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Tuesday, 8 May 1984
Page: 1773

(Question No. 649)


Senator Peter Rae asked the Minister representing the Minister for Primary Industry, upon notice, on 29 February 1984:

(1) What were the Principal recommendations of the Royal Commission into the Australian Meat Industry; and what steps have been taken in relation to each of the recommendations.


Senator Walsh —The answer to the honourable senator's question is as follows:

(1) In all there were 55 recommendations of the Royal Commission into the Australian Meat Industry. All recommendations were considered of importance and action has been taken on each with implementation completed or underway. A summary of the steps taken in relation to each of the recommendations follows:

FEBRUARY 1984

Recommendation

Present position

Re-organisation of Inspection service

'9.1

The Department of Primary Industry should proceed to re-organize the Commonwealth meat inspection service along the lines indicated in its final submission to the Commission. In particular, the removal of the service from the Bureau of Animal Health and placing of it in a newly-formed Export Inspection service is commended. Unless otherwise stated, the Department's proposals for its new inspection system-so far as they fall within the Commission's terms of reference-are endorsed. This applies to both legislative changes and administrative arrangements.'

9.1

The Export Inspection Service (EIS) was established on 16 March 1982.

The service is operating under a new decentralised management system whereby Regional Directors located in the States now report to the Director, EIS. The Meat Controller concept has been implemented and supervisory veterinary officers duties extended to line responsibility as well as review. Regional Director positions have been upgraded and in filling them, emphasis given to management ability.

New legislation (Export Control Act and Meat Inspection Act 1983 and associated delegated and sub-delegated legislation) brought into operation.

The EIS organisation includes a Compliance and Legislation Branch to examine allegations of malpractice and ensure compliance with requirements.

Inspection procedures and standards-domestic and export are under revision with new approaches being field trialled and discussed with international authorities .

Consultants have completed the following tasks:

a study on the scope for greater use of computers; a number of systems have been introduced, eg. manpower planning, registration and compliance systems. Design and software development of administrative, security and technical systems is ongoing and where necessary pilot trials have commenced training and development needs of EIS staff. A National Training Strategy based on the training consultant's recommendations has been developed and major training programs have been in progress since November 83

A Corporate Plan has been published with the assistance of a firm of Management Consultants. The Corporate Plan which covers a five year period commencing July 1983 identifies the major objectives to be achieved by EIS over the planning period. The Plan also serves to communicate to industry, Governments and other interested parties the nature and scope of the changes underway in the Inspection Service. Work has commenced on updating the Plan for the period 1984- 89

options for charging for inspection services. Study by consultants was completed in November 1983. The report has been circulated to industry, unions and governments and arrangements for consultation are well advanced. The report has been made available to the Interim Inspection Policy Council.

examination of human/industrial relations issues; report was received in February 1984. A number of the recommendations made by the Consultants have been implemented while others are now being incorporated into a detailed implementation plan for discussions with EIS staff and staff associations. It should be noted that the nature of some of the recommendations relating to awards and conditions may have implications for other public servants and need therefore to be considered in the wider context.

These and other DPI proposals have been commented upon separately where they have been subject to specific Royal Commission recommendations.

The Dual Inspection Service

'9.2

The relationship between the reformed Commonwealth service and the various State services will depend upon negotiations between respective governments. So far as Victoria is concerned, it is recommended that a joint authority be established along the lines already negotiated and reported to the Australian Agricultural Council.'

9.2-9.3

New South Wales Domestic Meat Inspection Service was transferred to the Commonwealth on 1 July 1983.

Victoria has entered negotiations without commitment for transfer of its service to the Commonwealth. After evaluation of the options, the Commonwealth does not support the Joint Authority concept having concluded that it would lead to further inefficiencies, increased staff and cost.

'9.3

In the case of the Northern Territory it is recommended that a similar result be aimed for, although the very small size of the Territory Service would suggest a comparatively larger role for the DPI.'

Discussions have taken place and are continuing with the other States (and the Northern Territory) aimed at improving meat inspection arrangements

a 'discussion paper' was prepared in April 83 by the Department of Primary Industry for the States' consideration

the Northern Territory indicated in March 84 that it wishes to progress negotiations on a single inspection arrangement and a steering committee of senior officials has been established and met in Darwin on 13 and 14 April 84

discussions with Tasmania and Queensland officials have taken place and are continuing on ways of improving meat inspection arrangements between those States and the Commonwealth

preliminary discussions have been held with Western Australia officials.

Staffing Economies

'9.4

Wherever overseas requirements and local circumstances permit, numbers of veterinary officers posted to meatworks should be reduced, more reliance being placed on senior meat inspectors, supported by visiting veterinary officers. All possible steps should be taken, to add to the interest of veterinary officers' work. Combined services should provide additional opportunities for this.'

9.4

Numbers of Veterinary staff have been reviewed and are at the minimum level commensurate with overseas requirements.

The Training and Human Relations Consultants have examined issues related to job specification, staff development and motivation of staff

professional development programs for veterinary staff are being implemented as part of the EIS National Training Strategy

the review of the former New South Wales domestic service has been completed and together with the findings of the Human Relations consultants has been used to redefine responsibility to ensure each management group is clearly aware of their responsibilities and to, as far as is practicable, place decision making at the workface.

A program of veterinary science orientated projects is being implemented to add to job interest.

'9.5

So far as is practicable, in the light of overseas requirements and sound meat inspection practices, managements should be encouraged to take over responsibilities for work on the chain now performed by meat inspectors. The numbers of meat inspectors should be correspondingly reduced but, on average, their work should become more responsible and call for greater experience and higher personal qualities. The introduction of approved quality controls and compliance checking methods may enable numbers of inspectors to be reduced in other areas also. Such possibilities should be regularly reviewed.'

9.5

A number of exercises, in areas concerned with quality control and compliance monitoring, are being field trialled. It is expected that one of the outcomes of these examinations will be greater economies in the use of inspection staff, by a reduction in full time inspection effort and devolvement to industry

The devolvement of on-chain disease detection and diagnosis, to industry is not a viable option at this time because of stringent overseas and State/Territory Government requirements. However, task forces within the EIS are working to review all aspects of inspection of meat and other products, and it is expected that these reviews will lead to changes in inspection practices and procedures that will increase productivity of inspectors.

Timetable for introduction is contained in the Corporate Plan.

Recruitment and Training of Meat Inspectors

'9.6

Increases in average responsibilities, together with greater emphasis on the checking and keeping of records, make it essential that there should be high quality in-service training available for inspectors. Appropriate management training should also be given to those inspectors in supervisory positions, or likely soon to be appointed to such positions, who can benefit from it-having regard to their age and the nature of their duties.'

9.6

A major review of EIS training requirements was carried out by the firm David Shave and Associates in 1982-83. A National Training Strategy has been developed based upon the consultant's recommendations and an intensive training program is underway utilizing departmental and other Government resources, consultants and tertiary institutions.

Major training initiatives scheduled to be completed in the current financial year

40 hours of refresher training for all inspection staff

supervisory management training for all veterinary officers, scientific and senior inspectors

residential management programs for selected staff

induction training programs for all new veterinary officers and meat inspectors

methods of instruction courses to provide in excess of 150 inspectors and veterinary staff with basic training skills

provision of appropriate training equipment at in excess of 100 establishments

development of multiskilling courses through Moorabbin TAFE.

Planning for Phase 2 of the strategy covering 1984-85 and 1985-86 is already underway and includes

30 hours reinforcement training for all inspection staff during 1984-85

courses to improve the communications skills of all supervisory staff and enhance the level of communication between Central Office, Regional Office and field staff

on works team 'building'

continuing residential management programs

supervisory training for inspection staff promoted to senior inspector positions

on-going management training for veterinary, science and senior administrative staff.

In 1982-83 the Government committed funds for a three-year training and development program for the Inspection Service.

'9.7

The Department should accept responsibility for co-ordinating the basic training courses available to meat inspectors in the various States. Recruitment policies should ensure that persons taking up those courses have the necessary personal qualities and abilities to cope with the higher demands which will be placed on them as meat inspectors of the future, particularly by way of inspecting and keeping records and writing reports.'

9.7

The Department is currently in the process of finalising its requirements for a pre-entry training course for meat inspectors. Discussions have already been held with a number of TAFE colleges.

Work is nearly complete on an officer integrity program in consultation with staff associations. This includes the provision of training packages and development of training films. The program has been partly implemented and will be fully implemented on 1 July 1984 with the completion of the integrity training film.

The EIS National Training Strategy provides for greater emphasis on clerical training for inspection staff. This training is being provided through the various supervisory and induction courses together with specialised training programs.

Delegation of Authority

'9.8

Decisions on particular questions of meat inspection, or concerning the security of export meat, should be made at plant or regional office level unless they could create an important precedent or otherwise raise policy issues. All decisions going beyond day-to-day routine should be reported to head office for information and, if necessary, comment.'

9.8

An integral part of the establishment of EIS has been the progressive development of responsibility from Central Office to the States and in turn the works level. To facilitate this, Regional Offices have been strengthened and greater emphasis given to selecting appropriate technical officers with management skills.

Rotation of Meat Inspectors

'9.9

Meat inspectors should normally be posted to establishments for a minimum of one year unless family separations or other hardships are involved. In those cases, three months postings would be reasonable.'

9.9

This recommendation is agreed with in principle. Full implementation has been delayed by a claim for award variation by the MIA, review by the Human Relations Consultant and an internal review of temporary transfer conditions and procedures.

As a first step, arrangements have been made for staff from closed meatworks to undertake three months temporary transfers in a planned manner. This has materially reduced the frequency of rotation of Meat Inspectors. A mangement program in accordance with the recommendation has been developed and negotiations with the unions on a proposal including, among other things, 12- month term transfers have begun.

Detection and Investigation of Malpractices

'9.10

The Department should, as a matter of some urgency, re-organise its Compliance and Evaluation Unit and establish an Investigations Unit, as proposed in its final submissions. The relations between the Investigations Unit and the AFP will require close attention-a good working arrangement between the two is essential. The employment of some former police officers in the Investigations Unit is recommended.'

9.10

The Compliance & Legislation Branch has been established comprising, Compliance, Program Review an Legislation Section with an Investigations Unit

A former Commissioner of ACT Police was the first head of the Investigations Unit and the unit is now headed by a newly recruited senior officer with a background in investigative matters.

Disscusions on the working relationship between EIS and the AFP have been held. Agreement has been reached between the two and a Memorandum of Understanding between the two parties has been implemented. Working relationships with the AFP are considered sound and operating effectively.

On the recommendations of Mr L. L. Gast, Associate Administrator, USDA the Branch Head position has been approved as a 'Senior Assistant Director' with PSB approval. Eight Regional 'Compliance Officer' positions have been established, and the Unit is operational on 27 February 1984.

The other sections of the Branch are involved in

reviewing the effectiveness and efficiencies of the EIS inspection effort

investigating allegations of malpractice

developing Commonwealth legislation appropriate for the present inspection function and new functions in this area assumed by the Department.

Information Management

'9.11

All telephone communications on matters which are not routine should be recorded in writing and filed appropriately. Complicated or important matters should be confirmed by letter.'

9.11

This is now normal office practice; and, specific instructions have been issued to all staff to ensure that this requirement is complied with.

'9.12

Any incidents of possible malpractice should be fully documented and filed both on the file relating to the particular establishment and on a file relating to the type of malpractice.'

9.12

All incidents of possible malpractice are fully documented, actively pursued to resolution, and filed in a separate filing system. A computer based retrieval system has been developed and implemented. This allows for establishment history to be retrieved quickly.

The incidents are categorised into 'active', 'inactive' or 'history'.

A summary of the incidents is produced quarterly for the Minister.

Free or Cheap Meat or Other Benefits

'9.13

Gifts of free meat to meat inspectors, veterinary officers or other government officers should not be permitted in any circumstances.

9.13-9.18

Export Control Act 1982 contains provisions, including severe penalties specifically designed to stamp out the practice of giving free or concessional meat to inspection staff.

9.14

The purchase of meat by such officials from meatworks at prices available to the general public, or to all workers at the premises, should be permitted.

Instructions issued in May and November 1982 advising industry and inspection staff of new requirements.

9.15

The purchase of meat by officials in any other circumstances should be permitted only with the written approval of the Department.

that EIS staff are not to receive free or discounted product (unless it is freely available to the public at that price)

9.16

In no circumstances should officials be permitted to purchase meat on terms better than those available to the full-time staff of the meatworks.

that industry are not to make any such offer.

9.17

Any meatworks which supplies meat, or official who receives it, in contravention of the rules prescribed should be subject to appropriately severe penalties.

Attendance recording has been tightened up and unannounced checks introduced. These are continuing on an ad hoc basis. Close supervision is also being given to travelling allowance claims arising from the seasonal and high level commitment to provide relief inspectors in different States. Follow up action, including laying of charges, is taken where appropriate.

9.18

Any meatworks which gives money or other valuable benefit to an official, without the approval in writing of the Department, or which helps an official to make a false claim for overtime payments, reimbursement of living or travelling expenses, or other money payment-whether from the meatworks or from the Department-should be subject to severe penalties. So, of course, should the official concerned.'

A review of ovetime being worked has been carried out by Regional Directors and checking procedures on overtime tightened.

All aspects of these recommendations have been implemented and are being monitored.

Penalties for Past Transgressions by Officials

'9.19

It would not be practicable to attempt to discipline all those officials who have come to notice as the recipients of wrongful benefits. It would not be fair to punish only those who have confessed to receiving money. On the other hand, some types of conduct cannot go unpunished.

9.19-9.20

All cases have been actively pursued and are the subject of a quarterly report to the Minister. The intention by the Commissioner that all past cases of free meat to Inspectors need not be pursued has been recognised.

9.20

I recommend that the cases which should be particularly pursued, with a view to appropriate prosecution or other disciplinary action, are those where substantial personal benefits have been demanded by an official, with express or implied threats, and those in which substantial benefits have been offered and received in circumstances suggesting that a particular return, by way of neglect of duty or other clearly wrongful act, was expected of the recipient.'

The Role of the Unions

9.21

The Australian Meat Inspectors Association will have a vital role to play in the months ahead in helping its members to come to terms with new organizational arrangements, perticularly where merging, or working closely, with State Government employees is involved. There will also be changes in manning scales and in responsibilities. Finally, inspectors will have to adapt to doing without certain valuable 'perks' of office-to put the matter in the kindest possible terms.

9.21-9.23

The Department has consulted both generally, through established Regional and Central Office Consultative Committees, and specifically, by special meeting of Executive, MIA, with both the MIA and POA concerning the many changes being made to long established practices. Union participation has been invited in a number of exercises. Union response has been good.

9.22

The Association has been very active in support of its members over the years and will no doubt wish to be closely involved in the developments which will now occur. The Department must recognise this fact and consult closely with the Association before committing itself to proposals which could affect the industrial interests of meat inspectors. I am confident that the Association will respond in a responsible way to the clear need of the industry for a new approach to meat inspection.

The various consultants have consulted with the unions who have and continue to play a major role in connection with implementing many of the recommendations made by the various consultancies and accepted by the Department.

A specific consultative mechanism, the Efficiency Initiatives Consultative Group , has been established to facilitate implementation of revised priorities and procedures. The group comprises senior representatives of the MIA, POA, EIS and PSB. Some of the matters currently being considered by the Group are:

revised meat inspection procedures

revised inspection procedures and other products

review of staffing levels

temporary transfer conditions and procedures.

9.23

The Professional Officers Association should similarly be closely involved in any proposed changes affecting the industrial interests of its veterinary officer members.

As a result of the transfer of the NSW domestic inspection service to the Commonwealth on 1 July 1983, a special union consultative group was formed to facilitate liaison between the unions, Commonwealth and State on this important matter.

The industrial relations area of the Department has been strengthened and proper communication mechanisms established between the industrial relations area and Export Inspection Service.

The unions have membership on the Ministerially appointed Interim Inspection Policy Council.

Registration of Premises

9.24

It is recommended that the DPI should promote in every way possible the concept of common standards of construction, hygiene and meat inspection for Australian meatworks. This Australian domestic standard should then also be applied in the case of all foreign markets which are prepared to accept it. Different special standards will then be only applied to those meatworks wishing to produce for export to those countries which insist upon such special standards.

9.24

A draft Australian Code of Practice for construction of abattoirs has been prepared by a joint State/Territory/Commonwealth Working Party and has been distributed to the Regulatory Authorities for comment

following consideration of any comments the draft will be made available to industry and other parties for comment. It is intended that the finalised document will be presented to SCA/AAC in August 1984.

A draft Australian Code of Practice for non-slaughtering establishments and construction materials has been prepared and circulated to Working Party members .

The development of an Australian Code of Practice for the production and inspection of meat is being undertaken by a task force within the Service

consultations are in progress waith States/ NT, staff associations, industry, overseas countries

issues were discussed in US, Canada and Europe, July 1983

and were further considered at an Australian/US/Canada/NZ meeting in Wellington , April 1984

pilot trials of revised post-mortem inspection procedures-cattle and pigs-were completed November/December 1983

field trialling of revised post-mortem inspection procedures-cattle and pigs- commenced February 1984 and are scheduled for completion in April-7 abattoirs in 4 States

staff associations and abattoir management have been closely involved in trials

pilot trials of Accepted Quality Level (AQL) Quality Control approach to carcase hygiene are in progress and expected to be completed in February 1984-5 abattoirs in 3 States

completion of pilot trials and field trials will take longer than anticipated because of complexity of AQL/QC approach and lack of objective data.

'9.25

The requirement that applicants for export premises registration should be 'fit and proper persons' is endorsed, but it is recommended that the power to refuse registration on this ground be used sparingly, particularly in relation to activities which did not endanger public health and which were indulged in before the requirement was introduced. With regard to future misdeeds, refusal or cancellation of registration should usually be based on conviction for a relevant criminal offence or failure to 'show cause' in the face of some cogent evidence of serious wrongdoing. The Department should have legal advice available at hearings of difficult registration applications.

9.25-930

Appropriate statutory provisions consistent with these recommendations have been made in the Export Control Act. Prescribed Goods (General) Orders that are being drafted will specify detailed conditions associated with the fit and proper person criteria.

9.26

It will be necessary to apply the test of fitness and propriety to persons who would participate in the management of the business as well as those who actually control the business.

9.27

Considerations of financial standing or technical competence should not be used as indicators of likelihood to indulge in malpractices, though they may be relevant for other purposes.

9.28

Appropriate appeal provisions should permit the testing of any adverse decision about a person's fitness to be associated with a registered establishment.

9.29

The DPI proposal to make it a condition of registration that may not be given to DPI officers, and may be sold to them only on terms approved in writing, is generally endorsed. See paras 9.13-18 above.

9.30

There should be provision for the Minister to suspend the registration of an export establishment in cases where there is cogent evidence of serious or repeated malpractice. The onus should then be thrown upon the applicant to show cause why the registration should be restored pending the cancellation hearings. Again there should be appropriate provision for appeal.'

'9.31

The DPI should consider employing officers with appropriate expertise in the construction of buildings and in mechanical equipment to assist with technical aspects of applications for registration. Other disciplines, such as food technology, should also be considered.'

9.31

EIS now has a number of officers with the appropriate experience and qualifications, referred to in this recommendation. When positions become vacant they are being reviewed to ascertain whether or not the designation and classification is satisfactory and when being filled officers with the appropriate background will be employed.

Industry Responsibility

'9.32

Much greater emphasis should in future be placed upon the acceptance of responsibility by managements for the quality and wholesomeness of their products. The meat inspection service should see its role primarily as policing controls instituted by industry, rather than providing those controls itself.

9.32-9.33

The Department is studying, and implementing where possible, revised inspection arrangements under which firms undertake greater responsibility for the quality and wholesomeness of their product. A number of reviews, in both meat and other products areas, are underway aimed at ensuring further development of responsibility to industry.

9.33

Recent history would suggest that a close watch needs to be kept on most operators, but where high standards are maintained and the inspection service believes the operator's self-regulation can be trusted, there should be some relaxation of controls-with a consequential financial benefit to the operator. For such an approach to succeed, both carrot and stick are necessary. A direct relationship between levels of surveillance and cost to the operator (based perhaps on the number of inspectors) would provide the carrot.'

Each establishment is assessed annually in terms of its 'risk' in respect of compliance and construction requirements

Program Review officers evaluate 'inspection control' at samples of establishments and relate them to management's record

integrity and reputation is assessed by Compliance Officers and an overall ' risk profile' developed.

See also recommendation 9.5.

Sampling and Species Testing

'9.34

The stick is provided by likelihood of detection in malpractice and the resulting penalties. Some aspects of the inspection service's role in this have already been dealt with (para 9.10 above). I also recommend that the random sampling and species testing of export products should continue indefinitely. However there should be a marked concentration of effort in areas of greatest risk, such as manufacturing beef awaiting shipment in independent coldstores and minced products. The areas and level of sampling should be reviewed from time to time. Samples should also be taken from any batch of meat which has given cause for concern about its nature, either because of its appearance or because of doubts about seals or documentation.'

9.34

These recommendations are in operation with practices under ongoing review.

Field testing of a species testing kit has commenced in Queensland, enabling inspection staff to conduct species testing at the works

this gives promise of being less costly than the laboratory testing procedures currently used

expect progress to all slaughtering establishments in Queensland by October 1984.

Refrigerated Containers

9.35

There should be provision for at least a limited check on the contents of refrigerated containers which have arrived at a wharf after travelling long distances relying on 'snow shooting'.

9.35

A working party consisting of representatives from the Chamber of Shipping, Customs and EIS met in 1982 to discuss issues and as a result the;

seal type has been changed to the Danish 'one-seal'-a security device-on shipping containers. The effectiveness of the 'one seal' is being monitored

compliance staff encompass within their program.

Penalties

9.36

The penalties provided for breaches of regulatory provisions must have regard not only to the underlying criminality of the offence-as where public health is put at risk-but also to the damage which breaches could do to a vital industry. EMR's should be kept constantly under review, so that they are not out of step with industry requirements, as appears to have been the case with 'robbing the pack'. Because the rewards for villainy can be very great, so must the sanctions be; the recently introduced and proposed levels of penalties are appropriate. On the other hand, when it comes to enforcement, there should not be an over- reaction against past weakness. Sanctions should be invoked with proper discretion, having regard to all the circumstances of the particular case.

9.36

Recent penalties of a nominal nature imposed by the Courts relate to industry malpractice under the provisions previously existing.

A new range of penalties is provided for in the Export Control Act with a maximum $100,000 fine or five years imprisonment or both.

In all inquiries due consideration is given to all the circumstances of the case .

Security Arrangements

9.37

Generally speaking there should be no increase in the levels of physical security which were imposed on meat in the export chain after the substitution scandal. Those arrangements should be kept under review and some requirements should be relaxed as soon as it is thought that Compliance and Investigation Units are firmly established.

9.37

Physical security arrangements are the subject of continuous review; findings to date indicate areas in which some rationalisation can be undertaken

restrictions relating to transfer of product between category A establishments have been removed

expected that further changes resulting in some relaxation will be made following the establishment of the Regional Compliance function on 27.2.84.

however, any change is dependent upon acceptance from the relevant overseas authorities.

Management of the Service has made it clear to industry that while it will pursue every avenue to reduce the high cost of the present physical security arrangements, it considers the risk is still too high to reduce the present intensity. Therefore, any change to the present system is being replaced by equally effective, but less costly, arrangements.

Use of 'Australia Approved' Stamps

9.38

Should be replaced with ones of fresh design as soon as arrangements for their smooth introduction are completed. Their future production and distribution should be strictly controlled. Penalties for theft, wrongful possession and forgery should be heavy.

9.38

Stamp design has been finalised.

Export Meat Orders to be produced in second half of 1984, incorporate new stamp.

The Export Control Act 1982 contains severe penalties for incorrect manufacture and usage of the stamps ($100,000/5 years or both).

The Act applies to existing stamps also from 1 January 1983.

Carton Sealing

9.39

DPI should continue to use its present system of carton sealing for the time being. It should continue to investigate, and to consult with the industry about the use of one piece cartons, and improved methods of sealing. Unless present sealing methods can be made more effective and less costly, their use should be reconsidered as soon as the Department is satisfied that its Compliance and Investigation Units are operating effectively. The possibility of numbering cartons for better documentary control and tracing purposes should be further considered.

9.39

The present carton sealing system is being re-evaluated to try to develop a more efficient and less costly system of carton security, utilizing existing meat industry procedures

the CSIRO and manufacturers of carton closing systems have been approached to determine if systems can be modified to ensure tamperproof closures on cartons.

Development of a new carton label which would be bar-coded or bear an encoded number to enable identification of individual cartons is proceeding.

A computer-based carton seal number checking trial is presently underway in Melbourne, aimed at reducing the need for full time inspector presence in some areas.

Sealing of Loads

9.40

The sealing of loads should also continue for the time being. Here again there is a need to keep technical aspects and record-keeping procedures under review in the light of evidence about how the present seals can be circumvented. Because of the great inconvenience and added costs which sealed loads can cause in some cases, the Department should investigate, with the export meat industry and the transport industry, ways in which exemptions from sealing could be granted. This will probably depend upon the development of a surer system of documentary controls than exists at present. In time it may be possible to eliminate the need for sealing loads. In the meantime consideration should be given to requiring receiving inspectors to sign for meat received and acknowledge the seal number.'

9.40

Truck sealing with Tyden Seals is to continue for the time being pending re- evaluation by the Compliance Section.

Sealing of Premises

9.41

The sealing of premises should be the first of the current security measures to be relaxed when the inspection service feels sufficiently confident of its policing arrangements to do so. The first step of relaxation should permit senior officers of a company to break seals provided advance telephone warning is given to a nominated officer of the inspection service and a written report is made of the circumstances by the company officer. Such incidents should be attended by DPI officers on a random basis.'

9.41

A study of practices and problems has recently been completed. Analysis of the findings indicates areas in which some rationalisation can be undertaken and appropriate changes are expected to be implemented shortly. Reduction in the level of physical security is linked closely to the development of an effective compliance program. USDA have indicated that their concurrence with a reduction in physical measures is largely conditional on this program being developed.

An extension of the security categoristion of meatworks is being undertaken in further defining categories where relaxation of security can be implemented.

Segregation in Coldstores

9.42

The complete segregation of export meat from other products in coldstores should only be required where there is a real possibility-because of the nature and method of packing of the products-that the goods could become contaminated or confused with similar goods or where domestic product could be deliberately substituted for export product. The degree of segregation required in each case should depend upon what is reasonable, given the physical set-up of the coldstore and the current pressure on storage space. The regulations concerning segregation of export meat in coldstores, smallgoods factories and permitted canneries should be in line with practices. Accepted non-observance of regulation creates a dangerous precedent.'

9.42

Segregation of domestic and export meat is being maintained.

Establishments provide floor plans which are evaluated on their merits.

Some relaxation of current requirements appears possible when effectve inventory controls are instituted by industry.

Inventory Control

'9.43

The Department should press on with its studies of inventory controls as part of its armoury of weapons against malpractice and, in particular, as a possible replacement for expensive physical security methods. At the least, company records should disclose certain prescribed types of information and be readily available to meat inspection officers. They would provide a starting point for investigations and, in the hands of properly qualified persons, could provide valuable evidence of malpractices.'

9.43

Consultants studied and reported on inventory controls as a possible replacement for existing physical controls which are under consideration. EIS has commenced further studies which do not directly involve inventory control but which are aimed at developing cost effective security measures.

The use of industry inventory control systems, where in operation, to enhance security is being studied.

AMLC Licences to Export

'9.44

AMLC should retain its separate function of licensing exporters, whether or not they operate export meatworks. Only those who intend to export on their own account should be licensed. The principles for the grant of a licence should be similar to those applying to the grant of registration of export premises, with due allowance of the differences in the two functions. Close liaison between DPI and AMLC should be designed to prevent anomalies in the grant or refusal of registrations and licences. Legislative provisions should permit the two bodies to have regard to each other's decisions.'

9.44-9.48

DPI has ongoing liaison with AMLC to confirm respective areas of responsibility and associated co-ordinating activity for the inspection of trade descriptions and supply according to contract specifications. The Chairman of the Inspection Policy Council is a member of the new AMLC Policy Council.

Since 1 October 1983 when objective trade descriptions were introduced DPI has been responsible for monitoring trade descriptions. AMLC has revised its involvement in Quality Assurance.

AMLC Powers of Inspection

'9.45

While reluctant to argue strongly against an increased inspection role for AMLC- particularly since it is on the borders of my terms of reference-I am bound to point out the illogicality of trying to unify State and Federal inspection systems while, at the same time, creating an additional Federal system.

AMLC has retained its separate function of licensing exporters regardless of whether they operate export meatworks. Amendments to the AMLC Act in 1982 ensure that only those who operate on their own account should be licensed.

AMLC and EIS are maintaining close liaison to minimise the chance of duplication occurring.

9.46

I believe that there should be a method whereby any shortcomings in export quality can be investigated, advice given and repeated failures to comply with overseas requirements dealt with. This system should be independent of the day- to-day inspection system, which may itself be partly at fault.

9.47

However I am not convinced that this type of 'trouble shooting' could not be performed under the overall umbrella of the Export Inspection Service-given proper liaison and co-operation with AMLC.

9.48

This is something to be worked out between DPI and AMLC, having due regard to possible cost savings and the risk of overlapping functions on the one hand, and the need for independent expertise in the field of quality control on the other. '

Export Documents

'9.49

DPI should proceed with its plans to obtain independent advice on the possible benefits which automatic data processing could bring to documentary controls over the export of meat. There is potential here for much greater efficiency without the loss of security, but the initial costs will be high, and all interested areas of government and industry should be closely consulted before any commitments are entered into. The present manual system works reasonably well and the supposed benefits of technological change could prove illusory.'

9.49

ADP trials on the issuance of health certificates by regional offices have indicated such systems are costly to run, not only to Government but to the industry

accordingly, it has been decided not to proceed with such arrangements; present manual systems are continuing.

A complete review of documentation and certificates is scheduled to be finalised by 30 June 1985 with streamlined procedures introduced by end of 1985.

Reviews to date have lead to the introduction of high speed facsimile equipment in each Regional Office, better telex systems and a reduction in the number of documents required to export product.

Halal Slaughter and Certification

'9.50

It is recommended that there be a single system of halal slaughter certification in Australia with an official Australian government certificate and an official Australian government stamp. This system should be under direct and continuous supervision by the Export Inspection Service of DPI.

9.50-9.53

A new system of Halal slaughter certification which meets the criteria established by the Royal Commission was introduced on 1 January 1984. The cost restraint aspects have been met by the establishment of a Halal Fee Justification Panel.

9.51

Description of product as halal, documentation for halal product and halal slaughter stamps should all be accorded the same status as other product descriptions, documentation and stamps and attract the same penalties for misuse .

9.52

With provision for the possible acceptance of others, those now in the field should be responsible for the religious aspects of halal slaughter. As long as those in the field are able to provide a satisfactory service, any further additions should be limited to those who appear to be capable of providing a similar service which would be accepted at least by some Muslim countries. The continued role of AFIC and the other bodies in the field should be reviewed from time to time in the light of their performance. There should be no monopoly of supervision of the religious aspects by AFIC, or any other body, if that can be avoided.

9.53

The reasonable costs, and only those costs, incurred by AFIC and the other bodies in the performance of their supervisory functions should be reimbursed. The necessary sum could be raised by a levy on exporters and producers dealing in the market for halal meat.'

Game Meat

'9.54

The meat inspection service should give the fullest possible coverage to companies or persons wishing to develop the game meat industry. It seems clear that the industry can only hope to develop successfully if there are tight quality controls observed by the companies involved and reasonably close supervision by the inspection service. This must include some supervision of field operations, because lax standards in the field can only lead to a product which is a health risk-and one bad incident of this type could easily put paid to whatever fledgling industry may have developed.'

9.54

Studies of the game meat industry are ongoing.

Data has been collected on Australian and overseas requirements with respect to inspection of game meat.

Provisions for game meat are being developed for inclusion in Ministerial Orders .

A Game Meat Code of Practice is currently being developed in co-operation with the States and Northern Territory.

The EIS Compliance Unit will pay particular attention to the game meat industry.

Pet Meat

'9.55

Generally speaking, all pet meat for export should be dyed with brilliant blue and come under the control of the meat inspection service. Written exemption could be considered in return for special security measures. Premises where such meat is processed should be registered and periodically inspected by the service or its agents. Prescribed records should be kept.

9.55

From 1 February 1983 all pet meat flesh for export has had to be stained.

On-going consultations are taking place with States/Territories to ensure periodic inspections of premises.