Proposed Australian Animal Welfare Standards and Guidelines – Exhibited Animals Consultation Regulation Impact Statement March 2014

A3.2 – Requirement for proficient keepers under Clauses – S1.5, S1.7, S2.6, S8.4, S8.5, S9.2, S10.2, S10.3 and S11.9

Under the proposed animal welfare standards there would be a requirement for proficient keepers or supervision by a proficient keeper/keeper numbers with respect to:

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  the management of an animal (S1.5);
  
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  working with a dangerous animal or entering or working in an enclosure containing a dangerous animal (S1.7);
  
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  when an animal is removed from its enclosure (S2.6);
  
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  handling of animals being captured or restrained (S8.4);
  
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  effecting the safe capture or restraint of animals (S8.5);
  
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  training (S9.2);
  
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  overseeing and coordinating all interactive programs (S10.2);
  
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  all interactive programs (S10.3); and
  
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  the transportation of an animal from the time of loading until the moment the animal is offloaded (S11.9).
  

However, it was confirmed by the expert consultative forum (ECF) that each large or medium facility would have at least one if not more proficient keepers and that, along with the additional training and hiring under proposed standard S1.4, keepers in small facilities would be up to appropriate minimum proficiency levels with respect to the aforementioned Clauses. The proposed standards do not require a keeper to hold a qualification to be deemed proficient and thus many keepers may be regarded as proficient without having completed a recognised course but have the necessary experience. It is understood that a proficient keeper’s restraint capabilities are defined under the standards as “any method, (whether physical, chemical or behavioural) of preventing an animal from performing an act or movement”. Therefore, with respect to proposed standard S9.2 it is interpreted that a proficient keeper would already have experience with conditioning or training of animals. Therefore, the aforementioned Clauses would not be seen to impose an incremental cost.

A3.3 – Incremental cost of recording assessment of keeper proficiency – S1.6

Under proposed standard S1.6 the operator must keep a record of the operator's assessment that a keeper is proficient. This cost is only the cost of documenting the assessment because it is assumed that keepers would otherwise already be assessed under the base case. The incremental cost of this proposed standard of the standards is estimated using the following assumptions:

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  documenting assessments would require an operator 30 minutes per annum per keeper
  
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  large facilities are assumed to already be documenting assessments;
  
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  the hourly charge out rate for record keeping is $50.42 (as it is assumed that a keeper would document the assessment with sign-off by the operator); and
  
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  95% of medium and small operators are already compliant with this proposed standard.
  

As shown in Table A3.4, the estimated cost of annual record keeping under proposed standard S1.6 would be $1,347 per annum.

As shown in Table A3.5, the estimated 10-year cost of record keeping would be $9,464 in present value 2012-13 dollars with 73.47% of the cost incurred by small facilities, particularly in NSW, VIC, QLD and WA.