standards and guidelines for the welfare of...

Discussion paper on DRAFT Australian Animal Welfare Standards and Guidelines - Livestock at Saleyards and Depots

DRAFTAustralian Animal Welfare Standards and

Guidelines – Livestock at Saleyards and Depots

(Saleyard Welfare Standards)

Discussion Paper on proposed standards

23 July 2013

Author: Dr David Champness, DEPI VictoriaVersion date: 23 July 2013

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Acronyms

AAWS Australian Animal Welfare StrategyALMA Australian Livestock Markets AssociationALPA Australian Livestock and Property Agents AssociationAVA Australian Veterinary AssociationAWC Animal Welfare CommitteeAWSC Animal Welfare Science CentreCCA Cattle Council AustraliaCOP Code of Practice (for the welfare of animals in saleyards)DPI Department of Primary Industries (Victoria)LMA (Victorian) Livestock Management Act 2010LSAV Livestock Saleyards Association of VictoriaLTAV Livestock Transport Association VictoriaLTS Land Transport Standards (Australian Animal Welfare Standards and

Guidelines – Land Transport of Livestock)OBPR Office of Best Practice RegulationPOCTAA Prevention of Cruelty to Animals ActRSPCA Royal Society for the Prevention of Cruelty to AnimalsSCoPI Standing Council on Primary Industries (replaced PIMC – Primary

Industries Ministerial Council)SRG Standards Reference GroupSWG Standards Writing GroupSWS Saleyard Welfare StandardsVCEC Victorian Competition and Efficiency CommissionVFF Victorian Farmers Federation


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Introduction

The primary purpose of this discussion paper is to outline the basis and rationale for each of the proposed saleyard welfare standards and to identify the person/s responsible for each of the standards.

This paper also introduces the objective of the required Regulatory Impact Statement and alternative options to be considered in the assessment.

Background

Following some media attention during 2011, saleyard animal welfare audit reports from Animals Angels, and ongoing reports of animal welfare issues at saleyards, the Livestock Saleyard Association of Victoria convened an industry stakeholder meeting with DPI Victoria on 12 December 2011. Industry representative groups included LSAV, LTAV, ALPA, VFF, CCA & NSQA.

It was agreed at this meeting that the current Model Code of Practice (COP) for the Welfare of Animals at Saleyards is now dated (last revised 2002), and is no longer adequate to promote the welfare of livestock in saleyards and meet the needs of Victorian livestock industries and current community expectations.

At this meeting, the industry representatives generally agreed that it would be in the best interest of the Victorian livestock industries to progress a revision of the current saleyard COP sooner rather than later. A follow-up meeting on 17 January 2012 re-confirmed industry’s preferred position to progress the revision of the COP into regulated Victorian Standards.

Under the Australian Animal Welfare Strategy (AAWS), Model COPs for animal welfare are being revised into Australian Animal Welfare Standards and Guidelines to be harmoniously adopted into state legislation. The saleyard COP is not scheduled for national revision for a number of years.

The current voluntary saleyard COP is referenced under the Victorian Prevention of Cruelty to Animals Act (POCTA).

The code would be revised into Victorian Standards and Guidelines for the Welfare of Livestock at Saleyards and could be regulated under the Livestock Management Act 2010 (LMA) and revoked from under POCTA legislation.

These new standards and guidelines should be reflected in industry quality assurance programs.

On a recommendation from the Victorian Livestock Industries Consultative Committee, the Victorian Minister for Agriculture endorsed the revision of the COP into Victorian Standards and Guidelines for the Welfare of Livestock at Saleyards.


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There is national interest in the development of these Standards suitable for national adoption. Animal Welfare Committee (AWC) has identified the development of national saleyard welfare standards as a high priority and has included it in its current work plan, and supported the work being undertaken by Victoria as a means to develop such national standards.

A business plan was drafted for the development of the Standards. This plan is based on the AAWS – Development of Australian Standards and Guidelines for the Welfare of Livestock Business Plan, February 2009 version.

The role of DPIV is to manage the overall process for the development of the Standards, provide technical representation and project support.

Standards Reference GroupA Standards Reference Group (SRG) was formed with representation from the following stakeholder organisations:

Industry memberso Livestock Saleyards Assoc of Victoria (LSAV) o Aust Livestock Markets Assoc (ALMA) o Aust Livestock & Property Agents (ALPA) o Livestock Transporters Assoc Victoria (LTAV) o Victorian Farmers Federation

Australian Veterinary Association (AVA) – Victorian Division Animal Welfare Science Centre (AWSC) Animal Welfare organisations

o RSPCA Aust and RSPCA Victoriao Animals Angels o Animals Australia

DPI o Principal Vet Officer- Livestock Management Standards o Bureau of Animal Welfare

Invited consultants (if required)

Standards Writing GroupA small Standards Writing Group (SWG) consisting of David Champness (DPIV) and Mark McDonald (LSAV) are responsible for drafting the standards and guidelines in accordance with the views of the SRG and the principals set out in the Standards and Guidelines Business Plan.

National ConsultationA national industry stakeholder workshop reviewed the draft proposed standards and guidelines in May 2013. The group endorsed the scope of the standards with the inclusion of depots, and agreed with the draft standards and guidelines with some amendments.


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Scope of Saleyard Welfare Standards

The saleyard welfare standards and guidelines apply to all livestock saleyard enterprises and livestock depots. The Standards do not apply to on-farm livestock sales, or markets where no permanent livestock handling facilities exist, however, the standards and guidelines should be used for guidance in the management of livestock at on-farm sales and farmers markets.

They apply to the main commercial livestock species: cattle, sheep, goats, pigs and horses that are handled through saleyards and depots.

The Standards apply to all those responsible for the care and management of livestock that are handled through saleyards, including saleyard managers / superintendents, saleyard staff, stock persons, agents, transport operators and drivers.

This scope was agreed to by the national AWC (AWC 6) on 25 June 2013.

Definitions of saleyard and Transport Processes

Saleyard Process – means all the stages involved in handling livestock through a saleyard or depot, including the receival of livestock into the saleyard complex or depot, unloading, yarding, holding, handling, drafting, weighing, NLIS scanning, penning into and out of selling pens, provision of feed and water, assembling, loading and dispatch from the saleyard complex.

Transport Process - means all the stages involved in moving livestock from one place to another and includes assembling, selecting livestock to be transported, holding livestock prior to loading, loading, transporting, unloading and handling livestock until they have reasonable access to water and feed at a destination.


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Discussion on proposed standards

Responsibility

The transition of livestock though the transport and saleyard process’ usually involves the process of ‘change in ownership’ and the ‘transfer of responsibility’. The chain of responsibility is integral to making sure that outcomes are consistent with livestock welfare. The central idea is that a ‘person in charge’ is responsible for the welfare of livestock at each stage of the saleyard process (and/or transport process) and has a duty of care to ensure the welfare of livestock under their control and to communicate vital information.

Please note the use of ‘a person’ or ‘a person in charge’ in the standards. ‘A’ means more than one person (plural) and not just a specific person. Use of ‘a person in charge’ is appropriate where responsibility is shared and may extend along a hierarchy of management.

Land Transport Standards

The Standards Reference Group agreed that the relevant standards and guidelines from the Australian Animal Welfare Standards and Guidelines – Land Transport of Livestock (Land Transport Standards (LTS)) should be transcribed and incorporated into the Saleyard Welfare Standards. The rationale for this approach is that saleyard operators and stakeholders will have one reference document for animal welfare in saleyards, rather than the need to refer to both the Land Transport Standards and Saleyard Welfare Standards (SWS) documents for the single enterprise.

Table 1 below lists the proposed saleyard welfare standards. The land transport standards and equivalent saleyard welfare standard are listed in the second column of the table respectively. Many of the other proposed saleyard welfare standards are based on or have overlap with some transport standards and these are listed in the third column of the table. The difference may simply be the scope of the standard in relation to the ‘saleyard process’ rather than the ‘transport process’. The fourth column indicates consistency with other relevant welfare standards such as the cattle, sheep, pig and /or horse standards. A lack of a tick in the fourth column does not infer lack of consistency, simply not relevant to the scope. Other proposed saleyard welfare standards not based on transport standards are indicated in the fifth column as either a new standard (New Std), existing standard (S) under the COP or a guideline (G) under the COP.


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Table 1.Saleyard Welfare standard

Equivalent LT std

Similar LT Std Consistent with cattle, sheep, pig

&/or horse Welfare Stds*

Saleyard COPS / G

S1.1 SA 1.1 COP S2.1 SA 2.1 GS3.1 SA 3.1 GS3.2 GS3.3 GS4.1 SA 5.7 S4.2 SA5.8 (ii) &

SB8.11S4.3 SB 7.3S4.4 SB 9.4 S4.5 SA5.8 GS4.6 SA 5.9 SS4.7 SA 5.11, SB 4.9 SS4.8 SB4.9, SB 8.12 S (pigs), G

(calves)S4.9 G

S4.10 SA 5.16 GS4.11 (SA5.17) GS5.1 GS5.2 SA 5.4 GS5.3 SA 5.6 GS5.4 New StdS6.1 SA5.3 GS6.2 SA 5.2 GS6.3 SA 5.1S6.4 GS6.5 GS6.6 GS6.7 GB8.8 GS6.8 SB 4.5 (iv)S7.1 SA 4.1, SA4.3, SA4.4 GS7.2 SA4.1, SB4.5 GS7.3 SA 5.17, SA 5.15 S7.4

SA 4.5, SA5.15S8.1 SA 4.1 GS8.2 SA 4.2 GS8.3 SA 4.3S8.4 SA 4.4S8.5 SA4.5S9.1 New StdS9.2 GS9.3 SA 4.5 GS9.4 SA 6.1 GS9.5 SA 6.2 GS9.6 SA 6.4 GS9.7 SA 6.5

* Note: lack of a in this column does not infer lack of consistency, simply not relevant to the scope.


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Proposed standards

1. Responsibilities and planningS1.1 A person must exercise a duty of care to ensure the welfare of livestock

under their control and compliance with these saleyard welfare standards.This standard further lists the particular responsibilities for all stakeholders involved in the saleyard process. They include:

i) Saleyard and depot operators including saleyard owners, managers and superintendents.

ii) Stockpersons (including livestock agents, agency staff, saleyard staff, stock persons and drovers)

iii) Livestock owners (vendor / buyer (or their nominated representative or agent)

iv) Consignors ((livestock owner / buyer) or their nominated representative)v) Transporters / drivers

S1.1 identifies the people responsible for the care and management of livestock at saleyards. These responsibilities are based on the responsibilities listed in sections 2.1 and 2.2 of the COP and SA1.1 of the LTS, and confirmed with relevant stakeholder groups (LSAV, ALMA, ALPA, LTAV).

The following standards (2-9) specify the actual minimum requirements.

2. Livestock handling, knowledge and skills

S2.1 A person involved in any part of the livestock saleyard process must have the relevant knowledge, skills and experience to perform their required task, or must be supervised by a person with the relevant knowledge, skills and experience.

S2.1 is very similar to the SA2.1 in the LTS, and the respective standards in the draft Cattle and Sheep Welfare Standards requiring people handling or performing tasks on livestock to be competent, having the relevant knowledge, skills and experience, or supervised by such person. Section 2.2 of the COP states “The importance of competent stockmanship cannot be over-emphasised. The ability to recognise the early signs of distress and injury in animals is an important skill which enables prompt remedial action to be taken. Competent persons are required to exhibit patience, commonsense and responsibility in dealing with animals. Inexperienced persons should not be given tasks requiring particular skills or be required to work alone at any time when animals are being handled. Inexperienced staff should be given training in stock handling by competent and skilled staff. Such training should emphasis the behavioural characteristics of stock.”

S2.1 applies to all people involved in the saleyard process.


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3. Saleyard facilities for handling livestock

S3.1 A person in charge must take reasonable actions in the construction, maintenance and operation of livestock handling facilities to ensure the welfare of livestock.Saleyard and depot facilities must:

i) be appropriate for the purpose and contain the species; and

ii) have flooring that minimises the likelihood of injury or of livestock slipping or falling; and

iii) be free from protrusions and other objects that could cause injury; and

iv) have sufficient vertical clearance for livestock to minimise the risk of injury; and

v) have unloading and loading facilities which are appropriate for the livestock and transport vehicles; and

vi) have pens constructed so that pigs cannot fight with unfamiliar pigs in adjoining pens; and

vii) have suitable watering facilities; and

viii) have suitable feeding facilities (where required); and

ix) have effective means to minimise the risk to the welfare of livestock from extremes of weather.

S3.1 is based on section 3 of the COP and SA3.1 of the LTS.Clause vi (pig pens) is based on section 5.1 of the COP in which it was a guideline.

The saleyard operator (owner, manager, superintendent) is primarily responsible for ensuring the construction and maintenance of the saleyards. The responsibility for the operation may extend to others.

S3.2 The saleyard operator must provide for and ensure the holding and selling of pigs and dairy bred bobby calves in a saleyard is conducted under a roofed area.

S3.2 is based on section 5.1 of the COP (special requirements for pigs) “Pigs are more susceptible to heat stress and sunburn than other livestock. They should not be exposed to long periods in direct sunlight or extremes of temperature. Spray facilities should be provide for cooling animals. All procedures involving pigs including holding and selling should be conducted under a roofed area.”

Section 5.2 of the COP (special considerations for unweaned (bobby calves)) states “It is desirable to provide a roofed area to protect calves from the sun.”

There was strong support from the Victorian SRG and national industry stakeholder workshop to mandate a roofed area to protect bobby calves at saleyards.Author: Dr David Champness, DEPI Victoria

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The Victorian saleyards which routinely sell pigs (Bendigo, Ballarat, and VLE Pakenham) have existing roofed areas for pigs. Colac saleyard infrequently sells pigs, and these are penned in covered calf pens.The Victorian saleyards which routinely sell dairy bred bobby calves, namely Shepparton, Warrnambool, Camperdown, Colac, Baw Baw, East Gippsland (Bairnsdale) and VLE Pakenham, all have existing covered / roofed calf pens.

S3.2 is the responsibility of the saleyard operator.

S3.3 The saleyard operator must provide water spray facilities and equipment for cooling pigs at a saleyard.

S3.3 is based on section 5.1 of the COP (special requirements for pigs) “Pigs are more susceptible to heat stress and sunburn than other livestock. They should not be exposed to long periods in direct sunlight or extremes of temperature. Spray facilities should be provide for cooling animals”.

The standard does not specify that spray equipment must be a fixed installation. The spray facilities may be as simple as a portable sprinkler system or hose and nozzle with suitable water pressure and flow rate, and suitable for the scale of the saleyard and environmental conditions. Saleyards should already have portable hoses and nozzles with suitable pressure for washing down / leaning pen floors.

S3.3 is the responsibility of the saleyard operator.


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4. Handling and husbandry

S4.1 A person who handles livestock in a saleyard or depot must do so in a manner that is appropriate to the species and class, and minimises pain or injury. Including:

i) livestock must not be lifted by only the head, ears, horns, neck, tail, wool, hair; or

ii) livestock must not be lifted off the ground by a single leg, oriii) mechanical lifting of livestock must ensure that the livestock is

supported or secured as necessary; oriv) livestock must not be thrown, or dropped except from a height which

allows the animal to safely land standing on its feet; orv) livestock must not be struck in an unreasonable manner, punched or

kicked; orvi) livestock with no room to move must not be forced, prodded, pushed

or excessively handled; orvii) animals which are unable to stand, must not be dragged except in an

emergency to allow safe handling, lifting, treatment or humane killing.

S4.1 is based on SA5.7 of the LTS with some amendments: removal on reference to poultry removal exemption for lifting sheep, goats and pigs by a single leg if less than

15 kg liveweight from clause (ii). This exemption is applicable in transport situations where access can be an issue in stock crates and ramps. The livestock handler should be able to position themselves in a saleyard situation to lift a smaller animal in an supported and appropriate manner without resorting to a single leg. It is okay to catch an animal by a single leg, but not lift or drag (except in an emergency).

clause (iv) is amended to allow the ‘dropping’ of animals from a “height which allows the animal to safely land standing on its feet”. This is consistent with the proposed sheep and cattle welfare standards.

Additional clause (vi) – based on section 4.2 of COP

The SRG discussed clause (v) in relation to the allowance to ‘strike” an animal. Some suggested animals should not be struck at all, and should delete the “in an unreasonable manner”. This was apparently discussed in the development of the LTS and settled on this clause. Everyone agreed that animals must not be struck ‘unreasonably”, but there is a difference between ‘slapping’ an animal for example on the back or rump compared with repeatedly hitting or striking an animal with force. The use of the comma after the word ‘manner’ separates the “punch” or “kick” distinguishing these from the ‘unreasonable manner’; ie you cannot punch or kick an animal at all.S4.1 applies to all people handling livestock in the saleyard.


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Electric ProddersS4.2 A person must not use an electric prodder on a bobby calf or a horse in a

saleyard or depot.

S4.2 is based on LTS SA5.8 (ii) (electric prodders not permitted on animals less than 3 months) and SB8.11 (must not use an electric prodder on a horse).

Additionally, section 5.2 (special considerations for bobby calves) of the COP states – “the use of electrical goading devices or dogs when handling, driving, weighing, loading or unloading is not an acceptable practice.”

The Victorian POCTA Regulation 14 (2)(a) prohibits the use of electric prodders on livestock less than 3 months (= bobby calves)

S4.2 applies to all people handling livestock in the saleyard.

S4.3 A person must not use an electric prodder on a goat known or visually assessed to be pregnant.

S4.3 is equivalent to LTS SB7.3. This standard is applicable to goats in the transport process and therefore extends to and is applicable to the saleyard process in handling in yards, loading and unloading. S4.3 applies to all people handling livestock in the saleyard.

S4.4 A person must not use an electric prodder on a pig except during loading or unloading and only where:

i) an individual pig weighs 60 kgs (live weight) or more; and

ii) other reasonable action to cause movement have failed; and

iii) there is reasonable risk to the safety of the stockperson.

S4.4 is equivalent to LTS SB9.4. This standard is applicable to the loading or unloading pigs during the transport process and therefore is applicable to the saleyard process. S4.4 applies to all people handling livestock in the saleyard.

S4.5 A person must not use an electric prodder on livestock in the saleyard or depot unless permitted in that species and must not use it:

i) on genital, anal, udder or facial areas; or

ii) on livestock under three months old; or

iii) on livestock that are unable to move away; or

iv) excessively on an animal.


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S4.5 is an extension of LTS SA5.8, broadening the scope of the standard to apply to animals in the entire saleyard process, not only the transport process (loading/unloading etc). The Victorian POCTA Regulation 14 (2) prohibits the use of electric prodders as per LTS 5.8

In relation to electric prodders, section 4.2 of the COP states “Their use must be restricted to the absolute minimum. The continual prodding of animals which have little or room to move must not occur.” S4.5 applies to all people handling livestock in the saleyard.

DogsS4.6 A person in charge must ensure a dog in a saleyard or depot is under

control at all times.

S4.6 is an extension of LTS SA5.9, broadening the scope of the standard to apply to dogs in the entire saleyard process, not only the transport process (loading/unloading etc).The COP has a standard of similar wording and the same intent – “Dogs must be supervised at all times and be secured when not working.”S4.6 primarily applies to the dog owner / handler, but can also extend to the dog handler’s employer (e.g. agent or saleyard operator) and also the saleyard manager.

S4.7 A person in charge must ensure that a dog working livestock in a saleyard is appropriately muzzled at all times to prevent the biting of livestock.

Section 4.2 of the COP has an existing “standard” stating “Dogs must be effectively prevented from biting.” and “Dogs must also be supervised at all times and be secured when not working”. Section 5.2 (special considerations for bobby calves) of the COP states – “the use of electrical goading devices or dogs when handling, driving, weighing, loading or unloading is not an acceptable practice.”

As with S4.6 above, S4.7 primarily applies to the dog owner / handler, but can also extend to the dog handler’s employer (e.g. agent or saleyard operator) and also the saleyard manager. The saleyard operator should have signage at the saleyards indicating all dogs must be muzzled when working livestock in the saleyards.

Muzzles need to be “appropriate” for the purpose, and be an appropriate fit. The use of a wire muzzle designed for greyhound dogs (with long muzzle) is not appropriate for a kelpie or border collie dog. Dogs must be able to breath freely.

S4.8 A person must not use a dog to move a bobby calf, horse or pig in a saleyard or depot.

S4.8 is based on LTS SB4.9 (“..must not use a dog to move a bobby calf during the transport process.”), and SB8.12 (“.. must not use a dog to move a horse during the transport process.”). Additionally, the COP has a “standard” of similar wording and the same intent – “Dogs must not be used to move pigs”. Author: Dr David Champness, DEPI Victoria



(The Pig Welfare Standards (MCOP) allows the use of dogs to aid in the movement of pigs on farm so long as the dogs are under control at all times and muzzled if they habitually bite).

S4.8 applies to the dog owner / handler.

Inspection of livestockS4.9 A person in charge must ensure that an inspection of livestock is

undertaken at the first reasonable opportunity, and at least once daily to ensure the health and welfare of all animals within the saleyard or depot.

Most livestock are held in saleyards for less than 24-30 hours, with few spending 36-48 hours (or more) in a saleyard. During the saleyard process livestock are handled (and therefore observed or inspected) several times, ie at unloading, during drafting and penning, selling, delivery to holding yards, and loading for dispatch. Therefore livestock are generally inspected several times over the course of the saleyard process. Although this standard covers all livestock held at saleyards, it is targeted at those animals held for extended periods, outside of or beyond the ‘normal’ delivery, selling and dispatch process and those held in depots. Several other standards ensure animals are inspected for “fitness for the intended journey” or “fit for sale” by different responsible people, eg during unloading (transporter / receiver), selection for sale (livestock agents) and selection for further transport (consignor) and at loading (transporter).

S4.9 primarily applies to the saleyard manager, but may also apply to the livestock owner (buyer or their nominated agent) to ensure the overall welfare of the livestock under their care in the saleyards.

WeatherS4.10 A person in charge must take reasonable action to minimise the impact of

extreme weather conditions on the welfare of livestock in a saleyard and depot.

S4.10 is similar to LTS SA5.16 broadening the scope of the standard to apply to animals in the entire saleyard process, not only the transport process.Section 3.3 of the COP states - “The provision of shade or cooling systems in hot climates and shelter from excessive cold for animals in holding facilities is desirable, recognising practical and economic limitations. Animals should be protected from extremes of weather.”

This standard is not mandating that saleyards have a roof over the entire yard. It is requiring ‘reasonable actions’ be taken through the provision of suitable facilities for the environment, and appropriate management including risk management procedures to minimise impact of welfare on the animals. Such measures may include postponing sales on forecast days of extreme heat, reduced penning density on hot days, increased frequency of access to water, permanent shelter wind breaks from cold southerly winds in the southern states.


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S4.10 primarily applies to the saleyard operator (owner, manager, superintendent), but may also apply to livestock agents in the management of the sale and livestock.

Newborn animalsS4.11 A person in charge must ensure that animals born during transport to, or

in a saleyard or depot, are managed to ensure the welfare of the newborn and dam.

Although the land transport standards prohibit the movement of animals in late pregnancy, it is acknowledged that this does occasionally occur, and the stress of transport may induce early delivery of newborn animals, which then require special care.Section 4.3 of the COP states – “…. The following categories should be separated – (a) females with suckling offspring”

S4.11 applies primarily to the person directly responsible for the livestock; in this case, usually the selling agent (and their staff) but the saleyard manager and their staff have some responsibility. The transporter will be responsible during transit to the yards and until notification of delivery to the receiver (usually the selling agent).


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5. Drafting and penning

S5.1 A person in charge must ensure that livestock are not overcrowded in a pen or yard, and must ensure that an animal is freely able to move, turn around and rise from a lying position unobstructed in a pen or yard.

S5.1 is similar to LTS SA5.4 in that there is a responsibility to manage the density of livestock in a pen. Whilst the saleyard operator (manager) has an overall responsibility for penning density in the saleyard through provision and often the allocation of appropriate holding, selling and post-sale holding pens, it will generally be the responsibility of the livestock agent / agency staff (and other stock persons) for the penning density of livestock in individual (selling) pens.

Although S5.1 and 5.2 are both about penning density, the first part of S5.2 is the requirement of the standard and the second part (determination of penning density) gives guidance to achieving the outcome based standard. S5.1 is more prescriptive to ensure animals (especially lambs) are not overcrowded.

S5.2 A person in charge must ensure that each pen or yard of livestock is assessed for appropriate penning density. The assessment is based on the body size of the livestock, and must be managed to minimise risk to the welfare of the livestock.

Determination of penning density must consider all of the following factors:

i) species and class

ii) size and body condition

iii) wool or hair length

iv) horn status

v) predicted weather conditions

vi) design and capacity of the pen

vii) time spent in the pen.

S5.2 is similar to LTS SA5.4.

Section 3.6 of the COP states – “The density of cattle in selling pens should allow for all cattle to have access to water. Appropriate stocking densities for sheep should take into account the age, condition, wood length and size of sheep. Lower densities should be used where there are calves or lambs at foot.”

Although a table of recommended animals per m2 would be a useful guide, there are too many variable factors as indicated in the seven clauses of S5.2. Penning density remains an exercise in judgement based on these and other factors, ie a qualitative rather than quantitative measure.


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As with S5.1 above, the responsibility for penning density in individual selling pens and yards will generally be the selling agent and their staff.

S5.3 A person in charge must ensure livestock are segregated into sufficient and where necessary, individual pens to minimise risk to the welfare of other livestock.

Determination of segregation must consider all the following factors:

i) species, class and size

ii) general health of the animals

iii) level of aggression.

Section 3.6 of the COP states – “Lower densities should be used where there are calves or lambs at foot. Different classes of stock should be maintained separately as far as practical. Individual pens should be provided for sale bulls.”

Section 4.3 of the COP states - “Animals of different species should not be mixed, in particular calves or sheep with pigs. Within species, unless they arrive in one consignment from a single point of origin, the following categories should be kept separated:

females with suckling offspring females known to be in advanced pregnancy mature entire males unfamiliar groups of pigs.

It is also desirable, whenever possible, to hold separately: hornless and horned animals animals of significantly different sizes.”

S5.3 is also consistent with LTS SA5.6 in segregating livestock.

S5.3 applies to all persons handling livestock in the saleyards. This will include the transporter when unloading, agency stock personnel and any stockpersons employed by the saleyard operator.

S5.4 A person must not excessively spin cattle around in a selling pen.

This is a new standard, initiated by an agent and supported by ALPA. Section 3.6 of the COP states – “Selling pens should allow for adequate viewing of stock by buyers.” If the COP guideline is followed, there should be no need to ‘spin’ cattle in a pen. This practice is a risk to safety for a person in a pen ‘working’ the cattle, it may cause distress and stir up the cattle involved as well as adjoining cattle, and risk trauma to the hooves of the cattle from the twisting action especially on concrete floors, leading to lameness and not being fit for further transport.

S5.4 is primarily targeted at selling agents and their staff.


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6. Feed and water

Note: The provision water (and feed) is a key determinant of livestock welfare during transport and the associated saleyard process.

Concern was raised about the lack of a requirement in the LTS to record when livestock last had access to feed and water pre-transport unless the journey is reasonably expected to exceed 24 hours. This lack of information creates issues for planning journeys from the saleyards.

Definitions

Reasonable access to waterMeans an opportunity for a minimum of four consecutive hours for livestock to be able to drink water of a suitable quality and quantity to maintain their hydration.

Time off waterMeans the period of time for which livestock do not have reasonable access to water during the transport process.

Maximum time off water means the limit which cannot be exceeded.

The minimum period to be recognised as reasonable access is four consecutive hours. If livestock are provided with access to water for less than four hours, their maximum allowable transportation time (time off water) is unchanged. If livestock provided with reasonable access to water for between four and 24 hours, the time for which such access was provided can be added to extend the total time of the trip if the livestock continue to meet the fitness requirements.If the livestock have a spell of the duration stated in the species requirements, the journey is deemed to be completed and another journey can be undertaken for the maximum time off water.

The time off water is calculated by accumulating the following time periods where reasonable access to water does not occur:

1. the period of time the livestock are being assembled (where reasonable access to water is not provided); plus

2. the period of time the livestock are held in a livestock holding facility prior to loading (where reasonable access to water is not provided); plus

3. the period of time the livestock are being loaded (where reasonable access to water is not provided); plus

4. the period of time where the livestock are on a vehicle whether moving or stationary (where reasonable access to water is not provided); plus

5. the period of time the livestock are unloaded and held in a livestock handling facility during transit or at a destination until reasonable access to water is provided.

SpellA spell is the provision of water, food and space to lie down to rest for the minimum time periods defined by land transport standards for each species and class of animal


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and is a mandatory requirement when maximum time off water is reached before starting a further journey.Water, food and space to lie down must be provided to all livestock, on a stationary vehicle or off a vehicle. Where animals are unloaded, a spell starts from the time all animals are unloaded and ends when animals are handled for reloading. Handling of animals should be kept to a minimum.A spell may occur voluntarily before loading, mid-journey or at the completion of a journey. Where livestock are spelled for 24 hours, any subsequent journey can be considered as a new water deprivation period.A spell does not include time spent in curfew.

WaterS6.1 Livestock at a saleyard or depot must be provided with reasonable access

to water and space to lie down within 24 hours of arrival at the facility by the person in charge, or within the maximum time off water period relevant to the species and class of animal if this time is less than 24 hours as defined in the Land Transport Standards.

LTS SA5.3 was developed as a risk management standard to ensure livestock received access to water in a saleyard where no record was readily available for when the animals last had water, thus ensuring the welfare of the animals.

The draft Cattle Welfare Standards have a guideline which advises “cattle should have reasonable access to water at least daily”.

The draft Sheep Welfare Standards have a guideline which advises “sheep should have access to feed and water daily except where reasonable management practices, such as shearing, preparation for sale, transport, slaughter and drenching, result in a longer period of water deprivation of 48 hours. Feed and water deprivation exceeding 48 hours should be avoided.”

The proposed standard S6.1 is an extension of LTS SA5.3, reinforcing the transport standard, but going further to ensure the livestock also have space to lie down within the 24 hour period of arrival.

This proposed standard allows for the management of any pre-transport water curfew.

Saleyards which do not have adequate watering facilities will need to be managed to ensure livestock are processed through the saleyard process efficiently in order to comply with the maximum time off water standards for the species and class of animals as per the LTS.

Some animal welfare organisations would like to see all livestock which are held overnight have access to water, whilst others want the stock to have access to water all of the time whilst held in saleyards. LSAV advise that not all saleyard operations can meet a requirement to have all animals on water overnight, but that they can be managed to provide reasonable access to water within 24 hours.


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This proposed standard ensures all livestock held in saleyards for 24 hours or more will have ‘reasonable access to water’ (as defined in the SWS and LTS definitions as “an opportunity for a minimum of four consecutive hours for livestock to be able to drink water of a suitable quality and quantity to maintain their hydration”). Walking livestock past a water trough in a yard or laneway is not ‘reasonable access to water’.

Possible scenarios for sheep sales include: sheep received into holding yards with water in the afternoon, drafted that

evening into sale pens, held overnight (off water), sold the next morning and transported after sale;

sheep received late afternoon/evening, put on water o/n, drafted and penned in morning, sold and transported;

sheep received in morning, drafted, penned, sold and transported same day; sheep received overnight or morning, drafted, sold, put into holding yards with

water after sale, removed from water for a few hours pre-transport (curfew), then transported.

The overall responsibility for ensuring compliance with this standard, that is, livestock are provided with reasonable access to water and space to lie down within 24 hours at the saleyard defaults to the saleyard manager, but as the receivers and likely primary carers of the livestock in the first 24 hours of delivery, the selling agents will also be responsible for ensuring compliance with the standard.

S6.2 A person in charge must manage time off water to minimise risk to the welfare of livestock according to:

(i) the increased risk to livestock welfare of longer journeys close to the permitted maximum time off water; and

(ii) the assessment of whether the livestock are fit for the intended journey; and

(iii) the predicted climatic conditions, especially heat or cold; and

(iv) the class of livestock, especially if weak, pregnant, recently having given birth, lactating or immature; and

(v) the nature of the intended journey.

S6.2 is equivalent of LTS SA5.2.

S6.2 is primarily the responsibility of the livestock owner ((buyer) or their nominated agent) as the consignor of the animals for the journey from the saleyards to the final destination (farm, feedlot, abattoir).

S6.3 If the maximum permitted time off water as defined in the Land Transport Standards is reached, the person in charge must provide the livestock with a spell (water, food, space to lie down and rest) as defined in the Land Transport Standards, before continuing the current journey or before starting another journey.

S6.3 is equivalent to LTS SA5.1. The transport and saleyard process’ are inter-related and this standard is applicable both transport and saleyards.Author: Dr David Champness, DEPI Victoria



The responsibility for provision of mandated spell under this standard will be dependent on whose primary care the livestock are under at the time of reaching the maximum permitted time off water. It may be the receiver of the livestock (the selling agent) but primary responsibility may be transferred to buyer (as the current owner) or their representative) if the maximum TOW period elapses after the sale.

S6.4 A person in charge must ensure pigs have access to water at all times in receival and holding pens.

This standard is based on section 5.1 (special considerations for pigs) and states – “Cool, drinkable water should be provided at all times in holding pens.” The saleyard operator must ensure watering facilities are sufficient and operating. The selling agent and their staff are responsible for ensuring the pigs are put into holding pens with access to water.

Feed

Section 3.8 of the COP states- “As a general rule animals should not be without food for more than 24 hours including the time spent travelling and yarding.

LTS guideline GA5.43 states – “Livestock at a saleyard, spelling facility or staging point should be provided with reasonable access to water after 12 hours, and to feed after 36 hours at the facility”.

The LTS specify maximum allowable periods of time off water (TOW) for each species and class of animals, and the minimum duration for a spell (provision of water, food and space to lie down to rest) in instances where livestock reach the maximum time off water, before starting another journey. Under the LTS, the provision of feed is ensured through mandating a ‘spell’ where max TOW is reached.

However, the saleyard process generally involves two transport journeys; transport to the saleyards and dispatch from the yards, (or one “continuous” journey with a period spent in the saleyard).

Where livestock are either not provided with water or have limited access whilst at the saleyards, the two separate trips will be considered as one journey under the LTS for calculating time off water (water deprivation time).

Where the maximum TOW is reached, and the animals are given the mandatory spell (water, food and rest (36 hrs for adult cattle and sheep)), then the dispatch trip is a separate transport journey.

Where maximum TOW is not reached, and the animals are given a voluntary 24 hour spell (water, feed and rest), any subsequent journey can be considered as a new water deprivation period.

As indicated in the definitions of time off water and spell, the provision of reasonable access to water during a transport journey including time spent in the saleyard will


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extend the allowable water deprivation time, but until the livestock have an actual spell (water, food & rest for at least 24 hours), the clock is still ticking on the journey time with respect water deprivation time.

Livestock provided with reasonable access to water at the saleyards will require feeding at the yards if they are held for an extended time. This time off feed will be shorter for mono-gastric animals (horses and pigs) and young, pregnant or lactating animals, than dry adult ruminants (cattle, sheep and goats). In order to maintain an animal’s health and welfare, the time period before feeding is required will also depend on the condition of the livestock, type of feed they have been on, and obviously how long they have been off feed before and during transit to the yards.

Therefore, similarly to the welfare ‘risk management’ standard SA5.3 in the LTS, which sets a ‘trigger time’ for provision of water, when it is unknown how long stock have been off water, it is proposed that saleyards require standards setting an outer time limit for provision of feed for livestock held at saleyards for extended periods. These are proposed standards 6.5, 6.6 and 6.7 below.

The draft Sheep Welfare Standards have a guideline which advises “sheep should have access to feed and water daily except where reasonable management practices, such as shearing, preparation for sale, transport, slaughter and drenching, result in a longer period of water deprivation of 48 hours. Feed and water deprivation exceeding 48 hours should be avoided.”

The provision of appropriate feed is primarily the responsibility the livestock owner / buyer (or their nominated representative or agent). To ensure the welfare of any livestock which have been left at a saleyard for longer than the specified times in standards 6.5, 6.6 or 6.7, and the owner hasn’t arranged for feeding, the saleyard manager will be responsible for their care and the provision of feed. Any cost should be borne by the livestock owner.

S6.5 A person in charge must ensure cattle, sheep and goats which have been held in a saleyard for 36 [*24 or 48] hours are provided with adequate and appropriate feed.

* The RIS should examine the option (variation) of either a 24, 36 or 48 hour time limit.

Forty eight hours in the saleyard will be a very long time off feed for most ruminant animals as they will have already been off feed for a number of hours prior to arriving at the saleyard, in some / many cases > 24 hours.Animals Angels and Animals Australia suggests feeding before 36 hours as saleyards usually don’t know how long livestock have been off feed prior to arrival. AWSC support a 36 hour period. RSPCA advocate a requirement for daily feeding.

There is a further consideration with respect to pre-transport curfew periods. One suggestion is to word the standard with an exemption clause such as – Livestock are exempt from this requirement to feed where the livestock are to be loaded for


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transport within four hours of the (36?) hour period, and the planned journey time is less than 12 hours. (Note: The livestock must meet the requirement of being fit for the intended journey as per the Land Transport Standards).

S6.6 A person in charge must ensure pigs which have been held in a saleyard or depot for 24 hours are provided with adequate and appropriate feed.

Guideline GB9.5 of the LTS advises: “On unloading, pigs should be fed and watered within 24-hour intervals in accordance with the relevant standards for production, saleyard and processing sectors.”

The Model COP for the welfare of Pigs states –“Pigs must be provided with daily access to feed that maintains their health and meets their physiological requirements. Weaners must be provided with access to feed at least twice daily.”

S6.7 A person in charge must ensure horses which have been held in a saleyard or depot for 12 hours are provided with adequate and appropriate feed.

Standard 5.4 of the Victorian Horse Code states “Horses must not be deprived of access to food for more than 24 hours”.

Under the LTS, there is no requirement to record the time livestock last had access to water unless the journey time is expected to be longer than 24 hours (LTS SA1.2). It is unlikely horses will have access to feed if they are deprived of water in transit for 24 hours.

Guideline GB8.8 of the LTS advises: “Adult horses should be fed and watered at floor level every five hours and as soon as possible after unloading, with a suitable quality and quantity of feed and water to minimise colic risk.”

LTS SB8.3 allows for an extended journey time to 36 hours (from 24 hours for adults) if they have access to water and feed every five hours (either on or off the truck/float).

S6.8 A person in charge must ensure bobby calves consigned to saleyards or depots for sale for slaughter are progressed through the saleyard and transport processes to ensure delivery to meat processors within a maximum of 18 hours from time of last feed.

S6.8 is based on LTS SB4.5 and is drafted to be consistent with the timeframe requirement mandated in clause (iv) of that standard.


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7. Pre-sale livestock inspection, selection and care of weak, sick and injured animals

S7.1 A person in charge must not present for sale livestock that are not fit for sale. An animal is not fit for sale if it is:

i) unable to walk on their own by bearing weight on all legsii) severely emaciatediii) visibly dehydratediv) showing visible signs of severe injury or distressv) suffering from conditions that are likely to cause increased pain or

distress during transportvi) blind in both eyesvii) known to be, or visually assessed not to be within two weeks of

parturition.

S7.1 is based on LTS SA4.1 (livestock must be assessed fit for the intended journey). ‘Fit for sale’ is defined with the definition based on and consistent with the LTS definition of ‘fit for the intended journey’. The definition has an additional element for pregnant mares, which is also consistent with the LTS.

This proposed standard is consistent with the general section of the COP which states – “Diseased, sick injured or drought weakened stock should not be consigned to, or processed through, saleyards”.

The aim of this standard is to ensure any animal/s which arrived at the saleyard which were non-compliant with the fit to load criteria, or were injured in-transit, are not further progressed through the saleyard process (sold), further exacerbating any welfare issues (pain or suffering), unless they are fit for sale and any further intended journey.

The person/s responsible (person in charge) will generally be the selling agent and/or their staff who were responsible for assessing, drafting and/or penning pre-sale the livestock.

S7.2 A person in charge must not present for sale a bobby calf, unless the calf is a minimum of five days of age, is in good health, alert and able to rise from a lying position. This standard does not apply to calves born in transit, or at the saleyard.

This standard is based in the general LTS SA4.1 (livestock must be fit for the intended journey) and the specific bobby calf LTS SB4.5 (must be 5 days old or more, in good health, alert and able to rise from a lying position. It is consistent with section 5.2 of the saleyard COP. S7.2 is primarily the responsibility of the selling agent to ensure the calves continue to be in good health and will meet the fit for the intended journey criteria for further Author: Dr David Champness, DEPI Victoria



transport. The consignor must ensure the age of the calf (as per declaration on bobby calf NVD).

S7.3 A person in charge must make the appropriate arrangements at the first reasonable opportunity for the separation of distressed, weak, sick or injured livestock for further assessment, rest and recovery, appropriate treatment or humane killing.

S7.3 is similar to LTS SA5.15 and SA5.17, but the responsibility (person in charge) is broadened to include all people along the supply chain in the saleyard process, not just the receiver (as per LTS). The responsible person/s will be the receivers of the livestock, which primarily will be the selling agents and their staff, but may include saleyard staff, transporters and livestock buyers. Under LTS SA5.15, the transporter must identify to the receiver any weak, ill or injured livestock.

S7.4 A person in charge must ensure that arrangements are made at the first reasonable opportunity for the appropriate care, treatment or humane killing of any animals assessed as not ‘fit for sale’ or sick, injured or diseased livestock.

S7.3 relates to the requirement for a person to separate distressed, weak, sick or injured livestock for further assessment or treatment, whereas S8.4 requires a person to arrangement for the appropriate care, treatment or killing of any identified or separated stock.

S7.4 is a ‘higher’ level responsibility than S3.3, for example a stock person employed by a livestock agency may identify and separate an injured animal for further assessment (as per S7.3) and notify their supervisor / senior agent. It is then responsibility of the supervisor / senior agent to either make the appropriate arrangements for care and treatment or humane killing, or notify to a higher level of the case, for example to the agency livestock manager or the saleyard manager / supervisor, who then accepts responsible for arrangements or the appropriate care and treatment.


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8. Pre-transport selection of livestockNote: standards S8.1 to S8.5 are as per standards SA4.1 to SA4.5 of the LTS.

These standards were assessed through the LTS RIS and are already endorsed by PIMC (2009) and adopted into state and territory legislation (2012/13). These five standards are the status quo or base case and therefore do not require inclusion in the saleyard welfare standards RIS.

S8.1 Livestock must be assessed as fit for the intended journey at every loading by a person in charge. An animal is not fit for a journey if it is:

i) unable to walk on its own by bearing weight on all legs; or

ii) severely emaciated; or

iii) visibly dehydrated; or

iv) showing visible signs of severe injury or distress; or

v) suffering from conditions that are likely to cause increased pain or distress during transport; or

vi) blind in both eyes; or

vii) known to be, or visually assessed to be near (within two weeks) parturition, as specified in the species requirements, unless time off water and journey is less than four hours duration to another property.

S8.1 is equivalent to LTS SA4.1.

S8.2 Any animal assessed to be not fit for the intended journey must only be transported under veterinary advice.


S8.3 The consignor must only supply animals that are fit for the intended journey.


S8.4 A person in charge must not load, nor permit to be loaded, animals that are not fit for the intended journey except under veterinary advice.


S8.5 If an animal is assessed to be not fit for the intended journey before loading, a person in charge must make appropriate arrangements for the care, treatment or humane killing of the animal at the first reasonable opportunity.



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9. Humane killing

S9.1 The saleyard operator must have a documented plan and procedures in place for the humane killing of livestock at the saleyard.

S9.1 is a new standard, however it relates to the saleyard Manager’s responsibility in the COP.

S9.2 The saleyard operator must ensure the provision of a designated person with the relevant knowledge, skills, experience and access to the appropriate equipment for the humane killing of the species and class of livestock routinely handled at the saleyard. The designated person/s must be available to humanely kill an animal within a reasonable time during normal saleyard operating hours.

Although S9.2 is a separate standard to S9.1, the two standards are inter-related with S9.2 being part of the implementation of the documented plan required in S9.1

This standard is an extension of Section 2.1 of the COP which states the saleyard manager should ensure - “subject to firearm legislation, a rifle and/or captive bolt pistol should be kept at yards and be readily accessible for use for emergency slaughter.”

Section 4.4 of the COP (unloading of injured animals) states – “Severely injured animals should be humanely killed without delay. If a veterinarian is unavailable, this should be done by, or at the direction of, the person in charge of the saleyards. It is unacceptable to delay killing severely injured animals for any length of time.”

S9.3 A person in charge of an animal that is suffering from distress, disease or injury that cannot be reasonably treated, must ensure the animal is humanely killed at the first reasonable opportunity.

S9.3 is equivalent to the respective proposed standards in the draft cattle and sheep welfare standards- “A person in charge must ensure a sheep / cattle that is suffering from severe distress, disease or injury that cannot be reasonably treated, is killed at the first reasonable opportunity.” It is also consistent with the first part of LTS SA6.2 “A person in charge must ensure a moribund animal is humanely destroyed by …..”

The standard is also consistent with LTS SA5.17 – “The receiver of livestock must make arrangements at the first reasonable opportunity for separating weak, ill or injured livestock for rest and recovery, appropriate treatment, or humane destruction and disposal of dead stock.”

It is also consistent and compliments LTS SA4.5 – “If an animal is assessed to be not fit for the intended journey before loading, a person in charge must make appropriate arrangements for the care, treatment or humane destruction of the animal at the first reasonable opportunity”.


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As stated in the comments above regarding S9.2, section 4.4 of the COP states “Severely injured animals should be humanely killed without delay. It is unacceptable to delay killing severely injured animals for any length of time.”

S9.4 A person in charge must ensure killing methods result in rapid loss of consciousness followed by death while unconscious.

S9.4 is equivalent to LTS SA6.1 and the equivalent proposed standards in the draft Cattle and Sheep Welfare Standards, and the MCOP for pigs. Adoption of this standard simply extends the scope to livestock in the saleyard of this widely accepted fundamental requirement for humane killing.

The standard is consistent with the section 7 of the COP (humane destruction) which states – “…, the method of slaughter should be effective and cause sudden and painless death of the animals”.

S9.5 A person killing an animal must have the relevant knowledge, skills and experience, or be under the direct supervision of a person with the relevant knowledge, skills and experience to humanely kill an animal.

S9.5 is consistent with the respective proposed standards in the draft Cattle and Sheep Welfare Standards and pig welfare MCOP for humane killing, in the requirement for the operator to have the relevant knowledge, skills and experience, or be under the direct supervision of such a person. It is similar to LTS SA6.3 in the requirement for a competent operator, or supervision by such person.

S9.6 A person humanely killing an animal must take reasonable action to confirm the animal is dead.

S9.6 is equivalent to LTS SA6.4 and the equivalent proposed standards in the draft Cattle and Sheep Welfare Standards, and the MCOP for pigs. Adoption of this standard simply extends the scope of this generic mandatory requirement to livestock in the saleyard process, not just on-farm or during transport.

S9.7 A person may only kill an animal using the blunt trauma technique if that animal is either a piglet up to 15 kg live weight, or a calf, kid or lamb less than 24 hours old. The person must kill the animal by a single blow to the head.

S9.7 is equivalent to LTS SA6.5 (with the removal of reference to alpaca, camels and deer as these species are not within the accepted scope of the saleyard welfare standards). It is consistent with the draft Cattle and Sheep Welfare Standards and pig welfare MCOP for humane killing.


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Consultation Regulation Impact Statement

A key aspect to creating animal welfare standards is to identify the costs and benefits that they will have for a wide range of stakeholders. This is typically done by preparing a Regulation Impact Statement (RIS).

A RIS is a required document prepared by the department, agency, statutory authority or board responsible for a regulatory proposal. The RIS includes recommendations for the most effective and efficient option and formalises and documents how authorities have assessed the costs, benefits and the possible changes to an existing (or a new) regulation.

Authorities are required to conduct public consultation to seek feedback and determine the level of support for the RIS. When the RIS is assessed, it must include a consultation statement that shows how consultation was undertaken, who was consulted and a summary of their views, and those views that were considered.

Problems and policy objective

The main underlying problems with the current voluntary Code of Practice and therefore a case for change to the development of the proposed national standards are those relating to:

a lack of national consistency,

a lack of clear and verifiable standards,

deficiencies in the existing model code for the welfare of animals at saleyards; and

uncoordinated animal welfare risk management.

In relation to the proposed standards and feasible alternatives the following overarching policy objective is identified:

To minimise risks to livestock welfare and unnecessary regulatory burden in a way that is practical for implementation and industry compliance.

The main criterion for evaluating the proposed standards and the feasible alternatives is net benefit for the community, in terms of achieving this policy objective.

The proposed form of government intervention is the endorsement of standards and/or guidelines by SCoPI with the intent of the standards being implemented by legislation in each participating jurisdiction. There are both economic and social grounds for such intervention, including various categories of market failure.


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Options

The options evaluated in terms of costs and benefits may include:

Option A: converting the proposed national standards into national voluntary guidelines (the minimum intervention option);

Option B: the proposed standards as currently drafted;

Option C: variations of the proposed standards as follows:

o S6.5 – The provision of adequate and appropriate feed to cattle, sheep and goats where they have been held in a saleyard for 24 or 48 hours (proposed S6.5 requires feeding after 36 hours).

Evaluation of Costs and Benefits

The RIS assesses the incremental costs and benefits of the proposed changes in standards, rather than changes in practices. Where current practice is lower than the current regulatory requirements, this is not covered in the RIS.

The term ‘base case’ means relevant status quo, or the situation that would exist if the proposed standards were not adopted i.e. any existing Australian standards or Codes of Practice, plus market forces and the relevant federal, state and territory legislation. The base case provides the benchmark for measuring the incremental costs and benefits of the proposed standards and other options.

The Office of Best Practice Regulation (OBPR) has previously advised that the base case does not need to be an option as all costs and benefits are incremental to the base case anyway. If the net benefit is lower than the base case, then the status quo will remain. Option A is described as the minimum intervention option (which OBPR requests to see in a RIS).

Where data exists, quantitative estimates of costs and benefits are made, using stated reasonable assumptions to fill in any essential data gaps. However, where sufficient cost and benefit data is not available, the evaluation will be made using qualitative criteria regarding the achievement of the policy objective. .

Comparing the cost and benefits against the ‘base case’ is hindered by the inherent inability to quantify benefits to animal welfare.

Multi-Criteria Analysis

A multi-criteria analysis (MCA) will likely be required as a formal benefits cost analysis will likely be impossible to complete because important costs or benefits cannot be quantified and expressed in dollar terms. A MCA can help top clarify why the proposed regulation is preferred over the alternatives. The key benefit of a MCA is that it allows qualitative judgements about the policy merits of different options to Author: Dr David Champness, DEPI Victoria



be made in a consistent and systematic manner. Hence, it promotes logical and considered decision-making and maximises transparency.

Three evaluation criteria may be used:i) Animal welfare benefits;ii) Net compliance costs to industry and government; andiii) Promotion of nationally consistent standards.

The basis of selection of the preferred option will be the one that generates the greatest net benefit for the community.


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