The development of the Australian Animal Welfare Standards and Guidelines for land transport of livestock, cattle and sheep represents a significant collaboration between governments, the industry councils and animal welfare non-government organisations facilitated by Animal Health Australia (AHA). It is intended that the standards and guidelines (S&G) documents will replace the Model Codes of Practice for the Welfare of Animals over time as resources permit. The new welfare standards contain many clearly defined welfare requirements but many issues remain unspecified and professional advice is important for guidance in these unspecified areas.
The purpose of the S&G documents is to state standards and guidelines for the welfare of livestock in Australia in a dual-purpose role. It is underpinned by a national agreement in that Ministers agreed in May 2009 that:
All future revisions of Model Codes and 'Australian Standards and Guidelines' documents must provide a number of:
a. clear essential requirements ('standards') for animal welfare that can be verified and are transferable into legislation for effective regulation, and;
b. guidelines, to be produced concurrently with the standards but not enforced in legislation, to be considered by industry for incorporation into national industry QA along with the standards.
The standard component is intended as the basis for law-making, in-fact adopting plain English language that is as close as possible to 'legal-speak'. The overall S&G document has a significant public communication role. These documents inform all those with responsibilities for the care and management of livestock on the acceptable standards of welfare and also provide guidelines for better welfare management. The standards will reflect available scientific knowledge, current practice and community expectations.
AHA is managing this process to develop the Australian Animal Welfare Standards and Guidelines for livestock under an agreed business plan that outlines the development process. Funding is by third shares from the Australian government, jurisdictions and relevant industries. The Australian Animal Welfare Strategy (AAWS) was the initiating force in 2005 for the development of the S&G business plan. The development structure consists of a core writing group and a larger reference group representing national interest organisations such as the Australian Veterinary Association. Key process components include public consultation (animalwelfarestandards.net.au) and the conduct of a Regulation Impact Analysis (office of best practice regulation). Key process values include; a commitment to consultation and consensus decision-making, transparency and accountability.
Priorities for S&G development are established by the senior technical committee - Animal Welfare Committee (AWC). To date only one S&G document has been developed and accepted. This is the 'Model Code of Practice for the Welfare of Animals - Pigs, 3rd Edition. However, the S&G for the Land Transport of Livestock Version 1, 2008, currently awaits endorsement and adoption into legislation once the issue over bobby calf time off feed standard is resolved. The cattle and sheep S&G are currently under development. The next candidates are; goats, horses, saleyards and abattoirs. The final proposed S&G documents will be endorsed as policy by the jurisdictional Ministers responsible for livestock welfare, primarily the Standing Council for Primary Industries (SCPI).
Despite good intentions at the technical level, there will be many challenges to the objective of harmonisation of animal welfare regulatory outcomes amongst the eight jurisdictions in Australia. Not-with-standing these circumstances it is expected that the national livestock regulatory outcome will be more consistent across jurisdictions than the current system. A nationally consistent regulatory outcome is important to livestock industries and veterinarians. Peak industry bodies also face significant challenges in consulting within their own organisations and establishing agreed industry policy positions to contribute to the S&G development.
Creation and implementation of regulations will be a lengthy process as evidenced by the efforts for the land transport standards for livestock. At the start of 2009, Ministers endorsed the standards but required further work to be done on the matters of; bobby calf time off feed (TOF), the use of prodders on pigs and the transport of age cull breeder poultry beyond 24 hours. A decision was not able to be reached for 24 or 30 hours calf TOF. There is now a standard that allows the use of prodders on pigs in transport under limited circumstances. The research for the poultry issue did not support extension beyond 24 hours in cages and the industry has changed to daylight pickup where necessary for delivery of birds. The target for completion of land transport regulations is now mid 2012.
The standards for acceptable welfare will become the 'must-do's'. All standards incorporate the word 'must'. There are two types of word construction of standards that can be identified; prescriptive (detailed) and non-prescriptive. The latter can be referred to as 'general principles' standards and these cover a number of important areas of welfare where there may be a lack of appropriate animal welfare indicators or appropriate science and a value judgement must be made for each particular circumstance. It is recognised that such standards may be difficult to interpret and enforce and the S&G document does not directly set out the detailed requirements to meet these non-prescriptive standards. For example the Land Transport standard, in relation to bobby calves states that they must be protected from cold and heat. In this context professional advice to livestock owners can be very important to reassure livestock owners of acceptable actions. This is similar to prevention of cruelty legislation (POCTA).
It should be noted that the guidelines underpin the objective of 'better welfare' and not the standards. The guidelines are the recommended practices to achieve desirable animal welfare outcomes (better than the standards). Guidelines use the word 'should' and are to complement the standards. The guidelines do not provide more detail for the standards and mostly represent a set of principles for better welfare management.
This approach in the S&G documents generally means that much of the detailed advice or standard operating procedures that may be relevant to best practice at a farm, regional, state or national level will not be found in the S&G document. This information will be rightly found in industry and government extension materials and veterinary and other professional advice. The livestock welfare S&G documents are not a 'one-stop-shop' text book for animal production despite the close relationship of animal welfare and health and the vast body of wisdom that exists. The industry service providers are actively developing industry better practice guides for welfare management.
Whilst the guidelines are important recommendations for better welfare outcomes, the major focus of the development groups is on the standards. The case for a new standard must pass four tests for policy development.
The four main decision-making principles (Linstone and Turoff 2002) used for standards are that they are:
The development of the Australian Animal Welfare Standards and Guidelines for the Land Transport of Livestock ('Land Transport Standards' - LTS) in 2007-08 is the inaugural project in an Australian Animal Welfare Strategy (AAWS) sponsored program of conversion of the existing Model Codes of Practice for the welfare of animals (MCOP).
The LTS comprises 6 general and 11 species chapters and will replace 6 MCOP for transport of a species, one draft MCOP and create provisions for the other species. The new document clearly states that Standards are the acceptable animal welfare requirements that must be met under law for livestock welfare purposes and guidelines are the recommended practices to achieve desirable animal welfare outcomes.
Key areas of interest in the land transport standards include:
It is expected that prescriptive standards for livestock handling and humane destruction will generally apply on-farm. Further details at: http://www.animalwelfarestandards.net.au/land-transport/
Efforts are currently being made by industries and AAWS to produce communication materials in anticipation of the mid-2012 enactment.
Discussion papers have been developed for eight significant welfare issues for cattle to provide a summary of the relevant science-based evidence and rationale of the writing group deliberations. These discussion papers will be used in public consultation planned for mid 2012. The topics are:
There are three discussion papers for sheep on the topics of mulesing, castration and tail docking. These discussion papers reflect the areas of more controversial welfare discussions but there are also other notable welfare issues outside of these papers.
Current chapters in the cattle S&G document address:
Current chapters in the sheep S&G document address:
Issues of general interest for veterinarians in the cattle and sheep S&G include:
Competency - with or without recognised training
The demonstration of competency to do tasks required for good animal management is a fundamental principle for good animal welfare but has caused a lot of controversy amongst industry partners who are concerned with future un-intended regulatory outcomes. The term 'competency' is not now mentioned in livestock S&G under development but there are requirements for supervision and training and accreditation in special circumstances.
It has been clearly stated by government representatives that there is no intention to create a training scheme or a 'licence to farm'. Formal qualifications are not required. There is no intended need for training or certification for the majority of livestock management procedures. The emphasis is on recognition of prior learning and on-the-job training. This topic leads on to the next issue of supervision.
Veterinary supervision - bears responsibilities
Supervision may be both indirect and direct and means both where it is not specified. Supervision by a veterinarian is proposed for cattle: tail docking, calving induction (indirect) and use of electro-immobilisation (direct, but vet only in NSW). For sheep, veterinary supervision is currently only proposed for embryo transfer. These requirements place extra demands on livestock veterinarians. A veterinarian offering advice has a responsibility to ensure that they are knowledgeable on the subject in question.
The definition of direct supervision is largely derived from NSW legislation:
A person (the supervised person) is acting under the direct supervision of another person (the supervisor) if the supervisor:
(a) provides instructions and guidance to the supervised person in relation to the subject activity; and
(b) oversees and evaluates the performance of the activity by the supervised person; and
(c) is contactable by the supervised person; and
(d) is supervising the person in accordance with paragraphs (a), (b) and (c) above; and
(e) is on the same premises as the supervised person while the subject activity is being undertaken; and
(f) is able to immediately render assistance to the supervised person, if required, at any time during which the subject activity is being undertaken.
Indirect Supervision; Supervision of a person when the person being supervised is not on the same premises as the supervising veterinarian. In this situation a system must be put in place (training, records, reporting, auditing) to ensure welfare outcomes.
Reasonable actions - what does it mean?
The terms 'reasonable actions' and 'appropriate', when used in a standard, confer a 'general principles', non-prescriptive element to the standard. The S&G document does not set out to provide the detail of the actions or practices that might be required to satisfy an acceptable standard of animal welfare behaviour. This reinforces the important role that veterinarians have to play to shape and inform the behaviours of the farming community through the specific advice that they provide to clients. The challenge for practitioners is to stay abreast of professional and community expectations.
'Pain relief' - what does it mean?
A major issue for the development of cattle and sheep welfare standards and guidelines is the painful nature of some husbandry procedures. 'Pain relief' is defined as: 'the administration of drugs that reduce the intensity and duration of a pain response'. Global animal welfare thinking on this issue is based on the three R's (reduce, replace, refine) with the addition of a fourth R, being to 'relieve' the painful and stressful effects of such procedures. An important principle is that the assessment of pain is an inexact science, but animals should be given the benefit of the doubt.
It has been shown that a combination of local anaesthetic and non-steroidal anti-inflammatory drugs can abolish the short term pain response but no drug delivers much relief beyond eight hours after administration. Stafford, Chambers and Mellor 2006, concluded that there are a limited number of analgesic drugs registered for use in cattle and concerns include costs and residues. Ketoprofen® and lignocaine appear to be the most successful combination registered to abolish the short to medium term pain response for castration. For sheep, the move to register Tri-Solfen as a schedule four remedy has promise of limited post-cut pain relief being made available through prescribing veterinarians. There are no registered NSAIDs for sheep. The regime applied will be guided by what is considered possible and reasonable in the circumstances given the restrictive scheduling of the drugs and the limited availability of veterinarians.
Non-uniform production systems - a challenge to harmonisation
Cattle are a robust species that are able to be managed across a wide range of production systems in Australia from small farms to extensive rangeland properties. This means difficulties will be encountered in achieving consensus on appropriate standards to optimise harmonisation of regulatory outcomes, particularly for pain relief, due to different jurisdictional views arising as a result of the production system differences.
Castration is included here as an example of a way to deal with this challenge for male cattle. After much consideration the following standard has been proposed for consultation, acknowledging that it is not a 'water-tight' regulatory solution:
S6.1 A person must *castrate* with *pain relief*, unless cattle are:
1) under six months old, or
2) under 12 months old if at their first *yarding*.
'Yarding' is defined simply as; 'the process of putting cattle into a cattle yard.' The search for an elegant solution to optimise harmonisation of regulatory outcomes continues with the likelihood that jurisdictions will not all regulate all of this proposed standard.
Sheep have a similar range in production systems from extensive outback to closely managed farms, but a similar dual range standard is not proposed for sheep marking or mulesing.
Developing animal welfare standards is a complex public policy process that includes; scientific, ethical, economic, practical and political considerations. The Australian Animal Welfare Standards and Guidelines will provide better direction to all persons responsible for livestock but not all issues are clearly defined. The standards are intended to become law where there are new requirements but it is not yet possible to determine the exact timing for the new regulations.
The Land Transport of livestock document defines many essential welfare requirements relevant on-farm to the species involved. Further consultation and revision of the cattle and sheep standards and guidelines is required before a recommendation is made to Ministers. The cattle and sheep development processes are broadly planned for completion in early 2013 but they are flexible and responsive to the needs of members. Further work will be required for regulation, communication, compliance and enforcement of the new welfare standards.