Exporter Supply Chain Assurance System Regulatory Performance Report

​A move towards a different reporting approach

The Exporter Supply Chain Assurance System (ESCAS) Regulatory Performance Report is a new approach to the way the Department of Agriculture (department) will provide information about the livestock export trade to stakeholders. 

This report offers a more efficient approach to reviews into both alleged and substantiated non-compliant activity across the livestock export markets.  The report also provides key ‘facts and figures’ relating to exporter and market performance for a given period (in this case, this first report covers January to December 2014). 

The advantage of the new reporting approach is that it allows readers to gain a snapshot of how ESCAS is performing in each of Australia’s livestock export markets in achieving international animal welfare standards for exported Australian livestock.

The department intends to publish this report at least twice a year, offering stakeholders some consistency and frequency in publishing livestock regulatory performance information.

The department’s new approach will improve timeliness in reporting while not reducing transparency. Regulatory performance assessment processes have not changed. Real-time monitoring and actions taken to control market risks remain in place.

Regulatory performance from 1 January 2014 to 31 December 2014; and release of reviews relating to non-compliant activity in export markets


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​​Overview

Since the implementation of the Exporter Supply Chain Assurance System (ESCAS), the Department of Agriculture (department) has typically published a separate report for each regulatory performance review (review) conducted into substantiated allegations or incidents of non-compliance.

The department will now be producing a report covering a specific period of regulatory performance, as well as releasing information summaries for any reviews that have been finalised. It is intended to publish this ‘regulatory performance report’ at least twice per year.

The advantage of the new reporting style, of which this is the first edition, is that it allows readers to gain a snapshot of how ESCAS is performing in each of Australia’s livestock export markets in achieving international animal welfare standards for exported Australian livestock.

The new reporting style provides information summaries for each finalised review into substantiated allegations or incidents of non-compliance. An information summary provides details of each review in a more concise format.
This report includes:

  • the outcomes of regulatory performance reviews conducted into substantiated allegations or incidents of non-compliance that have been finalised. The reviews may have been commenced before or during the reporting period.
  • a statistical overview of the performance of ESCAS in each market during the period of
    1 January 2014 to 31 December 2014.

Related reports

1. Period Summary

In the period from 1 January 2014 to 31 December 2014 (period), 515 consignments approved under Exporter Supply Chain Assurance System (ESCAS) requirements were exported from Australia and included a total of more than 3.5 million livestock. The livestock were exported to a total of 18 markets:

  • Bahrain
  • Brunei
  • Egypt
  • Indonesia
  • Israel
  • Japan
  • Jordan
  • Kuwait
  • Malaysia
  • Mauritius
  • Oman
  • Philippines
  • Qatar
  • Russia
  • Singapore
  • Turkey
  • United Arab Emirates
  • Vietnam

During the period, no substantiated non-compliance was reported to the department for supply chains in 10 of these markets.

In the period, the department commenced 22 regulatory performance reviews into reports of non-compliance with ESCAS requirements involving ESCAS supply chains in Indonesia, Israel (and Gaza), Jordan, Kuwait, Malaysia, Oman, United Arab Emirates and Vietnam. A summary of reviews currently in progress are listed at section four.

This period demonstrates an increase in exporters self-reporting possible non-compliance promptly, with the majority of reviews conducted relating to self-reports.

For incidents reported during the period, the department made a total of 9 findings of non-compliance. The following table summarises the findings of non-compliance against the relevant reports.

Table 1. Summary of findings of non-compliance for reports received and completed during the period January to December 2014

Web Number

Market

Findings

Total

Month of
Publication

Minor

Major

Critical

26

Jordan

 

1

 

1

February 2015

27

Vietnam

 

 

1

1

July 2014

29

Vietnam

1

 

 

1

May 2014

31

Indonesia

2

 

 

2

February 2015

32

Vietnam

1

 

 

1

February 2015

33

Jordan

 

1

 

1

February 2015

34

Indonesia

2

 

 

2

February 2015

Total

6

2

1

9

 

The department recorded one critical, two major and six minor non-compliances in relation to exporters’ ESCAS supply chains. In most cases of confirmed non-compliance, exporters took corrective action on their own initiative and the department’s review found those actions sufficiently addressed the concerns and therefore no further regulatory action was required.

The department did take regulatory action into potential ESCAS non-compliance in Jordan whereby additional conditions were applied to all exporters’ ESCAS supply chains servicing that market in an effort to help prevent, detect and manage unauthorised movement of sheep.

Conditions have also been applied in both Gaza and Israel markets to manage exports to those markets until the review relating to the Gaza market is complete.

The department continues to monitor, through independent performance audit reports and information submitted by exporters, the ongoing performance of the supply chains to determine what measures are appropriate to ensure international animal welfare standards are met. Any further regulatory action will be determined in accordance with the legislative requirements and the guideline on management of ESCAS non-compliance in the Live Animal Export Program.

2. Conduct of regulatory performance reviews

ESCAS requires exporters to send animals to facilities that meet World Organisation for Animal Health (OIE) animal welfare recommendations. Animals must remain in those facilities and the exporter must be able to account for all Australian animals within their supply chain. Legislation and other relevant documents to the export of live animals can be found on the department’s website at Acts, regulations, orders and standards.

The department assesses all reported information that relates to possible non-compliance with ESCAS requirements. Reports of non-compliance are provided through three pathways; self-reports from exporters, allegations from third parties, or Independent Performance Audit Reports (IPARs) for an ESCAS supply chain.

Where it is considered the information provided about possible ESCAS non-compliance may be substantiated, the department conducts a regulatory performance review (review). A review into whether non-compliance with the ESCAS regulatory framework has occurred typically involves obtaining information from exporters and third parties, undertaking technical assessments of photographs and video, making decisions on whether non-compliance has occurred or risks are evident, and considering whether any regulatory action during or following the review is necessary. Each report is treated on a case-by-case basis and a review may take several months to be completed.

Following a review, the department will classify its findings into either no confirmed non–compliance or minor, major or critical non–compliances. The regulatory action that the department may take will be determined in accordance with the legislative requirements and the Guideline on Management of Non-compliance (guideline).

In accordance with conditions of approval of an ESCAS consignment, exporters must notify the department in writing within five working days of becoming aware of non-compliance that has or may have occurred with an approved supply chain. If an exporter self-reports non-compliance and thereafter implements corrective actions for the supply chain to reduce the risk of non-compliance occurring again, the exporter may have effectively demonstrated control of the supply chain. This is a relevant consideration for the department when determining classification of non-compliance in accordance with the guideline and whether any additional regulatory action is necessary.

Recording non-compliance is an effective tool for the department to measure the performance of licensed exporters in accordance with regulatory requirements. Non-compliances are explained in further detail in the department’s guideline and can be found at Guideline - Management of Non-Compliance.

3. Release of regulatory performance reviews

This report includes seven regulatory performance reviews conducted by the department into allegations or incidents of non-compliance (see Table 2 below).

Table 2. Regulatory performance reviews now complete and included in this report

Web
Number

Month report
received

Type

Market

Species

26

 January 2014

third party report

Jordan

sheep

31

 May 2014

self-report

Indonesia

cattle

32

 May 2014

self-report

Vietnam

cattle

33

 May 2014

third party report

Jordan

sheep

34

 June 2014

self-report

Indonesia

cattle

35

 June 2014

self-report

Indonesia

cattle

36

 June 2014

third party report

Kuwait

sheep

A detailed summary of each review is presented below.

4. Summary of reviews currently in progress

The following table summarises regulatory performance reviews that are currently in progress as at 31 December 2014. The statuses of all reviews are posted onto the department’s website at Regulatory compliance investigations.

Table 3. Summary of regulatory performance reviews currently in progress as at 31 December 2014

Web #

Market

Species

Allegation or report of

Month received

Third party complaint/Exporter self-report

28

Gaza

Cattle

Animals outside supply chain and animal welfare concerns

February 2014

Third party complaint

37

Israel

Cattle

Animals outside supply chain

September 2014

Exporter self-report

38

Jordan

Sheep

Animals outside supply chain

October 2014

Exporter self-report

39

Kuwait

Sheep

Animals outside supply chain

October 2014

Exporter self-report

40

UAE

Sheep

Animals outside supply chain

October 2014

Exporter self-report

41

Malaysia

Sheep

Animals outside supply chain

October 2014

Exporter self-report

42

Oman

Sheep

Animals outside supply chain

October 2014

Exporter self-report

43

Jordan

Sheep

Animals outside supply chain

October 2014

Third party complaint

44

Kuwait

Sheep

Animals outside supply chain

October 2014

Third party complaint

45

Malaysia

Sheep

Animals outside supply chain and animal welfare concerns

October 2014

Third party complaint

46

Indonesia

Cattle

Animals outside supply chain

November 2014

Exporter self-report

47

Indonesia

Cattle

Animals outside supply chain

December 2014

Exporter self-report

48

Indonesia

Cattle

Overload of vessel

December 2014

Exporter self-report

49

Indonesia

Cattle

Overload of vessel

December 2014

Exporter self-report

50

Indonesia

Cattle

Use of unapproved abattoir line

December 2014

Exporter self-report

5. In-market regulatory performance (1 January to 31 December 2014)

A summary of the regulatory performance of ESCAS in each market is detailed below including:

  • the number of livestock exported to each market during the period
  • the number of reviews commenced by the department
  • the number and classification of any non-compliances recorded
  • details of any regulatory action taken by the department

Information on each review conducted by the department can be found on the department’s website.

In the period from 1 January 2014 to 31 December 2014 (period), 515 consignments approved under Exporter Supply Chain Assurance System (ESCAS) requirements were exported from Australia to 18 markets and included a total of more than 3.5 million livestock (Table 4).

Table 4. Livestock exported under ESCAS requirements between 1 January and 31 December 2014 (inclusive).

(Source: Department of Agriculture)

Species

Quantity
(Jan-Dec 14)

Buffalo

5065

Cattle

1,153,815

Goats

84,149

Sheep

2,268,047

Grand Total

3,511,076

5.1 Incident free markets

During the period, no substantiated non-compliance with ESCAS requirements was reported to the department for ESCAS supply chains in the following ten markets:

  • Bahrain
  • Brunei Darussalam
  • Egypt
  • Japan
  • Mauritius
  • Philippines
  • Qatar
  • Russia
  • Singapore
  • Turkey

A total of 953,379 sheep, 123,984 cattle, 154 goats and 488 buffalo were exported to ESCAS supply chains in these markets (see Table 5 below) with no incidences of non-compliance evident.

Table 5. Livestock exported under ESCAS requirements between 1 January and 31 December 2014 (inclusive) to markets with no incidences of non-compliances evident.

(Source: Department of Agriculture)

Country

Species

Total

# Consignments

Bahrain

Sheep

300,787

15

Brunei Darussalam

Buffalo

488

5

 

Cattle

4925

 

Goats

154

Egypt

Cattle

27,598

3

 

Sheep

72,842

Japan

Cattle

9119

18

Mauritius

Cattle

5714

3

Philippines

Cattle

26,480

10

Qatar

Cattle

1150

20

 

Sheep

577,550

Russia

Cattle

46,703

4

Singapore

Sheep

2200

1

Turkey

Cattle

2295

1

Grand Total

 

1,078,005

80

5.2 ESCAS performance in markets where incidents have been reported to the department during the reporting period (1 Jan 2014 – 31 December 2014)

5.2.1 ESCAS performance in Indonesia

  • In total, 724,150 cattle were exported from Australia to Indonesia under ESCAS requirements in the twelve month reporting period.
  • Eight self-reports of potential non-compliance with ESCAS requirements for cattle supply chains in Indonesia were submitted to the department by exporters during the period. The department commenced a review into all self-reports; reports where the incidents involved facilities that were common to multiple exporters supply chains were combined into a single review.
  • Following the completion of two reviews (reports 31 and 34), a total of five minor non-compliances have been recorded in relation to exporters' cattle supply chains. The department accepted that the actions taken by each of the exporters in each case sufficiently addressed the concerns and therefore no additional regulatory action was taken. Three other reviews remain in progress.

5.2.2 ESCAS performance in Israel (and Gaza)

Cattle
  • During the reporting period, 73,661 cattle were exported from Australia to Israel under ESCAS requirements. One exporter’s Israel cattle supply chain also included some facilities in Gaza. Livestock destined for the Gaza strip is exported to Israel, and then transported to Gaza. Since November 2013, no exports have been approved directly to Gaza.
  • One report of alleged non-compliance in Israel was reported to the department by a third party (report 30) with no non-compliance recorded. One report of potential non-compliance in Israel was self-reported to the department by an exporter during the period (report 37). The review remains in progress.
  • In addition, alleged non-compliance with ESCAS requirements for Australian cattle in Gaza was reported to the department by a third party, with several pieces of correspondence subsequently provided including additional information on the same matter. All correspondence received has been consolidated into a single incident (report 28) and the department has commenced a review. The review remains in progress.
Sheep

During the period, 125,131 sheep were exported from Australia to Israel under ESCAS requirements, with no incidences of non-compliance evident.

  • During the period, 266,615 sheep were exported from Australia to Jordan under ESCAS requirements.
  • Three reports of alleged non-compliance with ESCAS requirements for sheep exported to Jordan were submitted to the department by a third party (reports 26, 33 and 43), with one exporter also self-reporting possible non-compliance with its ESCAS (report 38). The department commenced a review into each of the reports.
  • Following completion of two reviews (reports 26 and 33) the department recorded two major non-compliances, both in relation to one exporter’s Jordan sheep supply chain.
  • Regulatory action was taken by the department for all exporters servicing that market following the first report of non-compliance and is detailed below. The corrective actions taken by the exporter following the second report of non-compliance sufficiently addressed the concerns and therefore no further regulatory action was taken by the department.

The department's review into two reports is still in progress (reports 38 and 43).

Regulatory action

Regulatory action has been taken by the department to further strengthen control and traceability elements of all exporters ESCAS supply chains in Jordan in an effort to help prevent, detect and manage unauthorised movement of sheep.

Since July 2013, additional conditions were progressively applied that require exporters to have supply chain officers, additional security, marking protocols at facilities and increased reporting obligations for their supply chains in Jordan (see below). The department also included the condition of extra independent performance audit reports for each supply chain, in addition to the regular audit frequency.

As part of the ESCAS, all exporters to Jordan are required to ensure:

  • supply chain officers are physically present at each facility within the supply chain
  • daily reconciliations of livestock are conducted
  • all sheep are ear tagged (original NLIS ear tag or where necessary a replacement tag)
  • all sheep are marked with a visible and durable exporter specific identification upon entry to the approved feedlots and exit from the feedlots to the approved abattoirs
  • adequate security arrangements are in place at each facility
  • monthly regional markets inspections are conducted for sighting of any Australian sheep
  • a supply chain manager reports each month on the effectiveness of the ESCAS
  • a declaration is submitted to the department by a person in management or control for the export company confirming whether or not Australian sheep remained within its supply chain up to the point of slaughter.

5.2.4 ESCAS performance in Kuwait

  • During the reporting period, 704,545 sheep were exported from Australia to Kuwait under ESCAS requirements.
  • Two reports of alleged non-compliance with ESCAS requirements for sheep exported to Kuwait were submitted to the department by a third party (reports 36 and 44), with one exporter also self-reporting possible non-compliance with its ESCAS (report 39). The department commenced a review into each of the reports.
  • Following completion of one review (report 36), no non-compliances were recorded and no additional regulatory action taken for sheep supply chains during the period.

The department's review into two reports is still in progress (reports 39 and 44).

5.2.5 ESCAS performance in Malaysia

Cattle
  • During the period, 51,307 cattle were exported from Australia to Malaysia under ESCAS requirements.
  • One report of alleged non-compliance with ESCAS requirements for cattle exported to Malaysia was submitted to the department by a third party (report 45). The department commenced a review into the report. That review remains in progress.
  • No non-compliances have been recorded and no additional regulatory action has been taken to date.
Sheep
  • During the period, 83,995 goats and 37,619 sheep were exported from Australia to Malaysia under ESCAS requirements.
  • One self-report of non-compliance with ESCAS requirements for sheep and goats exported to Malaysia was submitted to the department (report 41). The department commenced a review into each of the reports. That review remains in progress.
  • No non-compliances have been recorded and no additional regulatory action taken.

5.2.6 ESCAS performance in Oman

Sheep
  • During the period, 71,713 sheep were exported from Australia to Oman under ESCAS requirements.
  • One self-report of possible non-compliance with ESCAS requirements for sheep exported to Oman was submitted to the department by an exporter (report 42). The department commenced a review into the report. That review remains in progress.
  • No non-compliances have been recorded and no additional regulatory action taken.

5.2.7 ESCAS performance in the United Arab Emirates (UAE)

Cattle
  • During the period, 2557 cattle were exported from Australia to the UAE under ESCAS requirements, with no incidences of non-compliance evident and no regulatory action taken.
Sheep
  • During the period, 109,045 sheep were exported from Australia to the UAE under ESCAS requirements.
  • One self-report of possible non-compliance with ESCAS requirements for sheep exported to the UAE was submitted to the department by an exporter (report 40). The department commenced a review into the report. That review remains in progress.
  • No non-compliances have been recorded and no additional regulatory action taken.

5.2.8 ESCAS performance in Vietnam

Cattle
  • During the period, 178,156 cattle were exported from Australia to Vietnam under ESCAS requirements.
  • Three self-reports of potential non-compliance with ESCAS requirements for cattle exported to Vietnam were submitted to the department by exporters (reports 32, 27 and 29). The department commenced a review into each of the reports.
  • A total of one critical and two minor non-compliances were recorded in three cases for the relevant exporter’s cattle supply chain.
  • The department accepted that the actions taken by the exporters in each case sufficiently addressed the concerns and therefore no additional regulatory action was taken.
Buffalo
  • During the period, 4577 buffalo were exported from Australia to Vietnam under ESCAS requirements, with no incidences of non-compliance evident and no additional regulatory action taken.
​ ​
Last reviewed: 4 November 2019
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