AVA Submission on the land transport of horses - October 2022

Thank you for the opportunity to comment on the Consultation Regulatory Impact Statement (CRIS). Our process to inform this submission involved asking members for feedback on the CRIS statement and used this feedback alongside Australian Veterinary Association (AVA) knowledgebase and policies to develop the submission.

The AVA is the national organisation representing veterinarians in Australia. Our members come from all fields within the veterinary profession. Clinical practitioners work with companion animals, horses, livestock, and wildlife. Government veterinarians work with our animal health, public health, and quarantine systems while other members work in industry, research, and teaching.

The preferred option of the AVA is option 3, we are supportive of the regulatory approach and would like to see implementation of nationally consistent land transport standards for horse transport to improve welfare standards. Failure to have national consistency in animal welfare legislation between states make it difficult for industries to compete on a level playing field and could impose a greater regulatory burden on stakeholders.

Before we answer the questions outlined below, we have the following comments regarding the draft standards and guidelines.

• We would like to see SB8.1 amended to simpler wording stating the maximum journey time in any 24-hour period. This will be simpler for stakeholders and provide better welfare and enforceability outcomes. We suggest the following “A person in charge must ensure that the journey time does not exceed the time periods given below for each class of horse in any give 24-hour period”
• We are concerned in SB8.1 the maximum travel time for horses over 6 months old of 12 hours with 8 hrs rest may be based solely on human welfare, rather than the best welfare interests for the horse. The literature suggests that transport related horse welfare risk factors increase after 8hrs continuous transport.
• We would like to see a fit for purpose requirement for the transport vehicle within the standards. There is evidence that transport related problem behaviours can be associated with poor mechanical condition of vehicles. Anecdotally members report that severe injuries can occur due to the poor condition of the transport vehicle.
• We would like to see GB 8.2 be considered a standard not a guideline.
• In GB8.17 it states stalls should be at least 700mm wide and 2350mm long for a 15hh horse, this doesn’t appear to equate to 1.44m2 stated in GB8.12.
• Given the risk to horses being transported across the Bass Strait and the potential catastrophic outcomes ‘adequate provision’ as outlined in the existing Navigation Act 2012 needs to be defined. We would suggest that the voluntary guideline (GB8.4) should be mandatory for horses transported across the Bass Strait.
• We would recommend updating Figure B8.1 as although the lines go from the eye to the ear, the bullet entry point should be above the point of intersection.

Read the full submission here.