Exporter Supply Chain Assurance System Regulatory Performance Report 1 September 2017 to 30 November 2017
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 (for example 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.
|Exporter Supply Chain Assurance System Regulatory Performance Report 1 September 2017 to 30 November 2017 PDF||17||509 KB|
If you have difficulty accessing these files, visit web accessibility for assistance.
Period summary: 1 September 2017 – 30 November 2017
From 1 September 2017 to 30 November 2017, nearly 734,000 livestock (buffalo, cattle, goats and sheep) were exported in 86 consignments approved under ESCAS requirements from Australia to 13 markets (Table 1) by 20 exporters.
Table 1 - Markets for Australian Livestock exported under ESCAS - 1 September to 30 November 2017
Malaysia (including Sarawak)
United Arab Emirates
During this period, the department received reports of non-compliance with ESCAS requirements involving supply chains in Israel, Kuwait, Malaysia, Oman and Vietnam.
Three non-compliance investigations were completed and published by the department with three findings of non-compliance (Table 2). During this period, the department recorded three findings of minor non-compliance against ESCAS supply chains or facilities.
Table 2 Summary of findings of ESCAS non-compliance - reviews completed 1 September 2017 to 30 November 2017
ESCAS non-compliance reviews
3.1 Overview of findings
An overview of findings for reviews completed in the period 1 September to 30 November 2017 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 September to 30 November 2017
Animals reportedly involved
200 - 300
Unable to be determined
Self-report by exporter
*Non-compliance was recorded against a facility. The department will consider the findings of this report when assessing any future applications to add the facility to an exporter’s supply chain.
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:
- reviewed the risk rating of facilities
- requiring additional reporting from exporter supply chains
- requiring exporters to provide processing reports
- review exporter Supply Chain Management Plans (SCMP).
Corrective actions implemented by exporters this period included:
- suspending and removing a trader with identified non-compliance
- implementing additional oversight of animal welfare, control and traceability systems at facilities and key points of ESCAS supply chains.
ESCAS Regulatory Performance Reviews
- Kuwait – Report 141
- Oman – Reports 140 and 143
Emanuel Exports Pty Ltd
Phoenix Exports Pty Ltd
Wellard Rural Exports Pty Ltd
Acronyms and abbreviations
Independent Performance Audit Report
Exporter Supply Chain Assurance System
Supply Chain Management Plan
Standard Operating Procedures
Description of Supply Chain Elements
A facility where livestock is rested between journey(s) or holding facilities in a particular region where livestock are delivered from farms for assembly before a journey.
A facility where livestock are gathered to be fattened for market.
A facility used for the slaughter of livestock and production of meat or meat products
The Exporter Supply Chain Assurance System (ESCAS) was implemented in Kuwait on 1 March 2012.
As at 30 November 2017, a total of 32 consignments of livestock have been exported under ESCAS arrangements to Kuwait in 2017, including 554 cattle and 532,009 sheep making it the second largest market for sheep to date. There are currently four Australian exporters with approved supply chains to export livestock to Kuwait.
The department has previously published reviews of 16 reports relating to non-compliance in Kuwait. From these reports, 16 findings of non-compliance have been recorded against exporter supply chains and facilities. The reviews can be found at Regulatory compliance investigations.
As at 30 November 2017, there are no reports of non-compliance under investigation for Kuwait.
Report #141: Sheep exported to Kuwait – Minor non-compliance
On 8 September 2017 Animals Australia reported non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in Kuwait. The report advised:
- On 18 August 2017, hundreds of Australian sheep observed at Al Rai Livestock Market, were sold to private buyers and transported in car boots. The sheep had their ear tags intact, however no tag numbers were included with the report.
- On 1 September 2017, two Australian sheep were observed being slaughtered on the floor at an approved abattoir.
Video taken at Al Rai Livestock Market and the approved abattoir was provided with the report.
Information from the Animals Australia report was provided to exporters to Kuwait on 8 September 2017.
The department required exporters to advise how many animals they would have in Kuwait over Eid-al-Adha (Eid). Emanuel Exports Pty Ltd (Emanuel) was the only exporter to have sheep in Kuwait during Eid 2017.
No exporter supply chains are approved to have traders sell Australian sheep at Al Rai Livestock Market. The abattoir in the report and video was approved in the Emanuel supply chain and in the supply chain of two other exporters.
The video taken at the approved abattoir showed the slaughter of two sheep on the floor, the slaughter of one of these animals was not compliant with ESCAS requirements. The abattoir is not approved for slaughter on the floor in the Emanuel supply chain, however it is approved for slaughter on the floor in another exporter’s supply chain.
The department reviewed Independent Performance Audit Reports (IPARs) for the abattoir. No non‑compliance with animal welfare requirements or control and traceability systems was identified during any previous performance audits of the abattoir. The most recent audits were completed in March 2017. The abattoir has a risk rating of medium.
In the months prior to Eid, Emanuel visited facilities in their supply chain, assessed each facility’s capacity to handle the higher demand for livestock over Eid and security arrangements. Emanuel provided training to facility staff to address the risks identified in previous investigations. Emanuel also worked with the local government and municipalities to confirm ESCAS requirements.
Emanuel reconciled their control and traceability system records prior to and during Eid. They did not identify any discrepancies, and stated all animals were accounted for in their supply chain.
Emanuel advised that during Eid the trader observed at Al Rai Livestock Market had acted aggressively and refused entry to his pens at Al Rai Livestock Market when approached by supply chain staff in Kuwait performing routine checks. In response, the importer banned the trader from receiving or selling Australian sheep at his pen at the approved abattoir, consistent with the Emanuel’s Supply Chain Management Plan (SCMP). Following the ban, the trader no longer has a selling pen at Al Rai Livestock Market. The importer intended to reclaim any remaining sheep from the trader, however none remained in the pen.
The importer met with the abattoir’s management and supervisors to show the Animals Australia video, review the non-compliant slaughter, provide instruction on corrective actions and reiterate the importance of compliance with standard operating procedures (SOPs) for handling and slaughter of Australian sheep. Emanuel has not identified any further non-compliance at the abattoir.
Department actions and conclusions
Based on information provided by Animals Australia the department determined:
- At least 200 sheep were observed outside the approved supply chain at Al Rai Livestock Market and the sheep were exported by Emanuel. Non-compliant handling and transport of at least some of these animals occurred.
- The trader identified selling Australian sheep at Al Rai Livestock Market had approval to sell Australian sheep from an approved pen at an ESCAS approved abattoir only. Selling sheep at Al Rai Livestock Market was not part of the approved supply chain.
- At least two sheep exported by Emanuel were processed in slaughter lines which were unapproved for Emanuel at the abattoir, with one animal’s slaughter demonstrating non-compliance with ESCAS requirements.
Emanuel took action consistent with their SCMP to investigate and apply corrective actions in response to the non-compliance. The department assessed the actions taken by Emanuel were appropriate to address the non-compliance. The department intends to review Emanuel’s SCMP to identify and address issues with their traceability processes.
In assessing this matter against the guidelines for management of non-compliance, a minor non-compliance with ESCAS control, traceability and animal welfare requirements was recorded against the Emanuel Kuwait sheep supply chain.
The Exporter Supply Chain Assurance System (ESCAS) was implemented in Oman on 1 September 2012.
As at 30 November 2017, a total of 13 consignments of livestock have been exported under ESCAS arrangements to Oman in 2017, including 107,820 sheep making it the fifth largest market for sheep. There are currently four Australian exporters with approved supply chains to export livestock to Oman.
The department has previously published reviews of seven reports relating to non-compliance in Oman. From these reports, four findings of non-compliance have been recorded against exporter supply chains. The reviews can be found at Regulatory compliance investigations.
As at 30 November 2017, there are no reports of non-compliance under investigation for Oman.
Report #140: Sheep exported to Oman – Minor non-compliance
The Department of Agriculture and Water Resources received three exporter reports of non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in Oman during Eid-al-Fitr 2017 (celebrated between 26 and 28 June). The reports related to the same issues and facilities, and therefore have been combined into one review.
During Eid-al-Fitr, 200 to 300 sheep of Australian origin were observed arriving in private cars at an approved abattoir from an unknown source. Some of the sheep were handled in a non-compliant manner and some sheep were dead on arrival. Non-compliant handling of sheep within the approved abattoir was also observed (reported by Wellard Rural Exports Pty Ltd (Wellard) on 7 July 2017 and by Phoenix Exports Pty Ltd (Phoenix) on 10 July 2017).
As a result of their investigations into the above report, Phoenix reported that on 25 June 2017, members of the public had broken into a selling pen at an approved abattoir. Sheep were removed from the selling pen and handled and transported to the abattoir in a manner non-compliant with ESCAS requirements. The abattoir management shut down the selling pens and all sheep remaining in the pens were returned to approved feedlots.
No tag numbers, photographs or identifying information of the sheep was provided with the reports.
Exporter review and actions
Emanuel Exports Pty Ltd (Emanuel):
On 11 July 2017, Emanuel notified the department they had received information about potential non-compliance in Oman, however no detail was provided. The exporter specified it was not a self-report.
Emanuel advised they consulted their importer about the information provided by Phoenix and responded that the abattoir had confirmed selling pens were broken into. However Emanuel did not consider that the report of sheep arriving at an approved abattoir in private vehicles involved their supply chain as no discrepancies in their control and traceability system reconciliations were identified. Emanuel reported that security systems and compliant handling and transport were maintained at facilities in their supply chain over Eid-al-Fitr.
During the Eid-al-Adha festival (celebrated between 1 and 4 September 2017) Emanuel advised it would only supply animals direct to the abattoir for processing, and provide carcase only sales to manage the risk of loss of control.
Phoenix acknowledged non-compliant handling of sheep occurred within the approved abattoir. In accordance with their Supply Chain Management Plan (SCMP), Phoenix representatives perform regular animal handling training in market. Phoenix performed training both before and after receipt of the reports.
A Phoenix consultant reviewed the control and traceability system records and did not identify any discrepancies for animals in market prior to and after Eid-al-Fitr. The consultant visited Oman in July 2017 and conducted a physical count of stock on hand at the feedlot, which supported the accuracy of the traceability records.
Phoenix stated their in market consultant will perform monthly physical reconciliations of sheep at all facilities approved in their supply chain. Phoenix also advised Standard Operating Procedures (SOPs) for animal handling had been updated and are being followed.
A Wellard representative was present at the abattoir when Australian animals arrived in public cars. Wellard advised the sheep were stressed upon arrival and were immediately slaughtered to deliver the best animal welfare outcomes. No identifying information was collected for any of the sheep arriving in public cars.
Wellard advised their importer was not aware of any incidents (thefts) at selling pens on 25 June 2017 and they were only informally advised of a possible incident days later. Based on this advice Wellard were uncertain what had occurred. The incident did not come to the attention of the Wellard representative working at the abattoir on the day.
Wellard advised their control and traceability system records confirmed traceability of all sheep exported by Wellard was maintained between 24 June and 5 July 2017. Wellard will review security around the approved sales points and processing systems on a regular and ongoing basis and arranged for handling and slaughter training to be conducted at the abattoir.
The department provided all other exporters of sheep to Oman with the information received in the reports and asked them to respond to the information in the reports. At the time of the report, three exporters had sheep in Oman:
Another two other exporters had supply chains in Oman but did not have sheep in market.
At the time of the reports, the abattoir was approved in the supply chains of all exporters to Oman. The abattoir was first approved in September 2016 and had a risk rating of high (all facilities in Oman are high risk). The department reviewed all Independent Performance Audit Reports (IPARs) for the abattoir. The most recent performance audit was completed in June 2017. No non-compliance with animal welfare requirements or control and traceability systems was identified during any previous performance audits of the abattoir.
Supply Chain Management Plans (SCMPs) were implemented for all exporters to Oman in April 2017.
Departmental actions and conclusions
The department determined at least 200 sheep were transported to the abattoir in a manner non‑compliant with ESCAS requirements resulting in adverse animal welfare outcomes. The department also determined that sheep were not handled in accordance with ESCAS animal welfare requirements at the approved abattoir.
Although major non-compliance was observed, the exporter/s of the sheep could not be identified as no identifying information (ear tags or other markings) were provided with the reports. No exporters reported that they had exported the sheep.
The department found the corrective actions implemented by the exporters were consistent with their SCMPs. Exporter representatives were in market over Eid-al-Fitr to monitor compliance with ESCAS requirements. The department acknowledged on-going actions will be taken by exporters in response to the report of non-compliance.
In assessing this matter against the guidelines for management of non-compliance, the department determined a majornon-compliance with ESCAS control, traceability and animal welfare requirements had occurred in Oman, but was not able to make a finding against any exporter. The risk rating for all facilities in Oman remains high requiring quarterly audits. In addition all exporters to Oman are required to have a SCMP and to address the additional risks associated with Eid-al-Fitr and Eid-al-Adha. A minor non-compliance with ESCAS animal welfare requirements was recorded against the abattoir for non-compliance with animal welfare requirements.
Report #143: Sheep exported to Oman – Minor non-compliance
On 4 September 2017, the Department of Agriculture and Water Resources received a self-report from Phoenix Exports Pty Ltd (Phoenix) about non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in Oman during Eid-al-Adha (Eid) (celebrated between 1 and 4 September 2017).
Between 29 and 30 August 2017, Phoenix’s in-market representatives observed members of the public arriving at an approved feedlot and removing approximately 100 sheep from the premises. During removal of these sheep Phoenix representatives observed instances of non-compliant handling including sheep being trussed and dragged from the pens.
On 30 August 2017, Phoenix’s in-market representatives also observed five Australian sheep at a livestock market in Barka. Three National Livestock Identification System (NLIS) tag numbers and brands were identified which were linked to properties Phoenix had sourced sheep from.
On 1 September 2017, 20 to 30 Australian sheep were observed arriving for slaughter at an approved abattoir. The sheep were transported and restrained in a manner non-complaint with ESCAS requirements, including being transported in car boots and trussed. Phoenix representatives identified five NLIS tag numbers which could all be linked to properties Phoenix had sourced sheep from.
Phoenix representatives were in Oman as part of their ongoing commitment of additional oversight of their supply chain due to previous reports of non-compliance (see Report #140).
Immediate actions taken at the feedlot:
- The importer contacted the Oman authorities and requested they assist to remove the crowd from the approved feedlot.
- The importer’s staff intervened and stopped people taking sheep, and removed unauthorised people from the feedlot.
- Phoenix representatives addressed the crowd and advised the sale of sheep to the public was not allowed on 29 and 30 August 2017.
- Phoenix representatives intervened to address animal welfare and handling issues on 1 September 2017 as they were identified at the feedlot and abattoir.
Following Eid, Phoenix reconciled traceability reports from the Eid period and were able to identify that 144 sheep were unaccounted for—0.9% of the total livestock in market. The missing sheep are believed to be those taken from the approved feedlot by members of the public.
Phoenix representatives performed random spot checks of processes and documentation at approved facilities in their supply chain during Eid, which indicated compliance with Standard Operating Procedures (SOPs) for ESCAS traceability, transport and slaughtering.
Phoenix were unable to determine where sheep at the Barka livestock market came from and where those arriving at the abattoir left Phoenix’s supply chain.
Phoenix representatives managed and corrected handling issues at the approved abattoir as they arose.
Phoenix and their importer will increase security during future Eid festivals to ensure the public cannot enter the feedlot, and erect additional signage advising the feedlot cannot sell Australian sheep to the public.
At the time of the report, the feedlot was only approved for Phoenix and the abattoir was approved in the supply chains of two other exporters.
There are no livestock markets in Barka with ESCAS approved selling pens, therefore the sheep seen in the market were outside the approved supply chain.
Emanuel Exports Pty Ltd had approximately 300 sheep in Oman during Eid and did not identify any non-compliance in their supply chain. No other exporters had sheep in Oman during Eid.
Following previous non-compliance reports in Oman (see Reports #79 and #87), facilities in Oman are required to be audited four times a year. The department reviewed the Independent Performance Audit Reports (IPARs) for the feedlot and abattoir. No non-compliance with animal welfare requirements or control and traceability systems was identified during any previous performance audits of the feedlot or abattoir. The most recent audits were completed in June 2017. The feedlot and abattoir in this report are different to the feedlot and abattoir referred to in report #140.\
Departmental actions and conclusions
Based on information from the exporter, the department determined:
- approximately 144 Australian sheep were removed from the approved supply chain from an approved feedlot, some of these handled and transported in a manner non-compliant with ESCAS requirements
- Phoenix determined the loss of control through their traceability systems
- five Australian sheep were observed for sale outside the approved supply chain at an unapproved livestock market around 35 kilometres away
- 20 to 30 Australian sheep arrived at an approved abattoir from an unknown source and were transported and handled in a manner non-compliant with ESCAS requirements.
Phoenix identified the non-compliance through monitoring of their supply chain, and demonstrated their internal audit systems were able to identify the non-compliance. Phoenix took action consistent with their Supply Chain Management Plan (SCMP) to investigate and implement corrective action in response to the non-compliance. The actions taken by Phoenix were appropriate to address the non-compliance.
In assessing this matter against the guidelines for management of non-compliance, a minor non-compliance with ESCAS control, traceability and animal welfare requirements was recorded against the Phoenix Oman sheep supply chain.
ESCAS issues identified and addressed by exporters
These reports were received from exporters and complied with the department’s ESCAS self-report requirements. The reports were received within the required time frame, appropriate corrective action was implemented by the exporter and no regulatory action was taken by the department.
The department reviewed the information provided and did not investigate any further, the reports are recorded here for information purposes only.
Australian Rural Exports Pty Ltd (Austrex)
Thirty head of Austrex cattle were transported to an ESCAS approved feedlot outside the Austrex supply chain.
During a visit to an abattoir on 6 October 2017, Austrex representatives could not physically locate 20 cattle which were recorded as still being alive in their traceability system. As a result of their investigations, it was identified the on-site Animal Welfare Officer (AWO) had taken the individual RFID tags home post slaughter to scan later as he was paid by the hour and therefore would appear to have worked more hours. Austrex has requested that the AWO not be stationed at any of their facilities in the future. All animals were able to be reconciled and no loss of traceability or animal welfare issues were identified.
On 15 October 2017, five head of Austrex cattle were transported to an ESCAS approved abattoir outside the Austrex supply chain as they were accidentally penned with other exporter's cattle at an approved feedlot in preparation for movement to an abattoir.
Summary of reviews in progress as at 30 November 2017
Table 7 provides an overview of all regulatory performance reviews in progress as at 30 November 2017. The status of all reviews can be found on the department’s website.
Table 7 Summary of ESCAS regulatory performance reviews in progress as at 30 November 2017
Animal welfare concerns
Sheep and cattle
Loss of control, traceability and animal welfare concerns
Animal welfare concerns
Loss of control, traceability and animal welfare concerns
Self-reported by exporter