

Department Assessment:

The IPAR demonstrated non-compliance with ESCAS control, traceability and animal welfare requirements.

The exporter did not report the non-compliance at the time of submission of the IPAR or advise the department of corrective actions Otway were taking to prevent the movement of cattle to non-approved facilities.

Exporter actions:

The Otway CEO visited Turkey in June 2015 and inspected the supply chain as a result of the non-compliance. As part of this visit the CEO reiterated responsibilities of the feedlots and the need to inform the exporter of any reportable incidents with the remaining cattle in the supply chain. At the time of the visit it is estimated there were approximately 2000 cattle remaining in the supply chain.

Otway ceased exporting to Turkey and closed their approved ESCAS once all animals had been slaughtered in January 2015.

Department actions:

The department contacted the exporter and sought advice on why the non-compliance was not reported by Otway and what corrective actions had been put in place once the company received the audit report.

The supply chain was closed at the request of the exporter.

Department conclusions:

In assessing this matter against the guidelines for management of non-compliance, the department recorded a Critical non-compliance with control, traceability and animal welfare requirements against the Otway Turkey cattle supply chain.
The department will incorporate the findings of this report when considering any future ESCAS applications in Turkey.

Vietnam

Background

As at 31 August 2016, a total of 52 consignments of livestock have been exported under ESCAS arrangements to Vietnam in 2016, including over 2100 buffalo and 141 000 cattle making it the largest market for buffalo and the second largest for cattle by volume. There are currently nine Australian exporters with approved supply chains to export livestock to Vietnam.

The department has previously published reviews of 18 reports relating to non-compliance in Vietnam. From these reports, 16 findings of non-compliance have been recorded against exporter supply chains. The reviews can be found on the website.

As at 31 August 2016, there are eight reports of non-compliance under investigation for Vietnam.

Report # 106: Cattle exported to Vietnam

Incident report:

On 11 June 2016, International Livestock Export (ILE) self-reported a non-compliance with ESCAS requirements to the department.  The report was about the delayed slaughter of an animal after it was stunned and scanning equipment not in use.

Department Assessment:

The department assessed the report submitted by ILE and requested copies of the video from the CCTV.
The initial video submitted was assessed by the department and showed:

  • the animal was stunned correctly using a penetrative bolt stunner
  • the worker checking for corneal reflex before moving the animal
  • the stun to slaughter interval could not be determined from the video provided, however, ESCAS animal welfare standards do not specify a maximum stun to slaughter interval for penetrative stunning, only that the stun to slaughter interval should be kept as short as possible

The department requested video of other animals processed in the abattoir on the same night for further assessment and identified no non-compliance in the processing of these animals. The videos were reviewed by experienced officers from the department’s meat export programme.

The exporter reported that the Radio-Frequency Identification (RFID) scanner was turned off and hand held scanners were not used demonstrating non-compliance with ESCAS control and traceability standards for Vietnam and the industry six point plan.
Previous audits were reviewed and confirmed that the facility was audited twice in the eight months before this report. Both audits indicated correct slaughter methods were being used with a 15 second delay between stun and slaughter, and that the exporter had control of all operations within the supply chain.

Exporter actions:

As soon as the incident was identified the exporter suspended the facility as agreed by industry under their six point plan.

Department actions:

The department removed the facility from all exporters supply chains once it was confirmed that there were no Australian livestock remaining in the abattoir.

Department conclusions:

The department’s review of the video concluded that there was no non-compliance with ESCAS animal welfare requirements. The RFID scanner was turned off which indicated non-compliance with control and traceability requirements.

In assessing this matter against the guidelines for (management of non-compliance, the department recorded a minor non-compliance with ESCAS control and traceability requirements against the ILE Vietnam supply chain.

Summary of reviews in progress as at 31 August 2016

Table 4 provides an overview of all regulatory performance reviews in progress as at 31 August 2016. The status of all reviews can be found on the department’s website.

Table 4 Summary of ESCAS regulatory performance reviews in progress as at 31 August 2016

Web #

Market

Species

Report

Date

Received from

98

Vietnam

Cattle

Loss of control.

March 2016

Self-reported by exporter

99

Vietnam

Cattle

Loss of control and traceability.

April 2016

Self-reported by exporter

101

Malaysia

Cattle

Loss of control and traceability.

May 2016

Self-reported by exporter

102

Malaysia

Cattle

Loss of control and traceability.

May 2016

Self-reported by exporter

103

Israel

Cattle

Adverse animal welfare concerns.

June 2016

Animals Australia

104

Vietnam

Cattle

Non-compliant slaughter resulting in adverse animal welfare outcomes; loss of control and traceability; animal welfare concerns.

June 2016

Animals Australia

105

Laos

Cattle

Severe weather incident resulting in animal welfare concerns.

June 2016

Self-reported by exporter

109

Vietnam

Cattle

Animal welfare concerns; loss of control and traceability.

August 2016

Third Party

110

Vietnam

Cattle

Loss of control.

August 2016

Self-reported by exporter

111

Vietnam

 Cattle

Loss of control.

August 2016

Self-reported by exporter

112

Vietnam

Cattle

Loss of control and traceability.

August 2016

Self-reported by exporter

113

Vietnam

Cattle

Loss of control and traceability.

August 2016

Self-reported by exporter

​​​​​​​
Last reviewed: 4 November 2019
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