Open letter to respondents to the Public Comment on the LGAP Standards
29 January 2016
The Livestock Global Assurance Program (LGAP) Standards Committee wishes to thank those organisations and individuals who took the opportunity to provide constructive comment on the LGAP Standards.
The LGAP Standards Committee also acknowledges receipt of correspondence from several parties and notes their decisions not to provide comment on the draft LGAP Standards in accordance with the process determined by the LGAP Standards Committee or to comment on matters outside the scope of the LGAP Standards Committee's terms of reference (being the Standards).
The process which was followed for the 60-day submission of comment period was consistent with that applied by international standards setting bodies, such as the International Organization for Standardization (ISO). The process was necessarily formal and defined to allow all comments to be considered objectively by the LGAP Standards Committee.
The LGAP Standards Committee would like to correct some statements that have been made about LGAP and this process.
Coinciding with the implementation of the Exporter Supply Chain Assurance System (ESCAS) in 2011, the Australian Government commissioned an independent review into the livestock export trade which was undertaken by Mr Bill Farmer (AO) (the 'Farmer Review'). A recommendation of that review was that industry explore the application of QA through the supply chain back on farm to complement the Government's regulatory compliance program.
The research project commenced in July 2014 with a project team that includes specialists in the areas of project management, the live export industry, animal welfare, husbandry and behaviour, development and internationalisation of standards and conformity assessment programs, as well as the development and application of technology solutions.
The development of LGAP (or the Program) remains an ongoing research project of the Australian livestock export industry and no decision regarding whether or not the Program will be implemented has been made.
In accordance with an earlier scoping project, this research project is developing a conformity assessment and certification program, applicable to any market and designed to provide assurances that animals continue to be treated in accordance with the ESCAS Animal Welfare Standards for Australian livestock from discharge up to and including the point of slaughter.
At this stage, the scope of the research project does not include domestic assembly and exportation of livestock as this is managed under the Australia Standard for the Export of Livestock (ASEL).
As with any conformity assessment program, LGAP will be required to be governed by a set of Rules and Standards. Rules govern the operation (eg administration and management) of the program and the responsibilities of all parties. Standards are the technical requirements that must be met by those seeking recognition under the program.
Basis for LGAP
As the Program is to operate outside Australia and across international borders, the development of the Program overall, as well as the LGAP Standards and the LGAP Certification Rules, is intended to follow international guidelines including, but not limited to, the World Organisation for Animal Health's (OIE) Terrestrial Animal Health Code (Code), guidelines and standards published by ISO and the World Trade Organisation (WTO).
These guidelines include expectations of any organisation that is setting standards and of the standards development process.
In order to be internationally applicable, the requirements contained within the LGAP Standards themselves draw on more than 20 international and domestic standards, codes, guidelines and procedures relating to animal health and welfare.
Annex A provides a comprehensive list of the major reference documents considered in the formation of the LGAP Standards, and also the Certification Rules.
Method of commenting
The process which was followed was consistent with that followed by other international standards setting bodies, such as the ISO. It was a formal, defined process to enable constructive comments to be provided and considered by the LGAP Standards Committee.
The form provided for comment on the LGAP Standards had been designed to enable comment and input on the specific content of each element of the Standards and was not intended to prescribe an outcome. This was a genuine and legitimate method to gather what was expected to be substantial feedback from all interested parties in a constructive and efficient format that facilitates serious consideration by the LGAP Standards Committee.
It may be that in layman's terms, this appeared to be a complex process and that the LGAP Standards are complex, however animal welfare is a complex discipline that does require a degree of technical understanding.
Duration of comment period
The comment period opened on 30 November 2015 and was publically announced by the Australian Livestock Exporters' Council (ALEC) through media releases and statements. It has also been circulated on social media channels since the announcement. The public comment period ran for 60 days - a time consistent with expectations for the standards setting process provided by the WTO and ISO.
The development of LGAP is far from a cynical exercise. The LGAP Standards Committee is being managed separately from the livestock export industry and the industry respects the process. Submissions by organisations or individuals are not seen in any way to reflect support or otherwise for the trade, nor does such imply a change in policy by an organisation or individual.
It was the hope of the LGAP Standards Committee that all parties, both those in support of and in opposition to the trade, accept the opportunity to provide objective and constructive input into the LGAP Standards which aim to improve animal welfare in-market.
More than 30 organisations were directly invited to comment, including the OIE, the Australian Veterinary Association (AVA), Animal Health Australia (AHA), the Chief Veterinary Officer, World Animal Protection (WAP), RSPCA Australia, Animal’s Australia and Animals Angels. Understanding that it is impossible to directly invite all interested parties, it was the LGAP Standards Committee's genuine hope that those directly invited would forward this invitation through their networks.
In recognition of LGAP being an international program, operating outside of Australia and across international borders, World Animal Protection (WAP) – the OIE recognised international animal welfare representative body – was invited to nominate a representative to sit on the LGAP Standards Committee. They declined the invitation, citing limited capacity.
WAP (Australia), RSPCA Australia and Animals Australia have been engaged directly through face-to-face briefings during the research project.
It was the sincere hope of the LGAP Standards Committee that all organisations and individuals would contribute to this process in a constructive and considered manner.
LGAP is not self-regulation
LGAP is not proposed to be a form of self-regulation and it will not dilute ESCAS. ESCAS is an ongoing regulatory framework for Australian exported livestock covering animal welfare to the point of slaughter. It is not proposed that this would change under LGAP and, indeed, LGAP has been developed to strengthen the assurance sought under ESCAS and strengthen the commitment, oversight and management of welfare along the supply chain through Operators (ie exporters and importers) and Facilities (ie feedlots, farms and abattoirs). It will, if implemented, provide for a more transparent means of demonstrating ESCAS compliance, more immediate and thorough management of nonconformities and, potentially, scope for Facilities and Operators which seek to perform over and above ESCAS and OIE requirements.
LGAP is being designed not just for Australian exported livestock. Any Facility, anywhere in the world could be certified under the Program regardless of the country of origin as long as the LGAP Standards are met. As such, LGAP, if implemented, has the potential to do more for animal welfare on a global basis than any program currently in existence.
Opposition to the livestock export trade
The standards development process is one component within a broader research and development project focussed on the development of a conformity assessment program to support the live export industry meeting its regulatory obligations. The standards development process is based on animal welfare science. The invitation for public comment is not the appropriate forum to voice general opposition to the livestock export trade. Other channels are available to voice such concerns.
Dr David Kennedy
LGAP Standards Committee
ANNEX A: LGAP INFORMATION PAPER
Items Considered in the Formation of the Program Standard and Rules
In drafting the LGAP Standard and Rules, the following have been considered:
Standards setting (process)
• Australian Accreditation Board for Standards Development Organisations (2014), Requirements for the Accreditation of a Standards Development Organisation, Version 1_1.
• 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 (2012). Standardisation Guide 006: Rules for the structure and drafting of Australian Standards. Version 2.6.
• World Trade Organization (WTO): Agreement on Technical Barriers to Trade, Annex 3: Code of Good Practice for the Preparation, Adoption and Application of Standards.
• International Organization for Standardization (2009). ISO/IEC 17007:2009 - Conformity assessment -- Guidance for drafting normative documents suitable for use for conformity assessment.
• International Organization for Standardization (2012). ISO/IEC 17065:2012 - Conformity assessment -- Requirements for bodies certifying products, processes and services.
• International Organization for Standardization (2013). ISO/IEC 17067:2013 - Conformity assessment -- Fundamentals of product certification and guidelines for product certification schemes. The Standards (requirements) Local regulation relating to animal welfare in all major export markets, as well as:
1) Animal Health Australia ( 2012). Australian Animal Welfare Standards and Guidelines - Land Transport of Livestock. Canberra, Australia.
2) AUS-MEAT (2014). National Feedlot Accreditation Scheme Handbook: Rules and standards of accreditation, April edition (as amended). Available from www.ausmeat.com.au/nfas/standards/default.html.
3) Australian Government Department of Agriculture (2015). ESCAS Animal Welfare Standard, May.
4) Australian Government Department of Agriculture (2015). ESCAS Audit Guidance, May.
5) Australian Government Department of Agriculture (2011). Guidance on Meeting OIE Code Animal Welfare Outcomes for Cattle and Buffalo, Version 2.2, 20 August.
6) Australian Government Department of Agriculture (2011). Guidance on Meeting OIE Code Animal Welfare Outcomes for Sheep and Goats, version 3.3, 21 August.
7) Australian Government Department of Agriculture and Meat & Livestock Australia (2014). ESCAS Auditor Awareness Training Program, version 1, February.
8) Australian Government Department of Agriculture and Meat & Livestock Australia (2015). ESCAS Auditor Awareness Training Program, version 3, September.
9) Australian Meat Industry Council (2009). Industry Animal Welfare Standards: Livestock processing establishments preparing animals for human consumption, Second edition. Available from www.amic.org.au.
10) Australian Government Department of Industry, Innovation, Science, Research and Tertiary (2010). Australian Recognized Unit of Competence MTMP2010A - Apply animal welfare and handling requirements (Release 1).
11) Bulut H and JD Lawrence (2007). Meat Slaughter and Processing Plants' Traceability Levels Evidence From Iowa. Proceedings of the NCCC-134 Conference on Applied Commodity Price Analysis, Forecasting, and Market Risk Management. Chicago, IL, United States of America.
12) Council of the European Union (2009). Council Regulation (EC) No 1099/2009of 24 September 2009on the protection of animals at the time of killing, Official Journal of the European Union.
13) GLOBALG.A.P (2013). Integrated Farm Assurance - All farm base/Livestock base/Cattle and sheep, control points and compliance criteria, Edition 4.0.
14) Grandin T, American Meat Institute Animal Welfare Committee (2012). AMI Foundation Animal Care and Handling Guidelines & Audit Guide, August, Certified and Accredited by the Professional Animal Auditor Certification Organization.
15) International Organization for Standardization (2012). ISO 9001:2008 - Quality management systems - Requirements. Previous edition.
16) International Organization for Standardization (2015). ISO 9001:2015 - Quality management systems - Requirements. New edition.
17) International Organization for Standardization (2012). ISO/IEC 31000:2009 - Risk management – Principles and guidelines.
18) International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) (2012). ISO/IEC Directives, ISO Supplement, Appendix 3 (3rd Edition)
19) Meat & Livestock Australia (2006). Tips and Tools Feedlots: Heat load in feedlot cattle, Reprinted October, ISBN: 1 74036 505 4.
20) Meat & Livestock Australia (2012). Is it fit to load? Revised edition. ISBN: 9781741918885
21) Meat & Livestock Australia. Residues. Available from www.mla.com.au/Meat-safety-and-traceability/On-farm-riskmanagement/ Residues
22) Red Tractor Assurance (2011). Red Tractor Assurance for Farms: Beef and Lamb Scheme Standards, Version 2. Available from www.redtractorassurance.org.uk.
23) Red Tractor Assurance (2012). Red Tractor Assurance for Meat: Processing Scheme, Version 1. Available from www.redtractorassurance.org.uk.
24) WelfareQuality Project - www.welfarequalitynetwork.net
25) World Organisation for Animal Health (2014). Terrestrial Animal Health Code, V7:
a. Volume I, Section 4: General recommendations: disease prevention and control
i. Chapter 4.1: General principles on identification and
traceability of live animals
ii. Chapter 4.2: Design and implementation of identification
systems to achieve animal traceability
b. Volume I, Section 7: Animal welfare
i. Chapter 7.1: Introduction to the recommendations for animal welfare.
ii. Chapter 7.2: Transport of animals by sea
iii. Chapter 7.3: Chapter of animals by land
iv. Chapter 7.4: Transport of animals by air
v. Chapter 7.5: Slaughter of animals
vi. Chapter 7.9: Animal welfare and beef cattle production systems.