Standard

SA2.1 A person involved in handling, selection, loading, transporting and unloading
livestock must be competent to perform their required task, or must be
supervised by a competent person.

The industry does not want to spend money training people to handle animals with care and respect. As a result hitting, kicking and belting, although not acceptable are common place. For a person to be deemed competent it stands to reason they MUST be professionally trained.

The use of the term competent implies the person has some level of ability in humane and respectful handling. However there is no measure to gauge a level of competency as there is no training system in place.

There MUST be a national training scheme in place to guarantee that handlers have a recognised level of understanding and ability.

It is important that the competent is linked to a scheme in the standards.

Define competent- replace with:
SA2.1 A person involved in handling, selection, loading, transporting and unloading
livestock must be competent in and accredited to Australian National Training Scheme (number) to perform their required task, or must be
supervised by a competent and accredited to Australian National Training Scheme (number) person.

Standard

SA3.1 Vehicles and facilities must be constructed, maintained and operated in a way that minimizes risks to welfare of livestock.
Vehicles and facilities must:
i) be appropriate to contain the species
ii) have effective ventilation
iii) have flooring that minimises the risk of injury or of livestock slipping or falling
iv) be free from internal protrusions and other objects that could cause injury
v) have sufficient vertical clearance for livestock to minimise the risk of injury.

Trucks are fitted with ‘crates’ which enable the transport of a variety of animal species. Some crates are designed to transport more than one species. It is therefore important that the flooring be designed to allow footing and comfort for lying down of all species. For example: some cattle crate floors have raised ‘ridges’ built into the floor of the crate. This gives cattle a secure footing but when sheep are transported in these crates, they are, stressed with the transport process itself and unable to lie down.

There is no national crate standard which ensures all crates conform to an expected level for welfare. There is no requirement for a truck owner to prove his crate provides the internal head room, air flow and ventilation, and overall safety for the animals before he is allowed to transport the animals. At present it is up to the regulators to prove the crate fails to meet animal welfare laws. This means animals can suffer and die without thing being done about it.
The standard: ‘have sufficient vertical clearance for livestock to minimise the risk of
injury.’ This means an animal can be forced into a pen which is too small and be transported for hours under that condition. Prosecution is in providing evidence that the animal sustained injury- no mention of the suffering because the animal could not stand naturally. Totally unacceptable. In Europe the standard expects the animal to be able to stand with a certain amount of headroom.

Interestingly the guidelines state: GA3.5 The livestock crate should be designed to ensure that livestock, excluding poultry, can rise from lying in a normal manner without contacting overhead deck structures. Obviously they don’t want any enforcement of this so the standard has be written to be unenforceable.

Replace with:
SA3.1 Vehicles and facilities must be constructed, maintained and operated in a way that poses no risks to welfare of livestock.
i) be appropriate to contain the species.
ii) have effective ventilation- comparable to the air changes stated in std: SB8.9 whereby vehicles must have effective ventilation, with fans and other equipment providing at least 12 air changes per hour.
iii) have flooring that minimises the risk of injury or of livestock slipping or
falling, but also allow the animals to lay down on a flat surface.
iv) be free from internal protrusions and other objects that could cause injury
v) allow animals to stand naturally without touching overhead structures.

Standard

SA4.1Livestock must be assessed as fit for the intended journey at every loading. An animal is fit for a journey if it is:

Animals must not be prodded, pushed or harassed in any way would could obscure or mask an injury. Animals which may be able to weight bear on all four legs must also be checked for deformities like arthritis which may present as serious stressors during transport.

Include trained and accredited persons. Replace with:
SA4.1Livestock must be assessed by trained and accredited persons as fit for the intended journey at every loading. An animal is fit for a journey if it is:

i)able to walk on its own by bearing weight on all legs
Replace with:
i)able to walk on its own without human interference by bearing weight on all legs

ii)not visibly dehydrated
This clause can only be applied effectively if our amended SA4.1 is in place. The person responsible MUST be trained to know what to look for .

iii)not showing visible signs of severe injury or distress
Again, fully accredited persons with knowledge of animal distress (severe injury is obvious) must be in attendance to guarantee compliance.

iv)free from conditions that are likely to cause increased pain or distress during transport
Again, fully accredited persons must be in attendance to guarantee compliance especially in the case of recognising mastitis, brucellosis, cancers, arthritis.

v)not blind in both eyes

vi)not known to be, or visually assessed not to be, within 2weeks of parturition, unless the water deprivation time and journey is less than 4 hours duration to another property.

‘Not known’ and ‘visually assessed’ are not definitive and provide an ‘out’ when problems result. It is very difficult to visually assess pregnancy in animals.
The current Code of practice states that pregnant animals in the last trimester should not be transported. With good reason. In addition this guideline has worked well at preventing suffering and cruelty, so why change it? Late pregnancy animals can suffer pregnancy toxaemia and also premature delivery bought on by transport. The chances of survival of both mother and offspring are slim, with many mothers and newborns being trampled to death. (Example Cattle birthing enroute from Mt Augustus to Midland, many mothers and new borns died- successfully prosecuted)

The proposed Standard which will allow the transport of heavily pregnant animals has been drafted to accommodate the diary industry of Victoria.
Veterinarian signed certification must be provided for the transport of all late pregnant animals. Consignors must provide documentation attesting to the condition of their animals and must be held accountable for breaches of this requirement

Replace with:
vi) not to be, within 2 weeks of parturition, or within 2 weeks of giving birth, or lactating unless authorised with written documentation as fit for transport by a vet, the water deprivation time and journey is less than 2 hours duration to another property.

Standard

SA4.2Any livestock judged as not fit for the intended journey must only be transported under veterinary advice.

Vet advice may be given over the phone without the vet ever seeing the animal/s. This allows the ‘owner’ to get out of responsibility for any adverse outcome which could be prosecutable.

Replace with:
SA4.2 Any livestock judged as not fit for the intended journey must only be transported under signed veterinary authorisation.

Standard

A4.3 The consignor must only supply livestock that are assessed as fit for the intended journey
Acceptable

Standard

SA4.4Where livestock are assessed to be not fit for the intended journey before loading, the person in charge must make effective arrangements for the care, appropriate treatment or humane destruction of weak, ill or injured livestock at the first opportunity.

Trained and accredited persons must ensure the correct procedures are undertaken to minimize pain and suffering of livestock. This may include veterinary care administered in situ thus minimizing stress and further transport or euthanasia which must be undertaken immediately. Livestock welfare must be the priority and all solutions/treatments must be employed without delay. ‘The first opportunity’ is open to interpretation and the discretion of the ‘person in charge’. This may conflict with the needs of the animal which must take precedence.

Replace with:
SA4.4Where livestock are assessed by a trained and accredited person to be not fit for the intended journey before loading, the person in charge (again trained and accredited) must make effective arrangements for the care, appropriate treatment or humane destruction of weak, ill or injured livestock without delay.

Standard

SA5.1 If the maximum permitted time off water is reached, livestock must be
provided with water, food and rest before starting another journey.

Acceptable so long as the required time is stated in the Stds for each species in the species specific section.

Standard

SA5.2 Time off water must be managed to minimise risk to the welfare of the
livestock according to:
i) the increased risk to livestock welfare of longer journeys up to the permitted maximum time off water.
ii) assessed fitness of the livestock for the remainder of the intended journey.
iii) predicted climatic conditions, especially heat or cold.
iv) class of livestock, especially if weak, pregnant, recently having given birth, lactating or immature

The industry is trying to give drivers the leeway to make judgments without becoming too prescriptive, however it is necessary to provide some absolute direction. The longer the journey takes, the more risk the animals face which means that the time off water MUST be managed to ensure the animals do not suffer, however how is this to be managed? There must be designated ‘spell areas’ provided to ensure there is a place to unload, rest and water the animals. The driver must be provided with a set of parameters’ concerning long distance, fitness, climatic conditions and nature of the journey to which he drives

Replace with:
SA5.2 Time off water must be managed by way of documented contingency plans to avoid risk to the welfare of the livestock. Access to designated maintained ‘spell’ areas, for provision of rest, water and feed must be included in the contingency plan according to:

i) the increased risk to livestock welfare of longer journeys up to the permitted maximum time off water.
Direction: EG: If animals are going down due to exhaustion, then the animals must be off loaded and spelled for a minimum of 12 hours.

ii) assessed fitness of the livestock for the remainder of the intended journey.
If the animals are found to be within (these to be set) parameters then this action (stated action) must be taken.

iii) predicted climatic conditions, especially heat or cold.
Hot weather will cause animals to require water more so than in cold weather. Heat stress is a major contributor to suffering therefore if temperatures during transport rise above 40 degrees and the animals are suffering heat stress the animals are to be offloaded and watered. Transportation may resume after 12 hours. The only way to enforce this clause is to state temperatures.

Replace iv) with:
iv) class of livestock, -however, weak, pregnant, recently having given
birth or lactating should not be transported. –see SA4.1(vi) & SA4.4.
This class of animal must not be transported as specified in SA4.1(vi) & SA4.4 (previous standards). Further, what does immature mean? This needs to be defined clearly.

v) nature of the intended journey.
What does ‘nature of the intended journey’ mean? Does it mean that animals destined for slaughter can be treated with less consideration than those for breeding?

Standard

SA5.3 Loading density must be assessed for each pen or division in the livestock
crate or each container, based on average liveweight of the intended livestock
loading, and must be managed to minimise risk to the welfare of the livestock.

Determination of loading density must consider all of the following factors:
i) species
ii) class
iii) size and body condition
iv) wool or hair length
v) horn status
vi) climatic conditions
vii) nature of the intended journey.

This issue is of immense importance as animals can routinely suffer and die in transport after being forced into an already overfull pen.

The statement ‘based on average liveweight’ assumes that the animals are weighed prior to loading. Sheep and goats are not weighed before loading as a rule therefore any guess is just that – a guess and open to interpretation. For example: if there are many deaths or injuries at the end of a transport- an inspector will need to be present and able to verify the weight in order to estimate the numbers which should be in the pen. Even after doing so, proving cruelty would be impossible. Regardless weight is not an acceptable basis upon which to fill a pen, considering the person is only guessing weights. If too many are penned the risk of an animal going down and being unable to rise because he has too many pen mates is very probable. This is NOT preventing cruelty. It only allows the driver to force as many in as he can like they do now and say he didn’t realise they weighed more than they did if and when he should get inspected. Meanwhile the potential for suffering is enormous.

The only preventative way to minimise risk of suffering and cruelty is upon the basis of allowing enough room for an animal to rise unassisted and to have enough room to move. Often legs are seen poking out of the truck sides- because there are too many sheep in the pen and he has no where to go, his leg gets stuck outside and lack of room means he cannot move to withdraw the leg..

Weight of the animal is to be considered but not be the main consideration. Also include the following factors including-wet or dry wool, age of animal- (young animals often prefer to lay down), as well as those stated below.

Replace with:
SA5.3 Loading density must be assessed for each pen or division in the livestock
crate or each container, based on the ability for the animal to rise unassisted allowing enough room for the animal to move if necessary in order to withdraw legs and heads from outside the truck and must be managed to minimise risk to the welfare of the livestock. A minimum of 5% less animals should be loaded into each pen if horned.

Determination of loading density must consider all of the following factors:
i) species
ii) class
iii) size, age and body condition
iv) wool or hair length
v) horn status
vi) climatic conditions, Temperature ranges:
Density must be further reduced if animals have wool longer than 2cms and the temperature is 35 degrees or over.
vii) nature of the intended journey.
viii)Wet or dry wool

Standard

SA5.4 Drivers (except for train drivers and drivers of poultry) must have the final
decision on the loading density. Poultry pick-up crews loading poultry into
containers must have the final decision on the loading density.

Standard

SA5.5 Livestock must be segregated by sufficient internal partitions to minimise risk
to the welfare of other livestock based on:

i) species, class and size
ii) level of fitness
iii) level of aggression
iv) nature of the intended journey.

Please insert into SA5.5 as added measures:
v) Numbers of animals within the pen, in order to reduce surging.
vi) horned and unhorned should be segregate

The next section is also VERY important:

Standard

SA5.6 Livestock must be handled in a manner that is appropriate to the species and
class and does not cause pain or injury. Specifically:

i) livestock (excluding poultry) must not be lifted off the ground by only
the head, ears, horns, neck, tail, wool or feathers
ii) livestock must not be lifted off the ground by a single leg except in the
case of all poultry, and sheep, goats and pigs if they are less than three
months old
iii) livestock must not be thrown or dropped
iv) livestock must not be punched, kicked or struck by hard or sharp
instruments including lengths of metal piping, sticks or belts.

The purpose of good handling techniques is to ensure the animals suffer as little stress as possible and to prevent cruelty. The principles behind AW legislation is to reduce stress, pain, suffering and deaths by providing laws to PREVENT pain, suffering and deaths Any law, and the proposed Standards will be law should NEVER allow the mistreatment of animals to become mandatory. Clause ii, which allows the lifting of an animal by a leg if the animal is under 3 months if age is unquestionably cruel and as such unacceptable. This clause is also contradictory to the statement that the animal must be “handled in a manner that is appropriate to the species and class and does not cause pain or injury.”

As an isolated incident it demonstrates very poor handling methods but this action also has potential to allow further cruelties to be inflicted on the animal/s involved. If this clause remains in place we will see people throwing baby animals onto vehicles as a natural progression of lifting them up by one leg, and it will NOT be prosecuted.
If a person is trained in low stress handling methods lifting an animal by one leg would be unthinkable. Only the ignorant, arrogant, stupid and indifferent stoop to such levels.

Further, as animals are not born with year of ‘manufacture details’ how will anyone know how old the animal is? The ‘out’ for this cruelty is they person didn’t know the age of the animal and of course again, the inspector MUST prove that the animal suffered pain because of the lifting action. Impossible.

The industry have also removed the ‘dragging’ component. This means an animal can be dragged by their ears, horns, wool, neck, head feathers.

If Shearers drag sheep they should do so by pulling the animal along the floor by gripping the sheep under the front legs on the body - armpits.

And why is it permissible to lift poultry off the ground by their head or neck

Replace with:
SA5.6 Livestock must be handled by trained and accredited competent persons in a manner that is appropriate to the species and class and does not cause pain or injury. Specifically:

i) livestock must not be lifted off the ground or pulled or dragged by only the head, ears, horns, neck, tail, wings, wool or feathers) livestock must not be thrown, dropped, or slammed
iii) livestock must not be punched, kicked or struck by hard or sharp instruments including lengths of metal piping, sticks or belts.