On 29 January, ALEC received an open letter from Vets Against Live Export (VALE) expressing concern with the proposed standards for the industry’s Livestock Global Assurance Program (LGAP).
ALEC CEO, Ms Alison Penfold responded in an open letter to VALE. ALEC’s response is below;
Dear Dr Foster,
Thank you for your letter of 28 January 2016 advising of your decision, on behalf of Vets Against Live Export (VALE), not to provide comments on the Livestock Global Assurance Program (LGAP) Standards in accordance with the process determined by the LGAP Standards Committee.
As I am not a member of the Standards Committee and ALEC has no role in the outcome of the Standards Committee process, I have forwarded your letter to the LGAP Standards Committee for their consideration. Despite what you have written, I ask you to reconsider and take the opportunity to provide formal comments on the Standards.
By way of background the development of the LGAP is currently an ongoing research project of the industry and as such, no decision has yet been taken to move to implementation. The concept of a welfare assurance program covering the post-export supply chain stems from the 2011 Farmer Review commissioned by Australian Government which recommended that industry develop and implement a through-chain QA system to complement government regulation compliance programs.
The research project commenced in July 2014 with a project team that includes subject matter experts, specialising in the areas of project management, the live export industry, animal welfare, husbandry and behaviour, development and internationalisation of standards and conformity assessment programs; and the development and application of technology solutions.
In accordance with an earlier scoping research project, the research project was to develop a certification program, applicable to any market and designed to provide assurances that animals continue to be treated in accordance with international guidelines (the Exporter Supply
Chain Assurance System (ESCAS) standards for Australian livestock) up to and including the point of slaughter. As with any conformity assessment program, the Program is required to be governed by a set of Rules and a Standard or Standards.
Furthermore, as the Program is to operate outside of Australia and across international borders, the development of the Program overall, as well as the Standards and Rules, is intended to follow international guidelines including the OIE Code, guidelines and standards published by ISO; and guidelines published by the WTO.
In order to be internationally applicable, the standards development process has followed:
- AABSDO: Requirements for the Accreditation of a Standards Development Organisation, Version 1_1 (2014).
- ISO/IEC 17007:2009: Conformity assessment – Guidance for drafting normative documents suitable for use for conformity assessment.
- ISO/IEC Guide 59:1994: Code of good practice for standardization.
- Standards Australia: Standardisation Guide 006 – Rules for the structure and drafting of Australian Standards. Version 2.6 (2012).
- WTO: Agreement on Technical Barriers to Trade, Annex 3: Code of Good Practice for the Preparation, Adoption and Application of Standards.
These guidelines specify the expectations of any organisation setting standards and the standards development process.
I would like to now correct a number of your statements about LGAP in your letter.
The form provided for comment on the Standards has been designed to enable comment and input on the specific content of each element of the Standards and is not intended to prescribe an outcome. I am disappointed that you hold the latter view.
The development of LGAP is far from a cynical exercise and I am disappointed that you have been blinded by your opposition to the trade and rejected objective and constructive input into this process. The letter inviting VALE to participate was a genuine invitation respecting your organisation’s interest in the livestock export trade – regardless of your policy position. LGAP is being designed not just for Australian exported livestock. Any facility anywhere in the world could be certified under the program regardless of country of origin as long as the Program Standards are met. The development of auditable animal welfare standards for livestock anywhere in the world in a program that will provide a pathway to higher levels of welfare certification, we had hoped would be of genuine interest to VALE.
LGAP will not dilute ESCAS. ESCAS is a regulatory framework for Australian exported livestock covering animal welfare to the point of slaughter. This does not change under LGAP and indeed LGAP has been developed to strengthen oversight and management of welfare along the supply chain through operators (exporters and importers) and facilities (feedlots, farms and abattoirs). It will, if implemented, provide for a better demonstration of ESCAS compliance, more immediate and thorough management of non-conformances and potentially a scope for facilities and operators which seek to perform over and above ESCAS standards.
In addition, the research project does not propose any regulatory changes for the pre-export process including licensing and certification – these are outside the scope of the project and thus would be unaffected by the implementation of LGAP.
In relation to your comments about the transportation of livestock, extensive research by industry and investment in new vessels has been used to improve the conditions for livestock on board. Work continues for further improvement as any deaths on board are no comfort to exporters. Our aim is to see 100% of livestock exported arrive in market and current research is focused on addressing the key causes of mortality (respiratory disease in cattle and salmonella/inanition in sheep). Should you be interested in more information on these projects I would be pleased to arrange a briefing for you. In addition, there are a number of other projects focused on transport and a further research project is developing indicators of welfare along the supply chain to provide more objective data than is currently available. This work is important to developing a means of objective analysis rather than subjective statements that are not true measures of animal welfare.
Should you wish to do so, the opportunity remains open to VALE to provide comments on the Standards and I encourage you to contribute. This is a unique opportunity to influence welfare standards of a global welfare conformance program for livestock regardless of country of origin. ALEC respects the process as informing the development of LGAP standards and any submission by an organisation’s or individuals in no way reflects support or change of position on the trade.
The project is due to be finalised in the near future and as soon as a report is available for public release, I will provide you with a copy for your consideration. Should you have questions that arise from your consideration of that report, I would be happy to arrange an opportunity to discuss.
Thank you for your correspondence. As indicated I will forward your letter to the Standards Committee for their consideration and while I disagree with many of the points you have made, I note the views you have expressed.
Chief Executive Officer
PDF available here: ALEC Open Letter to VALE – 29 Jan