Kangaroo Shooting Code compliance

A Survey of the Extent of Compliance with the Requirements of the Code of Practice for the Humane Shooting of Kangaroos
Prepared for Environment Australia by RSPCA Australia
July 2002

2 Examination of the Regulatory Framework

2.1 Introduction

Inquiries with government agencies were in two main parts, the first being a desktop review of the regulatory requirements concerning kangaroo killing, and the second being discussions with representatives of the relevant agencies involved in the management of kangaroos.

The kangaroo management programs (KMPs) in each State (in Western Australia there is a separate management program for each species) were studied to determine the extent of responsibility for animal welfare issues. The KMPs examined here were prepared to fulfil the requirements of the Commonwealth Wildlife Protection (Regulation of Exports and Imports) Act 1982 and the associated Regulations (subsequent changes to legislation have not changed the requirement for the implementation of KMPs). What is contained within each of the KMPs is an expression of the State's obligations to the management of the kangaroo species, including welfare considerations during killing operations.

Other documents examined that are relevant to the animal welfare requirements for kangaroo harvesters were those issued by State authorities to commercial kangaroo harvesters, the Australian Standard for the Hygienic Production of Game Meat for Human Consumption (AS 4464: 1997 [1]) and the Australian Standard for Hygienic Production of Pet Meat currently being introduced to most States. These were examined for references to humane killing.

Within each of the four States involved in this survey, there is a government department that is responsible for the protection and care of the native fauna. In New South Wales this is the National Parks and Wildlife Service; in Queensland, the Queensland Parks and Wildlife Service within the Environmental Protection Agency; in South Australia, the Department of the Environment and Heritage; and in Western Australia, the Department of Conservation and Land Management. After analysis of each State's management program, discussions were held with representatives from the relevant agency involved in the management of kangaroos. Initially, these discussions were by telephone or email. A set of common questions were put to each representative in order to fill in some gaps in the knowledge of each State's management program(s), and to follow up certain issues arising from the desk-top analysis of the KMPs. These questions were discussed with each representative, then were sent as a letter to each agency. A copy of the letter is provided in Appendix 3.

Each State wildlife agency was visited during the field inspections of kangaroos and interviews obtained with representatives from the relevant department. During the period of the project, discussions were held with the following people:

  • New South Wales National Parks & Wildlife Service (Broken Hill): Joshua Gilroy
  • Queensland Parks & Wildlife Service (Charleville): Murray Evans
  • South Australia Department of the Environment and Heritage (Adelaide): Peter Last and Christine Arnold
  • Western Australia Department of Conservation and Land Management (Perth): Ken Atkins, Peter Mawson and Norman Press

In addition, the content of the various courses established for commercial kangaroo harvesters was examined for each State. Discussions were held with those persons involved with the development and running of these courses and of the shooting accuracy tests in NSW, Queensland and South Australia. All were connected with the Technical and Further Education (TAFE) system, as well as with other organisations, such as shooters' associations and firearm clubs. Copies were obtained of the notes for the Australian Game Meat Hygiene and Handling and Harvesting Kangaroos for Pet Food courses for NSW, and the Commercial Wildlife Harvesting Course for Queensland. In addition, assessment requirements for the firearms competency certification tests for Queensland and South Australia were obtained, as well as the course notes for the South Australian Firearms Safety Course.

Finally, in addition to legislation covering the conservation and management of kangaroos, each State has an Animal Welfare Act, or its equivalent, which covers acts of cruelty to animals. These acts were not examined during this survey.

2.2 State regulatory framework

2.2.1    New South Wales

The New South Wales KMP divides the State into two main zones: the Eastern-most third of the State is designated as a non-commercial zone. In this zone kangaroos can be shot but not sold. In the remainder of the State both commercial and non-commercial shooting is permitted.

2.2.1.1 Aims of the New South Wales KMP

The four aims of the NSW KMP (1998-2002) in effect during the survey were:

  1. to maintain viable populations of red kangaroos, Western grey kangaroos, Eastern grey kangaroos and wallaroos throughout their natural range;
  2. to minimise the adverse effects that certain densities of these four species may have on rangelands, on pastoral and agricultural production and other land uses;
  3. to maintain viable populations in these areas at all levels which will not, in the long terms, adversely affect these habitats;
  4. where possible, manage the species as a renewable resource, providing conservation of the species is not compromised.

That KMP was replaced by a new KMP on 1 January 2002. The new KMP is valid for 2002-2006 and has as its goal (which replaces the 'aims' of the previous program) to 'maintain viable populations of kangaroos throughout their ranges in accordance with the principles of ecologically sustainable development'. There is no longer any reference to damage mitigation in any of the 9 objectives of the program. Apart from reference to the Code itself, animal welfare is not explicitly mentioned in either the 1998-2002 or the current program. As the survey was undertaken when the 1998-2002 KMP was in force, the text of the report refers to this KMP and not the current one. The conditions and requirements referred to in this document have not substantially changed in the new KMP.

2.2.1.2 Licence conditions

There are three types of licences for shooting kangaroos in NSW. Firstly a landholder must apply for an Occupier's Licence to legally have kangaroos shot on the property. Kangaroos can then be shot commercially (if within one of the commercial zones) by the holder of a Trapper's licence, or non-commercially by the landholder themselves or their nominee (holding a General Licence).

Section 3.9 of the 1998-2002 NSW KMP states that the Code 'has been supplied to all licensed trappers, and is a condition of their licence', The KMP does not explicitly state that holders of an Occupier's licence must comply with the Code. However, the Declaration of Approved Management Programs for 1998-2002 requires that shooting of animals under the program is undertaken in accordance with the Code, and that the Code is supplied biennially to all shooters, with no distinction made between commercial or non-commercial shooting (see Box 2.1). According to agency staff, compliance with the Code is a condition of both the commercial (Trapper's) and non-commercial (Occupier's) licence and the Code is issued periodically to all licence holders.

Box 2.1 Conditions requiring compliance with the Code

The Commonwealth Declaration of Approved Management Programs for 1998 to 2002, under the Wildlife Protection (Regulations of Exports and Imports) Act 1982, for New South Wales, South Australia and Queensland includes the following conditions:

  • 'That the shooting of animals under the program is undertaken in accordance with the 2nd edition of the Code of Practice for the Humane Shooting of Kangaroos.'
  • 'That all shooters are supplied, at least biennially, with a copy of the 2nd edition of the Code of Practice for the Humane Shooting of Kangaroos, and made aware that they are obliged to abide by the Code.'

The conditions for the Approved Management Program for Western Australia are slightly different and state:

  • 'That the shooting of animals, for commercial use, under the program is undertaken in accordance with the 2nd edition of the Code of Practice for the Humane Shooting of Kangaroos.'
  • 'That all shooters are supplied, at least biennially, with a copy of the 2nd edition of the Code of Practice for the Humane Shooting of Kangaroos, and made aware of their responsibilities under the Code.

There are 15 conditions on the Trapper's Licence. These cover a range of requirements to do with tags and the disposal of carcasses. It also states that the licensee must be a holder of a current Firearms Licence, that the licensee must adhere, at all times, to the Code of Practice, and that the licensee will not possess or offer for sale any kangaroo carcass containing a bullet wound (other than kangaroos shot in the head in accordance with the Code).

It is also a requirement that commercial shooters must complete:

  • a one-day Firearms Accreditation Course run by the NSW Firearms Safety Awareness Council which includes an accuracy test on a rifle range;
  • a two-day TAFE course on 'Australian Game Meat - Hygiene and Handling'.

These courses are discussed further in Section 2.4.

2.2.1.3  Tracing of carcasses

Tags are issued to trappers and property owners in NSW and note is taken of the tag numbers and the property where killing is to be undertaken. Provided these tags have been used, it is therefore possible to locate the shooter of a carcass or skin that has been taken from a kangaroo that has not been shot as required by the Code of Practice (or by the conditions of the licence). The tag attached to every carcass or skin remains attached up to the processor stage. This numbered tag can be traced back to the shooter to whom it was issued.

2.2.1.4 Licence and harvest numbers

There were 551 licensed trappers in NSW in 2000. The number of trappers has gradually declined over the years, from 710 in 1997, to 664 in 1998 and 537 in 1999, with a slight increase in 2000. It is considered that the proportion of part-time to full-time shooters in NSW is about 80% part-time, 20% full-time. Many low volume part-time shooters have left the industry in the past three years as a result of mandatory licensing requirements (firearms accreditation, TAFE courses and vehicle standards).

In terms of commercial shooting, 6,236 occupier licences were issued for the commercial zone in 1999 and 5,130 in 2000. In 2000, 95.8% of kangaroos (883,478 kangaroos) reported as being killed in NSW were killed under commercial licence.

2.2.1.5 Enforcement and inspection procedures

In NSW, District Rangers and Investigators check Trapper and Chiller Returns, monitor average weights, inspect chillers and properties and monitor skin dealers' returns and premises. There are approximately 39 designated ranger positions within the commercial kangaroo management zone. This includes one full time ranger position specifically for kangaroo management. In addition, there are 15 other positions (such as Regional Managers, Area Managers and regional staff) that are also involved in law enforcement. The Service currently employs one chief law enforcement officer and several investigators to assist with law enforcement. Part of the inspection routine is to determine whether a kangaroo has been head- or body-shot.

2.2.2 Queensland

2.2.2.1  Aims of the Queensland KMP

The aims of the Queensland program are similar in intent to those of the 1998-2002 NSW KMP, ie to maintain viable populations of kangaroos and manage these populations as an ecologically sustainable resource, whilst minimising adverse effects on agricultural production or habitat. As with NSW, no explicit reference to animal welfare is made in either the aims or objectives of the program.

2.2.2.2  Licence conditions

There are three types of shooter's licence issued in Queensland. The Commercial Wildlife Harvesting Licence for commercial shooters, Damage Mitigation Permits issued to landholders and the Recreational Wildlife Harvesting Licence. Conditions placed on a commercial licence include the requirement for a Weapons Licence and shooting within the requirements of the Code of Practice. In addition, from 2000 onwards, a shooter is required to pass a shooting accuracy test in order to be eligible for a commercial licence. The Firearms Competency Certification Course is for Commercial Wildlife Harvesting Licence holders. All commercial shooters are now required to undertake a TAFE course on the Queensland Parks and Wildlife Service legislation and legal obligations whilst operating under a licence. The Queensland Livestock and Meat Authority oversee the meat consumption side of the industry, and have developed a TAFE course in hygiene for shooters for human consumption. (See Section 2.4 for a discussion of these courses.)

Applicants for a Recreational Wildlife Harvesting Licence must get written permission from a landholder before applying for this licence and must already have the required Weapons Licence. Kangaroos taken under a recreational licence or the damage mitigation permit are for personal use only and cannot be sold or given to another person. There is no process of carcass inspection under this licence or under the damage mitigation permit.

All licence and permit holders (including of damage mitigation permits) must abide by the Code of Practice, and, according to agency staff, a copy of the Code is sent to all licence holders.

2.2.2.3 Tracing of carcasses

As with NSW, it should be possible to locate the shooter of a carcass or skin that has been taken from a kangaroo that has not been shot in accordance with the Code of Practice, provided the appropriate tags have been attached. The tag attached to every carcass or skin remains up to the processor stage and this numbered tag can be traced back to the shooter to whom it was issued. Harvest returns supplied by commercial shooters in Queensland detail the tag number, shooter identity, location and date of shooting. Tags are also issued for recreational licence holders and a return must be provided (to head office, not to the Macropod Management Program office at Charleville). This system has been used in Queensland to locate a shooter who had sold a body-shot carcass to a dealer, leading to a court case (see Section 4).

2.2.2.4 Licence and harvest numbers

In 2000, 940 licences were issued for commercial shooting of kangaroos in Queensland. The percentage of part-time and full-time shooters in Queensland is considered to be similar to that of NSW, ie 80% part-time and 20% full-time.

Of the four States surveyed, Queensland has the highest level of commercial kangaroo killing with 1,378,505 kangaroos reported as being killed under commercial licence in 2000. This represents 98.5% of the total number of kangaroos killed in this State. Of those kangaroos killed commercially in 2000, 53% were Eastern greys, 32% were red kangaroos, and 15% were wallaroos (357 whiptail wallabies were also killed).

There is a high level of skin-only shooting in Queensland. In 2000, 559,419 kangaroos were shot for their skins, representing 41% of the total commercial kill. Skin-only shooting mainly occurs in the more remote parts of the State, as with Western Australia, as transport of carcasses to a processor is considered too difficult.

Up to August 2000, 114 Damage Mitigation Permits had been issued to landholders in Queensland (figures were not available for the entire year) and 21,504 kangaroos killed under these Permits (1.5% of the total harvest). As with commercial killing, the main species taken under these Permits is the Eastern grey kangaroo (80% of kangaroos killed in 2000). The Recreational Licence is restricted to 50 carcasses per year for each applicant. It is estimated that there are less than 50 recreational licences issued annually.

2.2.2.5 Enforcement and inspection procedures

In Queensland, law enforcement staff investigate alleged breaches and inspect shooter and dealer records and activities through a program introduced in 1991 (points 6.1-6.5 of the Queensland KMP). A unit of six Queensland Parks and Wildlife Service (QPWS) staff at Charleville have the responsibility of monitoring the kangaroo harvest and overseeing the regulation of the industry. There are approximately 50 rangers that conduct their duties in the commercial harvest area of Queensland. Part of the inspection routine is to determine whether a kangaroo has been head- or body-shot. In addition, QPWS trains police officers in enforcement matters relating to the commercial kangaroo harvest and they form an important part of the enforcement program. Data on kangaroo shooters and dealers is made available to police on their computerised network.

During 2000, Queensland Parks and Wildlife Service introduced a system of on-the-spot fines for offences concerning macropods, eg lack of tags, incorrect returns, no appropriate licence. This has led to a sharp increase in the number of prosecutions concerning infringements involving macropods. Other states also have on-the-spot-fines but it is not clear how similar these are to the Queensland system.

2.2.3 South Australia

2.2.3.1  Aims of the South Australian KMP

The South Australian program has six aims, three of which are similar to that of the other States and relate to maintaining viable populations of kangaroos, managing these populations as a resource, and minimising negative impacts of kangaroos. The additional three aims are as follows:

  • Ensure that kangaroo management practices and the commercial kangaroo industry adhere to animal welfare standards (Aim 4).
  • Ensure that the KMP and the commercial kangaroo industry adhere to best practice principles for wildlife management and harvesting (Aim 5).
  • Promote, develop and maintain effective communication structures within and between the kangaroo industry, agricultural industries, wildlife managers, the community and governments (Aim 6).

The fourth aim addresses the welfare of kangaroos and has the following stated outcomes:

'4.3.1   Animal welfare issues related to management of kangaroo populations are considered and a summary of considerations incorporated into the annual kangaroo quota submission.

4.3.2    The Code of Practice for the Humane Shooting of Kangaroos is enforced as a condition of permit.

4.3.3    The animal welfare implications of habitat management programs are addressed before action is initiated.

4.3.4    The animal welfare implications of kangaroo population dynamics in regions modified by human activity will be taken into consideration when developing regional kangaroo management strategies.

4.3.5    Any research on kangaroos or kangaroo populations will require approval from an Animal Ethics Committee.'

2.2.3.2 Licence conditions

In South Australia, a landholder is issued with a commercial or non-commercial Destruction Permit. South Australia's commercial harvest quota is broken up into two components, Sustainable Use and Land Management quotas. Kangaroos harvested in the State's commercial zone are taken according to either a Sustainable Use or Land Management Permit. Tags are purchased from National Parks and Wildlife (SA) by the nominated Kangaroo Meat Processor against the relevant commercial destruction permit, who then forwards them to the nominated Field Processor (shooter). If kangaroos are to be destroyed against a non-commercial destruction permit, then they can either be shot and let lie or affixed with a yellow tag if carcasses are to be removed from the property. It is possible for the holder of a destruction permit to nominate an agent to shoot the kangaroos (this is also the case in the other States). In all cases, the Code of Practice is enforced as a condition of permit.

Field Processors must complete the course in Game Meat Field Processing provided by TAFE prior to being issued a permit to commercially harvest kangaroos. This is a requirement of the Department for Primary Industries and Resources' Meat Hygiene Unit, to enable Field Processors to be accredited under South Australia's Meat Hygiene Act. A voluntary marksmanship course (including a shooting accuracy test) has been developed and presented by TAFE, in conjunction with the South Australian Field Processors Organisation. This course will be compulsory from July 1, 2002. South Australia as part of a revision of regulations is considering the mechanisms for, and implications of, prohibiting the entry of non-head-shot carcasses into the game meat trade.

One of the conditions of a destruction permit is that animals must be taken in a manner that does not cause unnecessary pain and is in accordance with the Prevention of Cruelty to Animals Act, 1985. Where the permit is issued for the destruction of kangaroos and/or wallabies, the permit holder must comply with the Code of Practice.

2.2.3.3 Tracing of carcasses

Kangaroo sealed tags are issued for commercial and some non-commercial kangaroo harvesting (when used for 'private use'). The trace-back procedures of South Australia are similar to those of other states. Tags are uniquely numbered, colour-coded according to species, and retained on the carcass until it is processed at the meatworks. Trace-back procedures in South Australia identify both the property on which the animal was shot, and the field processor that took the carcass. All permit-holders that receive permits under the SA KMP (landholders, meat processors and field processors) are expected to provide annual returns that accurately reflect their activities.

2.2.3.4 Licence and harvest numbers

In 2000, there were 79 licensed Field Processors in South Australia. In contrast with the other States surveyed, 75% of these licence holders were considered to be full-time shooters. There were 855 Destruction Permits issued for commercial purposes, and 836 for non-commercial purposes. According to the 2000 returns, a total of 291,477 kangaroos were killed for commercial purposes in South Australia, representing 89.3% of the total harvest.

2.2.3.5 Enforcement and inspection procedures

There are five law enforcement staff whose duties include random inspection of processing works, transport vehicles, chillers and shooters in the field, as well as surveillance operations and responding to complaints. All agency law enforcement staff are instructed to inspect for any incidence of cruelty (usually by recording any body-shot kangaroos) during monitoring of chillers and processors.

There are approximately 125 Rangers with the National Parks and Wildlife Service who are all certified as wardens and six Ranger staff with prominent roles in the KMP. Their duties include law enforcement, population monitoring, industry/landholder consultation, establishing and monitoring harvesting quotas etc.

2.2.4 Western Australia

2.2.4.1  Aims of the Western Australian KMP

There are three aims for each of the kangaroo [2] management programs in Western Australia. As with the other States, these are associated with maintaining populations over their natural range, containing the deleterious effects of kangaroos and, where possible, managing the kangaroos as a renewable resource providing the conservation of the species is not compromised.

2.2.4.2 Licence conditions

The management programs for Western Australia state (in paragraph 3.3.2) that one of the conditions of a Wildlife Conservation Regulation 6 licence (Professional Shooter's Licence) is that 'a professional shooter is required to comply with the Code of Practice for the Humane Shooting of Kangaroos'. No such condition is given for a Wildlife Conservation Regulation licence 5 (Damage Licence). For Western Australia, the Commonwealth Declaration of Approved Management Programs for 1998 to 2002 specifies only that shooting for commercial use is undertaken in accordance with the Code (see Box 1-for NSW, South Australia and Queensland this condition applies to all shooters). The Declaration also requires that all shooters are 'made aware of their responsibilities under the Code' whereas for the other States the wording is that they are 'obliged to abide by the Code'.

Despite the apparent differences between its responsibilities and those of the other States, according to agency staff, Western Australia requires total compliance with the Code of Practice for both commercial shooters and non-commercial shooters, with one exception. Non-commercial shooters are not required to comply with the minimum specifications for firearms if they are not licensed to possess the appropriate firearm.

Restricted Open Seasons are declared for both red and Western grey kangaroos over much of the Western Australian rangelands. Within a Restricted Open Season, it is possible for landholders (or their nominee), without having a licence, to shoot kangaroos that may be causing, or be reasonably expected to cause, damage. Conditions are established under the Restricted Open Season notices (appended to the management programs). One of these conditions is that all shooting under the provisions of the Open Season is to be carried out in accordance with the Code of Practice (except for the minimum firearms specification as mentioned above).  Professional shooters also have conditions on their licence that apply to the kangaroos they take from Damage Licence and Restricted Open Season areas. According to staff from the Conservation and Land Management agency (CALM), most kangaroo control undertaken on land holdings within the Restricted Open Season and Damage Licence area is by commercial shooters. CALM states that it strongly encourages the use of professional shooters for all kangaroo shooting. In Open Season areas, a Wildlife Officer may, if necessary, after inspection of that property, prohibit the shooting of kangaroos on that property until the landholder has obtained a Damage Licence.

There is a voluntary training course for commercial shooters of kangaroos for human consumption and pet food run by the WA Department of Health. This course is that offered by the Open Training and Education Network (OTEN) of TAFE NSW. A shooting accuracy test has been developed by the Professional Shooters Association of Western Australia, but has not been made compulsory. (See Section 2.4 for further details.)

2.2.4.3 Licence and harvest numbers

In 2000, 252 Professional Shooters Licences were issued in Western Australia.  About 80% of these shooters are considered to be part-time, a similar proportion to that in the other States surveyed (except South Australia). The number of kangaroos reported being killed for commercial purposes was 194,031 in 2000. Due to the Restricted Open Season system (where no licence is required), there is no record of the number of kangaroos killed for non-commercial purposes.

Although skin-only shooting is permitted in Western Australia, it has always been at a low level (less than 5% in the past, less than 1% at present). Even when it was first introduced, the option of skin-only shooting was only taken up by a few shooters. Skin-only shooting is only practiced in the more remote areas where it is considered unprofitable to transport carcasses to processors.

2.2.4.3 Tracing of carcasses

In Western Australia, royalty tags are issued to commercial shooters and/or landholders applying for a Damage Licence. Commercial shooters report on the properties they have taken kangaroos and list the kangaroos so taken by tag number. Processors report on what a shooter delivers and sells for processing. Shooters and processors are required to provide returns which enable kangaroos to be traced back.

2.2.4.4 Enforcement and inspection procedures

In Western Australia, the regulations are enforced by specialist Wildlife Officers who carry out inspections of kangaroo harvest and trade operations (points 7.1 and 7.2 in the KMPs). There are 33 full-time Wildlife Officers involved in law enforcement including chiller, processor and shooter inspections. Part of the inspection routine is to determine whether a kangaroo has been head-shot or body-shot.

2.3 Summary of State responses

2.3.1 Aims of the KMP

All States follow the aims endorsed by the Council of Nature Conservation Ministers (CONCOM), which are: to maintain viable populations of kangaroos throughout their ranges; minimise the unwanted impacts of kangaroos; and, where possible, manage the kangaroos as a renewable resource providing the conservation of the species is not compromised.

These aims were part of a document entitled 'National Plan of Management for Kangaroos' which was to be used as guidelines by the States in preparing their State management plans. These aims do not acknowledge an animal welfare role within any KMP. The only reference to animal welfare is the requirement that 'shooting is carried out in accordance with the Code of Practice for the Humane Shooting of Kangaroos'.

The only State program that has a stated aim to ensure that kangaroo management practices and the commercial kangaroo industry adhere to animal welfare standards is that from South Australia. The other three States programs follow the aims endorsed by CONCOM without any additions.

2.3.2 Licence conditions

Compliance with the Code of Practice is a condition of the Commonwealth Declaration of Approved Management Programs (see Box 2.1) and of the State kangaroo management programs themselves. All four KMPs contain conditions that the taking of kangaroos will be carried out in accordance with the Code, but in the case of NSW, Queensland, and Western Australia the KMP does not explicitly state that this applies to non-commercial as well as commercial licensees. However, in practice it appears that all States require, as part of the conditions of the appropriate licence, permit or restricted open season, that non-commercial shooters must abide by the Code. The one exception to this is in Western Australia, where some non-commercial shooters are not required to comply with the minimum specifications for firearms contained in the Code.

The shooter licensing or permit system in the four States can be divided into three groups: commercial harvesting licences (shooters that kill kangaroos and utilise the products commercially); damage mitigation licences (landholders and their agents who can shoot kangaroos and either let the animals lie or take them for personal use only); and recreational licences (applies only to Queensland). The different types of licences/permits used are summarised in Table 2.1.

Table 2.1  Licences within each state

State

Type of licence or permit required

Commercial harvesting

Damage mitigation

Recreational

 

New South Walesa

Occupier's Licence

Trapper's Licence

Occupier's Licence

None

Queensland

Commercial Wildlife Harvesting Licence

Damage Mitigation Permit

Recreational Wildlife Harvesting Licence

South Australiab

Destruction Permit (commercial)

Field Processor Licence

Destruction Permit (non-commercial)

None

Western Australia

Professional Shooter's Licence (and professional shooters taking kangaroos under a Damage Licence)

Damage Licence, and Restricted Open Season (no licence if product not leaving property)

None

 
  1. In NSW, commercial harvesting can only take place in areas in the commercial zone by a shooter holding a Trapper's Licence and only on properties covered by an Occupier's Licence.
  2. In South Australia, commercial harvesting can only take place by a shooter holding a Field Processor's Licence on properties that have a commercial Destruction Permit.

Commercial harvesting licences include conditions regarding the use of firearms, use of tags, keeping of records, and the use of the Code. In NSW, South Australia and Queensland it is a condition of a commercial licence that an appropriate game meat course is completed (it is not compulsory under conservation legislation in Western Australia but subject to Health Department regulation). In NSW and Queensland there is also a requirement for commercial shooters to undertake a shooting accuracy test. This is voluntary in South Australia (Compulsory from July 1, 2002) and has been developed for Western Australia but has not been made compulsory.

Fewer conditions are placed upon holders of damage mitigation licences. No appropriate course is required for these licence holders. The main conditions relate to the use of tags, providing returns giving the number of kangaroos destroyed, together with restrictions on the disposal of any kangaroo products.

2.3.3 Tracing of carcasses

Although there is some variation in tag use and the information that accompanies each tag, it is possible, in all States, to trace a tagged kangaroo back to the original holder of each tag i.e. the shooter. In all States, a record of the tags issued to each holder (usually a shooter) are kept by each wildlife management agency. In South Australia, the tag identifies the property, meat processor, shooter and chiller.

With kangaroos shot for human consumption, and with kangaroos shot for other products that are sold, eg pet food or skins, it is possible to trace the carcass back to the shooter, at least at the processor level. Tags are retained on skins until they are fleshed. Even though tags are removed in the fleshing process, it is possible to trace back to the supplier of a batch of skins and hence to those shooters dealing with the supplier. A requirement for this tagging is given in the Australian Standard for Hygienic Production of Game Meat for Human Consumption which states that 'Game animal carcasses shall be marked with an approved tag which shall be marked with the date of harvest and sufficient other information to allow the identification of the field processor and place of harvest' (Section 5.8 of the Standard).

2.3.4 Licence and harvest numbers

Table 2.2 provides a summary of the number of licences issued and kangaroos killed for each state surveyed. According to agency returns, 96.4% of kangaroos killed in NSW, Queensland and South Australia in 2000 were taken for commercial purposes (figures were not available to include Western Australia in this calculation). The number of kangaroos killed commercially in 2000 in all four States combined was 2,649,146. An accurate figure for the total number of kangaroos killed for damage mitigation or recreational hunting is not available, however returns from NSW, Queensland and South Australia indicate that at least 95,686 kangaroos were killed for non-commercial purposes in 2000.

In NSW, Queensland and Western Australia, approximately 80% of commercial shooters are part-time only. In contrast, in South Australia the majority (75%) of commercial shooters are full-time.

Table 2.2  Licence and harvest numbers for 2000

State

Licences issued

Kangaroos killed

Commercial

Non-commercial

Commercial

Non-commercial

Total

 

NSWa

5,130 Occupier's Licences

551 Licensed trappers

489 Occupier's licences

883,478

39,120

922,598

QLDb

940 Commercial Wildlife Harvester's Licences

-

1,378,505

21,504

1,400,009

SA

855 Destruction Permits

836 Destruction Permits

291,477

35,062

326,539

WAc

252 Professional Shooter's Licences

-

194,031

-

-

 
  1. Figures for non-commercial are limited to the Commercial Zone
  2. Figures  not available for the number of Damage Mitigation Permits issued
  3. Figures not available for the number of Damage Licences issued. The Restricted Open Season does not require a licence. Data not collected on the total number of kangaroos killed non-commercially.

2.3.5 Enforcement and inspection procedures

In each State the regulations underpinning the KMPs are enforced by agency officers who check licence holder's returns and carry out inspections of kangaroo harvest and trade operations, including properties, chillers and processors. All agency law enforcement staff inspect for any incidence of cruelty (usually by recording any body-shot kangaroos) during monitoring of chillers and processors.

In addition, all State's law enforcement staff undertake on-the-spot inspections of kangaroos being transported along public roads, in order to check for animals that are not tagged, have been body-shot or shot without the correct licence or permit. A system of on-the-spot fines occurs in some States. When these were introduced in Queensland a sharp increase was recorded in the number of prosecutions concerning infringements involving macropods.

2.3.6 Agency views on compliance with the Code

During discussions with agency staff, it became clear that all States felt that compliance with the Code during the commercial killing of kangaroos was adequate. However, no figures for the extent of compliance could be obtained. Representatives from Western Australia and South Australia felt that compliance with the Code during non-commercial killing was adequate, as both States encouraged the use of professional shooters and/or members of shooting clubs to undertake such activities.

Representatives from NSW and Queensland expressed concern about the lack of compliance with the Code during non-commercial harvesting, as well as the difficulties in attempting to undertake any compliance activities during this type of harvesting. None of the States could provide information about extent of illegal kangaroo harvesting, or compliance with the Code during such activities. Western Australia advised that from all its investigations, it appeared that the impact of illegal  shooting was insignificant to kangaroo populations.

All States use a similar method to measure the extent of compliance with the Code during commercial harvesting. During the periodic inspection of processors and chillers, enforcement officers in each State look out for any kangaroos that have not been head-shot. They also will inspect carcasses on shooter's vehicles. Although these inspections are mainly for tags, carcasses are also inspected to determine the extent of compliance with the Code. Another compliance activity is to respond to reports from the public concerning illegal and/or cruel killing of kangaroos.

2.3.7 Agency views on the provisions of the current Code

State agencies appeared to be satisfied with shooter compliance with the current Code, however all harvesting States have expressed a desire to review the Code.

Staff from the Queensland agency expressed concern over the use of a heart shot for injured kangaroos, as illustrated in Schedule 3 of the Code (this is discussed in more detail in Section 4) as this provision makes it difficult to prosecute for non-compliance. It was felt by staff from Queensland and NSW that recent legal constraints and attitudes taken by the industry (in terms of not accepting non-head-shot animals) may be outstripping the usefulness of parts of the Code.

2.4 Game meat courses and firearms competency tests

All four States have established courses for harvesters on handling game meat to be used for human consumption. The courses are called different names in each state, eg Australian Game Meat Hygiene and Handling in NSW, Commercial Wildlife Harvesting Course in Queensland, and there is also a separate course called 'Harvesting Kangaroos for Pet Food' in NSW. The successful attendance at the appropriate course is a condition of a harvesters licence in NSW, Queensland and South Australia. It is a voluntary condition in Western Australia.

The courses used in NSW, South Australia and Western Australia are based upon the course developed in NSW by the Open Training and Education Network - Distance Education (OTEN), which is part of the TAFE system. In Queensland, the Southern Queensland Institute of TAFE have developed their own course, but this is basically similar to that offered in the other States. However, the Queensland course has two modules, one covering the Macropod Management Program (developed in conjunction with QPWS), and the other covering the hygiene and handling of game meat (developed in conjunction with the Queensland Livestock and Meat Authority). All of the courses have a component that covers the humane killing of kangaroos.

By the end of 2000, about 1000 prospective commercial shooters had undertaken the course in NSW, with about 600-700 completing it successfully (Eric Middledorf, OTEN, NSW). The participants can work at their own rate and, if necessary, can be supplied with someone to assist with the writing of answers to questions during examination. The course cost $135 in 2000, but about one third are exempted from paying as they are on a low income.

All of the courses have a section dealing with humane killing that has the following objectives (taken from the NSW course notes):

'By the end of this unit you should thoroughly understand the regulations for the legal and humane killing of game.

You must be able to describe and justify:

  • the most effective way to achieve sudden and painless death for the game animal
  • accurate sighting in of your rifle
  • the required point of aim
  • permitted conditions for kangaroo shooting
  • the procedure for dealing with
  • wounded kangaroos
  • pouch young
  • illegal shooters.'

2.4.1 Firearms competency tests

In NSW and Queensland there is a requirement for commercial kangaroo shooters to undertake a firearms competency test. This is voluntary in South Australia (compulsory from July 1, 2002), and has been developed in Western Australia but not yet made compulsory.

The firearms competency test is similar for the three States, with one important exception in South Australia (see below). In NSW, South Australia and Queensland, the test involves shooting five rounds in an 80 mm diameter circle at a distance of 100 m. The size of the target has been derived from the approximate size of the target area on a kangaroo, ie the rear of the head (cranium), as described in the Code of Practice. The shooters can usually have two tries in any one day, and can come back on other days to re-do the test. It is usual for this test to be set up by a qualified firearms instructor, sometimes from an accredited shooting club, or from a government agency.

The NSW firearms accreditation includes a firearms competency test and a section on the Code of Practice. This is delivered by the NSW Firearms Safety Awareness Council. In NSW and Queensland, it is usual for the shooter to undertake the competency test during the day either lying, standing or sitting at a shooting range. Both these States recognise that the test conditions are different from those experienced by a shooter under normal operations, ie shooting from a vehicle at night with a spotlight. One case was reported in St George, Queensland where the shooting test was undertaken from vehicles during the day.

In South Australia, the shooting test for the Kangaroo Field Processor Firearm Proficiency Course is undertaken at night with a spotlight, from the shooter's own vehicle. This course is run by Regency TAFE College and uses properties where the owner is agreeable. It is argued by those running the course that the recreation of actual conditions allows a more realistic test to be presented. Staff from the College related anecdotal accounts of people attending the test in other States with heavy target rifles that require less skill to hit the target. A copy of the protocol for the South Australian course is given as Appendix 4.

It was pointed out by QPWS that some shooters failed the shooting accuracy test first time, even though they had been shooting kangaroos for many years. The course supervisor in South Australia stated that the shooting skills of those attending the test are high.

RSPCA Australia recommendations - training courses

2.1 It is recommended that satisfactory completion of the game meat harvesting courses and firearms accreditation courses should be made compulsory for all commercial licence holders in all States.

2.2 To ensure that testing conditions are as realistic as possible, a field-based shooting accuracy test such as that undertaken in South Australia should be adopted in all States as part of their firearms accreditation (ie testing should be carried out at night from a vehicle).

 

2.5 Discussions with inspectors of kangaroos to be used for human consumption

 

All kangaroos destined for human consumption must be inspected to ensure they are acceptable under the Australian Standard for the Hygienic Production of Game Meat for Human Consumption [3]. Each State uses an authority to inspect human consumption kangaroos e.g. Meat Industry Authority of NSW, Queensland Meat and Livestock Authority, WA Health. Kangaroos for export are inspected by Australian Quarantine Inspection Service (AQIS).

Individual inspectors encountered at game meat processors were questioned about the incidence of body-shot kangaroos. In addition, discussions were held with AQIS, Canberra, concerning a central database of information about rejected kangaroo carcasses, and about any general policy or guidelines for kangaroo inspection that may be relevant to this study. Peter Miller, Manager, Technical Services provided the information on the national database.

2.5.1 Australian Standards for the production of game meat and pet meat

The Australian Standard for Hygienic Production of Game Meat for Human Consumption applies to the production, for human consumption, of products derived from wild animals killed in their natural environment. Part of the standard addresses the harvesting of game animal carcasses and the following outcome is required:

'Only game animals of healthy appearance shall be harvested. They shall be killed humanely and handled in a manner which shall minimize the risk of physical and microbiological contamination' (page 9).

Section 5.5 of the Standard states that:

'Game animals shall be killed by an approved method which is in accordance with animal welfare requirements and which minimises contamination of the game animal carcass'.

The standard does not further describe any animal welfare requirement, but does make such a requirement part of the method used to harvest kangaroos for human consumption. In addition, there are conditions placed upon the person harvesting any game animal. Condition 5.1 states:

'A person who harvests game animals shall be approved by a controlling authority and have a certificate of competency or other approved qualification from an approved training course in the harvesting of game animals of the relevant species. The course shall cover killing procedures, recommended equipment, field processor's pre-harvest inspection, hygienic practice of field dressing and field processor's post-mortem procedure'.

Of relevance to this Report is the requirement to attend an 'approved training course in the harvesting of game animals of the relevant species'. This course needs to cover killing procedures as well as other aspects of kangaroo harvesting for human consumption. Such a course is available in South Australia, Queensland and New South Wales and all current kangaroo field processors in these States are required to successfully complete the course (see previous section).

In addition to the standard for game meat for human consumption is the 'Australian Standard for Hygienic Production of Pet Meat'. At present, this Standard is being presented to the kangaroo industry as a voluntary guideline, but it will possibly be officially adopted by each State. Section 1 of the Standard (The Scope and Application of This Standard) states that 'Operation under this standard requires compliance with the relevant Codes of Practice for the Welfare of Animals'. Clause 5.10 of the June 2000 draft covers the harvesting and transport of kangaroo carcasses' and states that kangaroos 'shall be killed humanely and identified to allow traceback'.

Clause 5.10.2 states:

'Kangaroos shall be harvested in accordance with other relevant legislation for the welfare and conservation of wild animals'.

 

Clause 5.10.5 states:

 

'Kangaroos shall be killed by an approved method which is in accordance with animal welfare requirements and which prevents contamination of the wild animal carcass'.

2.5.2 Responses from field inspectors

Although the field inspectors encounter and reject bruised meat at individual processors, there were no reports of bullet holes within the bodies of kangaroos destined for human consumption. In all States, it is the role of the wildlife management agencies, rather than the meat hygiene authorities, to inspect for non-head-shot kangaroos.

At present, there is no national database of the results from the kangaroo inspections, although one is being developed. Reports about rejected kangaroos seem to be confined to stating whether a carcass was fully or partially condemned. There are no records in any detail, and there are no specific records of kangaroos condemned because of bullet holes. It is a general requirement that body-shot kangaroos be condemned and the processor be informed of this, but nothing is recorded of this action. No record could be obtained of a kangaroo being rejected by AQIS on the basis of being body-shot during this survey.


[1] SCARM Report No.57, Agriculture and Resource Management Council of Australia and New Zealand

[2] There are separate management plans for each kangaroo species harvested commercially in Western Australia

[3] SCARM Report No.57, Agriculture and Resource Management Council of Australia and New Zealand