Introduction
2.1
The three essential elements of a traceability system—animal identification, property identification, and a central record—exist in a piecemeal and inconsistent fashion across jurisdictions, and within the horse industry. Due to the fragmented nature of existing registers across Australia, and the lack of uniformity in the information collected, these elements cannot simply be joined together into a single national system.
2.2
There are varying requirements across states and territories concerning the registration of horses, with only Western Australia requiring the individual identification of horses. No state or territory traces the movements of horses through a central record, though all require properties keeping horses to be registered with a Property Identification Code (PIC).
2.3
In addition to state and territory records, there are a large number of industry-based registers, of varying standards and coverage. Horses can be legitimately registered on more than one register, and a significant number of the horse population does not appear on any register.
2.4
Despite the lack of traceability for horses, traceability systems exist for cattle, sheep, pigs and goats in Australia. These systems—their establishment, design, and problem-solving methods—provide useful guidance for any potential future horse register.
Horse identification and registration in Australia's jurisdictions
2.5
As noted in Chapter 1, all states and territories require properties where horses are kept to have a PIC, but these codes do not translate into a system that identifies individual horses. Concerning the movement of horses, requirements vary between jurisdictions. For example, Queensland legislation requires a record to be kept of animals, including horses, which move across the cattle tick line. Whereas in Victoria, horses are exempt from internal and interstate livestock movement requirements.
2.6
Table 2.1 summarises the requirements across Australian states and territories with regard to PICs where horses are kept; whether individual horses must be identified under the PIC process; movement records (within jurisdictions); and the existence of any central records.
Table 2.1: Property and horse identification requirements in Australian jurisdictions
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ACT
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Yes
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Unclear
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Voluntary—held by individual for 30 days after event
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No
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NSW
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Yes
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Number of horses only
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Voluntary—held by individual; encourage preservation for 2 years
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No
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NT
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Yes
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Number of horses only
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Not required
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No
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Qld
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Yes
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Unclear
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Yes—held individually and retained for 2 years
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No
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SA
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Yes
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Number of horses only
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Unclear
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No
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Tas
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Yes
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Number of horses only
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Not required
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No
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Vic
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Yes
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Number of horses only
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Not required
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No
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WA
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Yes
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Yes—individual horses
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Voluntary—held by individual
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Unclear
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Source: compiled by committee, 2019.
2.7
The committee heard that horses are largely unregulated. Whilst livestock is tracked under National Livestock and Identification System (NLIS) and companion animals, such as dogs and cats, are registered under their respective jurisdiction's laws (such as NSW's Companion Animals Act 1998), horses are excluded from similar regulatory frameworks. This point was emphasised by the Australian Veterinarian Association (AVA) during a conversation about horse welfare and rider safety:
It's one of the last great frontiers that you can buy a horse today, hop on it and ride it away. You don't need to have a licence or register it and you don't even need to wear a helmet. Whilst that's a lovely romantic idea, I don't think that's sustainable in our modern, contemporary concept of community and expectations for animal welfare. I think you need to have accountability.
2.8
Whilst the AVA acknowledged that no one 'likes excessive regulation or overregulation', the lack of regulation for horses is problematic. The committee was advised that the horse is the most dangerous animal in Australia, 'responsible for more deaths and hospitalisations than snakes and spiders by a long stretch'.
Horse industry registers
2.9
Horse registration and identification systems are primarily operated by horse industry groups, whether breed-specific, discipline-specific or organisation-specific. Each register operates differently, with no compulsory obligation for any society to trace an animal for any purpose, except for some competition or breeding purposes.
2.10
Due to registers operating for different purposes, the information collected varies. In addition, the motivations for compliance differ between registers. For example, many groups require registration and identification as a condition of a horse's participation in the activities of the group (i.e. the racing industry), or to have a horse recognised as a certain breed. Some registers only record the horse, the rider and/or membership of a particular organisation or group.
2.11
These registers operate on the basis of a member's ongoing participation with an industry or organisation. Once a member departs that industry, or is no longer a financial member, then there is no requirement for that horse to remain registered. For this reason, no system operating in Australia is a whole-of-life horse register.
2.12
The committee received information on a number of existing horse registers. These registers vary in size, with the Australian Stud Book being the largest register in Australia. The data collected by these registers differs depending on the specific needs and purposes of each industry. A number of these registers are detailed below.
Australian Stud Book
2.13
The Australian Stud Book, a division of Racing Australia, has been the national register of Australian Thoroughbred horses since 1859 and currently holds more than 1.2 million records. The Stud Book represents 107,000 horses across Australia. It is the official authority for the identification of thoroughbreds in Australia and maintains the breeding records of the world's second largest population of thoroughbred horses. As an accurate historical and contemporary record, it is able to provide information on industry population, breeding statistics and trends for national and international use.
2.14
The Stud Book allocates a permanent life number to every horse. All horses must have their parentage verified and be accurately identified prior to acceptance. The Australian Stud Book provides microchips, and registers brandings. In 2003, Racing Australia introduced a requirement that horses are identified with a microchip, and since 2016, Racing Australia has used the Australian Stud Book to assist in 'delivering traceability of our horses from birth to their retirement from racing'.
Registrar of Racehorses
2.15
The Registrar of Racehorses is a fully integrated division of Racing Australia, which records and administers thoroughbred horse records for racehorses that are racing, or eligible to race in Australia. Racing Australia (and its principal racing authorities in each state and territory) processes and records leases; racehorse names; racing colours; information on visiting and imported horses; syndicates; and transfers of ownership. Around 13,800 thoroughbred horses are registered each year. The reporting requirements are enforceable through the Rules of Racing administered by Racing Australia.
2.16
In the case of Racing Australia, owners of racehorses notify its register of a horse's retirement from racing. Owners can specify the horse has retired to equestrian/pleasure, breeding, an official retirement program, or livestock sale. However, as noted earlier in this Chapter, a record of a horse's movement is only made at the first point out of the racing industry. There is no ongoing traceability of a horse because Racing Australia has no mandate for ongoing traceability.
Equestrian Australia
2.17
Equestrian Australia maintains a register of horses and owners. Horses are registered and identified through the state or territory affiliates of Equestrian Australia, and only financial members are able to register a horse. Equestrian NSW, a division of Equestrian Australia, has 8,000 members and 22,000 registered horses. Nationally, the equestrian sector has 59,097 registered horses.
2.18
The committee heard that once a horse enters the Equestrian Australia system, a basic traceability framework is established for that horse, with the requirement that horses are 'identified, microchipped and registered to an individual or group of owners'. Registration then permits the horse to enter Equestrian Australia sanctioned events, and failure to register results in the horse's ineligibility for such competitions.
2.19
This register records a horse's official competition history and ownership; however, if a horse is 'onsold to a non-member or is no longer competing in official competition…[then] traceability will cease'. Equestrian Australia also separately provides national passports, and registers horses and riders for Federation Equestrian International (FEI) events.
Australian Trotting Stud Book
2.20
Harness Racing Australia establishes the rules for the Australian Trotting Stud Book, which is regulated by a Council through the Keeper of the Stud Book. The annual stud book contains the records of all Standardbreds active in the trotting breeding and racing industry.
2.21
The Australian Trotting Stud Book previously used freeze angle branding to identify its horses, but in 2016, commenced microchipping registered horses in addition to its branding requirement. To be registered, a horse's breed must be verified, along with DNA genotyping.
Welsh Pony & Cob Society
2.22
The Welsh Pony & Cob Society (WPCS) maintains a stud book of Welsh and Part Welsh Ponies and Cobs. It relies upon members to advise the society when horses have died and acknowledges there may be some inaccuracies as a consequence of owners not providing updated information. Horses registered with the WPCS must be identifiable in some way, whether it be microchipping or branding.
Australian Continental Equestrian Group
2.23
The Australian Continental Equestrian Group (ACEG) manages an industry-based register and stud book for horses and ponies. It is a member of the World Breeding Federation of Sport Horses and works closely with European breed societies for Oldenburger and Westphalian horses. The group issues passports, which are recognised worldwide and by the FEI. The ACEG uses microchips to identify its registered horses.
Existing livestock traceability systems in Australia
2.24
There are existing livestock traceability systems in Australia for cattle, sheep, goats, and pigs. The RSPCA suggested to the committee that these systems might provide a workable model for a horse traceability register. The NSW Farmers' Association urged 'government agencies and the equine industry to engage closely with these bodies to incorporate lessons learned from existing systems'.
2.25
These livestock traceability systems have been implemented through negotiations between industry, stakeholders and government, which led to agreement on the systems' scope, requirements and operations.
National Livestock Identification System for cattle, sheep and goats
2.26
The NLIS allows the permanent identification and lifetime traceability of livestock. It was introduced in 1999 for cattle, and expanded to sheep and goats in 2009.
2.27
Policymaking for the NLIS occurs through Safemeat—an industry-government partnership responsible for meat safety. The Safemeat Secretariat is located in the Department of Agriculture. State and territory legislation forms the regulatory framework for the system. Meat & Livestock Australia (MLA), through a wholly owned subsidiary, Integrity Systems Company (ISC) administers the NLIS database. The NLIS also has standards and advisory committees.
2.28
ISC and the MLA have invested approximately $65 million into the NLIS over the 12-year period between 2006 and 2017. Over that period, the annual operating cost of the NLIS was $5.4 million. The ISC's activities are funded through red meat industry levies, with matching government research and development levy investment. According to a 2019 impact assessment for the period of 2015 to 2020, livestock traceability and food safety systems generated an economic benefit of $316.7 million, by avoiding disease costs and attracting export market premiums.
2.29
ISC advised the committee that the primary benefits of the NLIS were its biosecurity function, which allowed for the management of the ISC's emergency animal disease response and the rapid containment and eradiation of disease outbreaks. ISC added that other benefits include:
…the data management system that has created linking datasets to provide insights on particular animals beyond just movement and an ability to increase productivity. There are other benefits in relation to maintaining our brand reputation and to the broader public benefit, and there is the obvious economic prosperity that we receive as a result of the premiums that we gain within market and the broader sustainability outcomes as well.
2.30
More broadly, the ISC spoke of interconnectedness of other databases to 'generate a much bigger picture of our industry and identify productivity benefits', and that traceability:
…will only get bigger and bigger in terms of what customers are really after. From our perspective, if there is a traceability system across all domesticated animals, that's part of a risk management strategy for us as well when it comes to diseases that might jump species that we just don't know about at the moment. That could come up down the track, so an ability to contain it right across animals is a critical thing.
NLIS in operation
2.31
The NLIS involves four elements:
animal identifier (visual or electronic ear tag – device);
identification of physical location by means of a PIC;
web-accessible database to store and correlate movement data and associated details; and
legal enforcement to ensure compliance.
2.32
Under the NLIS, animals must be tagged (individually identified). Each time an animal is bought, sold or moved from one property to another, a livestock movement record is created on the NLIS database. NLIS accounts are free to open and operate. Depending on the agreements within industry sectors, livestock are identified in the central database either individually or by mob.
2.33
As of 2019, the NLIS database contained approximately 242 million registered devices, '24.3 million individual cattle movements, 38.3 million sheep-mob movements and 11 million individual sheep movements'.
2.34
Producer costs are largely due to the identification method itself (ear tag and its application to the animal), along with the cost of reading equipment. The NLIS was designed to reduce the impact on producers, through the investment of required infrastructure at large central points along the supply chain (saleyards, feedlots and processing plants).
2.35
In its submission to the inquiry, the NSW Farmers' Association identified continuing non-compliance with NLIS requirements as evidence traceability is a complex concept, requiring outreach and education to owners, event organisers and industry professionals.
2.36
The ISC explained that the NLIS system in Australia is recognised globally as the most advanced traceability system in the world. However, despite the success of the NLIS, it has faced a number of challenges. Of these challenges, the ISC highlighted the following with the committee.
Staged implementation (by state, sector and species)
2.37
The staged implementation of traceability within the NLIS resulted in complexity with communicating the requirements of traceability, 'to both the participants and customers, because of variable implementation timeframes across the states and sectors'.
2.38
Based on this experience, the ISC has learnt that where possible, a national agreement needs to reached for a traceability system's implementation. It also noted the need to minimise the lag between the sectors implementing traceability to reduce gaps in the data and information collected. During the hearing the ISC added that:
…there is a need to recognise local constituents' requirements, but, in terms of communication, education and training, it makes it a lot easier if you've got a consistent message and package that you are delivering.
2.39
If a staged implementation is pursued for horse traceability, the ISC recommended that where possible:
…try to minimise differences between jurisdictions. It may still be of benefit and necessary to do it in a staged way, but trying to do it in a consistent way is probably the key.
Different requirements in jurisdictions
2.40
Different requirements of the traceability in each state and territory jurisdiction created challenges for the ISC, such as:
complexity in communicating those differences to stakeholders;
difficulty establishing national traceability performance standards when state-based exemptions already existed; and
needing to accommodate state-based requirements into a national database.
2.41
These challenges highlighted the need for agreement on the requirements of traceability at a national level, and that state-based exemptions should be agreed and applied at a national level to limit state-based variations.
Communication and education
2.42
The ISC referenced challenges with communication and education of traceability, but highlighted that the importance of these requirements could not be underestimated. It noted resources were initially provided to support implementation of the program, but these 'were eroded over time as the system shifted from implementation to business as usual'.
2.43
The ISC highlighted the need for on-going and sustained investment into communication and education to be factored into a system's design. ISC submitted that failure to do so hinders compliance, and restricts 'regular 'touch-points' with participants to remind them of the "what" and the "why". This on-going investment is needed to reinforce compliance with new entrants into the system (see below).
Industry turnover
2.44
According to the ISC, further compliance issue arises from industry turnover. New entrants into the system need to be educated about traceability requirements, which means ongoing education programs are required, to ensure new industry participants understand their obligations.
2.45
An additional issue was the limited means for participants to regularly update their contact details once the system was established. For this reason, the ISC suggested that the system needs to be designed to require participants to regularly update their records.
Compliance and enforcement
2.46
Three challenges were identified by ISC concerning compliance and enforcement:
defining the role of industry versus the role of government concerning compliance and enforcement;
a reduction of resources to support compliance and enforcement over time; and
the penalties applied to breaches of traceability failing to discourage non-compliance.
2.47
ISC submitted that any compliance and enforcement regime requires adequate resources to be impactful, and that both industry and government are required to play a role in supporting compliance. The ISC does not manage or enforce compliance, but provides the reporting tools needed to monitor compliance.
Technology adaption
2.48
ISC advised that the NLIS system had a number of stakeholders unable or unwilling to engage with or adapt to the technology in use, resulting in a complex arrangement with the system's design and implementation. ISC leant that any system needs to have minimum technology requirements that are agreed to by all stakeholders and delivered in the most simple and cost-effective way possible. The ISC added that any system must be integrated into stakeholders' business management and that real-time benefit was key. Further, the system's design should incorporate ongoing growth and evolution of the industry.
2.49
Additionally, adoption of the system was hindered by the inability to smoothly integrate technology with other software and hardware systems. The technology used in a traceability system therefore 'needs to present a value proposition beyond compliance, in order to drive broad-based adoption'.
Value proposition
2.50
The ISC learnt that legislation was not enough, and more needed to be done to support stakeholders' participation and compliance with the system. Specifically, stakeholders 'need a compelling reason to comply with the system' and a value proposition must be established across all sectors of the industry 'to encourage end-to-end compliance'.
Funding
2.51
The ISC informed the committee that the NLIS has experienced an erosion of funding over time, due to industry and government priorities changing. This meant the NLIS had not been able to establish secure, longer-term funding for the system. Consequently, the ISC submitted that funding commitments needed to be established upfront, and must be sustained at a level to support compliance and continuous system improvements.
NLIS Pigs
2.52
From 1 February 2018, state and territory governments have been required to legislate for the mandatory traceability of pigs through NLIS Pigs. NLIS Pigs is administered by Australian Pork Limited.
Establishing NLIS Pigs
2.53
PigPass was setup at the same time as the original NLIS, with funding provided by Australian Pork Limited and matched by government funds. The Commonwealth contributed seed funding valued at $1,228,338 over three years.
2.54
The system was not specially designed; rather, it was created using a Microsoft Dynamics database. Alongside the tracking of pigs, Australian Pork Limited also uses Physi-Trace, which allows for the tracing of unidentified meat samples to their place of origin.
NLIS Pigs in operation
2.55
The system for pigs works similarly to that for other livestock. NLIS Pigs requires:
registered pig identification (ear tag or tattoo);
PigPass National Vendor Declaration (PigPass NVD) to track animal movement.
2.56
Its database contains 3,700 registered producers, of which approximately 2,000 are small producers with backyard or pet-pig operations. There are approximately 265,000 registered sows in the system (with an estimated 2.5 million commercial pigs in Australia at any one time). Australian Pork Limited added that not all pigs are incorporated into the PigPass system because they may not leave the farm, and therefore have no tracing requirement. Further, the system tracks the:
…movements of pigs from one PIC to another PIC, that's the key thing. If they're sitting on the one PIC and they're not interacting with any other pigs, then, from a biosecurity point of view, if there's a disease incursion it follows that the disease is only on that PIC.
2.57
The levy applied is $3.25 per pig slaughtered through the system, which includes both a marketing and research and development levy.
2.58
If a disease outbreak was to occur, such as the African swine fever, the PigPass system would be a significant tool to manage that incursion.