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5.9 Discussion
5.9.1 Outcomes designed to achieve
The outcomes expected from livestock export standards depend on the perspective of the particular stakeholder as follows:
Social: From the perspective of the broader community, standards can be viewed as a tangible and formal framework for advancing the cause of animal welfare. Thus lobby groups will deem
the standards as accurate and useful to the extent they result in animal welfare outcomes that accord with their expectations. In a social democracy, lobby groups such as RSPCA will be
given the opportunity to contribute to the community viewpoint but in arriving at a final position, our political process should balance the interests of all parties. In practice, most credence might
be given to those parties who have made a large material investment in the industry and generate secondary benefits such as employment.
Regulators: For the most part, regulators will judge the quality of standards in terms of capacity to achieve their stated goals. As discussed in section 2, complementary legislation, compliance
measures and quality assurance programs will support effective standards. Industry: In common with other stakeholders, operators will want the standards to assist with
achieving acceptable animal welfare outcomes. But operators will also want the standards to be efficient because they are well written and cost effective to apply.
5.9.2 Supporting rationale
As discussed in section 2.3, the rationale for standards lies firstly with delivery of acceptable animal welfare outcomes. To the extent they achieve this, standards act as a defence for the
trade when it comes under fire from minority interests.
5.9.3 Commercial Implications
This subject was extensively discussed in section 2.4.
5.9.4 Animal welfare implications
As discussed in section 2.3, the animal welfare implications of standards are demonstratively positive.
5.9.5 Verification of compliance
This subject was discussed in section 2.5 but additional comment is justified. One of the most difficult components of regulation is the ability to identify instances where operators fail to comply
with the prescribed standards. At a prescriptive level, the only way to achieve this is by monitoring, either continuously or by random audits. Monitoring and auditing, however, are
resource hungry activities and difficult to justify in terms of cost effectiveness. It is better, therefore, that the prescribed standards have strong links to outcomes so that failure to comply
will be reflected by overall performance. Our own experience suggests it will be possible on occasions to achieve satisfactory outcomes despite non-compliance to one or more aspect of a
standard. But if the standards accurately identify and reflect risk factors, outcomes will eventually be compromised if short cuts are routinely taken.
At critical points along the export chain, it is possible to use quality assurance and statutory declarations to achieve a high level of compliance. The documentation required by most quality
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assurance programs allows these declarations to be verified by subsequent investigation. This system marks a sophisticated regulatory framework and can be implemented progressively
according to the maturity of an export industry. The Australian regulatory framework already incorporates some ‘declaration based on QA’ but the approach is still in the early days of
implementation. We expect that mandatory declarations based on evidence of sophisticated quality assurance schemes will become more widespread as the framework continues to evolve.
5.10 Inconsistencies and knowledge gaps
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