MN15-03 - Revised horse traceability verification requirements for access to the European Union

​​​​Category: Legal requirements including market access requirements

NSFS reference: 20

Issue date: 27/02/2015

Date of effect: 13 April 2015

Review date: February 2017

Contact officers:

Surjit Kang
Veterinary Officer
Operational Integrity
Ph: 02 6272 3933

Mary Wu
Veterinary Officer
Export Standards Branch
Ph: 02 6272 3933

Distribution categories: Central and Regional Office, Departmental on-plant officer(s), Managers, Export Meat Establishments, State/Territory Regulatory Authorities

Implementation schedule

(to be completed by the departmental on-plant officer)

Date received:
Date discussed with Est. management:
Initial implementation date:
Date completed:
Management representative initials:
Dept. on-plant officer initials:

1. Purpose

To advise horse meat industry and Department of Agriculture staff of the revised horse traceability requirements for meeting market access requirements for the European Union (EU).

This meat notice supersedes 2013/10. The main changes are:

  1. Provision of original horse vendor declarations (HVDs) to abattoir from both horse supplier1 and previous owner/s if the consignor has not owned the horse/s for six months or more prior to EU slaughter
  2. Insisting on owners completing HVDs, not the agents
  3. Foreshadowing changes in the HVD consistent with this Meat Notice

2. Scope

This meat notice applies to export registered horse slaughtering establishment managements and Department of Agriculture personnel.

3. Responsibilities

3.1. Establishment management

  1. Immediately review the establishment approved arrangement (AA) against the contents of this Notice, including addressing actions taken where horses lose their uniquely numbered identification (ID) collars.
  2. Prepare and implement any necessary amendments to the establishment AA and present them to departmental staff for approval within 3 weeks from the date of publication of this notice.
  3. Implement approved AA changes.
  4. Ensure all establishment personnel have received training relevant to their tasks.
    1. Records of training are to be made available to the department upon request.
  5. Ensure the eligibility of each horse for the EU market is verified and confirmed before the slaughter
    1. The AA must describe the process of EU eligibility verification used prior to slaughter.
    2. Establishments must collect all original HVDs applicable to each horse presented for slaughter (i.e. HVD from the previous owner of 6 months or more, and where applicable the HVD from the horse supplier)
    3. All verified original HVDs and other supporting documentation are to be supplied to OPV before ante-mortem
  6. Conduct on-site horse supplier audits (minimum 4 each year) and telephone verifications (minimum one each horse slaughter shift) as required by this meat notice
      7. Ensure records of all phone verification activities, including questions asked and answers given, and the horse supplier audits are kept and are available on request.
  7. By end of November each year, submit the following to the On-Plant Veterinarian (OPV) for assessment and forwarding to Central Office
    1. All horse verification records i.e. horse supplier audits and telephone verifications
    2. Horse supplier audit schedule for the following year
  8. Records of all horse traceability verification activities are to be made available to departmental staff and/or overseas reviewer/s upon request.

3.2.  Departmental on-plant staff

  1. Review any establishment AA amendments and recommend to ATM for approval within a week of receipt from establishment management
  2. Undertake telephone verification activities (minimum of one telephone verification activity {by selecting one horse from a horse supplier and accompanying owners} every 10 horse slaughter shifts)
  3. Ensure the records of phone verification activities are kept, including questions asked and answers given
  4. Ensure the establishment management has verified all documentation supplied with the horse consignment/s and confirmed the EU eligibility for each horse before the blue EU ante-mortem card is issued on ante mortem
    1. Ensure all company verified original HVDs and other supporting documentation are supplied (to OPV) before ante-mortem
  5. Assess the verification records on receipt from the establishment management
    1. Clarify any concerns with establishment management before forwarding to Central Office
  6. Forward to MID.OpsCoord@aff.gov.au by mid-December each year for inclusion in the annual market access report to the EU all the verification records, including:
    1. Establishment supplier audit reports, including phone verification records obtained during on site supplier audit
    2. Establishment telephone verification records
    3. OPV telephone verification records
  7. On a weekly basis, undertake random in-depth verifications of HVDs and the company’s EU eligibility verification process for confirming the eligibility of the horses for the EU market.

3.3. Area Technical Managers

  1. Review and approve establishment AA amendments against the requirements of this notice within 2 weeks of receipt of the OPV recommended AA amendments.
  2. Include horse traceability verification activities conducted at the establishment by departmental staff and establishment management in the scope of the periodic audits.
  3. Ensure the establishment’s horse traceability verification activities are audited regularly (i.e. telephone verification activities by OPV and establishment management, the establishment management’s on-site supplier audits and EU eligibility verification system).

3.4. ​Department of Agriculture central office

  1. Review establishment management’s schedule of audits and select one audit for witness audit verification.
  2. Advise the Food Services Group (FSG) of the details, including location, of the establishment’s proposed horse supplier verification audit to be conducted.  FSG to assign the appropriate ATM to conduct the required witness audit.
  3. Review the following reports and prepare the horse traceability report for EU:
    1. Verification of reports submitted by the OPVs (telephone verifications by establishment managements and OPVs, and establishment management horse supplier audits)
    2. departmental witness audit reports of each establishment’s horse supplier audit
  4. The department provides a report on horse verification activities to the European Commission annually.

3.5. Food Services Group (FSG)

  1. Ensure one witness audit is completed for each horse slaughter establishment management’s supplier audits.
  2. Advise the responsible ATM of the details, including location, of the company’s proposed horse supplier to conduct the required witness audit.

3.6. Area Technical Managers responsible for the witness audit

  1. Conduct the annual witness audit of an establishment’s horse supplier audit as advised by FSG.
  2. Submit the witness audit report to the Central Office at following email address: MID.OpsCoord@aff.gov.au​

4. EU eligibility criteria for slaughter horses

The EU eligibility criteria for slaughter horses consist of:

  1. A fully completed HVD (Version 2015/02) must accompany all horses (domesticated and feral/brumbies) consigned to an abattoir for slaughter
    1. The EU eligibility of each horse must be confirmed prior to slaughter
    2. The latest version of the HVD template must be used
    3. Use of an agent2 for completion and signing of the HVD/s is not permitted i.e. the HVD/s can only be completed and signed by the horse owner.
  2. For all domesticated horses consigned to an abattoir for slaughter:
    1. Either the horses must have been under the control of the consignor for the last six months or more, or
    2. The horses must have been owned for six months or more by the previous owner.
  3. Where the consignor has owned the horse/s for less than 6 months, the consignor must present the originals of the HVD/s completed and signed by the previous owner/s confirming the treatment history of the horses for the last six months prior to slaughter
  4. The consignor must identify each horse at the time/point of purchasing3 for slaughter using uniquely numbered identification collars and the number on the collar must link the horse to the HVD.
    1. If a horse loses its identification collar, it becomes EU ineligible unless there is an alternative identification management system in use.
    2. If an alternative unique identification management system is used and that alternative identification number is documented on the HVD in detail, then establishments may be able to replace a lost collar by confirming the identity. This applies in all cases irrespective of when the horse has lost its collar i.e. en route to establishment, in the lairage/yards before or after ante-mortem inspection or on the way to knocking box, etc.
    3. All actions taken in response to horses losing ID collars must be documented.
    4. If the horses are consigned directly from owner’s place (i.e. if the consignor is the owner of horse/s for last 6 months or more) to abattoir, then abattoir may be considered as the purchase point and horses must be identified with the uniquely numbered identity collars by the owner at this point.
    5. The collar numbers must be specific to the establishment (i.e. maintain unique collar numbers)
  5. The farm of origin of the horse must be identified on the HVD:
    1. By the full street address of its location and,
    2. If one is issued, by its property identification code (PIC).
  6. For work health and safety reasons, feral horses and brumbies do not require identification collars, however a full description (e.g. mixed brumbies/feral and mob based physical characteristics etc) of the animal/s must be provided on the HVD.
    1. If the feral horses are consigned directly to abattoir from the property of origin the relevant feral horse section of HVD/s must be completed by the consignor (questions on the public health risk)
    2. Feral horses must not be mixed with the domestic horses.
    3. Each HVD consignment of brumbies/feral must not be mixed with horses from any other brumbies/feral HVD, i.e. one brumby HVD consignment on a HVD must remain discrete from all other brumbies/feral consignments on other HVD/s.
  7. The establishment management and horse supplier must confirm the eligibility of each horse for EU market before slaughter in accordance with the attached decision tree (Attachment 1).
  8. For product to be eligible for export to the EU, horses must:
    1. not be slaughtered during a treatment withholding period;
    2. not been treated with hormonal growth promotants (HPGs) or beta-agonists;
    3. Not been treated with any of the prohibited products listed in the HVD explanatory notes.
    4. be owned either by consignor or by previous owner for 6 months or more
    5. be presented with correctly completed HVD/s confirming EU eligibility and identified using uniquely numbered identification collar except feral horses (Note: the feral/brumby horses do not need identification collars for EU eligibility due to safety reasons).

5. Verification activities

  1. Horse traceability verification activities comprise at a minimum of telephone verification and audits of horse suppliers.
  2. Establishment management must document all corrective and preventive actions arising from their horse traceability verification activities.

5.1. Telephone verification

  1. Both departmental on-plant staff and establishment management conduct a random number of telephone verification calls on a selection of HVDs submitted with horses for slaughter
    1. Telephone verification activities require contacting the owner who has owned the horses for 6 months or more, and where applicable the respective supplier.
    2. Need to contact both consignor and previous owner/s where the consignor has owned the horse/s for less than 6 months
    3. A minimum of one supplier HVD and relevant previous owner/s associated with that HVD must be verified at a frequency as given in respective responsibilities section.
    4. Establishment management also conduct telephone verification calls during horse supplier audits. See below for details on telephone verification calls conducted during an audit.
  2. Telephone verification calls are to focus on verifying the previous six months ownership and the drug treatment history for the same period of the horses submitted for slaughter.
  3. Formal records of these telephone verification activities, including all questions asked and answers given, must be kept and made available to departmental staff and overseas reviewers upon request.

5.2. Horse supplier audits

  1. Establishment management must conduct physical on-site horse supplier verification audits annually. A minimum of 4 suppliers must be audited, or where there are 4 or less than 4 suppliers, all suppliers must be audited.
  2. Establishment management will restrict the horse supplier audits to horse suppliers only.
    1. Individual horse owners selling their horse/s direct to an establishment’s management may be subject to telephone verification calls by establishment management and/or the department.
  3. Horse supplier audits will review the horse supplier’s documentation, records, and practices; and will also include telephone verification tracebacks as described below.
  4. During a horse supplier audit, telephone verification traceback is conducted from kill floor data through the horse supplier to the original owner.
  5. Management is to document in the audit report all questions asked and all answers received during each telephone verification traceback call.
  6. Telephone verification calls conducted during a horse supplier audit shall comprise a minimum of 5% of the horse owners supplying the horse supplier or 20 randomly selected horse owners supplying the horse supplier (whichever is the smallest number).
  7. Establishment management must document all corrective and preventive actions arising from their horse traceability verification activities.
  8. Horse suppliers audited should be chosen at random, however establishment management should ensure that over time all horse suppliers to the abattoir are audited.
  9. Establishment personnel conducting the horse supplier audits and other verification activities should be trained and qualified for undertaking these activities.

5.3. Departmental witness audits

  1. Establishment management will advise the department of their schedule of horse supplier audits for following year every November.
    1. Establishment management must advise the department of any amendments to the schedule when a change arises.
  2. There will be one departmental witness audit of an establishment’s horse verification audit of suppliers each year. The department will select an audit from the nominated list.
  3. The ATM will produce a formal audit report of the witness audit.
  4. Any corrective action requests arising from the witness audit report will need to be addressed by establishment management within agreed timeframes.

6. Records

Establishment managements and the department must document their verification activities.

  1. Establishment managements are to make their verification records to the department and overseas reviewers available upon request.

7. Market access non-conformances

The product is ineligible for export to the EU (including but not limited to) where:

  1. There is no confirmation that domesticated horses consigned to an abattoir for slaughter were under the control of the consignor for the last six months, or the horses were owned for six months or more by the previous owner.
  2. All original HVDs are not received for a consignment of horses where a horse supplier is involved and owned the horses for less than 6 months.
  3. An agent is used in completing and signing HVD/s for horse/s eligible for EU slaughter.
  4. The previous owner does not know the treatment history of horse/s for the 6 months prior to sale.
  5. Domesticated horses are not identified by a unique number which is linked to the HVD (e.g. horse was not given a uniquely numbered horse collar at time of purchase from the owner of 6 months or more or has lost its identification collar on arrival at the abattoir or in transition).
  6. The horse vendor declaration form is incomplete.
  7. The horse/s has/have been treated with prohibited drug treatments.
  8. The horse/s is/are still within the withholding period of a drug treatment administered to the animal/s.

Clare Jones
Director
Export Meat Program

1​Horse supplier: consignors who have owned the horse/s for less than 6 months and who buy the horses from previous owner who owned the horses for 6 months or more.

2 Agent: a person who is authorised to act for another (the agent's principal) through employment, by contract or apparent authority. In this case the agent cannot complete and sign the HVD on behalf of the horse owner (the agent’s principal).

3 Time/point of Purchase: for EU eligibility purpose, the time of purchase is the time when the horses are purchased from an owner who owned the horses for last 6 months or more, e.g. where the horse/s is/are sold directly to abattoir by the consignor who owned the horses for last 6 months or more, the point of purchase maybe the abattoir or consignor’s property and the horse/s must be identified before moving into the abattoir paddocks or lairages. Where the horse/s is/are purchased by a supplier before being brought to abattoir, the point of purchase would be the property of previous owner who owned the horses for last 6 months or more and the horse/s must be identified at this point before being transported to abattoir or supplier’s property.

Attachment 1: HVD Part B Questions - Decision Tree for the current version of the HVD (2015/02)

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