Compliance imperatives Key elements of reform

Risk management considered in detail in Chapter 3 Risk management is a key element of reform. The review recommends a shift from the current prescriptive approach to an outcome-based approach modelled on international best practice in this area. It is important that risk management is robust and transparent, in keeping with accepted business practice. It is recommended that risk management be undertaken within industry using the following stepped approach: • For all consignments, a mandatory requirement that each exporter complies with ‘standards of baseline practice’; • For all consignments to the Red Sea andor Persian Gulf, a mandatory requirement that each exporter adequately manage heat stress risk; and • For ‘high-risk’ consignments, a mandatory requirement that each exporter develop a consignment risk management plan. ‘High-risk’ consignments can be defined as all consignments that are at increased risk of one or more adverse health and welfare outcome. The consignment risk management plan would be linked to a defined consignment, providing documented evidence that individual exporters have completed a well-defined series of steps relating to risk management, including risk assessment, risk management and risk communication. Incident management considered in detail in Chapter 4 Incident management is another key element of reform. An incident is deemed to have occurred when agreed outcomes are not achieved – in this case, the mortality rate has exceeded defined performance targets. In Chapter 4, detailed information is presented about the investigation of a minor incident those not involving government, including routine data collection, terms of reference, the investigating team, the investigation report, timing and linkages with the LESCO. SUMMARY: Risk management and incident management are key elements of reform. These tools are critical to industry efforts to achieve defined performance targets. These methodologies are considered in detail in Chapters 3 and 4.

2.2.5 Compliance imperatives

As mentioned in Section 2.1, the overall goal of the model will be compliance with acceptable animal health and welfare outcomes. For this reason, compliance imperatives are critical to the overall review. Under the current LEAP, compliance is achieved through two related mechanisms, namely accreditation and auditing. These elements will be retained, but amended in line with an outcome- based approach. Detailed information regarding compliance is presented in Chapter 5. Accreditation It is recommended that the accreditation be strengthened to include each of the following elements: • Pre-accreditation training; 30 • Accreditation on the basis of livestock-type for example, sheep, cattle andor goats; • Publication, at least within industry circles, of the circumstances surrounding code violations and sanctions imposed on exporters; • An accreditation fee structure determined on the basis of associated risk; and • The introduction of formal undertakings, as an alternative to the downgrading or withdrawal of accreditation. Auditing Auditing arrangements are currently based on a prescriptive standard. With the shift to an outcome- based standard, it is recommended that there be significant changes to the scope and emphasis of auditing, as follows: • A primary audit would be conducted with all exporters. The purpose of the primary audit is two- fold. With respect to animal health and welfare outcomes, it would be undertaken to test the validity of reported information, and would also be used to compare actual results with agreed thresholds throughout the export process. With respect to risk management, it would be conducted to assess competency in the planning and implementation of risk management relating to animal health and welfare throughout the export process. • A secondary audit would only be enacted if aspects of the primary audit were considered uncertain or unsatisfactory, and would be undertaken to assess compliance with all other aspects of LEAP, including adherence to the ‘standards of baseline practice’. It is also recommended that the timing and intensity of auditing be determined using a risk-based approach, with particular attention being given to those exporters associated with high-risk consignments. SUMMARY: Significant changes are recommended with respect to accreditation and auditing, in keeping with the shift to an outcome-based approach. These changes are considered in detail in Chapter 5.

2.2.6 The Livestock Export Standards and Compliance Organisation