Compliance investigation report 14 - sheep exported to Jordan

​Summary

On 20 June 2013, the Department of Agriculture (the department) received a complaint from Animals Australia alleging non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in Jordan. The complainant alleged that many hundreds of Australian sheep exported under ESCAS arrangements had been offered for sale and slaughter at locations in Jordan and Lebanon which are not in an approved supply chain. Photographs and videos of sheep were provided to the department. Animals Australia advised that these were taken during a visit to Lebanon on 7 June 2013 and to Jordan between 8 and 10 June 2013.

The department’s investigation included assessment of information provided by Animals Australia, departmental records of export consignments, information provided by the two exporters that have exported to Jordan under ESCAS arrangements, information from the National Livestock Identification System (NLIS) database and information collected independently by the department.

The investigation concluded it was highly likely that many of the sheep depicted in the photographs were Australian, based on the presence of ear tags and other physical characteristics. The investigation could not confirm all of the sheep shown in the photographs and videos were exported under ESCAS or which of the two exporters was responsible. The investigation traced eight sheep shown in the photographs and videos to consignments exported under ESCAS requirements by Livestock Shipping Services Pty Ltd (LSS).

This was the first complaint received about sheep leaving the supply chain in Jordan. Similar to other export markets where there has been a number of sheep found outside of the supply chain, all exporters of sheep to Jordan are now required to undertake additional activities designed to strengthen control and traceability within the exporter’s supply chain.

1. Introduction

On 20 June 2013, the Department of Agriculture (the department) received a complaint from Animals Australia alleging non compliance with Exporter Supply Chain Assurance System (ESCAS) arrangements in Lebanon and Jordan. The complaint alleged that many hundreds of Australian sheep exported under ESCAS arrangements had been offered for sale and slaughter at locations not included in the approved supply chains. The complaint included photographs and videos of sheep that Animals Australia advised were taken in Lebanon on 7 June 2013 and in Jordan between 8 and 10 June 2013.

2. Conduct of the Investigation

On receipt of the complaint from Animals Australia, the department assessed the information and commenced an investigation.

ESCAS requirements for feeder and slaughter livestock exported to Jordan took effect on 1 September 20121. Since 2003, no livestock have been exported directly from Australia to Lebanon. However, the department is aware that some sheep exported from Australia to Jordan prior to the implementation of ESCAS were later sent on to Lebanon. The complaint alleges that the sheep were exported to Jordan and later transported into Lebanon. The focus of the investigation was to determine:

  1. If the photographs and videos were taken in the locations on the dates alleged by Animals Australia.
  2. If any sheep shown in the photographs and videos were exported under ESCAS arrangements (that is, after 1 September 2012), and if so, can the exporter be identified.
  3. If the handling and slaughter of sheep shown in the videos provided by Animals Australia was consistent with the World Organisation for Animal Health (OIE) animal welfare requirements as set out in the ESCAS checklist.

1 Further information on the ESCAS framework is available on the department’s website.

3. Information Supplied by the Exporters

A condition of ESCAS approval is that the exporter must provide the department with any additional information that the department requires. The department identified that two exporters, Livestock Shipping Services Pty Ltd (LSS) and Wellard Rural Exports Pty Ltd (Wellard), had received approval to export sheep to Jordan between 1 September 2012 and 10 June 2013. Each exporter exports to a separate approved supply chain. The two supply chains share one common facility, an abattoir.

On 5 July 2013, the department wrote to the two exporters with approved supply chains in Jordan. The letters requested that the exporters provide specified information relevant to the investigation.

Supply chain 1

LSS provided all of the information requested by the department. A summary of the information provided is shown below in Table 1.

Table 1. Summary of information requested by the department and responses received from LSS for supply
Information Requested

Summary of Exporter response

Comment on the normal time taken to slaughter all animals in one consignment in the supply chain.

The exporter reported that due to the large numbers of sheep held in the feedlots, sheep could remain in the supply chain for up to eight or nine months or longer.

Any information relating to animals exported prior to 1 September 2012 remaining in the supply chain, if relevant, including the number of sheep exported prior to 1 September 2012 and details of the method of separation of the sheep exported prior to 1 September 2012 from sheep exported after 1 September 2012.

The exporter provided information on the sheep exported to supply chain 1 prior to 1 September 2012. The exporter’s submission stated that there were a small number of pre-ESCAS sheep remaining, and that it is understood that some of these sheep may have been sold to Lebanon after 1 September 2012. The exporter reported that the Property Identification Codes (PIC) identified in Lebanon do not correlate to any of their pre- or post-ESCAS records.

Sheep exported prior to 1 September 2012 are being held in separate pens at the feedlot facilities. The exporter advised this was confirmed by an independent audit. LSS also advised that in addition to instructions issued to the importer to hold pre and post ESCAS sheep separately, the importer was advised to treat all sheep as post ESCAS sheep.

LSS reported that at the time of introduction of ESCAS (1 September 2012) there were approximately 75,000 pre-ESCAS sheep still in the supply chain. LSS reported that sheep can remain in the supply chain for 8 – 9 months or longer. LSS suggested that there was a short-term confusion between pre- and post-ESCAS sheep, resulting in ESCAS sheep moving outside the approved supply chain or a mix up of sheep during transfer or sale to other destinations.

Detailed data for the supply chain for sheep exported since 1 September 2012.

The exporter provided a detailed reconciliation of sheep exported since 1 September 2012. The exporter advised the department that they determined in a review conducted of all facilities and activities in the supply chain, the importer’s reconciliation does not indicate that there were any sheep moved outside of the approved supply chain.

Electronic list of property identification codes for the sheep exported to Jordan in each of the consignments identified.

The exporter provided a list of PICs for each consignment of sheep exported since 1 September 2012. There were 933 vendors listed for the seven consignments.

Note that two of these consignments had not arrived at the time the footage was taken.

Exporter plans to investigate the integrity of the accountability system of the supply chain.

 

The exporter concluded that there is not any objective indication of the possibility of any non-compliance with the ESCAS supply chain since its inception.
The exporter provided information on actions taken following the complaint, which included:

  • Sending the LSS Supply Chain Manager to Jordan to assist the importer and supervise the investigation of the concerns through a full desktop and physical review of all facilities and activities in the supply chain
  • Reviewing the evidence provided in the complaint
  • Instructing the importer to continue to hold pre and post ESCAS sheep in separate pens at the feedlot facilities
  • Instruct the importer to process all sheep as post-ESCAS sheep.

Supply chain 2

Wellard provided all of the information requested by the department. A summary of the information provided is shown below in Table 2.

Table 2. Summary of information requested by the department and responses received from Wellard for supply
Information Requested

Exporter response

Comment on the normal time taken to slaughter all animals in one consignment in the supply chain

The exporter reported that in general the time taken to slaughter all sheep in a consignment exported can be between 40 to 90 days.

Any information relating to animals exported prior to 1 September remaining in the supply chain, if relevant, including the number of sheep exported prior to 1 September and details of the method of separation of the sheep exported prior to 1 September from sheep exported after 1 September 2012.

The exporter provided information on the sheep exported to supply chain 2 prior to 1 September 2012. Exporter representatives visited their facilities in Jordan in April 2013 and confirmed that there were no Australian sheep being held there at that time. This meant that there was no requirement for separation as there were no pre-ESCAS sheep at the premises when their first ESCAS consignment arrived in May 2013.

Detailed data for the supply chain for sheep exported since 1 September 2012

The exporter provided a detailed reconciliation of sheep exported since 1 September 2012. There was no evidence of sheep leaving the approved supply chain in the reconciliation provided.

Electronic list of property identification codes for the sheep exported to Jordan in each of the consignments identified.

The exporter provided a list of PICs for each consignment of sheep exported since 1 September 2012. There were 81 vendors listed for the one consignment exported to this supply chain.

Exporter plans to investigate the integrity of the accountability system of the supply chain.

The exporter concluded, based on the reconciliation and a detailed assessment by Wellard staff, that there was no leakage from the supply chain.

The exporter provided information on actions taken to date, which included:

  • Sending company staff to Jordan to investigate the concerns
  • Meeting with the importer
  • Physical count of sheep in the feedlot
  • Reviewing the evidence provided in the complaint.

The department reviewed records of all feeder and slaughter sheep exported to Jordan since ESCAS requirements took effect on 1 September 2012. The records showed that six consignments had been exported on five voyages between 1 September 2012 and 10 June 2013 to the two approved exporter supply chains. A summary of the voyages and supply chains is shown below in Table 3.

Table 3. Summary of voyages of slaughter sheep exported to Jordan and discharged between 1 September 2012 and 10 June 2013 showing exporter, discharge date, coded voyage identifier, load port, number of sheep and coded supply chain.
Exporter

Voyage

Load Port

Sheep

Completion of Discharge Date

Supply Chain

LSS

1

Adelaide

51 060

23/10/2012

1

LSS

Fremantle

21 916

23/10/2012

1

LSS

2

Fremantle

48 385

11/11/2012

1

LSS

3

Fremantle

35 061

17/02/2013

1

LSS

4

Fremantle

69 763

25/03/2013

1

Wellard

5

Fremantle

45 722

23/05/2013

2

LSS reported that sheep may remain in the supply chain for more than nine months. The last LSS consignment exported to Jordan prior to ESCAS implementation in the market (1 September 2012) arrived in Jordan on 11 August 2012, ten months before the photographs and video were taken. In July 2013, LSS reported that there were approximately 75 000 pre-ESCAS sheep still in the supply chain at the time that ESCAS was introduced (1 September 2012). At the time the complaint was received, LSS had exported 226,185 sheep under ESCAS on four voyages, the last of which completed unloading on 25 March 2013 (Table 3).

Wellard had exported one consignment of 45,722 sheep, which completed unloading in Jordan on 23 May 2013. The company advised there were no pre ESCAS sheep exported by Wellard from April 2013 (see Wellard response, Table 2).

4. Investigation Findings

The investigation concluded that the photographs and video provided by Animals Australia were taken on the dates alleged by Animals Australia.

The photographs and video showed sheep at locations in Irbid and Sahab in Jordan, as well as in Lebanon. Some of the breeds of sheep in the photographs and video provided are commonly exported from Australia, including Merino and Merino crossbreed sheep. Many of the sheep were tail docked and mulesed, which are common husbandry practices in Australia. Mulesing is practiced only in Australia. Based on physical characteristics, the investigation concluded there were approximately 1100 Australian sheep in the photographs and videos.

In addition, many of the sheep in the photographs and videos had ear tags and ear notches consistent with Australian identification systems. Sheep exported from Australia are required to have a visual National Livestock Identification System (NLIS) ear tag that bears the PIC of the property the sheep originated from; the tags do not identify individual animals. Many sheep in the photographs and videos appeared to have Australian NLIS tags, of which 51 had a clearly readable PIC and were able to be traced back to identify the Australian property of origin.

Some of the sheep had short wool and some had visible shearing marks in their wool, which indicates that the sheep were recently shorn. The sheep that were recently shorn were most likely shorn close to the time of export in order to meet standard 1.19 of the Australia Standards for the Export of Livestock (ASEL) and exported in a consignment that arrived in Jordan shortly before the photographs were taken.

The department, therefore, concluded that it is highly likely that many of the sheep in the photographs and videos were exported from Australia to Jordan. This conclusion was based on the department’s assessment of the sheep shown in the photographs and videos including the breed and appearance of the sheep and the presence of ear tags and ear notches.
Taking into account that at the time the photos and video were taken, 271,907 sheep had been exported under ESCAS arrangements, the department considered it was more likely than not that many of the sheep shown in the photographs and video were exported under ESCAS arrangements. The department considered the possibility that the sheep in the photographs and video were exported prior to 1 September 2012, but concluded that it was more likely that many of the sheep, especially those that were recently shorn, were exported under ESCAS arrangements. Several sheep in the photographs were able to be traced to ESCAS consignments listed in Table 3.

The investigation found that of the 51 readable tags, eight could be linked only to post-ESCAS consignments exported by LSS. There were two readable tag numbers that were linked to post-ESCAS consignments for both exporters but the investigation could not determine which consignment the sheep originated from.

The complaint from Animals Australia also included photos and videos showing the handling and slaughter of sheep at roadside stalls outside of approved ESCAS supply chain facilities. As discussed above the department determined that it is highly likely these sheep were of Australian origin and likely they were exported under ESCAS arrangements.

The department reviewed the videos of sheep handling and slaughter against the ESCAS animal welfare performance targets and measurements checklist for sheep. The assessment determined that the handling and slaughter shown in the video did not meet several points in element 1 (handling of livestock), element 2 (land transport of livestock) and element 6 (slaughter without stunning) of the checklist. A summary of the assessment findings is outlined in Table 4.

As the department could not definitively link the sheep that were the subject of the poor handling and slaughter practices to a particular exporter or consignment, a specific finding in relation to animal handling and slaughter could not be made against a particular exporter.

Table 4. Summary of non-compliances identified during the department’s animal welfare assessment for videos of sheep handling and slaughter against ESCAS checklist.
Animal welfare performance measure or target Assessment by the department

Element 1 - Animal Handling

1.8 Animals are handled to avoid harm, distress or injury.

 

 

 

Ineffective manual restraint and handling of sheep is shown. The videos show animals being dragged by the hind leg on back, and also being lifted and carried by legs and back of the neck for an extended period. The sheep are then restrained by a foot on the neck.

 

 

Element 2 – Land Transport of Livestock

2.5 The vehicles were suitable for transporting livestock of the class involved and for the distance required.

The videos show sheep being transported in the boot of a car.

Element 6 – Slaughter Without Stunning

6.2 The approach to, and floor of the restraining area is not slippery

Videos show the sheep slipping on the wet tiled floor; a foreleg goes down a drainpipe in the floor.

6.3 The method of restraint employed is appropriate for the size and class of livestock being slaughtered

The technique used to restrain sheep prior to slaughter was inappropriate.

6.4 Animals are presented for slaughter without being unduly stressed.

A sheep was shown in the videos to be isolated before slaughter; the sheep was dragged by a hind leg and shown slipping and struggling.

6.8 The head of the animal is kept in extension to prevent the edges of the wounds touching until the animal is dead

Immediately after sticking the head is released and moves back to its normal position.

6.15 Animals must not have water thrown on them or be otherwise disturbed prior to confirmed death.

Videos show the sheep being hosed down before death is confirmed.

5. Investigation Conclusions

The investigation concluded that it is highly likely many of the sheep shown in the photographs and videos were of Australian origin and more likely than not that the sheep were exported from Australia to Jordan under ESCAS arrangements.

The investigation could not confirm if all of the sheep shown in the photographs and videos were exported under ESCAS or which exporter was responsible. While some poor handling and slaughter practices were apparent in the videos, the department could not link the animals to a particular exporter, therefore a specific finding in relation to animal handling and slaughter was not made against either exporter.

The investigation was able to confirm that eight of the sheep were exported by LSS under ESCAS arrangements. The department has recorded a major non‑compliance against the LSS supply chain in relation to this finding. The non-compliance was classified in accordance with the Guideline - Management of Non-compliance. The non-compliance was classified as major because there was a loss of control; the animals were no longer in the approved supply chain facilities.

6. Regulatory Actions Taken

In accordance with the Final Report of the Industry Government Working Group for Live Sheep and Goat Exports, any regulatory actions taken as a result of the finding of the investigations apply to all exporters of livestock to the market. Although non-compliance was only recorded against one exporter (LSS), the investigation was unable to establish which supply chain facilities were associated with the sheep found in Irbid and Sahab in Jordan as well as Lebanon. Regulatory actions were applied to all exporters supplying sheep to the supply chains in Jordan.

In addition to the normal ESCAS requirements, exporters of sheep to Jordan have been required to undertake additional activities to strengthen control and traceability elements of their supply chains.

Additional requirements were applied to LSS from July 2013, due to a delay in the exporter providing the department with the reconciliation of its supply chain.

In October 2013, in response to additional information provided to the department (and currently under investigation), the department applied additional requirements to both exporters, to provide greater confidence that ESCAS would be complied with.

From July 2013 LSS were required to undertake the following additional activities:

  • A Supply Chain Officer (SCO) must be in place to monitor the supply chain including conducting daily reconciliation of sheep.
  • The exporter must supply the department with an independent audit report on the effectiveness of the SCO, which must assess:
    • whether the SCO conducted regular reconciliation; and
    • the effectiveness of actions taken by the exporter to account for sheep and prevent movement of sheep to locations outside the supply chain.

From October 2013 both exporters were required to undertake the following additional activities:

  • Ensure that a Supply Chain Officer (SCO) is physically present at each facility within the supply chain to ensure that traceability and control is maintained and complete the following activities:
    • conduct daily reconciliations of all animals
    • ensure that all animals are marked with an exporter specific identification on entry to and exit from the feedlot.
  • Every three weeks, provide the Department of Agriculture with:
    • A declaration confirming whether sheep remained in the supply chain and that appropriate security is in place
    • A consolidated report on daily reconciliations completed by the SCO at each facility.

The exporters have complied with the additional conditions and provided the required reports. These reports monitor whether sheep are remaining in approved facilities particularly when transported from the feedlot to the abattoir. The numbers arriving at the abattoir are reconciled with the number slaughtered and the number that left the feedlot. The reports have not shown loss of animals.

Two separate investigations are underway into further allegations (October 2013 and January 2014) of leakage of Australian sheep in Jordan.

Last reviewed: 4 November 2019
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