ANNEX 3
INVESTIGATION REPORT INTO ALLEGED NON-COMPLIANCE WITH
ESCAS ANIMAL WELFARE PERFORMANCE MEASURES AND TARGETS:
NORTH AUSTRALIAN CATTLE COMPANY PTY LTD AT ABATTOIR 3
SUMMARY
Abattoir 3 slaughters only cattle from North Australian Cattle Company (NACC)’s approved
Exporter Supply Chain Assurance System (ESCAS); therefore, all cattle seen in the video
footage were sourced from Australia.
The investigation finds that the video footage shows 14 slaughter practices that are noncompliant with ESCAS animal welfare performance measures and targets.
The investigation recommends that the Secretary take regulatory action with regard to NACC.
The investigation makes four observations.
1.
INTRODUCTION
This is the report of an investigation into allegations made by Animals Australia to the
Department of Agriculture, Fisheries and Forestry (DAFF), of non-compliance with ESCAS
animal welfare performance measures and targets.
For the purposes of this investigation the abattoir at which the non-compliances were alleged
to have occurred is named ‘Abattoir 3’. DAFF identified that Abattoir 3 is part of the
approved ESCAS of the North Australian Cattle Company Pty Ltd (NACC).
2.
SOURCES OF INFORMATION
1.
Formal complaint and video footage sent to DAFF by Animals Australia
2.
Analysis of the video footage by RSPCA Australia
3.
Animal welfare assessment of the video footage by DAFF Animal Welfare Branch and
the Office of the Chief Veterinary Officer
4.
ESCAS documentation previously provided by NACC
5.
Report from NACC including:
o
summary report of their internal investigation
o
analysis of the video footage
o
number of cattle exported under ESCAS (including breakdown by consignment
and abattoir)
o
audit reports
o
list of cattle slaughtered in Abattoir 3
o
standard operating procedures (SOPs) for Abattoir 3
o
corrective actions taken by NACC in response to the video footage.
Page 1 of 8
3.
EVALUATION OF INFORMATION
3.1. Complaint and video footage from Animals Australia
The video footage made at Abattoir 3 shows the slaughter without stunning of four cattle,
using a Mark 4 slaughter restraint box with head/neck restraint. Two other slaughter restraint
boxes are visible in the background; one that appears to be a Modified Mark 1 slaughter
restraint box (with stunning stand) to the far right of the scene, and an unidentified slaughter
restraint box to the far left. Neither is seen in use during the video footage.
The video footage also includes vision of a second abattoir at the same location. A scene of
the videographer walking between facilities is included.
Two of the cattle have eartags that are not clearly visible:
Animal given the identification 01: A single tag in the left ear that is yellow and green,
or one yellow tag and one green tag.
Animal given the identification 04: A green tag in the left ear.
It is not possible to see any writing on any of the eartags.
No brands are visible on the cattle seen being slaughtered.
3.2. Animal welfare assessment of the video footage by DAFF Animal Welfare Branch and
the Office of the Chief Veterinary Officer
Officers from the DAFF Animal Welfare Branch, and the Office of the Chief Veterinary
Officer reviewed the video footage against ESCAS animal welfare performance measures and
targets. These performance measures and targets are on the DAFF website at daff.gov.au
/__data/assets/word_doc/0004/2133445/Guidance-on-Meeting-OIE-Code-Animal-WelfareOutcomes-for-Cattle-and-Buffalo.doc.
The cattle seen in the video footage could not be identified by eartag, and so were given
identification numbers by this investigation.
The assessment of the video footage by DAFF Animal Welfare Branch and the Office of the
Chief Veterinary Officer shows 14 non-compliances against several aspects of ESCAS animal
welfare performance measures and targets. The full text of the Animal Welfare Branch and
the Office of the Chief Veterinary Officer review is at Appendix A of this Annex.
This investigation used the animal welfare assessment to compile a table of compliance, or
non-compliance against ESCAS animal welfare performance measures and targets. The result
is set out at Table 1.
Page 2 of 8
Table 1: Assessment of the video footage against animal welfare performance measures and
targets
Compliant or non-compliant
Animal welfare performance
measure or target
6.6
6.8
6.9
6.12
6.14
6.15
The head is restrained for as
short a time as possible prior to
sticking, and in no case for
longer than 10 seconds
The head of the animal is kept
in extension to prevent the
edges of the wounds touching
until the animal is dead
The method of restraint
employed is working effectively
The throat is cut using a single,
deep, uninterrupted fast stroke
of the knife.
Death, indicated by cessation of
pulsatile bleeding and lack of
corneal reflex and lack of
rhythmic breathing, is assured
before performing any other
procedures
Animals must not have water
thrown on them or be
otherwise disturbed prior to
confirmed death
Animal ID
01
02
07
08
Noncompliant
Noncompliant
Compliant
Compliant
Noncompliant
Noncompliant
Noncompliant
Noncompliant
Inconclusive
Not assessed
Not assessed
Non compliant
Not assessed
Not assessed
Inconclusive
Not assessed
Noncompliant
Not assessed
Noncompliant
Noncompliant
Noncompliant
Noncompliant
Noncompliant
Noncompliant
Note: The video did not show the full slaughter process for all four head of cattle; therefore,
some animal welfare performance measures or targets cannot be assessed at all, and some
cannot be assessed for all cattle. In the latter case, the table cell has the entry ‘Not assessed’.
There are a total of 14 non-compliances.
3.3. ESCAS documentation previously provided by NACC
NACC submitted an initial audit report to DAFF as part of the documentation for their initial
ESCAS assessment. The audit report noted that slaughter without stunning occurred at
Abattoir 3. A non-conformity relating to traceability was noted at an earlier audit, but was
closed out in this audit, and there were no outstanding non-conformities. The audit noted no
non-conformities relating to animal welfare.
3.4. Report from NACC
On 14 March 2012, DAFF received a reply from NACC to a Directions Letter DAFF had sent
on 1 March 2012. The Directions Letter requested information about an abattoir included in
one of NACC’s export supply chains that DAFF had identified as a possible match for the
abattoir in the video footage. NACC’s reply letter:
o
confirmed that the abattoir seen in the video footage was the abattoir in NACC’s supply
chain, that this investigation had designated Abattoir 3
Page 3 of 8
o
contained records of the total number of cattle exported under the ESCAS, including a
breakdown of numbers sent to each abattoir in their approved ESCAS
o
contained NACC’s own analysis of the video footage
o
contained steps taken by NACC since receiving the Directions Letter, which included:
–
an NACC representative attending the abattoir immediately and monitoring
slaughter activity, addressing all staff and reinforcing the Animal Welfare
Standards
–
arranging an audit of the abattoir, and arranging for further training of abattoir
staff.
NACC analysis of the video footage
NACC identified several non-compliances against ESCAS animal welfare performance
measures and targets.
Cattle sent to Abattoir 3
The response from NACC on 14 March 2012 indicated that at that time, cattle from
10 consignments that NACC has exported through its ESCAS had been slaughtered at
Abattoir 3.
NACC confirmed that the only cattle slaughtered at Abattoir 3 are cattle they export from
Australia. They also provided a list detailing the cattle slaughtered at Abattoir 3 on the dates
that the video footage was made; 47 of their cattle were slaughtered on 24 January 2012 and
44 were slaughtered on 26 January 2012.
Standard operating procedures
NACC provided a translated copy of the SOPs used at Abattoir 3. This SOP sets out
procedures to be followed during the slaughter process, with specific reference to procedures
to address Animal Welfare Performance Targets 6.6, 6.14 and 6.15.
Although the SOPs at Abattoir 3 are of a good standard, some improvements could be made
to detailed procedures. The video shows that Abattoir 3 staff do not properly follow the SOPs,
which indicates that additional staff training is required so that animal welfare performance
measures and targets can be met.
Animal welfare performance audit
NACC also provided an animal welfare performance audit report that included a site visit on
6 March 2012, i.e. after the date the video footage was made and after the initial visit by an
NACC representative in which animal welfare standards were reinforced in discussions with
staff. The performance audit was only for Abattoir 3; no other elements of the supply chain
were audited. This audit report noted that slaughter without stunning occurred using both
Mark 4 slaughter restraint boxes (with and without ‘head’ restraint). The audit report also
noted no non-conformities.
Page 4 of 8
3.5. NACC actions and outcomes
Upon becoming aware of the video footage, NACC immediately sent a representative to
Abattoir 3. This allowed NACC to confirm the identity of the abattoir seen in the video
footage. The representative monitored the slaughter process for four consecutive nights.
NACC issued a document to Abattoir 3 reiterating their obligations under their contractual
arrangements, a copy of which was provided to DAFF.
NACC identified several breaches of animal welfare that had occurred. They arranged for
additional refresher training from Meat and Livestock Australia for all staff at Abattoir 3.
NACC also identified the need for a more recent audit, and so engaged the independent
auditor they previously used at Abattoir 3, to immediately perform a new audit. This audit
was performed on 6 March 2012, and the report was provided to DAFF as part of NACC’s
initial response to DAFF’s Directions Letter. The audit noted no non-compliances with the
animal welfare checklist at the time of the audit.
NACC also identified that the second Mark 4 slaughter restraint box at Abattoir 3 lacks a head
restraint. NACC confirmed in later correspondence that the head restraint was installed in the
week of 19 March 2012.
4.
FINDINGS
4.1
Is the abattoir part of an approved ESCAS?
Picture 1 is a still scene of Abattoir 3 taken from the video footage. Picture 2 is of Abattoir 3,
provided by NACC.
Picture 1.
Still scene from the video footage made at Abattoir 3, showing slaughter using a Mark
4 slaughter restraint box with head restraint
Page 5 of 8
[This image was removed as it may offend]
Picture 2:
Photograph of Abattoir 3 provided by NACC
Note that in the still scene and the photograph, the Mark 4 slaughter restraint box with head
restraint; the position of the column; and the background tiling are identical.
The identification of the abattoir as Abattoir 3 was also directly confirmed by NACC and by
the Indonesian Ministry of Agriculture.
According to NACC, Abattoir 3 contains three slaughter lines and slaughter restraint boxes:
o
one slaughter line that uses a Mark 4 slaughter restraint box with head restraint
o
one slaughter line that uses a Mark 4 slaughter restraint box without head restraint
o
one slaughter line that uses a custom-built slaughter restraint box.
This evidence shows that abattoir seen in the video footage is consistent with the abattoir in
an approved ESCAS, that this investigation has designated Abattoir 3.
4.2
Were the cattle sourced from Australia under an approved ESCAS?
NACC has confirmed that cattle they had exported from Australia were slaughtered in
Abattoir 3 on the dates (24–26 January 2012) that the video footage was made. The cattle
slaughtered on those dates were exported in consignments that were compliant with the
Export Control (Animals) Order 2004 and Australian Meat and Livestock Industry (Export of
live-stock to the Republic of Indonesia) Order 2001(No. 2), and subject to an approved
ESCAS.
NACC has exclusive use of Abattoir 3, i.e. no animals other than their own are slaughtered at
Abattoir 3. This is sufficient to conclude that the cattle seen in the video footage were sourced
from Australia.
4.3
Is there any non-compliance with ESCAS animal welfare performance measures and
targets?
Officers from DAFF’s Animal Welfare Branch and the Office of the Chief Veterinary Officer
assessed the video footage. They identified 14 non-compliances against several items of the
ESCAS animal welfare performance measures and targets. This number of non-compliances,
and the non-compliance with animal welfare performance measures and targets 6.8 and 6.15
for all four head of cattle, indicate a systemic loss of control over animal welfare, to the
degree that it is likely that other cattle slaughtered in Abattoir 3 were subject to the same noncompliances.
Standard operating procedures
As noted above, NACC provided a translated copy of the SOP used at Abattoir 3. This SOP
sets out procedures to be followed during the slaughter process, with specific reference to
procedures to address Animal Welfare Performance Targets 6.6, 6.14 and 6.15.
The slaughter procedure seen in the video footage did not conform to the SOP.
4.4
Is there any non-compliance with other aspects of ESCAS?
Control
Page 6 of 8
Fourteen non-compliances in total, and the non-compliance with performance measures and
targets 6.8 and 6.15 for all four cattle, indicate a systemic loss of control over animal welfare.
The fact that these animal welfare non-compliances were detected by an external party, not by
NACC’s internal quality control procedures, indicates reduced control over ILE’s approved
ESCAS.
Traceability
NACC provided documentation detailing the movements of cattle to abattoirs within the
approved ESCAS under investigation. There is no indication of a loss of traceability within
the approved supply chain.
4.5
Is there reason for the Secretary to take regulatory action?
Abattoir 3 is part of NACC’s approved ESCAS, and the four cattle seen being slaughtered in
the video footage were sourced from Australia and exported under an approved ESCAS.
The video footage shows 14 non-compliances with ESCAS animal welfare performance
measures and targets during the slaughter of the cattle. This number of non-compliances
indicates a systemic loss of control over animal welfare.
The fact that these non-compliances were detected by an external party, not by NACC’s
internal quality control procedures, indicates reduced control over NACC’s approved ESCAS.
For these reasons, the Secretary should take regulatory action with regard to NACC in
accordance with the ‘Guideline: Management of Non Compliance: Exporter supply chain
assurance system (ESCAS) for feeder and slaughter livestock to Indonesia’.
Page 7 of 8
5.
OBSERVATIONS
There is evidence that multiple lines and slaughter restraint boxes exist within Abattoir 3, not
all of which are contained in NACC’s ESCAS. Abattoir 3 contains two Mark 4 slaughter
restraint boxes, as identified and approved in NACC’s ESCAS, but this investigation has
revealed that these slaughter restraint boxes may vary in their exact configurations, and that
other slaughter restraint boxes are present on Abattoir 3. This raises the issue that additional
assurances may be needed to ensure the use of only those slaughter restraint boxes and lines
that are part of an approved ESCAS.
In August 2011, the Australian Chief Veterinary Officer released a review report on the Meat
and Livestock Australia (MLA) – designed Mark 4 slaughter restraint box (Schipp 2011).
This slaughter restraint box contains a head restraint strap to provide adequate head restraint
at the time of slaughter. NACC has identified that at Abattoir 3, one of the Mark 4 slaughter
restraint boxes does not have any head or neck restraint, and the second Mark 4 slaughter
restraint box (seen in the video footage) has a hydraulic neck restraint, but not a head restraint
as per the MLA design.
From the foregoing, this investigation makes the following observations:
1.
DAFF should investigate and clarify what constitutes acceptable head restraint on a
Mark 4 slaughter restraint box, for slaughter without stunning.
2.
DAFF should consider the impact of slaughter restraint box design variations on animal
welfare at the time of slaughter. This consideration may necessitate seeking additional
information on existing ‘copy Mark 4’ slaughter restraint boxes that are part of an
approved ESCAS.
3.
The Secretary could require in future ESCAS applications, identification of any
abattoirs that contain multiple slaughter lines/slaughter restraint boxes. Details should
include (but not be limited to) descriptions of all lines/slaughter restraint boxes
available on a single premises; clear identification of which ones are part of the ESCAS
application; what slaughter or other processing will occur on other lines present; and
what measures will be taken to ensure slaughter of cattle sourced from Australia is done
only on lines/slaughter restraint boxes that are part of an approved ESCAS.
4.
The Secretary could require in future ESCAS applications that exporters advise whether
any local livestock are slaughtered in abattoirs included in ESCAS applications, so that
this can be considered in identification of cattle in any future investigation.
6.
REFERENCES
Centre for International Economics, 2011, LIVE 156, The contribution of the Australian live
export industry, Meat and Livestock Australia, July 2011 p40
Perkins et al, 2010, LIVE 131, Linking pre export factors to post delivery performance in
cattle exported from northern Australia to Indonesia, Meat and Livestock Australia, October
2010 pp16–17
Schipp M, 2011, An assessment of the ongoing appropriateness of Mark 1 and IV restraint
boxes, Australian Government Department of Agriculture, Fisheries and Forestry, Canberra
Page 8 of 8
ABATTOIR 3
Livestock 01 – Video footage file 447 – Mark 4 slaughter restraint box
Comments: Generally calm and well managed procedure, knives sharpened etc
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
6.6 The head is restrained for as
short a time as possible prior to
sticking, and in no case for longer
than 10 seconds
20 seconds of effective manual
head restraint before sticking
Non-compliant
6.8 The head of the animal is kept
in extension to prevent the edges
of the wounds touching until the
animal is dead
6.9 The method of restraint
employed is working effectively
Head not restrained to maintain
extension after sticking
Non-compliant
When laid on side animal displays
no signs of distress and head
restraint is rapidly applied
without multiple attempts or
delay
Inconclusive
6.14 Death, indicated by cessation
of pulsatile bleeding and lack of
corneal reflex and lack of rhythmic
breathing, is assured before
performing any other procedures
6.15 Animals must not have water
thrown on them or be otherwise
disturbed prior to confirmed death
No check of cranial or somatic
reflexes
Non-compliant
Water being run on and around
body (stick + 40 seconds with
certainty) and wound handled
(stick + 51 seconds) w/out
checking for signs consistent with
death
Non-compliant
DAFF AWB assessment
DAFF investigation
assessment
Minor welfare impact as this animal appears calm and
not struggling despite presence of people etc.
Application of head restraint after lying animal on side
has potential to be serious problem if animal wet and
distressed
Minor welfare impact as this animal appears calm and
not struggling despite presence of people etc. High risk
however if this was not the case
Non-compliant
Vocalisation cannot be confirmed or denied with
certainty due to the quality of the footage and sound
track. The target is that < 5% of animals vocalise during
restraint. Animal appears calm when laid down so any
distress it may have been experiencing when in the
restraint box initially was minor and transient
Minor in this case but major area of risk. Checking that
the animal is dead before undertaking further
procedures is the animal welfare 'critical control point'
during unstunned slaughter
Inconclusive
Minor direct impact observed. No signs of sensibility
associated with these interventions
Non-compliant
Non-compliant
Non-compliant
APPENDIX A
DAFF animal welfare checklist
number
Livestock 02 – Video footage file 447 – Mark 4 slaughter restraint box
Comments: Overall the operators are calm and methodical but when signs that may be related to struggling by an animal that is still conscious occur, the operators do not stop what
they are doing.
DAFF animal welfare checklist
number
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
DAFF AWB assessment
DAFF investigation
assessment
6.6 The head is restrained for as
short a time as possible prior to
sticking, and in no case for longer
than 10 seconds
12 seconds of effective manual
head restraint before sticking
Non-compliant
Minor and marginal
Non-compliant
6.8 The head of the animal is kept
in extension to prevent the edges
of the wounds touching until the
animal is dead
Head not restrained to maintain
extension after sticking
Non-compliant
Non-compliant
6.15 Animals must not have water
thrown on them or be otherwise
disturbed prior to confirmed death
Water being run on and around
neck, body and sticking cut (stick
+ 8 to 17 seconds with certainty)
and further cutting plus handling
of sticking wound (stick + 43
seconds) w/out checking for signs
consistent with death
Non-compliant
Minor welfare impact as this animal did not move head
etc to create more pain at the wound site. However,
agonal breathing appears to be occurring at stick +59
seconds, raising questions about speed of
exsanguination
Uncertain impact - the further cutting is associated with
responses that may indicate consciousness but the
footage is not good enough to check for associated signs
to confirm whether or not this is the case. It is a high
risk area because death has not been assured and the
operators do not stop what they are doing to check
whether or not the response is associated with
consciousness
Non-compliant
Livestock 07 – Video footage file 502 – Mark 4 slaughter restraint box
Comments: Animal is quiet and does not appear to be fighting restraint when footage starts as side of restraint box tilts open at t-21:06. Subsequent operations are performed with a
minimum of staff and the welfare outcome - despite the non-conformances - is reasonable under the circumstances. Staff appear to need further training in signs of death and general
animal welfare in order to have confidence that the welfare outcome under other circumstances will also be reasonable.
DAFF animal welfare checklist
number
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
DAFF AWB assessment
DAFF investigation
assessment
6.6 The head is restrained for as
short a time as possible prior to
sticking, and in no case for longer
than 10 seconds
Workers start to work to restrain
the head and neck at t=21:29 and
the animal does not appear
unduly disturbed. Restraint is
complete at t=21:40 as the
person shooting the video is
moving towards the restraint box
and sticking appears to start at
t=21:47 (unclear due to image
movement) and continues until
t=21:51
Sticking complete at t=21:51 and
head restraint released by
t=21:56. The animal will not be
dead in this time
Disturbance in the footage due to
movement makes it impossible to
say with certainty when sticking
actually commences plus distance
from operation initially means it
is impossible to see what is
actually occurring in detail. The
knife does not appear to leave
the wound site
Compliant
No observable adverse welfare impact
Compliant
Non-compliant
In this instance the welfare impact is minor as the
wound edges are not subsequently seen to be touching
or touched
Non-compliant
Inconclusive
No impact observable
Inconclusive
6.8 The head of the animal is kept
in extension to prevent the edges
of the wounds touching until the
animal is dead.
6.12 The throat is cut using a single,
deep, uninterrupted fast stroke of
the knife
DAFF animal welfare checklist
number
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
6.14 Death, indicated by cessation
of pulsatile bleeding and lack of
corneal reflex and lack of rhythmic
breathing, is assured before
performing any other procedures
At t=21:56 the worker holding
the head looks into the wound
before releasing the ear - he may
be checking for completeness of
the arterial cut. Subsequent
footage does not show any
checks of corneal reflex and
breathing as specified
Water sprayed on head/neck and
wound area, starting at t=22:08
Non-compliant
No welfare impact in this instance as the animal appears
dead when further knife work is undertaken on neck
wound starting at t=22:52
Non-compliant
Non-compliant
Minor welfare impact is apparent in this instance
Non-compliant
6.15 Animals must not have water
thrown on them or be otherwise
disturbed prior to confirmed death
DAFF AWB assessment
DAFF investigation
assessment
Livestock 08 – Video footage file 502 – Mark 4 slaughter restraint box
Comments: This animal appears agitated in the restraint box starting at t=26:10 and operator reaches in at the front of the restraint box and appears to tap animal on the head with his
hand a couple of times to position it for restraint. The animal appears reasonably calm when dropped onto its side. The performance of sticking is non-compliant with 6.12 as there is a
'double cut' involving withdrawal of knife from the wound between the operations but the welfare impact is negligible. Subsequent procedures however indicate that the staff do not
understand the principles of animal welfare at slaughter as no attempt is made to prevent further suffering or regain control when it is clear the animal is still experiencing pain and
distress.
DAFF animal welfare checklist
number
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
DAFF AWB assessment
DAFF investigation
assessment
6.6 The head is restrained for as
short a time as possible prior to
sticking, and in no case for longer
than 10 seconds
Restraint applied at t=27:00 and
sticking at 27:03.
Compliant
No breach observed. -
Compliant
6.8 The head of the animal is kept
in extension to prevent the edges
of the wounds touching until the
animal is dead
The head is released from
restraint immediately after
sticking. Water seen to be
sprayed on and around
neck/wound around t=27:19 and
into wound with apparent
response struggling at t=27:22
that results in the unrestrained
body sliding and the head
'flopping' off the table so that the
wound edge is rubbing on the
metal edge of the platform.
Further struggling at an increased
frequency occurs indicating
additional pain and distress being
sensed
Non-compliant
Major in this instance - see comments against 6.15
Non-compliant
DAFF animal welfare checklist
number
DAFF AWB description of
slaughter activity
DAFF AWB
assessment
6.9 The method of restraint
employed is working effectively.
The first attempt to restrain the
head (starting at t=26:46) is
ineffective as the animal pulls
away from the one man involved.
Non-compliant
In this instance there is a significant and additive
adverse welfare impact. This is why the requirement
includes that animals cannot escape the restraint
Non-compliant
6.14 Death, indicated by cessation
of pulsatile bleeding and lack of
corneal reflex and lack of rhythmic
breathing, is assured before
performing any other procedures
No checking is apparent but
footage is discontinuous. The
response to post-stick procedures
indicates the animal is still
conscious.
Non compliant
The response of the animal to some of the post-stick
procedures indicates it is conscious and experiencing
distress. Even if checks were performed, they were
incorrectly interpreted or performed.
Non compliant
6.15 Animals must not have water
thrown on them or be otherwise
disturbed prior to confirmed death
Water is being sprayed on and
around the hind quarters starting
at t=27:14 with apparent
'flinching' in response but no
increase in struggling. Water seen
to be sprayed on and around
neck/wound around t=27:19 and
into wound with apparent
response struggling at t=27:22
that results in the unrestrained
body (belly restraint was released
at t=27:20 despite activity and
tail twitching) sliding and the
head 'flopping' off the table so
that the wound edge is rubbing
on the metal edge of the
platform. Further struggling at an
increased frequency occurs
indicating additional pain and
distress being sensed
Non-compliant
Animal appears conscious and sensing water which when sprayed into the wound area - would cause pain.
The response indicates this was consciously sensed
and the impact - which is worse due to the lack of
effective restraint - is critical
Non-compliant
DAFF AWB assessment
DAFF investigation
assessment