Livestock Export Review

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Last updated: 30 Aug 2011

Against Animal Cruelty Tasmania


Against Animal Cruelty Tasmania (AACT) wish to state at the outset that we are completely opposed to live export of any and all sentient non–human beings. We wish for live export to end immediately. Our comments that follow are made with this aim in mind.

Response to Terms of Reference

  1. the facilities, treatment, handling and slaughter of livestock, exported from Australia, in the importing country for consistency with the World Organisation for Animal Health (OIE) recommendations and standards set out in Terrestrial Animal Health Code (2010) published by the World Organisation for Animal Health and other relevant standards

    Non–human animals should not be exported live from Australia regardless of the end destination. Over three decades, Australia has sent more than one hundred and fifty million sheep and cattle to be slaughtered in other parts of the world, such as the Middle East and South East Asia. Livestock ships can carry up to one hundred thousand non–human animals on voyages that can last up to three weeks. More than two million animals have died on these ships en route, deaths deemed an ‘acceptable’ loss by an industry that puts profit above all else.

    Using World Organisation of Animal Health (OIE) standards as a benchmark is not acceptable – they are well below Australian standards and lead to unacceptable suffering. Ending live export entirely is the only way forward, and the only means to avoid this inexcusable cruelty.

  2. the adequacy of the Australian Standards for the Export of Livestock (ASEL) as they apply to the preparation and export of all livestock with consideration of responsibilities for compliance and enforcement of the ASEL

    Although there are Codes of Practice and the Australian Standards for the Export of Livestock (ASEL) that set out minimum standards for the trucking of animals, outlining the stocking densities, conditions, and so on of the animals on board, these codes are entirely voluntary. There is NO policing undertaken to ensure the trucks are not over loaded and that the animals are fed, watered, are upright or otherwise in good condition at the beginning, during and after the journey. (source:

    The WA Department of Agriculture Journal 31(3) reviewed 2002 states that sheep are "counted and those with injury, overt ill health or not–to–specification (wrong sex or those in poor condition) are rejected. Rejected animals are either destroyed or sold for slaughter." Whereas this may possibly be the case when the animals get to the feedlot– we only have the live export industry word for that, but we do know for a fact is that there is NO monitoring or enforcement by ANY Federal or state government department in ANY STATE to ensure compliance with the animal welfare requirements within the Federal live export regulations (ASEL) or the state animal welfare legislation from SOURCE to PORT. This means the animals transported from the farm or source can be ill, suffering minor or major injuries, and unfit for transport when moved from the farm to the port and onto the ship. (source:

    It is of immense concern that the Australian Government is misleading the world in such a way as to suggest that the export regulations governing live export are complied with because they would not know. It is also of immense concern that animals are routinely transported and that both the Federal and state governments know and ignore that these animals are not checked to ensure compliance with the regulations and legislation. It is our firm belief that the Federal and state government wholeheartedly and unreservedly support this legal cruelty due to the fact they FAIL to fund routine livestock inspections for compliance. (source:

    Time and time again serial non compliance has been proven by those involved in animal welfare yet the exporters continue to get their licences for live export from the Australian Government. The Australian Quarantine & Inspection Service (AQIS) trust that the exporter will comply and do not maintain checks on the health and welfare of animals. They instead turn a BLIND EYE. (source:

    While the Standards take a “whole of chain approach” covering all aspects of the livestock export trade from planning through to on–board management, many sections of the Standards lie outside the jurisdictional powers of the Australian Government, and could only be enforced under State and Territory legislation. (source:

    No Australian State or Territory government has yet legislated to recognise the ASEL, and, as a result, large sections of the ASEL are effectively unenforceable. (source:

  3. the adequacy and effectiveness of current Australian regulatory arrangements for the live export trade

    It is apparently common practice to overload trucks with sheep, and reports of ’crushed sheep’ were bought to the attention of AQIS (Federal Australian Quarantine Inspection Service) and the RSPCA, over the December 2003 January 2004 period. Not a great deal has changed since 2004, except to say that RSPCA plays NO part in port or transport inspections of any animals. What can be seen at port side is the arrival of trucks with sheep on sheep, sheep smothering other sheep and downers – they are sheep that are unable to get up perhaps because they have broken legs, crushed ribs, internal injuries or are dying. Common incidents of heads and legs trapped outside the sides of transport crates occur because the animals have no room to pull their body parts inside the enclosure. This shows clearly that there are just too many animals inside the crates. It also clearly demonstrates the failure of the current self regulation of the industry. (source:

    Despite the Australian Standards for the Export of Livestock (ASEL) requirement that EVERY animal is individually inspected for compliance with the export criteria and fitness for travel, they are not. AQIS do visit the loading of a ship from time to time, however much of the loading occurs without their presence. As is clear, there is no independent monitoring or policing of this trade. The exporter contracts a vet who possesses accreditation provided by AQIS to say that he has, apparently, an understanding of the requirements of live export to check the sheep as they pass by on the race to the ship. It would be inconceivable in our view that one vet could possibly check 100,000 sheep as they run by. (source:

    Current regulatory arrangements are totally inadequate. As soon as Australian animals leave Australia they have no protection against cruel treatment. Importing countries do not have basic animal welfare legislation/anti–cruelty legislation (or, enforce such legislation) and as such these animals have absolutely no protection once they leave Australia. Any assurance that Australian animals will be protected from cruelty and mistreatment is not guaranteed in legislation and therefore cannot be relied upon. (source:

  4. the types of livestock suitable (weight, age, body condition, breeds) for export as feeder or slaughter animals

    No live non–human animals should be exported from Australia regardless of the why they are being exported. Available scientific evidence shows that exporting non–human animals live directly compromises their well–being. All species subjected to live export are exposed to stresses that are wholly unacceptable, given that in many cases the stress levels lead to death. Goats, deer, wild camels and pregnant animals are at increased risk when subjected to the stressors of live export. Transporting non–human animals from a cold climate (Australian Winter) to a hot climate (Northern Summer) seriously exacerbates heat stress (which can lead to extreme suffering and a prolonged and painful death) .

  5. the extent of monitoring required for each export consignment of feeder or slaughter livestock, in a manner that ensures accurate and transparent reporting to the Australian Government of the condition of the livestock from departure from Australia up to and including the point of slaughter in the country of destination

    Until such time as live export ceases (which should happen immediately) all non–human animals must be monitored closely throughout the journey. In fact, a high level of monitoring is required to ensure standards are met.

    Third party independent auditing is required to take the responsibility out of the hands of the live export industry. The current self–regulation by the industry leads to excessive levels of suffering that AACT consider totally unacceptable.

  6. the risk management strategies necessary to address the welfare of animals from departure from Australia, up to and including the point of slaughter in the country of destination

    So–called “risk management strategies” will never address AACT’s concerns for the well–being of non–human animals subjected to live export, as it takes a welfarist approach to evaluating the situation. We believe that as sentient beings, sheep, cattle, goats and other species should be afforded rights that are afforded human animals. Clearly, transport of humans would never be allowed under these conditions and therefore serious consideration should be given as to what is appropriate for other species. As humans we have responsibility to ensure we treat non–human animals with a level of care and compassion that we would exercise towards other humans.

    The more than two million sheep, cattle and goats that have died on ships during thirty years of live exports is a clear indication that the industry is very much about cruelty and neglect. Many of these animals suffer horribly and die slowly due to illness, failure to eat the pellet diet (starvation), heat stress, and so on. Most die in their crowded pens without any aid or treatment. Risk management strategies will do little to change this situation

    There is much evidence to substantiate reports of extreme cruelty due to exporting non–human animals live. There are health and welfare risks to the animals at each stage of the journey from loading, to transport, at the feedlot, and at slaughter. Stress is cumulative.
  7. other matters relevant to these terms of reference that the reviewer considers appropriate.

    Animals die on every ship that leaves Australia. Allowing live export is a death sentence. The causes of death on board ships carrying sheep have been studied extensively during the last 25 years and are:
    Inanition (failure to eat) 47%
    Salmonellosis 27%
    Trauma 12%
    Miscellaneous 14%

    It is simply inexcusable to allow live export to continue when it leads directly to the suffering of millions, and the premature death in transit of around 75 000 sentient beings every year.