4.3.3 Option A: (non-regulatory option – voluntary national guidelines)
Option A would involve the issuing and promotion of agreed national risk-based guidelines once every 5 years by SCoPI. These agreed national guidelines would encompass ‘should statements’ as opposed to ‘must statements’ and, unlike the proposed standards, these guidelines would not become regulations and therefore would not be mandatory (i.e. adherence104 would be voluntary).
These agreed national guidelines would be additional to industry guidelines or QA programs in the ‘base case’. The voluntary national guidelines would also be additional to existing state or territory standards and codes of practice and guidelines under the ‘base case’.
Unquantifiable incremental net benefits of Option A (Criterion I – animal welfare)
Option A would be likely to lead to improved animal welfare outcomes, depending on the level of voluntary adherence with the national guidelines, through a better management of risks to animal welfare in both beef and dairy cattle farms. Specifically, there would be improvements to the welfare of animals in ensuring the provision of adequate feed and water, suitable environments, health care, opportunity to express most normal behaviours and protection from fear and distress. However, any resulting improvement over the base case is likely to be significantly less than that which would occur under a situation of mandatory compliance with enforceable, risk-based and clearly understood standards.
Potential and unquantifiable incremental net costs of Option A (Criterion III –adherence costs)
Under Option A the beef and dairy farm industries would incur voluntary costs, depending on the degree of adherence to the voluntary guidelines. However there would be no incremental costs imposed under Option A as compared to the ‘base case’. Importantly, any voluntary cost incurred would be driven by the degree of adherence to the guidelines. A description of potential voluntary costs that might be incurred is summarised in Table 19 in Part 4.3.2 of this RIS. The cost per state or territory under Option A (as illustrated in Table 19 in Part 4.3.2) will again depend on the degree of adherence to the guidelines.
Unquantifiable incremental net benefits of Option A (Criterion V – nationally consistent guidelines)
Option A would be marginally more effective in promoting consistency, albeit from the prospective of voluntary guidelines. Industry-wide guidelines would have some positive effect on the economy and reducing transaction costs by having a ”one-stop-shop” in relation to cattle however this would be limited by the extent of adherence. The AAWS would be limited in its ability to facilitate improved consistency of animal welfare outcomes across states and territories.
Public consultation question 5: Do you believe that the net benefits achieved under option A, including welfare benefits and reduction in excess regulatory burden, are justified?
4.3.4 Option B: (the proposed national standards)
Option B would involve the issuing and promotion of agreed national risk-based standards once every 5 years by the SCoPI. These agreed national standards would encompass ‘must statements’ and, unlike Option A, these standards would become regulations and would be mandatory (i.e. compliance would be mandatory). The mandatory national standards would replace existing state or territory model codes of practice and guidelines under the ‘base case’.
Unquantifiable incremental net benefits of Option B (Criterion I – animal welfare)
As compared with Option A, Option B would lead to much more improved animal welfare outcomes, through a better management of risks to animal welfare in cattle farms due to mandatory compliance with enforceable risk-based standards. Specifically, there would be improvements to the welfare of animals in ensuring adequate feed and water, suitable environments, health care, opportunity to express most normal behaviours and protection from fear and distress. In particular:
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risk management of extreme weather, natural disasters, disease, injury and predation: all uninspected cattle across all states and territories would achieve welfare benefits. As shown in Table 10, this has the potential to affect an unknown proportion of 27.54 million cattle per annum;
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handling and management of cattle including electro-immobilisation and identification and branding: an unknown proportion of 16.75m cattle (see Table 8) across QLD, WA and NT would benefit from better handling; an unknown proportion of 23.54 million cattle per annum across NSW, QLD, SA, WA and NT would benefit from mitigation of exhaustion (see Table 9); an unknown proportion of 27.53 million cattle across Australia would benefit from a reduction in the inappropriate use of electric prodders (see Table 10); reducing dog bites of cattle or calves by requiring dogs to be under effective control or muzzled when moving calves; there would be improved welfare for an estimated 150 tethered cattle across Australia with 100 cattle in NSW and 10 cattle in each of the remaining states of VIC; QLD; SA; WA and TAS (see Table 14) by requiring exercise; an unknown proportion of 179,548105 cattle for which electro-immobilisation is used would benefit from this practice being performed by competent persons in QLD, SA, WA, NT and ACT (see Table 13); an unknown proportion of 241,503 cattle would no longer be subject to the use of electro-immobilisation as a form of pain relief (see Table 13); an unknown number of 27.54 million cattle in all states and territories would be affected by an improvement in cattle identification techniques appropriate to the production system; an unknown proportion of 2.2 million106 cattle in NT, 611,583 cattle in TAS and 8,808 cattle in ACT would benefit from elimination of the painful head branding procedure;
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pain relief during castration, disbudding, dehorning and spaying: 40,297 calves would benefit from pain relief during castration with the majority of 24,516, 7,498 and 4,722 calves affected in QLD, VIC and WA, respectively (see Table 1); 122,294 calves would benefit from pain relief with the majority of 49,883, 24,637 and 30,690 calves affected in QLD, VIC and NSW, respectively (see Table 6); the number of calves that would benefit from conditions placed on use of caustic disbudding would be an unknown proportion of 24,346 calves per annum with the majority (i.e. an unknown proportion of 15,520 calves) in VIC (see Table 7); as shown in Table 4, Option B would require accreditation and appropriate competency with regards to spaying with the number of cattle affected being some unknown proportion of an estimated 319,582 heifers and 169,574 cows per annum throughout Australia and with the majority in QLD107; pain relief with respect to spaying would benefit 124,637 heifers and 39,002 cows per annum throughout Australia with the majority in QLD (i.e. 144,714 heifers and cows) (see Table 2); an estimated 10,174 cattle per annum with the majority, 8,998, in QLD would benefit from a ban on the use of vaginal spreaders (see Table 3);
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breeding management: uninspected calving cattle in all states and territories would achieve welfare benefits. This would affect an unknown proportion of 14.57 million cattle (with the bulk of 6.31 million in QLD)108; as shown in Table 15, an unknown proportion of 84,139 induced calves would be affected by improvements to welfare in terms of either receiving colostrum or being humanely killed by 12hrs of age and with the majority likely to be in VIC.
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calf rearing systems: approximately 548 calves across Australia would experience an improvement in welfare in relation to the prevention of accumulation of faeces and urine in indoor systems (see as Table 17). The majority of these calves would be in NSW (189 calves) and TAS (137 calves) - followed by QLD and SA (see Table 17).
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dairy management: an unknown proportion of 1.6 million dairy cattle throughout Australia including: NSW, VIC, QLD, SA, WA, NT and ACT would benefit from improvements in heat stress management; the number of dairy cows, which would benefit from being tail docked with veterinary advice, and for the purpose of treating injury or disease, is estimated to be 61,800 per annum with the majority in VIC (i.e. 50,000 cows) (see Table 5).
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beef feedlots: an unknown proportion of cattle housed in unaccredited feedlots throughout Australia would benefit from improved heat management and dietary outcomes under Option B.
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humane killing: an unknown number of calves that would otherwise be killed with blunt force trauma over 24hrs of age would benefit under Option B in all states and territories.
The number of cattle affected by particular standards across Australia is summarised in Table 21. The breakdown in welfare impacts and number of cattle affected by state and territory is summarised in Appendix 6 of this RIS.
Table 21 – Summary of number of cattle affected annually by welfare standards under Option B as compared to the base case109
Welfare issue resolved under Option B
|
Number of cattle affected
|
Inspection of cattle at intervals
|
% of 27,536,177
|
Better handling of cattle
|
% of 16,746,366
|
Reduced exhaustion of cattle
|
% of 23,529,937
|
Reduced misuse of electric prodders
|
% of 27,536,177
|
Reduced biting of cattle from dogs not under effective control
|
unknown
|
Reduced biting of calves from unmuzzled dogs
|
unknown
|
Exercise of permanently tethered cattle
|
150
|
Electro-immobilisation performed by competent persons
|
% of 179,548
|
Electro-immobilisation not be used as pain relief
|
% of 241,503
|
Improved less painful cattle identification techniques
|
% of 27,536,177
|
Banning of painful head branding procedure for cattle
|
% of 2,817,749
|
Requirement of pain relief for castration
|
40,297
|
Requirement of pain relief for dehorning
|
122,294
|
Conditional use of caustic disbudding
|
% of 24,346
|
Accreditation and competency required for spaying
|
% of 489,156
|
Requirement of pain relief for spaying
|
163,639
|
Banning the use of vaginal spreaders
|
10,174
|
Inspection of calving cattle
|
% of 14,568,089
|
Humane killing or receipt of colostrum for induced calves less than 12hrs old
|
% of 84,139
|
Prevention of accumulation of faeces and urine in calf rearing indoor systems
|
548
|
Improved heat stress management for dairy cattle
|
% of 1,600,000
|
Tail docking only to occur under veterinary advice and for welfare reasons
|
61,800
|
Improved heat stress management and dietary outcomes for cattle in unaccredited feedlots
|
unknown
|
Humane killing of calves over 24hrs of age
|
unknown
|
Unquantifiable incremental net benefits of Option B (Criterion II – reduced regulatory burden)
Option B would be effective in promoting national consistency. Industry-wide standards in relation to: S5.7 electro-immobilisation; S5.10 head branding; S6.2 castration; S6.4 dehorning and S6.7 spaying - would have a positive effect on the economy and would reduce transaction costs. The number of farms affected by a reduction in jurisdictional inconsistencies is currently unknown, but is being sought via public consultation questions in sections two, four and Appendix 2. The AAWS would have increased ability to facilitate improved consistency of animal welfare outcomes across states and territories.
Furthermore, Option B would reduce regulatory burden with respect to unnecessary competency requirements with respect to castration, dehorning and artificial breeding procedures and would allow for caustic dehorning of calves under certain conditions. However both the extent of competency training that would be saved and the variety of conditions for caustic dehorning are not known Therefore, the incremental benefit of Option B in relation to these matters remains unknown.
Quantifiable and unquantifiable incremental net costs of Option B (Criterion III – compliance costs)
Option B would impose incremental costs of approximately $36.51m over 10 years in 2012-13 dollars110, as summarised in Table 19. The costs would be mainly attributable to the cost of pain relief111 when either dehorning cattle under certain circumstances; or when performing the flank approach for spaying or webbing112 of cattle, under proposed national standards S6.4 and S6.8, respectively. These two incremental costs would amount to approximately $19.11m in 2012-13 dollars (see Table 19). As shown in Table 19, the most impacted state would be QLD with respect to both proposed national standards (S6.4 and S6.8), with an incremental cost of $13.56m in 2012-13 dollars. Proposed standards under Option B are also likely to result in minor unquantifiable costs and cost savings as discussed in Part 4.3.2 of this RIS.
Public consultation question 6: Do you believe that the net benefits achieved under option B, including welfare benefits and reduction in excess regulatory burden, are justified?
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