In order to adhere to international principles for good standards setting, the LGAP Standards were made available for a 60 day public comment period which commended on 30 November 2015 and ended 5pm 29 January 2016 (AEDT). Overall, 20 submissions were received from various organisations and individuals representing 188 comments.
A number of animal welfare and activist organisations as well as individuals provided constructive comments in the prescribed manner. Professor Temple Grandin also provided comment on the LGAP Standards.
While some criticism was made regarding the prescriptive format for commenting on the LGAP Standards, as explained by Committee Chair, Dr Kennedy in an open letter, this was necessarily a formal, defined process that would allow structured comments to be provided to and considered by the LGAP Standards Committee. The process was consistent with that used by other standards setting bodies such as the ISO.
Some commenter's chose not to follow the defined process and submitted correspondence to the LGAP Standards Committee either in support of the Program and the LGAP Standards or in opposition to the livestock export industry in general. Some organisations declined the opportunity to direct comments to the LGAP Standards Committee and rather provided responses directly to the Minister for Agriculture, some in support and some in opposition to the trade and the Program. Vets Against Live Export (VALE) chose to publish an open letter, which was responded to by the Australian Livestock Exporters Council.
During its March 2016 meeting, the LGAP Standards Committee followed a set process whereby each and every submitted comment or item of correspondence received was considered and a determination made based on the following classification:
- Noted - The comment was a statement and did not provide recommendations, suggestions or guidance for changes and was considered to be 'unactionable'.
- Accepted - The comment was accepted in its entirety or with only minor amendments.
- Partially accepted - The comment was accommodated but not exactly as suggested.
- Not accepted - The comment was considered but not adopted.
The public comment process provided for comments to be received in-confidence. In the interests of transparency, the LGAP Standards Committee agreed that a compilation of comments without identifying information and including the LGAP Standards Committee's determinations could be made publicly available.
Summary of outcomes
From the 188 comments provided, 33 or 18% were Noted (ie statement only and not actionable). Of the 155 that were actionable:
- LGAP 1001: 49% - Accepted/Partially accepted and 51% - Not accepted
- LGAP 1002: 73% - Accepted/Partially accepted and 27% - Not accepted
- LGAP 1003: 67% - Accepted/Partially accepted and 33% - Not accepted
- No comments were received on LGAP 1000.
Overall, the LGAP Standards Committee Accepted or Partially accepted 52% of actionable comments with 48% Not accepted.
On 8 March 2016, having considered the public comments and correspondence, and agreed changes based on these, the LGAP Standards Committee unanimously accepted the revised LGAP Standards.