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Estimates: Rural and Regional Affairs and Transport Legislation Committee: Agriculture and Water Resources Portfolio: Australian Livestock Export Corporation Limited

Estimates & Committees
Lee Rhiannon 6 Jun 2018

Thursday, 24 May 2018

Awassi sheep/Live export

Senator RHIANNON: Mr Thompson or Ms Clegg, I want to ask about mortality figures. Do you believe that the mortality figures reported to the department from the each shipment are accurate? What I'm trying to understand is on what you base this belief, considering crew are throwing carcasses into hoggers or overboard?

Dr Clegg : I do believe that the figures that we receive from the accredited vets or from the stockmen are accurate. I do realise that the ability to count 60,000, 70,000 or 80,000 sheep onto a ship and off a ship over several ports poses problems. We certainly see in our end-of-voyage reports from the master discrepancies in the number that were said to be loaded on to the vessel and the number that were discharged in ports. In some cases, more are discharged than got on. In other cases, there have been mortality events or we have assumed that there have been mortality events.

Senator RHIANNON: Going back to the issue about the carcasses, we know carcasses are being thrown overboard. Do you have figures about how many carcasses are discarded in this way?

Dr Clegg : We only get the number of deaths on the ship. When the animals have died, they're either going to be put through a hogger or they're going to be disposed of in accordance with MARPOL requirements.

CHAIR: You might share with the committee what you mean by 'put through a hogger'.

Dr Clegg : On some ships they have, I suppose, a grinding machine that's suitable for sheep up to a certain size. The dead sheep will be put through the hogger.

Senator RHIANNON: What happens to the contents of the hogger?

Dr Clegg : That will be released into the ocean, but, again, they are required to meet the MARPOL requirements.

Senator RHIANNON: You started off answering this question by saying you believe the figures. So it's based on the fact that you believe they're giving you correct figures. That's what we rely on.

Dr Clegg : Yes.

Senator RHIANNON: Does the department require the individual ear tag numbers of sheep who have died to be provided?

Dr Clegg : The sheep are not individually identified; they're identified to a property. We don't require the PIC numbers—the property identification code numbers—of sheep that are exported. Sometimes we will get individual information about cattle deaths, but generally we don't require that. We're just after the number that die.

Senator RHIANNON: You don't require it, but I understand they have individual ear tags. Wouldn't that be one way of trying to verify an industry which seems pretty out of control?

Dr Clegg : You could actually do that, yes.

Senator RHIANNON: You could do that, so why don't you do it?

Dr Clegg : It could be an improvement.

Senator RHIANNON: It could be an improvement.

Dr Clegg : We've got the Australian Standards for the Export of Livestock review underway at the moment, and that's something I'm sure they'll consider: the way we can improve knowing what the number of animals getting on and getting off a vessel is. It is fair to say, of the things that are not going well, not being able to accurately count the number of livestock that get on or off the ship used to be a problem in the 1950s and 1960s, but I think technology has moved along a lot. It's certainly an area that we'll be focused on.

Senator RHIANNON: When you find more sheep getting off the ship than got on the ship, there's clearly a problem. What do you do about that? If that's a trend with that particular exporter, do you start to then doubt the veracity of their figures?

CHAIR: Just before you answer, Ms Clegg, and I'm sorry to interrupt, media have joined us in the room. Are any committee members or officials opposed to the media being here? There being none, I remind the media not to take any photographs that would identify an artefact or a document in front of a senator. The secretary will share with you the range of movement that you are entitled to do. Sorry, Senator Rhiannon.

Senator RHIANNON: I want to move on to the issue about independent observers. Can you just briefly, but thoroughly, tell us what the role of the independent observers is, please?

Dr Clegg : We've placed independent observers on vessels because of the footage from the Awassi Express. It raised doubts in our minds: was this just limited to one ship or was it a problem on all ships? So independent observers have been placed on ships to observe the daily care of animals—that they are being fed and watered, that injured animals are being treated, that those animals that need to be put down are put down, that the conditions of the pens are managed, that the plan that the exporter put in place to manage the welfare of the livestock during the voyage is working or isn't working.

Senator RHIANNON: So they've got a big job?

Dr Clegg : They have a reasonable job, but they've got—it's a 26-day voyage—plenty of time.

Senator RHIANNON: They are employees of the department?

Dr Clegg : They are.

Senator RHIANNON: Isn't it more accurate to call them 'department observers'? They are not independent; they are department observers. Isn't that accurate?

Mr M Thompson : I think we've variously called them independent observers, independent departmental observers or vets.

Senator RHIANNON: Considering the loss of trust that there is now with how this is playing out, it would be good to be accurate, because 'independent observer' sounds like it's a communications tool. Anyway, we'll move on. Will the reports and video footage and photographs taken by the departmental observers be made public?

Ms Freeman : At the moment, we've just started—obviously the reports are coming in from our observers—and we are just trying to come up with a framework. We are well aware that the public will be very interested in these reports. We are trying to come up with a sensible way to both look at the information to improve our compliance framework, if you like, but in addition provide information that we know the public will be interested in.

Senator RHIANNON: But, seriously, what's so hard about that, considering again the lack of trust? Wouldn't it be really sensible to just say, 'We will provide the footage that comes back, and they're required to send it back to us every day,' or once a week or whatever your plan is?

Ms Freeman : There are some real mechanics with just the ability to send information from close to the equator at sea, as is the problem with the AAVs that are currently on board some of the vessels. So we are obviously looking at options for technology to provide the information. But it isn't a matter of just hitting 'send' on some video footage.

Senator RHIANNON: When will you make the decision on how you're going to manage that?

Ms Freeman : I'd have to take that under advisement.

Senator RHIANNON: Okay. Is the department observer required to sight and note all mortalities before they're disposed of?

Dr Clegg : No, they're not required to sight and note them, but they are walking around the vessel with the AAV; they are noticing the mortalities; they are checking the shipboard records that come in each day; and they are talking to the AAV and the stockmen and the crew about what's been going on.

Senator RHIANNON: The welfare implications are 24/7. Your department observer will obviously have conditions of work and will need to sleep and eat and will not always be there. Why is there only one department observer to undertake this enormous workload?

Dr Clegg : One of the issues on the ships is the ability to locate the officers, in fact, on the vessel itself. We have room for one. They're not a normal component. We need the AAV to be there, we need the stockmen to be there, and we need all the crew to be there on the livestock vessel. The officers themselves are able to manage their hours and check things as they see fit during their voyage.

Mr Quinlivan : I think it would be worth making the general observation that we're making a transition to—for want of a better word—a more heavy-handed regulation of this trade, and we're trying a whole variety of things, one of which is the observing service that we've just talked about. In the event that we think there would be benefits in two observers or some different kind of observation, we've got the capacity to make that adjustment.

Senator RHIANNON: In regard to the release of information, I understand that there have been some suggested requirements from the exporters that they may not agree to information being released, video footage being uploaded and photographs being sent back because of commercial-in-confidence and privacy reasons. Have those issues been raised with you?

Ms Freeman : Not the specifics of that, but we have actually asked all the exporters, and we've said to them we will be looking to publish information gained by our observers on board vessels and seeking their agreement for us to do that. So we're currently just working through that with each of them now.

Senator RHIANNON: If they start talking about privacy and commercial in confidence, in so many estimates I go to, commercial in confidence is a stonewall. I frankly want an answer. I think it's really important.

Mr M Thompson : That's an issue that we'd have to discuss further with the exporters, but, as Ms Freeman just said, our preference is for that information to be publicly available.

Senator RHIANNON: But you have just said, Mr Thompson, that you will be raising it with the exporters. Does that mean that if they arrive at the meeting and say: 'This is commercial in confidence. The future of our industry depends on it,' you will just say, 'Okay, we can't do it'? How are you going to respond?

Mr M Thompson : It has been raised with the exporters already. That's an issue that we'll have to negotiate with them.

Senator RHIANNON: But I'm actually asking: what is your response to it? Otherwise, it sounds like we could well be back at estimates, and you'll be saying: 'There's no information. They said it's commercial in confidence. We can't ruin this industry.'

Mr M Thompson : As the regulator, we'll have to consider our options. I'm not going to add to that, but we'll have to consider our options.

Senator RHIANNON: So you haven't considered it yet? You haven't got a framework of how you're going to deal—

CHAIR: Senator, Ms Freeman made it quite clear at the start of your questioning that she will take your question under advisement. That says to me that there are considerations that can't happen here at the moment. I imagine there'll be legal considerations and a whole suite of things, so I don't know that the witnesses can add much more to that, other than to indicate to you that their objective is—

Senator RHIANNON: Chair, it was quite a fair question. I was just asking: have you got a framework about how you will judge commercial in confidence? That's a fair question.

Mr Quinlivan : I think it would be fair to say our framework is to achieve as much as transparency as we reasonably can. What that means in practice is something we're testing with the operators at present. But, since the conditions under which each journey is going ahead are not a commercial-in-confidence matter, the experience on the vessel and compliance with those conditions generally should not be either. That's the position we'll be taking into those conversations, but we've got to have them.

Senator RHIANNON: With regard to the department observer on board, what power do they have to compel? What right do they have to enter areas and have access to where they believe they should be able to go? How are you working that out with the exporters? Is there some protocol that can be publicly released?

Dr Clegg : On the work of the independent observers?

Ms Freeman : Their legal powers?

Senator RHIANNON: Yes. When they're on the ship, can they say, 'I need to go onto this deck down in that corner'? Can they go wherever they want to? What's the protocol to allow that?

Mr M Thompson : We'll just ask one of our colleagues to come to the table.

Mr Sanson-Fisher : The independent observer is an authorised officer under the Export Control Act and they're entitled to the run of the vessel effectively, except as otherwise directed by the master.

Senator RHIANNON: Unless directed by the master?

Mr Sanson-Fisher : Yes, the master remains in control of the vessel.

Senator RHIANNON: Therefore, they would have the power to say no?

Mr Sanson-Fisher : Potentially.

Senator RHIANNON: Thank you. It's recently come to light that onboard veterinarians' daily reports and end of voyage reports say that there are breaches of ASEL. So we know that's going on. When only a small percentage of the animals have died and they've been listed as euthanased—I understand, is some of the things that we're hearing about. Considering we are hearing about clear breaches of ASEL, isn't this showing where we could have a continuing problem with how the regulations or the protocols are followed on board these ships post the tragedy that we saw on 60 Minutes?

Ms Freeman : I'll pass to Dr Clegg if she'd like to add any further. But, as Mr Thompson indicated in his opening statement, the reporting requirements in place indicated that the information that we received regarding those voyages was clearly inadequate. So they did technically meet ASEL as it stood in terms of providing those reports, but I think it's very clear that the information provided did not indicate the animal welfare conditions on the voyage were conveying correctly the extent of the problems on the Awassi Express, and I think that's quite clear and those reports were inadequate.

Dr Clegg : They did, though, report that ewes had lambed. They did report things like that. They didn't include things like, 'The horns of the sheep were too long'. Is that the sort of thing you're referring to with the ASEL breaches?

Senator RHIANNON: Can I ask about the ones on this ship, because isn't it the case that the ewes are not supposed to be pregnant when they're on the ship?

Dr Clegg : Pregnant ewes are not supposed to be sent but ewes can be sent. The ewes need to be preg-tested beforehand. The testing arrangements can have a two per cent error rate. So you've got—

Senator RHIANNON: So that's my question. Over a two per cent error rate in terms of the number of lambs that are being born is an example of the conditions breaking, not working; they're breaking the rules.

Dr Clegg : I wouldn't say that the exporters are deliberately putting on sheep that that are going to lamb.

Senator RHIANNON: No, I'm not saying it's deliberate, but they're not following the checks they're supposed to, so the system is not working.

Dr Clegg : No, they've followed the tests. They’ve done the tests. No test is 100 per cent accurate. No blood test you ever have is ever 100 per cent accurate. Nothing that you do like that—ultrasounds that they do, they have an error rate. You'll get a result back for that ewe and it will say it's not pregnant.

Senator RHIANNON: Has the department ever taken regulatory action in regards to any breaches? I think we are all agreeing there have been a number of breaches. Have you taken any action over the breaches?

Dr Clegg : On this particular voyage or on any voyage?

Senator RHIANNON: Generally.

Dr Clegg : Generally speaking, with pregnancies, unless there's been a huge number of animals that have been found to be pregnant, no, we haven't done that because of the error rate that exists.

Senator RHIANNON: But generally. With all these breaches, can you give us any examples of where you have actually followed through?

CHAIR interjecting

Senator RHIANNON: I'm just finishing off that question.

CHAIR: No, I indicated—and everyone does this to me and I've got low tolerance. Is this your last question?

Senator RHIANNON: It's my last question. I'm just trying to get this question answered, but with all due respect, Chair, you've also had a good run, so let's be fair.

CHAIR: I'll tell you what, why don't you take on the chair's role and you can have a good run too. This is your last question.

Senator RHIANNON: Let's be fair. It is and I'm just trying to get it answered in a general way, not just about ewes.

CHAIR: Well, just ask the question for Jiminy Cricket's sake.

Dr Clegg : Senator, yes. When we see animals being prepared that don't meet the requirements, they're rejected from the consignment and they're usually rejected because they don't meet the ASEL standards—their horns are too long, the wool length is too long that, that sort of issue. They're not as described. We've had cattle that were to be exported to China a few years ago that were described as 'thin with a summer coat' that were actually quite fat with a winter coat. So, yes.

Senator RHIANNON: The question was 'Has the department ever taken regulatory action?'

Dr Clegg : Yes.

Senator RHIANNON: Yes?

CHAIR: Officials, do not answer the question. That's it. I'm not going to tolerate this. Senator Hinch, you have the call.

Senator HINCH: I have one question for Senator Ruston. We know that the McCarthy review recommended reducing stocking density et cetera, but I'm wondering why the government has looked at the Australian Veterinary Association's Dr Parker, who said:

Irrespective of space allocation, thermoregulatory physiology indicates that sheep on live export voyages to the Middle East during May to October will remain susceptible to heat stress and die due to the expected extreme climatic conditions.

And they say—

CHAIR: Senator, I indicated at the outset that we had set a framework for this and we'd sent the message through. It was clear that questions asked and answered won't be followed up again. That question's been asked and thoroughly answered.

Senator HINCH: I'm entitled to ask it. I'm sorry I missed that. If you're one senator, you can't be in every room, every day, at every time.

CHAIR: I appreciate that, but put yourself in our experience. In five minutes another one will come and take up 15 minutes on the question, and another and another.

Senator RHIANNON: Chair, he's got a right to ask his question.

CHAIR: The answer is on the Hansard. Senator Hinch, if you've got some follow-up questions—

Senator RHIANNON: He can ask what he likes.

Proceedings suspended from 17:10 to 17:22

CHAIR: We will now resume. Senator Hinch has yielded five minutes to Senator Rhiannon.

Senator RHIANNON: Mr Thompson, how many export permits for live sheep exports have been granted since the 60 Minutes story and the receipt of video files from Animals Australia went to your office?

Mr M Thompson : I might ask my colleague Ms Freeman to answer that.

Ms Freeman : Are you after since 8 April? Would that be correct?

Senator RHIANNON: Yes; good.

Ms Freeman : We've had seven, by my calculations.

Senator RHIANNON: For those seven, can you explain what additional conditions, if any, were placed on these exports?

Ms Freeman : A range of conditions have been applied. They've included an independent observer, reduced stocking densities that have been applied—

Senator RHIANNON: Is that the 17.5 per cent increase in space? Is that the one you're referring to?

Ms Freeman : For the most part yes, that's been correct. I think we've had one or two voyages where that amount has been 15 per cent that have actually been travelling to areas that have slightly cooler weather—through the Red Sea.

Senator RHIANNON: Has there been anything apart from the department observers and the extra space?

Ms Freeman : Kuwait has been the first port in some cases. We've also had cases where—and Dr Clegg can correct me—when we've calculated the stocking density we have also added that it will be the weight of the animal at the time of arriving in the port as opposed to when they embark on the voyage. Basically animals will gain weight for the most part over the life of the voyage. So, when you're actually weighing the animals and weighing what the stocking density would be, an allowance is made for a bigger animal needing more space, which will effectively reduce the stocking density.

Senator RHIANNON: I was actually interested in how the 17.5 per cent figure was arrived at. Can you explain that, please?

Dr Clegg : The 17½ per cent figure was arrived at after the footage appeared on the network. The average increase we have normally applied to sheep export voyages after a mortality event has been in the order of 10 per cent. In some instances we've applied 15 per cent. Because of the severity of the symptoms that were shown on that ship we asked for more than 15 and arrived at 17½ per cent.

Senator RHIANNON: So, it wasn't so much on any scientific basis—

Dr Clegg : No.

Senator RHIANNON: but that it was so terrible. Okay. Thanks very much. Can you advise on how the new information in the form of the 395 video files was taken into account in assessing whether the travel arrangements were adequate for the animals' welfare? Is that what you're referring to—you saw all the terrible footage and then you went for 17.5?

Dr Clegg : Yes, we saw the footage and did a number of things. One was to apply a reduced stocking density on voyages for that exporter on other vessels that contain sheep. The other thing that we did was to put the observer on the vessel and ask for photos and videos to be taken.

Senator RHIANNON: I want to ask about the McCarthy review and one of its recommendations, particularly in light of the Australian Veterinary Association submission. They made a submission to the review. Their submission talks about the thermoregulatory physiology of sheep and how that indicates that sheep on live export voyages to the Middle East from May to October remain susceptible to heat stress and death. I'm sure you're aware of that. The AVA recommend that sheep should not be on voyages in those months from May to October. My question is: Dr McCarthy did not recommend any suspension during this period, and the department supports his recommendation. Can you help me reconcile the reason for the different conclusions here? Did Dr McCarthy make any new discoveries about the physiology of sheep that the AVA has missed? There is clearly a disjunct here.

Dr Clegg : I'd say that it's a difference between different scientists and opinions. The heat stress risk assessment model takes into account the weather in the countries of destination. By making sure that the ventilation on the vessels is compliant with the model, that it is delivering the ventilation that the shipowner claims it is, and by ensuring that the stocking densities are well managed, the heat stress risk assessment model should work. I do understand the AVA's point that there is always going to be a temperature at which sheep can't thermoregulate. But to suspend the entire trade from May to October on the probability of some sheep dying on some voyages is quite a step. Therefore part of the actions of the department are to review the conclusion that Dr McCarthy has come to with his risk assessment level. Implementing his proposal of a 75 per cent—I don't want to say it's a threshold, before death—but he has asked that the heat stress risk assessment be based on the probability of animals experiencing heat stress. That is a very, very significant reduction in the number of sheep that could be exported, which would lead to the closure of the trade in the summer months, and that isn't what he ended up recommending. He didn't recommend that.


CHAIR: Just before we move on: Senator Rhiannon, I've spoken to the deputy and we've consulted our colleagues, and no-one else has anything for LiveCorp. So what we're prepared to do is bring them on now and you'll have the unlimited time you need to exhaust yourself with LiveCorp in an effort to treat them in the same way that we treated Animals Australia and let them go. Can I have them back to the table, please?

Senator RHIANNON: As I said, I have a number of questions about the issue, but I don't know if they're to LiveCorp. They will be handled by the department, so I can't make that call.

CHAIR: Senator, that would be true of a whole string of witnesses we've had over the last two days. It's not right to keep them here. There hasn't been a question to them for over an hour—or I think there was one. So we're going to handle it this way. You've got an unlimited period of time. You can explore whatever you want, for hours if you want to.

Senator RHIANNON: I want to be fair to everybody. I'm quite happy to come back after dinner—when I thought I would be coming back—and go with the department. If I can't go with the department and they say that I've got to go to the witnesses who have gone—

CHAIR: No. I've just made a ruling. Can LiveCorp can come back to table? You can stay with them for hours until you exhaust your interest in whatever it is that the witnesses have to provide. We can't have contingency—

Senator RHIANNON: I'll say that I have no questions for them, because most of my questions, I am sure, are for the department, and I can put questions on notice to them any time.

CHAIR: Thank you very much. 


Biosecurity import levy & Invasive ants

Proceedings suspended from 18:30 to 19:29

CHAIR: We will resume the 2018-19 budget estimates of the Senate Rural and Regional Affairs and Transport Legislation Committee.

Senator RHIANNON: I want to ask some questions about the biosecurity import levy. The budget outlines that $360 million will be collected by the new biosecurity import levy. I just want a breakdown and an understanding of how it works. Could you specify how much of the biosecurity import levy will be spent on environmental national biosecurity?

Ms O'Connell : The biosecurity levy was a suggestion made in the quite comprehensive review of the biosecurity system which was published in the middle of last year. It was announced by the government as part of the budget. The levy won't come into place until the middle of next year, 2019. In terms of what it will raise, there's an estimate of $325 million.

Senator RHIANNON: Did you say $325 million? I thought it was $360 million.

Ms O'Connell : It depends on whether it's the cash treatment or different treatments of it. We've been sticking with the number of $325 million that appears in the paper. We can explain the difference between $325 million and $360 million.

Senator RHIANNON: Considering the time, I'll accept what you're saying. I am interested in how it will be spent.

Ms O'Connell : The government's already made some decisions in this budget on how the funding will be spent. There were announcements in this budget of $121.6 million on biosecurity-related measures. As I said, the levy doesn't come in until 2019 so there's potential for further decisions of government to be made. We can take you through the breakdown of the $121.6 million in the budget for biosecurity, if that assists.

Senator RHIANNON: Yes.

Ms O'Connell : I'll ask Mr Koval to go through that.

Senator RHIANNON: I am particularly interested in how much is going to be spent on national monitoring and surveillance.

Ms O'Connell : There are measures that go exactly with that.

Senator RHIANNON: So you've got line items for that?

Ms O'Connell : Yes.

Mr Koval : As Ms O'Connell said, the biosecurity import levy was a response to the review into the priorities of the biosecurity system. The government made some announcements in the budget of additional biosecurity measures. There was $51.5 million announced for priority pests and diseases; this is looking at national action plans for priority pests and diseases, and maintaining and improving diagnostic capacity for pests and diseases which has an impact irrespective of whether it's environmental or production based. It's for all pests and diseases that we are concerned about. There's $27.8 million for assurance and verification; this is making sure our systems are working. The measures are treating the pests and diseases of concern, and we can be satisfied that biosecurity is effective and efficient.

There's $7.5 million for seamless border clearance, which is about looking for new technology to make the border work smarter—for example, new X-ray technology—so we can get a better understanding of what's coming through in a faster environment. In addition, there are a couple of other measures that were announced in the budget. There is $14.8 million for international ports, for dealing with increased people traffic through airports and sea ports, and there is some money for fruit fly in Tasmania.

As Ms O'Connell said, there are a number of environmental recommendations in the IGAD report. Some of those have already started. For example, we have already started work on a priority list for environmental pests and diseases. We've had the first workshop, and the second workshop will be in June, about how we build that priority list of environmental pests.

Senator RHIANNON: My next questions were going to be about the priority pest-and-disease planning and response, which has $51.5 million allocated over four years. Is that different from what you referred to?

Ms O'Connell : That's one of the measures that Mr Koval outlined. That is a key feature, in terms of the budget measures. This links back to the review report. The review report recommended that for priority pests and diseases we have a comprehensive action plan ready to go. Part of this funding is to build the comprehensive action plan for the priority pests and diseases.

Senator RHIANNON: How will the priorities for this spending be determined?

Ms O'Connell : Within the priority pest-and-disease planning? There will be several things that are done as part of it. There's developing and implementing the national action plans for priority pests and diseases. That will be focused on the high priority pests and diseases. There's offshore intelligence gathering that we'll be doing as part of that, and surveillance and capacity building in neighbouring countries as part of prevention measures, and building on previous investments in that area that we've made that have paid considerable dividends. We'll also be increasing our response capacity under our current Biosecurity Act and maintaining and improving our diagnostic capability. We've seen quite an increased demand for diagnostic capability across the biosecurity network so that we can diagnose pests and diseases much more rapidly.

They're some of the things. One of the smaller measures, as part of it, is to meet our obligations under the Australian foot-and-mouth disease vaccine bank for the next few years. So there are a range of things within that $51.5 million for priority pest-and-disease planning.

Senator RHIANNON: Maybe you don't have it divided up this way, but I was interested in what the allocation was for the agricultural sector.

Ms O'Connell : We divide things into pests and diseases. Our concern is pests and diseases.

Senator RHIANNON: So you make an assessment of the level of threat from a certain pest and then you're looking at it across the board. Is that a fair assessment?

Ms O'Connell : I think that's a reasonable assessment of it. It's focused on the pests and diseases.

Senator RHIANNON: Not the sectors.

Ms O'Connell : Not necessarily the sectors. The sectors have a part to play in it because, if you're going to do a cost benefit, you'll look across the various sectors—environmental, whether it goes to our way of life, production et cetera. All of those make a contribution when you're doing a cost benefit. Taking something on the plant side, our No. 1 plant pest disease is Xylella and that has a major impact, including environmental. We do it by pests and diseases because there's no point in planning for a disease only for production or only for environment. It's the disease—a bit like myrtle rust.

Senator RHIANNON: Totally. I can understand that. I want to ask about the recommendation of a senior expert position of chief community and environmental biosecurity officer, that this be established in the environment department. When will the office be established? It appears there are some delays in establishing. Could you explain that, please?

Ms O'Connell : Not so much delays in establishing. This report that has that recommendation was considered by ministers mid-last year as a draft. They put the report out, agreeing to make it public, mid-last year with the view of offering opportunities for people to comment. We've had, certainly, some extensive consultation—Mr Koval might talk to that—on the recommendations not just within governments but also with states and territories who are a key contributor to the biosecurity system, and, much more broadly than that, including NGOs and environmental et cetera.

So there's been a lot of consultation and feedback on how these recommendations should be implemented. Mr Koval outlined that some of the things immediately within our gift we've gotten on and done. Some of those are in progress. If you want, I can mention a few of those that relate to environmental biosecurity—

Senator RHIANNON: Is it going to be established in the Department of Environment and Energy?

Ms O'Connell : The decision as to where it will be established is yet to be taken.

Senator RHIANNON: When will it be made?

Ms O'Connell : I can't tell you when it will be made but it will be made soon.

Senator RHIANNON: Who makes the decision?

Ms O'Connell : It's essentially a decision for government to make about how it wants to do it.

Senator RHIANNON: At cabinet level, is it?

Ms O'Connell : I'm not going to talk about how government makes the decisions to do it.

Senator RHIANNON: I'm just trying to work out the process. It seems a fair enough question.

Ms O'Connell : Potentially, yes.

Senator RHIANNON: I love that word 'potentially'. So is it at cabinet level?

Ms O'Connell : It's a decision for government to make.

Mr Quinlivan : We've got a number of things that need to be settled by an expenditure review committee as part of the normal budgeting process, and it's most likely going to be one of those decisions.

Senator RHIANNON: The budget allocation has been made, hasn't it?

Mr Quinlivan : That will be part of the decision-making.

Senator RHIANNON: I wanted to ask about invasive ant specialists. I understand that they met in Queensland back in 2016 and they've got a plan. When's the plan going to be finalised?

Ms O'Connell : I think there are two things here, and just want to be clear. We've got a eradication plan for the red imported fire ant in Queensland, and that's a significant response and eradication plan. There's also a broader plan around ants in general and an approach to be taken with exotic ants. So I just want to be—

Senator RHIANNON: I am interested in the yellow crazy ant—an incredible name. So the wider—

Ms O'Connell : The wider plan for what we call tramp ants?

Senator RHIANNON: Yes. I was actually interested in when the plan will be finalised.

Ms O'Connell : If it's specifically yellow crazy ants—

Senator RHIANNON: Yes.

Ms O'Connell : There's funding given to the Department of the Environment and Energy to deal with yellow crazy ants in the Wet Tropics. If that's specifically what you want to talk about, it's the department of the environment who is funded to deal with the yellow crazy ant.

Senator RHIANNON: So that's not you?

Ms O'Connell : No. We have the eradication of the red imported fire ants. We're also looking at tramp ants more generally and what can be done in relation to exotic ants, which we're happy to talk about. But, if you specifically want to talk about the funding that the government has provided for the eradication of yellow crazy ants, that's the—

Senator RHIANNON: What about the red fire ant?

Ms O'Connell : That's us. We're very heavily involved in the red imported fire ants eradication plan. It is one of Australia's largest eradication efforts ever that has ever commenced on eradicating the red imported fire ants.

Senator RHIANNON: When will the plan be finalised to get rid of the red fire ant?

Ms O'Connell : There is a plan underway. There is a group that is doing it. All governments have contributed to the eradication effort and it's underway.

Senator RHIANNON: How much has the federal government contributed?

Ms O'Connell : It's a contribution over 10 years.

Mr Koval : The Australian government contributed 50 per cent of the total of the red imported fire ant eradication program in South-East Queensland. In real terms, if you take inflation and everything else, it's just over $202 million.

Ms O'Connell : So in the order of $200 million over 10 years. This is to deal with the incursion of red imported fire ants in South-East Queensland. That incursion has been around for a long time—15 or 20 years. I was going to say a couple of decades. One of the enduring lessons about biosecurity is that when there's an incursion it's always a lot cheaper to go in very quickly and attempt immediate eradication rather than allow it to become established. It has become established in that area in South-East Queensland—hence the huge cost to eradicate it. We have had more recent incursions of red imported fire ants recently, within the last 12 months or so, in Port Botany—a single instance. But, jumping on it quickly, it cost $1 million to get rid of and deal with. That's why surveillance, detection and all those things are really important, because if you can get to it earlier it's going to cost you a heck of a lot less than if it becomes established.

Senator RHIANNON: Just out of my own interest, did it come in in a container?

Ms O'Connell : The recent one in Port Botany, yes, on a container. And that's relatively common for red imported fire ants and a number of other exotics—we call them hitchhikers, because they hitchhike on the containers. There are a number of things that come in on containers that are of concern, but the sooner we can detect it through surveillance, eradicate and get onto it, the better, because it's a lot cheaper than if they're allowed to establish, which is what did happen here.


McCarthy Review

Senator RHIANNON: The minister stated that it would implement all of the recommendations from the McCarthy review. I want to explore one of those to understand how this is going to play out. Dr McCarthy recommended changes to the HotStuff heat stress risk assessment. I understand that was to ensure it was based on animal welfare rather than mortality. We've had some discussion about that. This is where I get into the figures. He recommended a change from a two per cent probability of five per cent mortality to a two per cent probability of five per cent heat stress score 3. Does the department plan on making those changes?

Mr M Thompson : Could you take us to which recommendation you're referring to there?

Senator RHIANNON: Recommendations four and five deal with the heat issue. There's the query about what you're doing.

Mr M Thompson : The department's response to that—and I think the minister has made comments to this effect as well—is that we support those recommendations, subject to testing and consultation. That goes to the comments that we've made a number of times about doing some further work and seeking some further views from a range of stakeholders on those recommendations and how we could implement them, their veracity and whether there are other ways to achieve that outcome.

Senator RHIANNON: When you say it is subject to testing and consultation, these days those words ring alarm bells. We need to explore it more at this late hour because of everything that's gone down. I did note that the McCarthy review stated that these changes to the heat stress risk assessment could occur—and these are the words in the review—'reasonably quickly and should be operational for this northern hemisphere summer or at a minimum by 1 July 2018.' Reasonably quickly—that's clear language. Your view that it is subject to testing and consultation could be described as kicking it into the long grass, but I hope I'm wrong. The department has responded to this recommendation. I understand you've also said that it will undertake further consultation and testing on the proposed model over the next three months. Is that accurate—over the next three months?

Mr Quinlivan : That's our plan. I think I said earlier today that we were expecting to discuss that process with the minister next week. We were not able to do that this week because our paths didn't cross, but it would be a priority for next week.

Senator RHIANNON: Is it accurate to say that what you mean by that is you're suggesting a process over three months, but you'll take that to the minister and see if he approves?

Mr Quinlivan : I'll discuss with him next week what process we'll follow. We might ask for comment on these particular recommendations, and the analysis supporting them, in the McCarthy report with some questions of our own and have a public consultation process on that. I mentioned earlier that the intention was that, after that process, we would need to form a view on our preferred heat stress model and do a regulation impact statement on that and then it would be adopted.

Senator RHIANNON: So do I take from that answer that it could be three months, longer than three months or shorter than three months depending on your meeting with the minister? Is that fair?

Mr Quinlivan : There's the discussion with the minister and also our own scope thinking on how long we think it needs to take. Any process that involves a public consultation is six weeks or two months before you do any work. So it certainly won't be done in less than three months. That would not be possible.

Senator RHIANNON: So it could be three months, or it could be more than three months?

Mr Quinlivan : Yes, but hopefully not too much longer than that.

Senator RHIANNON: Why does the department believe that this further delay is necessary, when Dr McCarthy believed quite clearly that this could be implemented reasonably quickly and before 1 July this year?

Mr Quinlivan : Because we felt that the implications of immediate acceptance of these particular recommendations were so significant it would be unreasonable for us as a regulator to adopt them without giving all of the affected parties, interest groups and so on an opportunity to have a say about them before we made a decision.

Senator RHIANNON: Therefore, when it's been reported that the minister wants these recommendations fully implemented, that may not be correct?

Mr Quinlivan : I think he was saying that he wants a strong heat stress risk assessment model implemented. He also—I think in his press release, although I don't have it in front of me—talked about further work to be done on that. I think he was clearly referencing the need to work out how that was going to be done in practice. What we're now talking about is the process that will resolve that question of what we're actually going to do in practice. Dr McCarthy's work generally was quite scientifically robust and has been supported by the community of people who have expertise in this area. But his panting score model and so on is new and has not been discussed with many of the interested parties, so we felt it was necessary to have a broader discussion with that.

Senator RHIANNON: I missed that bit. Which did you say hadn't been discussed much?

Mr Quinlivan : His panting score model. I'll get one of the people with more expertise than me to take you through it. But it's a crucial part of his heat stress model. It hasn't really been very widely discussed. I'm not saying there's anything wrong with it.

Senator RHIANNON: Is this about the formula?

Mr Quinlivan : No, it's the actual decision-making model.

Ms Freeman : It's basically the significance of shifting to a model that assesses risk on heat stress rather than mortality. That's actually a very big deal. How you might do that is very important. In the short time Dr McCarthy had, he didn't have time to consult and test his analysis. What Mr Quinlivan has been talking about is us developing an arrangement to do just that. I'll pass to Dr Clegg, and she can talk about what that actually means in reality about what he was trying to measure.

Dr Clegg : On page 19 of his report, he has provided an amalgamation of heat stress indicators so that there's a more systematic way of assessing the heat stress that sheep might be suffering from and relating it to a panting score. The current ASEL has just three standards. Dr McCarthy was pointing out that it needed to be standardised across all exporters, rather than exporters—or vets in particular—each having their own individual way of providing that assessment. They also did that for heat stress. Some AAVs use their own method for describing the level of heat stress. In the interests of having more consistent data and assessing the problem more reliably, I guess, he has developed this amalgamation table. Our intention is to implement that now, but it will also be something that the ASEL committee will discuss in its review. Again, that will give it greater airing amongst relevant experts.

The department is implementing recommendations 1 and 2 straightaway. I think recommendations 3, 4 and 5 are all about the heat stress risk assessment modification, which we're putting out for greater consultation. Recommendation 6 is the panting score table, which we are going to implement. Recommendations 7 and 8 are about a future model of the risk assessment. That's for 2019, so that's okay. The pen air turnover recommendations—Nos 9, 10 and 11—are all going to be implemented now. We're organising with both the Australian Maritime Safety Authority and LiveCorp, which was the research industry R&D body, to work out how to audit the ships and provide the verified information on these PAT scores through to the model developer.

Recommendation 12 was on the curfew adjustments for stocking density. We're developing an order to implement that. Recommendation 13 was about compliant loading of animals and we're also working on that now. Dr McCarthy recommended that the weight of animals be standardised a little bit better than we are doing. Some animals may be curfewed; some may not. If animals are curfewed—that is, they haven't had food and water for, say, 12 hours—they'll obviously be lighter than if they had been fed and watered. So he wants an account made of that so that into the heat stress model goes the actual weight of the animal to try to avoid any underallocation of space.

We're implementing recommendation 14. That's the observation that he makes that sawdust, while not essential for all voyages, should be a component in all sheep export consignments so that if the sheep pad on which the animals are lying becomes too wet there are ways of addressing it through the application of sawdust should it be required. Recommendation 15 is about future research. Recommendation 16 is also something that we will refer to the Australian Standards for the Export of Livestock review, the ASEL review. Recommendation 17 is about animal carcasses. We've been in contact with AMSA about those particular recommendations. Recommendation 18 is on dropping the reportable level from two per cent to one per cent. We're doing that straightaway. Recommendation 19, which is about daily reporting, we're implementing. That links into recommendation 6 and that table. Those two go together.

Recommendation 20 is on automated watering systems. The Awassi Express was a sheep carrier that actually didn't have automatic watering on four or six of its decks that were only for sheep. It had automatic watering for cattle but not for sheep. That's actually been addressed now and we're making it a requirement in our new legislation that exporters can only use export vessels that have automatic watering if they're going to travel to the Middle East. Recommendation 21 we're implementing straight away—to improve the information in exporters' heat stress management plans. Recommendation 22 we've been carrying out ever since the footage went to air, which is to make Kuwait the first destination point if ships are travelling to the Gulf and Kuwait is a destination port on that voyage.

Recommendation 23 is something a little bit for the future and it involves the Australian Maritime Safety Authority. Dr McCarthy notes himself that, by 2019, there should be automated continuous environmental monitoring equipment installed. We don't have any objection to that. So we're doing what we can, as soon as we can—apart from the ones that require consultation or are set for the future.

Senator RHIANNON: It's recommendations 4, 5 and 6—the ones about the heat stress—that are the controversial ones.

Dr Clegg : It's 3, 4 and 5, I think. No. 6 we can do because that's that table.

Senator RHIANNON: Thank you. Sorry about that. With regard to that, in some of the reports it has been suggested—I think the minister might have said this, too—that the model could result in stocking density reductions of up to 79 per cent. That's a reduction of 79 per cent for high-risk voyages. Isn't that where the controversy lies, because a reduction to that level would make it uneconomical? That's why there's growing concern and that is in fact why you're hesitant on these recommendations.

Ms Freeman : I suspect that it would be a reduction of a far lower number than 79 per cent that would have an impact—but that is not a matter for us. The point is, I think, to reiterate what Mr Quinlivan said, that it's actually an untested approach. The reality is that it actually would reduce the numbers by a very significant amount and that needs to be tested.

Senator RHIANNON: So are you—

CHAIR: Thank you, Senator. That's your time. 


CHAIR: Chair? No. Senator Rhiannon?

Senator RHIANNON: Just to finish off on where we were at, are you aware that the RSPCA, in commenting on recommendations 3 to 5 and the delay that's now occurring, stated: 'This is a deliberate delaying tactic that is legally questionable and will result in further animals suffering heat stress that would otherwise be avoided with the timely implementation of the revised HSRA.' Are you aware of that statement, and what's your interpretation when they say it's 'legally questionable'?

Mr Quinlivan : I wasn't aware of that specific statement but I think, with our plan to consult further on the development of a new management model with some quite innovative ideas in it, with far-reaching implications, our approach is at least partly informed by our legal obligations, as a regulator, to be reasonable—to give people a chance to have a say before we make decisions that have major implications for them. I haven't seen, obviously, the legal advice that the RSPCA has but I can say that our own planned handling of this, at least in part, is based on us thinking about our legal obligations as a regulator.

Senator RHIANNON: I asked you before about the process—because you had said three months but then you explained it could be more than three months. When will we know what that process is? I think you said you're about to meet with the minister?

Mr Quinlivan : We're hoping to settle it with him next week. We want to make a quick start on it, so I would hope—

Senator RHIANNON: So you'll possibly be making an announcement at the end of next week?

Mr Quinlivan : As soon as we can. I won't put a particular time frame on it, but we want to start as quickly as possible. We'll need to announce it, obviously, to commence the process with something specific for people to respond to. So it will be as soon as possible.

Senator RHIANNON: Thank you. I want to go back to something that was said before dinner. One of you gave evidence that the formula and the software had been independently peer reviewed.

Mr Quinlivan : I think that was a statement by LiveCorp, talking about the HotStuff model.

Senator RHIANNON: Yes. The information that I've gained over dinner is that in fact it has not been independently peer reviewed. If you're saying that it has been, can you provide the evidence please.

Mr Quinlivan : I think we're saying that it was LiveCorp.

Senator RHIANNON: You're saying that has to go to LiveCorp?

Mr Quinlivan : Yes. We'll take that on notice. I would be very surprised if what they said wasn't factually correct, because that model has been used. It's quite important for the decision-making. It has been controversial. So I would be very surprised if they had made a mistake along those lines, but we will make sure they answer that on notice.

Senator RHIANNON: In taking that on notice, can you ask them to provide who peer reviewed it and what their professional standing is.

Mr Quinlivan : We will do that.

Senator RHIANNON: Is it the case that HotStuff is commercial-in-confidence, so we can't actually see it? Is that the case, or can it be released so that we actually know what this algorithm is?

Dr Clegg : It's intellectual property that's owned by LiveCorp but it contains data within it that is about individual ships and shipping companies. I think that's the commercial-in-confidence information.

Senator RHIANNON: That is pretty extraordinary, because it means our regulatory framework depends on an algorithm that cannot be released. So we can't have any scrutiny with—

Mr Quinlivan : I think the point being made there is that it's not so much the algorithm but the data that is sensitive.

Dr Clegg : One of the pieces of information that's within the model is the details of ventilation per deck. Each deck has a different pen area turnover rate. The pen area turnover of the decks will depend on how many animals can be carried on that ship at particular times of the year and whether they're cattle or sheep. That's information that the shipowners provide to the people who hire them. They don't make it available generally.

Mr Quinlivan : Having said that, I do think you're on to a legitimate point here.

Dr Clegg : Yes.

Mr Quinlivan : We have been asking ourselves whether the arrangements for access to the model and the public transparency of the use of the model and its products is sufficient. I think you've identified a genuine issue there. That's definitely on our to-do list.

Senator RHIANNON: It would certainly help us at least get to the foundation of building some trust around this issue. Sometimes I do understand why departments come up with commercial in confidence, but in this case I really can't understand it. We're talking about boats, sheep on a deck et cetera. So you're saying that it's the data and not the actual algorithm that's the issue of why—

Mr Quinlivan : Yes. It's like having an architect's drawing of your boat, effectively.

Senator RHIANNON: Right. I see.

Mr Quinlivan : We take your general point. We are definitely going to look at this because we have our own concerns about it.

Mr M Thompson : In that context, Dr McCarthy recommends that we get independent verification of the pen air turnover and in response to the McCarthy review that's something that we will be following up.

Senator RHIANNON: When you say you are 'following up' on both those issues, is this something you'll follow up and then there will be public engagement like how you're consulting on the other issues that we just discussed? Is this part of what you're talking about?

Mr M Thompson : On the one I just mentioned, we hope to do that in condition-setting for vessels from now on. It's something that we will look to do.

Ms Freeman : I would also add that we've already started talking to both AMSA and LiveCorp and, for want of a better way of describing it, the person who drives the model and getting all the parties together to look at the data, what information we need, what needs to be verified and by whom. That goes to how the model is actually constructed—

Dr Clegg : And confidence in the model.

Ms Freeman : Yes.

Dr Clegg : So the data at least that's entered into it has been audited and is correct. It's checking that the fan rate, for instance, is actually producing the output that the fan manufacturer says it is. It's not just, 'I put this in 20 years ago or 10 years ago and that's the fan rating and therefore that's my PAT.' It's not as simple as that, but knowing what the ratings and structures are the within the ship are critical to working out how much air flow sheep actually get in their pens.

Ms Freeman : We've already commenced that.

Senator RHIANNON: When you say you're consulting with parties, is that just industry representatives or does it include the animal groups as well?

Mr M Thompson : If you're talking about the consultation we plan to run on the heat stress risk assessment and management elements of the McCarthy review, it won't just be with industry; it will be with a wider set of stakeholders.

Dr Clegg : On the PAT itself, that will be with the parties that have the information.

Mr M Thompson : That's a specific technical issue.

Dr Clegg : So with the model owner, the ships are—

Senator RHIANNON: So it's secret? It's not public?

Mr M Thompson : It's not that it's secret—that's the bit that's kind of touching on what could be commercial-in-confidence information. What we're seeking to do, consistent with Dr McCarthy's recommendations, is to have an independent verification of the data that they're providing into the model. That's one bit. Then, in terms of the wider set of issues in recommendations 3 to 5, 7 and 8 that we're consulting further on, that will be an open process.



Senator RHIANNON: Thanks very much. I'll move on to greyhounds now.

CHAIR: Senator, your time has nearly expired. You want to start a new topic?

Senator RHIANNON: So everybody doesn't have to get up and down, maybe I'll wait until I come round again.

CHAIR: If everyone takes their time, you won't come around again. So, if you have something that's really occupying you, I'll allow you a bit more time.

Senator RHIANNON: Thank you very much. On greyhounds, how many export permits have been granted outside of the Greyhounds Australasia passport scheme?

Dr Clegg : We don't take into account Greyhounds Australasia's passport scheme. We issue permits based on the Export Control (Animals) Order. The Greyhound passport scheme is not part of our issue of permits.

Senator RHIANNON: I was asking how many export permits had been granted outside, separate from the Greyhounds Australasia's passport scheme.

Dr Clegg : They're all outside.

Senator RHIANNON: They're all outside?

Dr Clegg : Yes.

Senator RHIANNON: So you don't have anything to do with Greyhounds Australasia?

Dr Clegg : No.

Senator RHIANNON: Is the government aware of how many dogs have been exported illegally so far this year?

Dr Clegg : I don't have any information about the number of dogs that have been illegally exported.

Senator RHIANNON: So you are not able to track that, or you don't get reports after the fact or anything?

Dr Clegg : No. We have details of what we have issued permits for but not what we haven't.

Senator RHIANNON: How many have you issued?

Ms Freeman : I can answer that. From 1 January 2017 to 31 March 2018, there were 333 greyhounds, of which 88 per cent of those went to New Zealand.

Dr Clegg : That's 293 dogs.

Senator RHIANNON: Do you have any activities, tracking these periodic reports of greyhounds being illegally sent over to Macau or wherever?

Ms Freeman : I think once dogs get exported it comes under the jurisdiction of the importing country.

Senator RHIANNON: But for a while they are in Australia—so no information?

Dr Clegg : No.

Senator RHIANNON: How many greyhounds have been exported to New Zealand? I think you've answered that—88 per cent of 333.

Dr Clegg : Yes, 293 dogs out of 333.

Senator RHIANNON: How many greyhounds have been imported from New Zealand?

Dr Clegg : I don't know, because I don't do imports. I'll have to take that on notice.

Senator RHIANNON: Separately, how many have been imported to Australia via New Zealand from a third country?

Dr Clegg : How many imported into Australia?

Senator RHIANNON: Yes, imported from New Zealand but they're coming from a third country, via New Zealand.

Mr Quinlivan : We'll take that on notice.

Senator RHIANNON: Do you have any concerns about that—that there are possible channels where dogs are being brought into Australia representative that they're coming from New Zealand when in fact they're not? Is that something that's been flagged with you?

Dr Clegg : I have confidence about New Zealand. New Zealand is one of our close trading partners, and I would have confidence in New Zealand's quarantine system.



Senator RHIANNON: Okay. I'll now turn to donkeys. Can you confirm that the federal government will not support the live export of donkeys from Australia to supply the—and I can't pronounce the word—ejiao trade?

Dr Clegg : I don't know how to pronounce it, but I think it is the donkey skin product trade.

Senator RHIANNON: Yes. There is a gelatine that comes off the skin that is now becoming a booming trade.

CHAIR: Senator Rhiannon, I am sorry, but we'll have to leave it at that.

Senator RHIANNON: I will leave that one and come back to it.


Dr Clegg : We haven't had any requests to export donkeys for slaughter purposes, which is what they'd have to be for the ejiao trade. I think we've had something like 14 donkeys exported in the last year, from memory. I can give you the exact numbers of that. But they are very small numbers. There's been no confirmed interest in it. There were some requests a couple of years ago, but there was also an enormous amount of public outcry over the idea of exporting donkeys for slaughter. Since then, we've had nothing. Nor do we have any conditions.

Senator RHIANNON: If there were a request, would it be turned down? Are we at the point that it's not going to be a yes?

Mr M Thompson : That's really a policy question, I think.

Ms Freeman : There's currently no government policy about extending ESCAS to equines as part of that. But Dr Clegg is absolutely right: we haven't had a request to do so.

Senator RHIANNON: How many donkeys are being sourced from the wild for slaughter in federally approved abattoirs? Can you answer that or take it on notice?

Mr Cunningham : In relation to the question of how many donkeys have been processed in export-registered establishments, there have been approximately 1,250 in the last 12 months.

Senator RHIANNON: So they've been processed at abattoirs in the Northern Territory, in the main?

Ms Cooper : There are three abattoirs in Australia that are approved to slaughter donkeys for human consumption.

Senator RHIANNON: Where are they?

Ms Cooper : There is one in South Australia, one in Queensland and one in the Northern Territory.

Senator RHIANNON: Are the donkey parts for export?

Ms Cooper : The donkey is processed for export, correct, but I understand some of it does go to the domestic market.

Senator RHIANNON: And, for the export, is that part of the ejiao trade?

Ms Cooper : That is something that seems to be unique to the Chinese market and, at this stage, we don't have access for donkey to China.

Senator RHIANNON: They're not going to China; therefore, they may not be part of the ejiao trade. But we're not absolutely sure.

Ms Cooper : Correct.

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