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Authors: Main Authors: Maria BOADA – SAÑA, Katarzyna KULIKOWSKA Second Authors: Iris BAUMGÄRTNER, Magdalena ROMAŃSKA, Tea DRONIJC Contributors: Nina ENGWALD, Francesca PORTA, Gerit WEIDINGER Revisor: Xavier MANTECA
- Transport of live animals by sea to third countries is an area where efficient control of Member States involved and the European Commission, and data on the welfare of animals are lacking. The system in place seems incapable of guaranteeing animal welfare stipulated by EU legislation. Its shortcomings on several levels can lead to animal suffering, unfair competition among Member States and loopholes that may be abused by operators.
- Most of the exported animals are transported in inadequate livestock vehicles: only 6% of 78 EU-approved livestock vessels were purpose-built to transport animals, majority are older than the average age of vessel scrapping, and 69% fly substandard flags (most black-listed). In the years 2019-2020, 2,504 deficiencies were found in EU-approved livestock vessels, many posing a threat to animal welfare, health and safety. Since 2017, livestock vessels worldwide have remained the No. 1 vessel category for number of detentions (as a result of serious deficiencies).
- Fitness of animals for transport by sea is not always verified. Conditions in which they are carried on vessels are usually unknown, as is information on numbers and causes of mortalities. In most cases, their welfare in third countries from unloading from the vessel until they reach their destination is not verified.
- The shortcomings need to be remedied by sourcing relevant data through feedback, monitoring, scientific research and audits; by imposing stricter requirements; by ensuring better and harmonised enforcement; by providing procedures and feasible legal tools for authorities involved. Revised and clear regulation with more provisions on sea transport is needed. Trainings and a higher level of expertise need to be organised, especially for expert teams approving livestock vessels.
- Sea transport of animals is a topic which seems neglected by scientific research, EU institutions, competent authorities and Member States, leading to the problems identified and explained herein.
This research study presents an analysis of EU export of live animals by sea from the perspective of animal welfare and procedures that affect it more or less directly, such as vessel approvals or controls at exit points. The conclusion indicates the need to improve and harmonise existing procedures.
Livestock vessels and their deficiencies
As of the date of this research study, 78 EU-approved livestock vessels are in operation. The majority of these vessels are older than the average age of vessel scrapping, and only two are not yet at the “high risk” age according to Paris MoU risk profiling. Most (73 out of 78) had been used to transport other cargo, and at the end of their careers were converted to transport live animals. Such conversion does not take into account the needs and behaviour of animals during transport by sea (an under-researched area), or which species will be transported. Only 6% of the EU-approved vessels were originally built to transport animals, also without considering species-specific needs. Only 2 EU-approved livestock vessels fly a European flag, while 69% fly substandard flags (most black-listed, some grey-listed). Being the only vessel category that carries a living, sentient cargo, livestock vessels should be required to fly white-listed flags only and be classed by highest performing societies.
In the years 2019-2020, 2,504 deficiencies were found in EU-approved livestock vessels, many posing a threat to animal welfare, health and safety. In general, livestock vessels have remained a No. 1 category for the number of detentions (as a result of serious deficiencies) in the years 2017-2019 worldwide.
Based on deficiencies found in the last 2 years, more than half of the vessels operating in the EU pose a serious welfare risk for the animals transported.
Livestock vessel approval by the EU
Despite poor performance with regard to major international standards, these vessels remain approved by the EU to transport live animals, posing a high risk for the animals, crews and maritime environment. This is caused by shortcomings of the system in place. The standards of vessel approval procedures differ considerably among Member States: they are not harmonised and not applied consistently. The responsible competent authorities frequently lack resources (time and/or personnel) to carry out a proper inspection of a vessel. They are not suitably qualified and experienced to assess the necessary technical systems of vessels, which are nevertheless critical for the welfare and health of animals. Detailed procedures should be drafted to help with inspections, and sufficient resources are necessary to guarantee proper inspection quality.
Livestock vessels are controlled by two types of inspecting bodies: Port State Control (PSC) inspectors for marine safety, and veterinary competent authorities for approval as a livestock vessel and before each loading of animals. The two services do not share a communication platform. Veterinary authorities seem not to use the vessel deficiency database, and therefore approve very substandard vessels to carry live animals. On the other hand, PSC inspectors do not directly include animal welfare in their inspections and do not know what is required to ensure it. Communication failure also exits among Member States in regard to checks performed by veterinary competent authorities, which may lead to transporters using this gap to apply for approval in ports with less strict requirements. Member States with exit ports approved for livestock should immediately notify all competent authorities of all Member States involved of any problems with vessels. PSC inspectors and veterinary authorities should cooperate to avoid approval of substandard vessels. Preloading inspections of vessels in EU ports for the approval of a journey are likewise deficient, with similar problems and similar solutions needed.
The quality of documentary checks before journeys is frequently insufficient, missing important elements, such as identification of a transporter for the sea part of the journey (to be held responsible for any shortcomings), or taking into account weather along the whole route until the final destination in the third country. As a result, many competent authorities, both at the place of departure and in port, approve the transport with incomplete or incorrect documentation, putting animal welfare at risk, for example due to heat stress. After arrival of animals in EU ports, their fitness for further transport is not always verified. Animals are routinely not unloaded into stables before loading onto the vessel. Their inspection is only possible during reloading from truck to vessel, in gangways and on ramps, with many animals moving at the same time, making a proper check for any unfit individuals difficult.
Vessel deficiencies, incorrectly organised journeys, deficient checks of fitness of animals for further transport, and defective documentation are further aggravated by the fact that neither the competent authorities at the place of departure, nor those at the EU exit port detect and report these administrative deficiencies. As a result, they remain uncorrected. Lack of feasible contingency plans also has the potential to negatively affect animal welfare when unexpected situations arise. Journey-specific contingency plans are not always required from organisers and transporters. Contingency plans for all stages of the transport should be required, designed, and used as a practical, feasible tool to prevent animal suffering. The welfare of exported animals remains largely unknown during the sea part of the journey and during transport in the third country to the final destination. On board vessels and in third countries there are no EU representatives to ensure animal welfare according to EU law until the animal reaches its destination. This fact itself should prevent competent authorities from approving exports of live animals until a system is in place to guarantee compliance with EU regulations. Moreover, protection of animals at sea is needed on a level similar to protection of animals transported by road, where extensive control has been mandated. On livestock vessels, there is no control of conditions in which animals are transported. Veterinary care on vessels is lacking despite the long duration of these journeys. Member States do not routinely ask for feedback information regarding injuries, diseases, and mortalities during sea transport and immediately after it.
Law enforcement problems
Competent authorities from Member States involved in exporting live animals by sea confirm that difficulties in enforcing Regulation No. 1/2005 exist, and that there are doubts regarding how to enforce parts of it. They identified several enforcement challenges, extreme temperatures, and lack of communication between Member States and third countries being most important ones. Moreover, crew training and competence, the organiser’s obligations, the sea transporter’s obligations and the definition/identification of the transporter and organiser, were identified by them as the most difficult points to enforce in relation to transport by livestock vessel.
Public health and environmental concerns
Long-distance transport of live animals inherently poses serious risks for animal and public health due to possible spread of diseases. Moreover, lack of data and control of procedures applied on board livestock vessels leads to questions about illegal disposal of carcasses and uncontrolled disposal of manure of growing numbers of animals transported over marine protected zones: the Mediterranean and Black Seas.
The shortcomings need to be remedied by sourcing relevant data through feedback, monitoring, scientific research and audits; by imposing stricter requirements; by ensuring better and harmonised enforcement; by providing more clear procedures and feasible legal tools for authorities involved.