Code of Practice for the Intensive Lamb Finishing Sector

Your feedback

Some initial feedback relating to Draft 9 of the Code of Practice follows. The views expressed are from a range of individuals and businesses and do not necessarily represent the views of those working within this project.  If you would like to comment on any of these items, please visit our “how to contribute” page.

Feedback posted October 1 2008:

Environment and Design

• We have been affected by heavy traffic travelling on an access road to a large feedlot with no curfew times in place. Is it possible to include feedlot access roads in the separation distance requirements?
• Where standards and guidelines are based on cattle standards and guidelines, a conversion ratio of 10:1 should be used.
• Amend S4.4 “Pests must be controlled within the intensive lamb finishing system as they contribute to disease, damage infrastructure and equipment and are a significant source of irritation to stock and personnel” to “If any nuisance animal are to be controlled within the intensive lamb finishing system as they contribute to disease, damage infrastructure and equipment and are a significant source of irritation to stock and personnel, it must be undertaken using humane lawful methods”. Nuisance or pest animals should also be defined.
• Not only feedlots constructed on deep sands should have clay applied and rubble compacted to a depth of 450 mm – suggest soil tests ensure that all clays can be treated to AS1231 levels, to minimise seepage, otherwise clay lining to the appropriate standard should be considered.
• Maximum permeability for manure pads and lagoons should be defined as 10-9 mm/sec.
• A separation distance for the spreading of nutrient from boundaries, gullies and watercourses needs to be included.
• Clause S1.4, “Where the site is to be located above groundwater resources an expert independent assessment must be conducted” should be amended to “All sites must be assessed in relation to groundwater impacts”.
• For best practice, the minimum slope of a roof structure to maximise heat loss and minimise heat build up should be included.
• Wind breaks are more effective when porous (ie, not a solid wall). Porosity of 30 to 50% may be best practice.
• Carcase disposal by burial is not generally appropriate.

Format

• The document contains unnecessary repetition

Management

• A register of lamb mortalities/morbidities by diagnosis should be kept to satisfy animal health and welfare authorities.
• Clause S11.9 “Lambs must be handled in a manner that does not cause pain or injury” should include “electric prodders must not be used”
• All personnel handling lambs must have passed low stress stock handling training.
• The following acts should be considered and referenced if appropriate: Veterinary Practitioners Act, Poisons and Therapeutic Goods Act and The Stock Medicines Act.
• Samples of feeds should be retained for potential later feed analysis.

Health, welfare and nutrition

• Amend clause S13.4 from “All medications must be administered in strict accordance with the manufacturer’s instructions or under veterinary supervision” to “All Prescription Animal Remedies (S4s) only to be used under direct veterinary supervision.  All non-PARs to be used in strict accordance with manufacturers instructions”.
• Include Listeriosis, PEM, non-laminitis lameness and E coli tin the animal health section
• Shade must be provided when the temperature exceeds 25 degrees (refer G3.8 Shelter should be provided to avoid heat and cold stress and G11.2 Shade should be provided during times of the year when the weather is likely to exceed 30°C.)
• Animals must have protection from inclement weather when the temperature is below 10 degrees.
• Introductory periods for grain adaptation quoted in clause S34.9 should be moved to guidelines and not be prescriptive. Defining a minimum 21 day introductory feeding period where diets contain >60% grain is seen as prohibitive and denies use of shorter feed introduction that is currently being successfully used by some lamb finishers.
• Remove reference to sampling grain from a filled silo from the top and bottom (G34.5) as this promotes unsafe OH&S work practices. Samples should only be taken when either filling or emptying silos.
• The methods of euthanasia should be expanded to include other accepted humane methods such as exsanguination.

Supply Chain Management

• A standard should be included to prevent restricted animal materials (RAM) being fed either intentionally or unintentionally.
• Commercial feed must only be sourced from a QA accredited supplier.

 

Feedback Posted August 2008

Definitions and scope

• Feedlots with less than 500 head should be excluded from the Code of Practice
• Feedlots with less than 1,000 head should be excluded from the Code of Practice
• All feedlots, regardless of size, should be included because the principles remain the same regardless of size and the environmental requirements (ponds etc) change according to factors such as size and rainfall
• It would be helpful if some tools could be developed to help with calculations relating to environmental requirements

• Pasture based finishing systems should not be included in the Code of Practice
• Pasture based finishing systems should be included in the Code of Practice because they impact the environment and have similar requirements to other finishers in terms of health, welfare, management, etc.
• Drought lots should be included as the same principles apply
• If drought lots are not included, they should have a separate document

• The document should be called “Guidelines” and not a Code of Practice
• The document should be called a “Code of Practice” to encourage consistency across the industry and different states. Councils, DPIs, EPAs and other bodies should base their regulations on the Code or adopt it as appropriate.

• Environmental guidelines should consider length of time and season of operation, as well as numbers

Format

• Pasture based systems should have their own document
• Standards should be in a different document to guidelines which should be a document providing best practice information
• The standards and guidelines should be kept together, so that the Code of Practice is a total reference
• The animal health section is valuable but should be a separate document
• Include more information in the health section, such as symptoms
• Use the health information to make a “ute guide”

Environment and Design

• Areas designated for the  spreading of effluent must be located above the 1 in 5 year flood line
• Areas designated for the spreading of effluent must be located at least 2 metres above the shallowest watertable
• Feedlots must not be constructed on flood prone land
• Sites should not be selected where significant vegetation removal is required
• More weight should be given to community amenity to ensure that landscape screening and buffers are more strongly encouraged

• Environmental management plan should include the management of weeds introduced from feeds

• Separation distances should not be dependent on the size of the nearest town
• The current code of practice is based on cattle research and guidelines. Research to determine if this is appropriate would be invaluable.

• Deep collection ponds reduce evaporation and increase odour
• The current recommendations for pond storage appear adequate
• Storage ponds should not be required for small feedlots, particularly, where there is good distance to property boundaries
• Regular pen cleaning helps to reduce odour
• Waste generated from feedlots can create value added products

Management

• Should a minimum weight be required before entry into a feedlot?
• Include information about shearing with snow combs
• Include information about Bioclip
• An evacuation plan should be included
• A fire management plan should be included

Health, welfare and nutrition

• Curfew – time off feed should be no more than 24 hours on-farm
• The maximum time off water, including transport time, should be 24 hours
• A minimum feed intake should not be stipulated as this will vary
• it is not appropriate for lambs under three months to be lifted by one leg

• Information about virginiamycin, Bovatec and buffering products should be included
• Antibiotics must not be included in rations
• Feed suppliers should have a responsibility to provide details of any antibiotics included in feeds

• Include OH&S where implications of mishandling may be critical, eg, scabby mouth
• Minimum ME and protein shouldn’t be stated as inexperienced operators may misinterpret the information as satisfactory requirements not minimums.