This chapter considers support for a national horse traceability register, and the proposed functions that such a register could include. Many of these functions go beyond a traceability register that merely allows for the identification and location of individual horses.
This chapter concludes with a summary of a number of national horse traceability systems implemented in other international jurisdictions. These traceability systems have been largely driven by food safety standards established by the European Union (EU). Of these systems, the United Kingdom's (UK) traceability system is considered in more detail, with many stakeholders referring to this system during the inquiry as the most advanced and thorough system in the world.
Support for horse traceability
The majority of submitters and witnesses to the inquiry supported the development of a horse traceability register. This support was not aligned with one particular interest group; rather, support was conveyed across the entire spectrum of stakeholders that make up the horse industry. Despite this high degree of support, some stakeholders expressed caution and highlighted several challenges that must be addressed to achieve a successful traceability regime.
Support for horse traceability largely orientated around a traceability register's capacity to:
improve understanding of Australia's horse population;
strengthen biosecurity and emergency management;
support efforts to improve horse welfare;
improve oversight of the horse meat industry and the exportation of horses;
improve breeding practices;
maintain the integrity and professionalism of the horse industry; and
document the movement of horses.
Each of these potential functions of a national horse traceability register are considered in this chapter.
Degree of support
The level of support demonstrated throughout this inquiry echoed a similar degree of support shown in the 2017 NSW Department of Primary Industry's (DPI) Horse Identification Survey results. Of the 2,200 responses from horse owners and associations, over 70 per cent of respondents agreed that there were benefits of having compulsory identification and a central database, and 68 per cent believed that identification should be compulsory across Australia. Ninety-one per cent supported a national database that records horse owner's details and horse identification information.
The DPI summarised to the committee its view of the significant benefits a mandatory horse identification scheme would bring to the horse industry but emphasised that any scheme must be a national scheme. DPI suggested that a national scheme:
…includes improved disease management, enhanced emergency preparedness in fires and floods by knowing more accurately where horses reside and who their owners are, a reduction in theft, a reduction in the misrepresentation of a horse's history, and better rehoming of lost horses and identification of owners of horses that may have been treated inhumanely.
The DPI added that the NSW Police Force had also 'made it very clear' to the DPI that it was 'supportive of horse identification because of horse theft'. The NSW Police Force submitted that it had originally made the case for improved identification of horses at a national level, which ultimately led to the DPI's working group. NSW Police Force's support for traceability is primarily to enhance information available to its officers during criminal investigations.
Support for a national traceability register also extended across the horse equestrian and racing industries. Equestrian NSW informed the committee that it was absolutely supportive of a national system and was 'prepared to be part of the administration effort and support to make that system work'. Its national body, Equestrian Australia, offered cautious support for a national traceability register. Whilst it believed it would provide 'significant benefit for the whole-of-life tracking approach and improve the safety and risk management of horse and rider' it was also 'unsure of the viable model, how that would look and how feasible it is to develop, implement and maintain'.
Racing Australia communicated its absolute belief that a national horse traceability register would strengthen its biosecurity regime, horse welfare across the industry and would eliminate the 'gap that exists within [its] existing traceability regime'. Similarly, Harness Racing Australia welcomed 'any practical and cost-efficient initiatives designed to bring about improvements in regulating and enforcing horse traceability across all equine sectors'. The racing industry's support for traceability was reiterated in the aftermath of the 7:30 investigation.
Other stakeholders, such as the Australian Veterinarian Association (AVA) and the NSW Farmers' Association, also expressed their support for traceability. The AVA argued that '[n]o quality management system can consider itself fit for purpose unless it has identification and traceability'; whilst the NSW Famers' Association stated '[t]raceability isn't just nice to have; it's a necessity'.
AgForce Queensland Farmers submitted that its members saw a mismatch between the 'current lack of traceability for horses' and the investment in traceability for other livestock for biosecurity purposes. The submission highlighted that horses were often kept alongside other livestock, and were readily transported.
Nationally, Animal Health Australia was of the belief that 'there must be a horse traceability system and register' as a means to create a 'resilient biosecurity system'. The Department of Agriculture likewise commented that '[y]ou can certainly see there could be advantages with having a horse traceability system', especially one designed to address disease outbreaks.
Concerns about traceability
While stakeholders conveyed a high degree of support for horse traceability, others urged caution. Thoroughbred Breeders Australia (TBA) submitted that although it supports the principle of a national traceability register, it 'would need to be convinced of its efficacy' and that existing traceability provisions practised by the industry should not be duplicated under a national register.
The TBA's view later evolved after the 7:30 investigation. Its Chief Executive Officer, Tom Reilly later clarified that the TBA supports 'the creation of a model that will register who owns every horse and record where that animal is being kept' and that a 'register would be important in ensuring that every owner of every horse provides a minimum standard of care'.
Dr Roger Paskin submitted that national traceability was 'not an issue to be taken lightly' and a number of matters needed thorough consideration before decisions were made. Similarly, while supportive, the AHIC warned a horse traceability register 'is likely to be difficult to enforce, expensive to manage and potentially controversial in the industry'.
Ms Robyn Lawrie warned the introduction of traceability would take some time and stated:
There are many stakeholders with different views and a number of jurisdictions related to states and breeds. The task of just agreeing requirements for such a system, let alone building it and populating the database, is a huge task and will take many years.
The NSW Farmers' Association cautioned that many horse owners did not have contact with the horse industry and suggested that support for horse traceability may not be immediate.
Ms Judy Tainsh submitted many horse owners would not see a benefit in paying a fee or levy for a register; many often declined to spend money to join an organisation or register their horse because they saw no personal benefit. As such, horse owners needed to be consulted to discuss the value of a traceability system.
Additional costs to horse owners and the duplication of data was also raised by a number of stakeholders, who warned that these factors may undermine support for a national register.
The committee received only two submissions that opposed horse traceability. Ms Deidre Wood opposed a register on the basis the regulatory burden would be unnecessary and onerous and would increase the cost of keeping horses.
Ms Karrie Louden raised several objections to a register for all horses. She argued that horse movement and registration was not a federal issue and that existing registers were sufficient as they captured people who moved their horses frequently. Further, Ms Louden suggested that only horses which are slaughtered for human consumption need to be traced and that there is no evidence to suggest a national register would improve animal welfare outcomes, reduce 'backyard' breeding, improve safety for riders, or combat rural crime. Concerning a biosecurity outbreak, Ms Louden argued the PIC register and social media would suffice in informing horse owners. Ms Louden suggested the whole idea was 'a complete waste of time and money' as there was 'no way a national register can do any of the things that are suggested it will do'.
Potential functions of a traceability system
Although animal identification and traceability systems, where they exist, are primarily tools for addressing many animal health and food safety issues, their functionality can be broader, depending on the detail recorded in the central database.
The design, amount and type of information, and compliance and enforcement required for a horse traceability register would vary depending on the functions it was intended to serve. A number of these potential functions are considered below.
Understanding the Australian horse population
As discussed in Chapter 1, there is no accurate record of the number of horses in Australia. The committee was informed that even if it was possible to amalgamate the current number of registries, they may account for less than half the horse population. Many submissions stated a comprehensive horse traceability system would identify with accuracy the number and location of horses across Australia. Further, it could allow for the tracing of horses removed from the wild.
The lack of information on horse numbers and locations has consequences in many areas, including biosecurity and emergency management. It also has implications for horse research. Dr Kirrilly Thompson submitted that the absence of good data about horse numbers and locations meant research relies on non-randomised sampling strategies. As such, horse owners and carers not involved in formal activities or members of accessible networks are excluded. Dr Thompson noted that the impact of this bias on research findings could not be determined.
Biosecurity and emergency management
Many stakeholders pointed to the functionality of a horse traceability system to strengthen Australia's biosecurity measures, particularly for its potential capacity to shut down disease outbreaks more rapidly. The committee heard that a national horse traceability register designed for a biosecurity outbreak would be the main driver for proceeding with traceability framework. The equestrian and racing industry's traceability systems are already designed for this purpose.
Traceability allows for authorities to quickly and correctly identify an animal and its past movements and to communicate with owners. The need for traceability in instances of disease outbreaks was illustrated by a recent survey of horse owners in Australia that found almost one in five had no identifiers.
One example of a biosecurity threat was the Equine Influenza (EI) outbreak of 2007, which spread to more than 10,000 properties, required the vaccination of more than 140,000 horses, and caused major disruption to horse movement and thus the horse industry, across the country. A DPI report into the outbreak concluded that the industry was locked down for a period of six months, and took eleven months for the horse industry's operations to return to normal. Further, DPI estimated that the cost of the outbreak to the horse industry was approximately $350 million; however, the AVA and the AHIC believe the total economic loss was up to $2 billion.
In response to the EI outbreak, a traceability database was created through a collaborative effort between industry and government, which was managed by the AHIC (Horse Emergency Contact Database). However, after the outbreak subsided, support for the system was not maintained, and eventually, the AHIC discontinued its use.
A significant number of submitters argued the lack of a traceability register made a response to a disease outbreak difficult and possibly prolonged the outbreak. The committee heard that personnel involved in the EI outbreak had advised the DPI that the lack of a central database meant 'horse identification was a major issue experienced in that outbreak that significantly hampered and complicated the response of biosecurity agencies'. The committee heard that DPI's response to the outbreak relied heavily on its officer's local connections and knowledge, and in some cases, using binoculars to scan a landscape to see where horses were located. Had there been a traceability register:
…we could have gone to them, or at least planned our day better so that we could have been more efficient and picked up all the horses in a certain area on the same day, it would have been a big help.
The AVA advised that the during the outbreak, government authorities 'appeared to be flying blind when it came to estimating how many horses were at risk, and how many horses were in the buffer zones to target for vaccination'. The committee explored this statement further, and in response, the AVA explained that the absence of data meant there was no quality management system and for that reason, would be flying blind again if another disease outbreak was to occur. The AVA pointed out that efforts to create a database in response to the 2007 EI outbreak took months to become operational, and, once it was, it was not maintained, therefore:
…we're back to a state of low knowledge. If we were to have an outbreak, all we would have is the experience of having managed it once successfully. AVA would be advocating that we use that same method once again—that we quarantine, restrict movement and let the virus burn out. But that's at the cost of hundreds of millions of dollars.
In a worst-case scenario, the AVA warned that ongoing immunisation of horses for EI would cost the industry between $200 and $300 million a year and:
…would be a burden on the industry, and we should avoid that. A proper quality management system, using electronic identification and traceability, will be the foundation of us avoiding epidemics or managing epidemics like equine influenza in the future, let alone worrying about things like African horse sickness, which is a shocking disease that has got a 90 per cent mortality rate.
Equestrian NSW spoke of an Australian Bureau of Agriculture and Resource Economics and Sciences study, which found that had a better traceability system existed at the time of the 2007 EI outbreak, the cost of the outbreak would have been less. Further, the research found that the thoroughbred traceability system helped prevent the EI outbreak from becoming much worse.
The committee was also alerted to tightening requirements for disease status—particularly concerning trade. The World Organisation of Animal Health requires 'evidence of absence' rather than 'absence of evidence' concerning the existence of new, emerging, or exotic diseases. According to the AVA, the only way to meet this requirement is to have a national horse traceability register.
More broadly, in terms of responding to emergencies, the committee also received evidence of the need to identify animals likely to be affected by catastrophic events like bushfires and floods. A traceability register would facilitate their removal and return. The DPI's working group highlighted this potential functionality for horse traceability as part of its work.
Improved rider safety
The committee heard that working with horses, and horse riding specifically, were inherently risky activities, with horse-related injuries to human beings relatively common, ranging from mild wounds to death. As previously noted, the AVA emphasised that horses are the most dangerous animal in Australia, and effectively operate in an unregulated environment.
The committee heard the causes of accidents vary and could be attributed to the rider, the environment, or the horse. Research has shown horse behaviour is a precipitating factor in as many as 61 per cent of incidents. It has also shown the importance of understanding the suitability of certain breeds for work and riding requirements.
To this end, the implementation of a horse traceability register would improve transparency around a horse's history to determine its suitability for various roles, such as training for beginner riders, or a rider with disability. Knowing the history of a horse could allow a potential buyer to identify who bred the horse, who trained it, and who has owned it.
The tragedy that unfolded for Mr Mark and Mrs Juliana Waugh's daughter illustrates the importance of knowing a horse's history. In 2009, their daughter, Sarah Waugh died in a fatal horse accident during a beginner riding course at a Dubbo TAFE. Mrs Waugh explained:
A still-registered racehorse, Snakey Thought, fresh off the track from five recent races with no retraining was placed in a New South Wales government sanctioned course for beginner riders. It still beggars belief that someone did this. But more important is that a New South Wales government sanctioned education course allowed this to happen. This was possible because there were no rules in place—nothing to stop someone misrepresenting the horse, lying about the horse and misleading those involved.
The committee heard that the absence of a record of the horse's history meant that TAFE NSW staff could not confirm the horse's suitability for the course, and had they known, they 'would not have accepted it for use in a beginner riders course'. And whilst the racing industry has a robust registration system, other horse transactions:
…are open to deception—that's not to say that all horse owners do this; this is a small percentage, but my daughter is dead because of that small percentage—with there being little any buyer can do about it and, increasingly, the possibility of an unsuitable horse ending up in inexperienced hands and leading to an accident like Sarah's.
Despite Mr and Mrs Waugh's advocacy for horse traceability, they also recognised that traceability would not eliminate all risks associated with horse riding; instead, they maintained that it would minimise the risk. Further, traceability would support the safety codes of practice that the NSW Government implemented after their daughter's fatal accident.
However, doubts were expressed to the committee about whether horse traceability would achieve the goal of improved rider safety. The AHIC was of the view that horse sales were sufficiently policed by people exercising due diligence in conjunction with the Australian Consumer Law. It submitted that a traceability register would be a helpful, but collateral benefit and ultimately it would 'fix some of the problem [but] [i]t won't fix all the problem'. Further, safe handling of horses depended entirely on the experience of the managers, educators or trainers involved.
A similar view was presented by Animal Care Australia who also stated that 'problem owners who create problem horses may not be identifiable in the horse's past, and the horses themselves will be the ones to suffer as a result'. The organisation foresaw increased litigation when injured new owners might file compensation claims against previous owners.
Despite these divergent views, there was some agreement a traceability register had the potential to allow the identification of dangerous horses; and horses that, because of their previous use, may not be suitable for a subsequent purpose. Horse SA made clear that a register would not resolve the issues of workplace safety (and horse welfare), but:
…it's an evidence based tool to give our industry credibility and provide a red-flag warning system on which we can act. Most importantly, we can stand with our hand on our heart and say we're doing the best we can for our national horse herd and the people who care for them.
The committee was warned, however, that horses identified as 'problem horses' often went from home to home and at each stage, the level of care diminished. It was thus important to consider the welfare consequences for horses identified as problem horses.
Stakeholders made several propositions as to how a traceability register might improve horse welfare, and assist with the identification of owners who mistreat their animals. The committee was also told traceability would support the existing welfare programs of the racing industry, as well as support the industry's social licence to operate. Traceability could potentially provide data to inform research into horse welfare; communicate general information on horse welfare; and record/mandate veterinary treatments.
One issue faced by veterinarians and animal welfare groups is identifying owners in cases of horse abandonment and animal hoarding. The committee heard of examples of horse neglect, such as 116 hoarded horses recently being euthanised due to starvation. RSPCA informed the committee that in 2018–19 it investigated 1,712 reports relating to horses, with 67 per cent due to underweight animals, and insufficient feed or water. In these situations, the AVA explained that a general response to neglect is the denial of ownership, and without traceability, there is no means for authorities to enforce accountability. This concern was echoed by the RSPCA:
…inspectors face many challenges with horse cruelty reports, as it can be difficult to determine an owner where a horse is unidentified and no-one is living on the property.
However, in circumstances where horses were microchipped, RSPCA investigators had easy access to an identification tool to determine the 'horse's identify and owner details, which allows them to get in touch with the owner in a timely manner'. It also enabled the identification of horses subject to multiple investigations.
When the committee questioned whether a register would capture those irresponsible horse owners at risk of neglecting their animals, the AVA responded that a traceability regime would establish a compliance mechanism. This mechanism would be an accountability measure for people to be held to account before those horses were starved.
The committee also heard that traceability had the additional benefit of allowing for the centralisation of animal welfare reporting and the communication of welfare information directly to horse owners. This could include reminders of certain health checks to be performed on a horse at specific intervals, for instance, hoof checks by a veterinarian. Animal Medicines Australia proposed the creation of individual equine health records within a horse register. The organisation stated that accurate records supported good equine health, fundamental to high standards of animal welfare.
Racing industry–horse welfare concerns
Concerns were also expressed about the welfare of horses from the racing industry. Of the state and territory racing bodies, Racing NSW (and the Australian Capital Territory) has been a leader in the space of horse welfare, rehabilitation and rehoming programs. Since 2012, Racing NSW has supported rehoming efforts by horse owners and trainers, and also takes carriage of a horse to rehome and/or provide long-term care if required, including relocation to one of six properties designated for retired horses (equating to 3,200 acres across NSW). In 2017, Racing NSW enshrined this requirement in its by laws and regulations:
Rule 114 says that no owner or trainer can put their horse anywhere other than a good home when it leaves the racing industry. So, for that first point of exit, there's a rule in place that says you need to ensure that that home is good and the horse will be as well looked after as it would have been whilst it was in the industry. It also requires that it can't be sent directly to a knackery from us or directly to a saleyard—where it may end up at a knackery.
Despite efforts by Racing NSW to prevent its retired horses from being killed, its powers to do so only exist at the first point of departure from the industry. As previously discussed, Racing Australia supports horse traceability for its capacity to track horses beyond their racing careers. It noted Racing Australia and state and territory racing agencies have no legal authority to require subsequent changes in the ownership and location of horses to be advised and updated. As explained by Racing Australia, a national traceability register would subsequently:
…strengthen equine welfare across the industries that make up horses in Australia, and will help us in filling a gap that exists within our existing traceability regime.
Racing Australia continued that traceability would also:
…ensure that state and other animal welfare agencies could have them from that point on, in terms of visibility, where they are and who's responsible for them.
However, even with a national horse traceability register, Racing Australia clarified that a racing body's responsibility for horses would not extend beyond that first point of departure from the industry. Rather 'responsibility would presumably rest with either state agricultural authorities or, in [NSW], the RSPCA'. This was also emphasised by Racing NSW, having stated that whilst its ensures retired horses are sent to a suitable home, it does not have the 'jurisdiction, visibility or control over what happens after that point'. Racing NSW also spoke of the importance of creating a market to house the industry's retired horses. Racing Victoria discussed its $35 million investment to rehome and retrain its horses; however, disclosed that despite its strong endeavour, it would be a folly to suggest 'that every horse has a healthy future when, practically, we don't have the capacity to ensure that very appropriate insight is met'.
A national traceability register speaks to the social licence of the horse racing industry. A register was said to reflect a community expectation that the racing industry make appropriate provisions for horses upon retirement. Harness Racing Australia agreed the harness racing industry required public confidence, demanding high standards of integrity and regulation.
This public confidence and social licence, however, was undermined with alleged horse welfare concerns revealed by the ABC's 7:30 investigation into the racing industry. Footage provided to the investigation showed the mistreatment of horses at a Queensland abattoir, which were subjected to beatings and electrocutions, and in clear distress at the time of their death. The footage, which shocked the nation, reignited calls for improved horse welfare outcomes and a national horse traceability register to strengthen accountability.
In response to the 7:30 investigation, the racing industry re-iterated its support for a national horse traceability register. Racing Victoria stated that a national horse traceability register would help 'develop a national approach to the management of horse ownership and whereabouts'.
However, the investigation did not result in a firm commitment from across the racing industry for the application of Rule 114 across all jurisdictions. Mr Gregory Nichols, representing both Racing Australia and Racing Victoria, informed the committee that a national ban on knackeries and abattoirs, similar to Racing NSW's Rule 114, had not been a 'full conversation at Racing Australia level' but could feature at an upcoming board meeting. Mr Nichols added that the racing industry was a federation model, and for that reason, 'principal racing authorities determine policies within their states'. As a representative of Racing Victoria, Mr Nichols clarified its view that 'there are alternatives to a prohibition on the abattoirs'.
No reference was made to the national application of Rule 114 after the Racing Australia Board met on 12 November 2019. Racing Australia advised the committee that its current consideration of equine welfare issues continued at its recent Board meeting. Further:
A proposal for the national adoption of the Racing NSW Local Rule prohibition on Thoroughbreds being directly or indirectly sent to an abattoir, knackery or being similarly disposed of, was put to the Racing Australia Board during the latter half of 2018, but no resolution on the matter was reached.
Racing Victoria clarified that it had previously objected to the national application of Rule 114. Although supportive of re-homing its horses, Racing Victoria was of the view that the humane euthanisation of a horse is warranted in some circumstances, and that an abattoir ban can have adverse implications as demonstrated by the experience in the United States. However, Racing Victoria was:
…prepared to reconsider the efficacy of a ban or greater restrictions on the slaughter of thoroughbreds. This would require an integrated national legislative and enforcement framework involving government and industry.
Racing industry data
Of particular interest to some stakeholders, and emphasised by the 7:30 investigation, was the accuracy of the racing industry's data. Each year the racing industry breeds thousands of horses, with an estimated third of the total racehorse population exited annually.
Harness Racing Australia provided the committee with a thorough breakdown of its breeding, retirement and death statistics. Table 3.1 shows the number of horses Harness Racing Australia breeds, and retires, and also the number which die each year.
Table 3.1: Harness Racing Australia breeding, retirement and death statistics, by year
Foals born that do not race each year
Horses died from accident or natural cause
Horses euthanised due to injury or illness
Horses euthanised for other reason (including knackeries/abattoirs)
Source: Harness Racing Australia, answers to written questions on notice, Senator Faruqi (received 1 October 2019)
Unlike Harness Racing Australia, Racing Australia did not provide specific figures as requested by the committee; it instead made reference to its Racing Australia Fact Book 2017/18 and annual reports for this data. These reports provide a broad range of statistics, such as breeding statistics, horse registrations, retirement destinations, economic activity and industry trends. Breeding statistics, extracted from the Racing Australia Fact Book 2017/18 are found in Table 3.2.
Table 3.2: Racing Australia breeding statistics.
Number of foals bred (live foals)
Source: Racing Australia Fact Book 2017/18, p. 40.
These documents, however, do not appear to provide horse retirement figures or the number of horses that have died each year. The committee subsequently sought further clarification about retirement figures with Racing Australia, which according to the 7:30 investigation amounted to an estimated 8,500 horses each year. In response, Racing Australia was unable provide a figure; instead, it noted that a figure would be obtained in the course of its engagement of a consultant to examine the 'completeness and accuracy of Racing Australia's horse records'. Similarly, Racing Australia was not able to provide the number of thoroughbreds listed as active but which had not raced or trained in the past 12 months.
Another contestable figure provided by Racing Australia concerned the number of its horses that were sent to abattoirs and knackeries each year. Throughout the committee's inquiry, Racing Australia referenced that only one per cent of its retired horses ended up in abattoirs and knackeries. In its first appearance, Racing Australia discussed with the committee its analysis of its retirement of racehorses:
Twenty-three per cent go into breeding activities…Then, as the annual report reveals, you always get those people who leave forms blank. Less than one per cent of the forms are blank. One per cent go off to the livestock sales—some of those are sold on to farms and stations across the country. Four per cent died of natural causes—recognising, of course, that, under the rules of racing, until they leave the industry horses can only be euthanased on the order of a veterinarian…Less than one per cent were classified as having been to abattoirs—that's across the country.
…when you retire a horse from the industry you have to fill out a form. There are penalties that apply there too. Those forms are filled out. Then what we do is: we send a sample of those forms to each of the states and territories involved, so that they can undertake checks to ensure that we can be confident about the data we're collecting. While we won't check 100 per cent of the data…we do random checks to ensure that when they tell you, 'It's at Mr Smith's farm at Goulburn,' it is actually there.
Whilst the racing industry communicated that a minimal number of its retired horses ended up at knackeries and abattoirs, the 7:30 investigation challenged the racing industry's statistics. It reported that of the estimated 8,500 horses that retire from the racing industry each year, an estimated 4,000 horses per year were unaccounted for and potentially ending up in Australia's abattoirs and knackeries. The 7:30 investigation also found that horses at the abattoir were registered as 'active' under the Australian Stud Book.
In response to the footage, Thoroughbred Breeders Australia (TBA) wrote to its 4,500 members calling for Racing Australia's official retirement figures to be examined so that 'the wider public has confidence in their accuracy'. Concerning the number of racehorses killed in Australia's abattoirs, the TBA called for the industry's official figure of one per cent to be further scrutinised. The TBA also highlighted the need for a national traceability register.
The committee asked Racing Australia whether it intended to examine its official figures. In response, Racing Australia said it had commenced an audit to look at the 'processes to ensure that we block the misses—the occurrences where we don't accurately record where horses go'. However, Racing Australia noted that this audit would not encompass official retirement figures and added:
That's a very noble aim and it's one that we will aspire to, but the reality is that there are a number of logistical reasons that we will struggle to accumulate an accurate picture of those numbers.
Racing Australia later clarified that the examination of retirement figures would be 'explored in the course of the…examination of Racing Australia's horse records'.
The committee also sought further clarification about the how the official figure of one per cent of horses ending up in knackeries or abattoirs was calculated. In response, Racing Australia explained that retirement figures are not a 'whole-of-life view', instead are from birth to when they depart from the industry. Racing Australia denied that it was:
…advocating that only one per cent of horses meet their demise; we're not saying that whatsoever. What we're saying is: at the end of their racing career, when they move out of the sport, the owners notify us of the next phase of their life.
Harness Racing Australia had also engaged an independent consultant to review all state and national harness racing policies and procedures, including:
…the robustness of data input and data analysis regarding horse traceability within the harness racing industry.
Horse processing and food safety
The committee heard of the benefits traceability may have concerning the treatment of horses when they arrive at abattoirs and knackeries. In addition, submitters and witnesses in support for traceability argued it was needed to meet EU food safety requirements.
Horsemeat and treatment or horses at Australia's abattoirs and knackeries
Horsemeat for human consumption is a small market in Australia; instead, horsemeat is predominately used for animal protein (pet food industry) or exported for international horsemeat markets, such as those found in Europe.
There are no accurate figures on the number of horses that are killed through Australia's abattoirs and knackeries each year. However, the Department of Agriculture informed the committee that in 2018–19, Australia exported 2,600 tonnes of edible and inedible horse meat products to eight countries, with the top four markets being Belgium, Russia, Switzerland and Vietnam.
The committee received various estimates of the number of horses killed each year in abattoirs and knackeries in Australia. As previously noted, Racing Australia advised the committee that less than one per cent of its horses registered horses were classified as having been taken to abattoirs. Harness Racing Australia reported that 201 of its registered horses were 'euthanized for other reasons' over a five year period, which included horses sent to abattoirs and knackeries.
Various stakeholders argued that there were inadequacies with the industry's efforts to accurately record the whereabouts of retired horses and for this reason, were unable to provide an accurate figure on the number of horses killed. Further, the total number of horses killed in these facilities was unknown. The Australian Equine Unification Scheme and Hunter Horse Haven stated that 69 per cent of horses sold at saleyards end up being slaughtered. Horse SA stated that the information available on horse slaughter was speculative and that more needed to be done to understand the horsemeat processing sector.
Various submitters and witnesses argued a national traceability register would provide information on slaughtered horses. The RSPCA agreed that a national horse register would assist with understanding what is happening at abattoirs and knackeries, and the origin of the horses that end up there. Further, these facilities could be required to record the microchip numbers of horses killed, and upload this data onto a national database.
Racing Australia was also supportive of a traceability register as a means to support its efforts to re-home retired horses and prevent them ending up in slaughterhouses and abattoirs. This view was reiterated by Racing Australia in the aftermath of the 7:30 investigation; however, the racing industry would not guarantee an end to their horses ending up at these facilities. It also acknowledged on notice that it 'understands that some Thoroughbreds are sent directly to abattoirs and knackeries', and that it was 'considering the most effective ways to reduce (or potentially eliminate) Thoroughbreds being sent to' these facilities.
Harness Racing Australia argued that preventing its horses from ending up in abattoirs or knackeries was a commitment it would not be able to uphold:
…no, we are not in a position at the moment where we would head down that path with giving a commitment, because I don't think it's a reality that we could ever, with hand on heart, be able to promise.
The job for us and our clear responsibility is to provide as many opportunities after they have retired from their activities in our racing industry to live full and quality lives. It's a clear and critical focus for us to ensure that they are given every opportunity, whether it be within the farms that they were bred on and performing duties there or moving into other equestrian and pleasure pursuits.
This position was shared by Racing NSW and Racing Victoria. Racing NSW referenced jurisdictional limitations and that it does everything in its power to re-home its horses and 'make sure that those horses have a happy and healthy home'. Racing Victoria added that it was a reality of the industry that it cannot guarantee that:
…every horse will have a happy, long and fruitful life. What we are doing is representing the reality, and the reality is that, albeit our aspirations to ensure as many as possible [are rehomed], we are not going to get to 100 per cent.
The committee also heard that an additional mechanism to reduce the number of horses being slaughtered was the incorporation of a 'do not slaughter' declaration into a traceability register. The UK's Central Equine Database (CED) includes this option. However, the AHIC and the Australian Continental Equestrian Group maintained that it is ultimately the horse owner's choice to determine whether a horse ends up in a slaughterhouse or knackery.
The Australian racing industry, when asked about a 'do not slaughter' option being integrated into a national horse traceability register, provided a mixed response. Racing Australia and Racing Victoria did not provide a definitive answer, and instead re-iterated that the industry was governed by a federated model and would require consensus across all jurisdictions. Racing NSW said it would need to be further explored, but had been discussed within the racing body. Harness Racing Australia, however, responded that it would be hard for its members to agree to this measure. Injury, behavioural issues, disease and economics were identified as potential concerns.
Concerning food safety and the exportation of horse meat, the committee heard that the current Australian system was inadequate. The European food market has been the primary driver for the implementation of traceability registers in the EU. Since February 2005, EU law has mandated that all horses are required to have a passport for identification and a central database that maintains identification records. These registers help ensure drug residues are kept out of the food system and to prevent the adulteration of horse meat products.
The committee heard that Australia fails to meet these EU standards due to the lack of a national horse database. The Australian Equine Unification Scheme and Hunter Horse Haven stated that it was unsure how Australia continues to export horsemeat to Europe.
Concerns with Australian compliance with EU standards has been an ongoing issue for the industry. In 2012, the European Commission found deficiencies with Australia's horse identification controls.
When asked whether Australia's traceability measures met EU horsemeat requirements, the Department of Agriculture explained:
The current traceability is the tag that goes around the horse's neck, which is, I would think, from the Europeans' point of view, definitely not sufficient security for identification. But, to date, they have accepted that, and, when they come out to do audits of our export establishments and they're auditing horses, they always comment on that and ask: 'When are you going to improve this?' So it's of interest to them, definitely, yes.
Submitters forewarned that it was likely that future changes to EU requirements for horsemeat would call for Australia to implement greater information on horses.
Further issues were highlighted by the 7:30 investigation. In a statement released by the Department of Agriculture, it clarified that whilst animal welfare was the responsibility of the states and territories, the Department of Agriculture was responsible for the 'export abattoirs…to ensure Australian export standards are met'. For this reason, the Department announced it had conducted a critical incident audit of the Queensland abattoir identified in the 7:30 investigation, which may result in regulatory action.
Improved breeding practices
The committee heard a horse traceability register might be used to improve breeding practices in Australia by reducing backyard breeding, and raising the standards of breeders.
The AVA stated horse breeding was poorly regulated and the fact there were no significant limitations, other than economic, meant there was indiscriminate breeding of large numbers of animals. The AVA advised the committee that backyard breeding was similarly unregulated and for this reason:
There are a lot of horses that are bred indiscriminately because it's a nice idea, and that's an example of backyard breeding. That in itself doesn't have to be a bad thing, if you have the capacity to look after them and care for them. Once again, identification and traceability would be the basis of at least knowing where the horses are living, and, if you're planning on breeding and having a foal, it would be recorded so we could at least understand it. Our data would become information and could become wisdom for policy decisions in the future. As I said, in the contemporary era, it's not unreasonable to expect people who want to keep animals and breed them to be accountable for them, and if you're going to have accountability you need an information system.
A number of submissions and witnesses stated that identification would end the anonymity of sales to knackeries and abattoirs, and flow back to a reduction in backyard or indiscriminate/unplanned breeding.
Several stakeholders pointed to ways in which test results on horses could be collected as part of a register, which would provide data on genetic hereditary diseases, performance traits, and genetic technological advances. If this information was made publicly available, it could reduce the incidence of recurring and defective traits. This information would be a particular benefit for small breeders who may not be aware of current research or evidence of good practice for horse welfare.
Maintaining the integrity of trade in horses and professionalising the industry
Several suggestions were proposed to the committee concerning traceability and the integrity of the trade in horses. Submitters argued traceability would strengthen consumer confidence by allowing for the validation of horse identity before purchase and verification of health status. The committee received evidence that the only way to confirm the ownership of many horses was by sighting a sales receipt.
Traceability would allow commercial horse transporters to check and validate horses and confirm payment details from the correct owners; allow sale yards to confirm horse identity; and deter theft and fraud (see below). Traceability would also allow for the identification of substituted horses.
The committee heard that verified information on provenance was valuable to breeders, racing clubs, and sport horse organisations. A register had the potential to add value to horses by recording a history of ownership, training and performance.
The committee also received evidence that if a horse traceability register was to have a broad scope, it could potentially be used by horse industry groups to manage their breed or competition registers. It was noted many breed societies and clubs are small, can be volunteer-run, and have small budgets. Access to a platform to manage studbooks or administer events could improve the quality and accuracy of services offered.
Stakeholders expressed support for national horse traceability to address horse theft. One of the impetuses for initiating the DPI's investigation into the merits of horse identification in NSW came from the NSW Police Force. DPI, which sits on a rural crime advisory group with NSW Police, explained to the committee that the NSW Police Force had difficulty proving stock theft in the absence of horse identification. For this reason, the NSW Police Force have 'made it very clear that they're strongly supportive of horse identification because of horse theft'.
In its submission, the NSW Police Force explained that the key objective for its support of a national register was to assist with its criminal investigations into instances of stolen or substituted horses, and improved rider safety. According to the NSW Police Force, traceability 'would provide police with substantial supporting evidence during…criminal investigations'.
Mrs Juliana Waugh spoke of the challenges faced by NSW Police concerning the investigation into her daughter's death in 2009. Mrs Waugh stated that investigative authorities, including the courts, had difficulty locating the horse involved in the accident, confirming ownership, and when the horse was sold, 'both before and after the accident'.
Movement of horses
The committee heard various perspectives on the inclusion of movement records into a national traceability register. This functionality was supported by Equestrian NSW, who thought it would be easy to develop a practical digital system that tracks movements. Mr Mark Waugh provided an example this type of tracking app currently in use in Queensland, designed to track movements of animals, including horses, as part of its efforts to control cattle ticks within the state. The Australian Continental Equestrian Group considered traceability as a logical next step for existing requirements under state legislation for horse movements to be tracked.
The committee questioned Mr Waugh on what constitutes a horse movement and how this could impact on recording requirements of a traceability system. In response, Mr Waugh advised that a register should be updated in a circumstance where a horse is moved to another property with an alternative PIC. However, if done so on a regular basis, then practical considerations should be made.
The DPI informed that committee that it would not support any recording of movements in the same way that other livestock are tracked because:
…that would be extremely complicated for horses. Generally what happens at events these days is that, if you go to a pony club or a show, they will ask you for your PIC. They'll record it when you get there. If they have a chip, they would also scan it. They may scan it or they may not. We would not look at or support the recording of movements of horses as happens with cattle and sheep, because that's done for different reasons around traceability.
DPI explained that whilst a register would not track specific movements of horses, it would be a valuable tool to enforce and restrict the movement of horses during a biosecurity outbreak. In this circumstance, DPI would declare a control order, which is enforced by the NSW Police Force who are authorised biosecurity officers. The DPI added that individual identification is helpful because it provides authorities with additional information about a horse's registered location.
The Department of Agriculture shared DPI's view, and advised the committee that it did not believe it would be feasible to design a horse traceability register similar to cattle and sheep because horses move from place to place on a daily basis and then return home. For this reason it would be questionable to expect horse owners to track these movements daily. However, the Department of Agriculture highlighted the importance of:
…having a PIC, where the horses are actually located, is really crucial. That's a very important thing to know for helping to respond and identify where horses are. It would help to contain a disease outbreak.
The implementation of comprehensive horse traceability systems in other countries has largely occurred in the EU, including the United Kingdom (UK). Whilst discussions about the implementation of a national horse traceability regime in Canada and the United States have occurred, neither country has sought to implement such measures. As previously detailed, the impetus for a comprehensive horse traceability system in the EU is largely driven by a food safety imperative.
Since February 2005, EU law has mandated that all horses are required to have a passport for identification. Whenever a horse is moved, it must be accompanied by the passport, and the passport is transferred with the horse when ownership changes.
In relation to register, France, the Netherlands and Luxembourg were all referenced by submitters during the inquiry. These countries have each taken different approaches to a centralised database that aligns with EU regulations. For example:
in France, the Identification System Indexing Equidae (SIRE) was originally created to improve breeding through horse identification but has progressively expanded to address animal disease/biosecurity and food safety;
the Netherlands uses a pre-existing digital web-based studbook information system that feeds required information automatically into a government database; whereas,
Luxembourg has adopted an integrated model where individual studbook systems/databases from seven horse studbooks (each with their own regulations) were combined with the national horse identification and registration database of the Luxembourg government, which is controlled by an independent service provider.
The UK's model of horse traceability was referenced throughout this inquiry. The committee heard there is broad support for horse traceability within the equine industry in the UK, which is estimated to contribute over eight billion pounds to the British economy each year. This support is derived from the benefits traceability delivers for biosecurity, horse identification, border security, horse welfare, food-chain safety, scenario planning, and national and international trade.
In the UK, horse identification documents (horse passports) can be issued by organisations (passport issuing organisations, or PIOs) approved by the Department of Environment, Food and Rural Affairs (DEFRA). Fifty-four horse PIOs manage the studbooks; and there are 14 organisations that do not manage a studbook but are authorised to issue horse passports.
The horse passport requires a horse to be identified by a veterinarian. It includes a completed silhouette that identifies the horse's markings and provides details of the microchip. The passport also contains medication pages, including a declaration that states whether the animal is intended to enter the food chain. Once a horse has been declared as 'not for human consumption', a subsequent owner cannot change this designation. The passport must always accompany the horse.
The UK meets its EU-mandated requirements for horse traceability through the CED, which holds the core equine identity for the national herd, estimated at around 1.3 million animals with more than 650,000 owners. The committee was advised this database goes beyond requirements established in EU legislation to bring greater functionality and benefits to the equine industry.
Prior to its implementation, DEFRA established a Traceability Design User Group. This group, which included the British Horse Council, was consulted about the desired functionality. The consultation intended to design the CED to meet the data needs of industry, for instance, for genetics, standards, performance and innovation. This work is ongoing.
A particular benefit of the CED raised by submitters was its ability to avoid duplication by allowing approved non-government bodies (PIOs), to provide regular transfers of prescribed data from their databases to the CED.
Further, while it is free to input the mandated information, the CED has been designed to offer additional functionality for a fee. If a sporting organisation wants to manage events, with live cross-checking of veterinarian data to ensure horses are vaccinated, and the recording of results, this can be done through the digital database and its app. A breed society can track its bloodstock, histories, and vet data. The image below is an example of the level of detail contained within a CED equine profile:
Figure 3.1: Equine profile, Central Equine Database, United Kingdom
Source Horse SA, 'Find out about the Central Equine Database UK, YouTube, 15 March 2019
Horse traceability in the UK is underpinned by a range of regulations, including the recently updated Statutory Code of Practice for the Welfare of Horses, Ponies, Donkeys and their Hybrids; the World Health Organisation One Health program addressing antimicrobial resistance; the development of new animal breeding regulations; minimum operating standards for passport issuing organisations; and the animal welfare act.
More recently, the UK Government has made it mandatory for all horses, ponies and donkeys in the UK to be microchipped by October 2020. The UK Government introduced this legislation as a means to address animal welfare concerns for horses. The delay in the application of this law is to allow time for horse owners to combine microchipping with a routine visit to a vet. As of 15 March 2019, 45 per cent of horses had been microchipped and recorded into the CED. This measure is supported by both the British Horse Council and the RSPCA.