Action Plans Monitoring Reporting

The secondary audit The secondary audit to be enacted if aspects of the primary audit are considered uncertain or unsatisfactory would involve a more detailed audit of compliance with increased levels of substantive testing. As previously explained, using the Audit Testing Matrix, where the primary audit has raised suspicions over the compliance of the exporter, more detailed testing is required to obtain the level of assurance required to assess whether the exporter is in fact compliant. The secondary audit would therefore involve: • Audit of a larger sample of an exporter’s shipments; and • Conducting random audits of physical livestock shipments. in order to obtain the required level of assurance as to whether the exporter is in fact compliance. RECOMMENDATION 33: It is recommended that a secondary audit be enacted where the primary audit results are unsatisfactory or inconclusive. The secondary audit would audit an increased sample of shipments in addition to increased instances of random physical audits of shipments in order to obtain sufficient evidence to assess compliance or non-compliance.

5.3.3.3 Action Plans

The requirement for action plans to be developed where instances of significant non-compliance are identified currently exists within the LEAP Rules for Accreditation. Corrective Action Requests CAR’s are issued and contain: • Details of significant non-compliance issues; • Details of actions required to remedy the situation; • Accountabilities for implementing these actions; and • Timelines indicating when these actions must be implemented. The LEAP Rules for Accreditation also contain provisions for follow-up audits to be conducted to review CAR’s and ensure that actions have been taken by the designated timeframe. The wording of the standard, however, only states that follow-up audits “may “ occur. Despite the fact that follow-up audits may be conducted in all instances of identified non-compliance, this implies that there is a possibility that CAR’s will not be pursued, thereby increasing the risk of exporters not implementing recommended actions to remedy their non-compliance. RECOMMENDATION 34: It is recommended that Section 5.3 of the LEAP Accreditation Rules be amended to state that follow-up audits will be conducted for all initial audits that result in the issue of a Corrective Action Request CAR to ensure that required actions have been implemented. 90

5.3.3.4 Monitoring Reporting

Linkages with LESCO will be central to the proposed auditing process. As a result of the primary audit, important information will be gained with respect to compliance with animal health and welfare outcomes as well as outcome reporting, and also with respect to risk management plans. Similarly, the secondary audit will provide information relevant to compliance. Formal reporting structures are needed to ensure that this information is reported to the LESCO compliance sub-group. This information is critical to the role of LESCO in managing the industry risk management development program see section 4.4.5.2. SUMMARY: Linkages between auditing and LESCO will be central to the recommended auditing process, and formal reporting structures are needed. Information from the primary and secondary audits will assist LESCO to fulfil its responsibility to effectively manage the industry risk management development program.

5.3.3.5 Continual Improvement