Compliance Investigation Report 11(a): Cattle exported to Malaysia in May 2013


On 3 May 2013, the Department of Agriculture received a complaint from Animals Australia alleging non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in Malaysia. On 6 May 2013, video footage was provided that Animals Australia advised was taken on 19 April 2013 at an abattoir in Malaysia.

The allegations were that Australian cattle were not handled or slaughtered according to World Organisation for Animal Health (OIE) standards and that the abattoir identified in the video (‘the abattoir’) was included in an approved ESCAS. This report details the investigation regarding these allegations.

The letter also reported that there was possible non-compliance with ESCAS requirements concerning sheep and goats in Malaysia at separate facilities. These allegations are the subject of a separate report (report 11(b)).

The video showed handling and slaughter of cattle at an abattoir included in three exporter supply chains. One of the exporters was not using the facility at the time of the allegations. The investigation found that it was likely the cattle in the footage were exported from Australia and were most likely exported under ESCAS requirements. However, due to the quality of the footage provided, the investigation was unable to confirm the tag numbers of the cattle or determine which exporter exported the cattle.

The department determined there was evidence of some non compliance with OIE animal handling and slaughter requirements for cattle, as set out in the ESCAS animal welfare performance targets and measurement checklist, at the abattoir.

From the time the complaint was received and while the investigation was occurring, additional conditions were applied to ensure compliance with ESCAS requirements. These conditions were applied to subsequent consignments exported by International Livestock Export Pty Ltd (ILE) and Austrex to the abattoir. Subsequent independent performance audits performed at the abattoir have confirmed compliance with OIE animal welfare recommendations.

No non-compliance was recorded against either exporter.


On 3 May 2013, the Department of Agriculture (the department) received a complaint from Animals Australia alleging non compliance with ESCAS arrangements in Malaysia. The complainant alleged that Australian cattle were not handled and slaughtered according to World Organisation for Animal Health (OIE) standards at an abattoir in Malaysia included in an approved ESCAS (‘the abattoir’).

The complaint included video footage of cattle provided on 6 May 2013, that Animals Australia advised was taken on 19 April 2013 at the abattoir in Malaysia.

ESCAS requirements for feeder and slaughter livestock exported to Malaysia took effect on 1 September 2012.

Conduct of the Investigation

On receipt of the complaint from Animals Australia, the department assessed the video to determine whether there was evidence supporting the allegations of non-compliance with regulatory requirements. The initial assessment of the video footage supported the complaint from Animals Australia and a formal investigation by the department was commenced.

The focus of the investigation was to determine:

  • If the video footage was taken in the facility in Malaysia on the date alleged by Animals Australia
  • If any cattle shown in the video footage were exported from Australia under ESCAS arrangements (that is, after 1 September 2012) and if so, can the exporter be identified
  • If the handling and slaughter of cattle shown in the video footage was consistent with the OIE animal welfare requirements, as set out in the ESCAS animal welfare performance targets and measurement checklist.

The department’s investigation included assessment of the information provided by Animals Australia, departmental records of export consignments, independent initial and performance audits performed at the abattoir, information provided by the exporters including an independent animal welfare assessment of the evidence, and information collected independently by the department.

The department identified that three exporters had received approval to export slaughter cattle to Malaysia between 1 September 2012 and 19 April 2013 under ESCAS arrangements. On 9 May 2013, the department wrote to the three exporters that had received ESCAS approvals that included the abattoir in question. The letters requested the exporters provide information relevant to the investigation. All three exporters provided a report on the allegations. Two exporters, International Livestock Export (ILE) and Australian Rural Exports (Austrex) also provided an assessment of the video footage, conducted by an independent animal welfare expert.

Initial assessment found that two exporters, Australian Rural Exports Pty Ltd (Austrex) and International Livestock Export Pty Ltd (ILE) had approved ESCAS supply chains that could potentially be linked to the livestock that were the subject of the ESCAS non-compliance allegations. These exporters and their consignments have been the subject of the investigation. A third exporter, South East Asian Livestock Services (SEALS) had not sent any cattle to the abattoir under ESCAS requirements at the time the footage was taken and was excluded from further investigation.

Investigation Findings

The investigation concluded that there was no reason to doubt that the video was taken in the abattoir on the date alleged by Animals Australia. The abattoir is part of an approved ESCAS for multiple exporters in Malaysia.

The video footage showed slaughter of what appeared to be Brahman/Brahman cross cattle at the abattoir. Brahman and Brahman cross cattle are exported from Australia to Malaysia for slaughter. All cattle within Australia, including those exported from Australia, are required to have a National Livestock Identification System (NLIS) radio frequency identification device (RFID) that contains a microchip encoded with a unique identification number. In addition, a NLIS identification number is printed onto the surface of the tag. Some cattle in the video footage were observed to have RFID ear tags consistent with Australian NLIS requirements; however the individual code on each RFID was not readable due to the quality of the video footage.  As such, the investigation was unable to identify cattle to a particular consignment or exporter.

The records showed that 12 consignments by three exporters consisting of a total of 16 462 slaughter cattle had been exported and arrived in Malaysia between 1 September 2012 and 19 April 2013. Two consignments that had been exported but not yet arrived in Malaysia at the time the video was taken, were excluded from the investigation.

Departmental records showed that several consignments of cattle exported under ESCAS requirements were being slaughtered at the abattoir around the time that the video was taken, and so it was likely that the cattle seen in the video were exported to Malaysia under ESCAS requirements. At the time of the complaint two exporters, Austrex and ILE, had sent cattle to the abattoir.

The complaint included several video files with approximately 21 minutes of video showing slaughter of cattle in the abattoir and approximately three minutes of compiled video of a downer animal in the raceway leading to the abattoir.

The investigation considered the animal welfare assessment of the video provided by the department’s animal welfare experts as well as an assessment provided by an animal welfare expert on behalf of the exporters involved. These assessments provided different opinions as to whether cattle were showing signs of consciousness after stunning and slaughter and highlighted the difficulty in determining this when cattle are electrically stunned. However it was determined that there was evidence of non-compliance with one of 20 points of the checklist relating to animal handling, and two of 22 points of the checklist relating to slaughter with stunning. The non-compliances relating to slaughter concerned the routine for checking for evidence of death after slaughter. The handling and slaughter non-compliances are summarised in Table 1. The department also reviewed initial and performance audits performed at the abattoir before and shortly after the complaint, which did not show any of these non compliances occurring.

Table 1 - Summary of non-compliances identified during Department of Agriculture assessment of video provided in the allegations against the cattle ESCAS handling and slaughter checklist
Animal welfare performance measure or target Assessment by the Department of Agriculture
Element 1 – Handling of livestock
1.9 - Downer animals (animals that cannot walk or stand) are identified and provided with special handling and management. In several videos (3 minutes of cumulative footage) animal was visible down in a raceway and appeared unable to stand. The animal is shown to be by itself for most of the time. Staff are shown trying to startle the animal into rising. At one point, another animal is observed to walk over the top of it. No actions were seen to be taken by staff to prevent this from occurring at the time. Finally the animal is left alone in the raceway. A later video shows the animal standing and walking away.
Element 5 – Slaughter with Stunning
5.20 - Death, indicated by cessation of pulsatile bleeding, lack of corneal reflex and lack of rhythmic breathing, is assured before performing any other procedures. Cattle were seen being electrically stunned and released from the restraint box. After stunning, the cattle were quickly slaughtered. It was not apparent that checking for signs of death, including checking of corneal reflexes, occurred after slaughter.
5.21 - Animals must not have water thrown on them or be otherwise disturbed prior to confirmed death. Cattle were not seen to be checked for signs to confirm death had occurred after slaughter and prior to performing further handling and hosing down of the slaughtered cattle.

Investigation Conclusions

The investigation found that while it is likely the cattle were exported from Australia under ESCAS requirements it was not possible to determine which licensed exporter exported the cattle, due to poor visiblity of cattle ear tags in the videos.

The conclusion from assessment of the video footage is that some aspects of the handling and slaughter of cattle shown in the footage were not in accordance with all required points in the ESCAS checklist, and this non-compliance could potentially lead to poor animal welfare outcomes for cattle at that facility.

Regulatory Actions

During the course of the investigation, two exporters using this abattoir applied for further approvals to export cattle to the Malaysia supply chains. Having considered the information provided by Animals Australia, and the exporters, and the information collected by the department, subsequent consignments of cattle to Malaysia by ILE and Austrex were required to undertake the following additional activities:

  • A designated animal welfare officer must be present in the abattoir whenever cattle from the relevant consignment are being slaughtered
  • For the first consignment of cattle to Malaysia by ILE and Austrex approved after receiving the complaint, an independent audit must be undertaken at the abattoir, including a physical visit to the facility, within 30 days of slaughter of the first animal from the consignment. The audit must include observation of slaughter of animals from the consignment, and verification of whether a designated animal welfare officer was present at all times that cattle from the consignment were being slaughtered.

The department will continue to monitor performance of the abattoir through Independent Performance Audit reports. The last audit performed in November 2013 did not find evidence of any non-compliance.

Actions Taken by the Exporters

In May 2013 after reviewing the footage, Austrex and ILE advised the department that they had sent representatives to Malaysia to review the training and operations at the abattoir. Both exporters also advised the department that they arranged for Meat and Livestock Australia (MLA) to undertake additional training with abattoir staff after the complaint. Austrex and ILE advised that the operator of the abattoir has had an additional animal welfare officer (AWO) trained to assist their supervisor who would be identifiable in uniform. Both exporters provided additional audits of the facility, occurring on 16 May 2013 and on 25 July 2013 – the second audit occurring in accordance with the additional condition of approval applied to consignments for ILE and Austrex as listed above. These audits did not find any evidence of any non-compliance and the second audit noted that an Animal Welfare Officer was present during the whole slaughtering process.

In addition, SEALS agreed to conduct an audit of the abattoir within three weeks of slaughter of the first animal from their only consignment exported that included use of the abattoir. The department has since received this audit, performed on 30 August 2013, which showed that slaughter and handling was in accordance with OIE animal welfare requirements.

Actions taken by other parties

On becoming aware of the allegations in May, the Director General of the Malaysian Department of Veterinary Services (DVS), Datuk Dr Abdul Aziz Bin Jamaluddin, informed the Australian Chief Veterinary Officer Dr Mark Schipp of the DVS’s support for animal welfare, and advised they would take the following actions which relate to animal welfare including:

  • Improving security measures at all government owned abattoirs including installing closed-circuit television
  • Appointing Animal Welfare Officers at all State DVS Offices.
Last reviewed: 22 April 2021
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