Standard

SA5.8 Dogs must be under control at all times during loading, transporting and unloading livestock. Dogs must not be transported in the same pen as livestock. Dogs that habitually bite; deer, goats, pigs, poultry, sheep and
ratites, must be muzzled.

Who decides that the dogs are ‘habitual biters’? What does under control mean? On a lead, chained? Dogs run around while the person is tending to the job- what happens if he doesn’t see the dog bite an animal. Either muzzle ALL dos or don’t.

Replace with:
SA5.8 Dogs must be under control of their handler at all times during loading, transporting and unloading livestock. Dogs must not be transported in the same pen as livestock or in a pen visible to stock. They must be transported out of view from the animals transported. Dogs must be muzzled.

Standard

SA5.9 Drivers must ensure that the ramp and the vehicle are properly aligned and that any gap between the ramp and the vehicle is sufficiently narrow to avoid causing injury during loading and unloading.

Acceptable

Standard

SA5.10 The driver must inspect:
i) the livestock crate immediately before departure, to ensure that doors are closed
ii) the receival yard immediately before unloading, to ensure that there is free access and sufficient space for the livestock intended to be unloaded.

Acceptable

Standard

SA5.11 The driver must inspect livestock (except poultry):
i) on the vehicle before departure
ii) within the first hour of the journey and then at least every three hours or at each rest stop, whichever comes first
iii) at unloading.

Does a driver have to stop when a member of the public lets him know there is an issue with the animals he is transporting especially important to prevent suffering and or cruelty?

Replace with:
SA5.11 The driver must inspect livestock (except poultry):
i) on the vehicle before departure
ii) within the first hour of the journey and then at least every three hours or at each rest stop, whichever comes first
iii) at unloading.
iv) when made aware of a problem by the public

Standard

SA5.12 Upon identifying a distressed or injured animal at an inspection, the driver must provide or seek assistance at the first opportunity. Weak, ill or injured livestock must be identified to the person receiving the livestock.

How soon is ‘first opportunity’? 5 Minutes or 5 hours later? Maybe after he has been to the pub or had lunch?

Replace with:
SA5.12 Upon identifying a distressed or injured animal at an inspection, the driver must provide or seek assistance without delay. Weak, ill or injured livestock must be identified to the person receiving the livestock.

Standard

SA5.13 The person receiving the livestock must make arrangements for separating weak, ill or injured livestock for rest and recovery, appropriate treatment, humane destruction and disposal of dead stock.

There is no mention of how long the receiver may take in assisting weak, injured or ill or indeed killing severely injured or dying animals.

Replace with:
SA5.13 The person receiving the livestock must make arrangements without delay for separating weak, ill or injured livestock for rest and recovery. They must also arrange without delay appropriate treatment, including efficient, humane destruction by trained and accredited competent people for severely injured or dying animals and disposal of dead stock.

Standard

SA5.14 The driver must make arrangements or take action during extreme hot or cold conditions to minimise the risk to the welfare of livestock.

What is ‘extreme’ weather? What arrangements should he take? Park up in a shady spot?

Replace with:
SA5.14 The driver must make arrangements or take action during extreme hot or cold conditions to minimise the risk to the welfare of livestock. Extreme is weather over 40 degrees summer and below 5 degrees winter.
Providing cover for the animals during wet weather and shade for animals in hot-40+ weather. Protection must be provided for recently shorn or young, weak or older animals.

Standard

SA5.15 Where there is a road accident involving the transport vehicle, all livestock must at the first available opportunity be
i) assessed, in the standing position if possible,
ii) removed for treatment
iii) humanely destroyed at the accident site.

Again ‘first available opportunity’?

Replace with:
SA5.15 Where there is a road accident involving the transport vehicle, all animals must without delay be
i) assessed, in the standing position if possible,
ii) removed for treatment
iii) humanely destroyed at the accident site. The person must be trained and accredited and competent to undertake this task

Standard

SA6.1 Humane destruction methods must result in immediate loss of consciousness followed by death while unconscious.

Replace with:
SA6.1 Humane destruction methods must result in immediate loss of consciousness followed by death while unconscious. When loss of consciousness is not immediate induction of unconsciousness should be non aversive and must not cause anxiety, pain, distress or suffering of the animals.

Standard

SA6.2 Humane destruction must be carried out:
i) on moribund livestock
ii) by a competent person or under direct supervision of a competent person
iii) using an approved method for the species
iv) at the first opportunity.

Anyone who has a gun or a mallet can be deemed competent. All persons in any facility along with drivers who have the overall responsibility of duty of care to the animals IE managers, drivers must be trained in emergency slaughter procedures.

Replace with:
SA6.2 Humane destruction must be carried out:
i) on moribund livestock
ii) by a trained and accredited competent person or under direct supervision of a trained and accredited competent person
iii) using an approved method for the species
iv) without delay.

Standard

SA6.3 Where a competent person is not immediately available to humanely destroy an animal, a competent person must be contacted to carry out the procedure at the first opportunity.

Fully trained persons must euthanise immediately

Replace with:
SA6.3 Where a trained and accredited competent person is not immediately available to humanely destroy an animal, a trained and accredited competent person must be contacted without delay to carry out the procedure without delay.

Standard

SA6.4 A person humanely destroying an animal must take reasonable action to confirm the animal is dead and to ensure death.

What does ‘reasonable action’ mean? A note in the guidelines to this document states ‘the confirmation of an animal’s death following a humane destruction procedure can be a difficult task to judge, and requires training and experience of species differences in responses’.

Replace with:
SA6.4 A person humanely destroying an animal must be trained, accredited and competent and must take reasonable action to confirm the animal is dead and to ensure death.

Standard

SA6.5 Firearm use must be in the frontal or poll positions, except for cattle and pigs.

Acceptable

Standard

SA6.6 Captive bolt use must be in the frontal or poll positions, be accompanied by appropriate restraint, and be followed by an effective procedure to ensure death.

What is appropriate restraint? 10 people holding the animal down? Please define. You cannot ensure death no matter what procedure unless you are trained and accredited in emergency slaughter.

Standard

SA6.7 Blunt trauma to the brain must only be used on specified newborn livestock less than 24 hours old or piglets up to 15 kilograms liveweight, and must be followed by an effective procedure to ensure death.

What are ‘specified’ livestock? Assessing a piglet’s weight is pure conjecture therefore does not prevent cruelty but rather allows an out for breaches of this standard.

Replace with:
SA6.7 Blunt trauma to the brain must only be used on specified newborn livestock less than 24 hours old and must be followed by an effective procedure to ensure death. Only trained and accredited competent people skilled in this procedure must use this method.

Standard

SA6.8 Animals must be assessed to be unconscious before pithing.

Training must be provided for operators to be able to perform thus task- A note in the guidelines to this document states ‘the confirmation of an animal’s death following a humane destruction procedure can be a difficult task to judge, and requires training and experience of species differences in responses’.
The same would apply to the task of ensuring the animal was unconscious.

Replace with:
SA6.8 Animals must be assessed to be unconscious by a trained accredited and competent person before pithing.

Standard

SA6.9 Lethal injection is an approved method for all species but must be performed by a veterinarian or an approved person.

Acceptable