Purpose
To provide licensed livestock exporters with clarifications about the requirements outlined in Export Advisory Notice (EAN) 2014-12: Risk management for export of livestock by air released on 6 August 2014.
Background
On 6 August 2014 the department issued EAN 2014-12: Risk Management for export of livestock by air in response. This was in response to three reportable mortality incidents involving the export of livestock by air which were investigated by the Department of Agriculture. Subsequent to this there have been a number of requests for clarification.
Meaning of 'Time of Loading'
The declaration attached to EAN 2014-12 includes the words ‘I declare that the aircraft’s ventilation system is adequate for the planned consignment and functional at the time of loading’.
The ‘time of loading’ means the time of loading animals into crates. A revised declaration is attached to this EAN and has been amended to read:
‘I declare that the aircraft’s ventilation system is adequate for the planned consignment and functional at the time of loading animals into crates’.
The department is aware that loading into crates often occurs several hours before loading into the aircraft and sometimes before the aircraft has landed at the airport. There are a number of actions that the exporter can take before the aircraft arrives to check that the ventilation is adequate. This includes running a Livestock Air Transport Safety Assessment (LATSA) and asking the airline to run the Boeing or Airbus (or other aircraft manufacturer) equivalent risk assessments. Exporters must decide how they are managing the risks associated with air transport for their consignment and base their declaration on their management plans.
The exporter should also check, as part of their due diligence, that the aircraft’s ventilation system is fully functional and adequate for the consignment at the time of loading crates into the aircraft. If the exporter is unable to confirm that the ventilation is adequate at this time, loading should not proceed. Exporters must have contingency plans in place to manage livestock in the event that they are not able to be loaded onto the aircraft.
Declaration Check Boxes
The declaration attached to EAN 2014-12 included check boxes. The intention is for exporters to indicate which risks had been addressed. The wording of the declaration has been amended to the following to make this clear:
‘I declare that the above licensed livestock exporter has conducted due diligence when planning the consignment (LNC) identified above to address the risks associated with transport of livestock by air, including (please check all that are applicable):’
Exporters must indicate which risks have been identified by checking the boxes next to each risk that has been addressed for the consignment.
Instructions
- Exporters are required to submit the attached declaration to the Department of Agriculture regional office, confirming that they have completed due diligence addressing the risks associated with transport of livestock by air, and that the aircraft’s ventilation system is adequate for the planned consignment and functional at the time of loading into crates. The declaration must be submitted prior to issuing the export permit
- The department may, during the assessment and export process or during an audit, require an exporter to provide evidence that due diligence has been undertaken to address the risks associated with transport of livestock by air and to confirm adequate ventilation of the aircraft. This may include a LATSA assessment.
- If exporters are unsure about how to address the risks associated with the export of livestock by air then they need to engage an industry expert to help them with their plans.
- Completion of the Aircraft Lower Deck Checklist for Carriage of Livestock by Air and Carriers Main Deck Ventilation Declaration will no longer be required as a condition of approval for air consignments.
This will be effective from 17 November 2014 and will be reviewed after six months.
Jenny Cupit
Assistant Secretary
Live Animal Export Branch
Contact officer: Kate Makin / Tim Naylor
Ph: (02) 6272 4581
Email: Livestock Exports
Attachment 1: Export of Livestock by Air – Exporter Due Diligence Declaration Word [56 KB]