Wool Trade

Mulesing alternative category proposed for wool declaration

Terry Sim, February 19, 2020

INDUSTRY and market opposition to categorising mulesing alternatives as ‘non-mulesed’ on the National Wool Declaration has led to a third round of consultation on the issue.

The Australian Wool Exchange yesterday circulated an update proposing that wool from sheep treated with an alternative breech modification method to mulesing be categorised on the NWD as AM – alternative method.

The latest attempt at describing wool from sheep treated with mulesing alternatives on the NWD has been circulated to the 161 submitters to the second round of consultation, with comments required by February 28.

However, the third round of NWD consultation has also raised the issue of AWEX board consensus on the question.

AWEX had previously suggested that the current NM category be broken up into:

NM1: No sheep in this mob has been mulesed, and an alternative method to mulesing has not been used.

NM2: No sheep in this mob has been mulesed, and an alternative method to mulesing, such as freeze branding, clips or intradermal injections (Skintraction), has been used.

However, the latest AWEX update said it was clear from the Round 2 submissions that sectors of the market perceive and value NM as wool coming from sheep that have not been mulesed or had no alternative method (to mulesing) applied.

“The proposal in Draft 1 to use NM1 and NM2 as a potential method of reporting separate methods was thought to be unclear and had little support.

“DRAFT NWD V8 18 Feb 2020 reinstates NM and proposes Alternative Methods (AM) to mulesing be introduced as separate from non-mulesed (NM),” the update said.

In the latest NWD draft, the definition of NM now includes a reference to AM:

NM: All sheep in this mob are not mulesed, and no alternative method (AM) to mulesing has been used.

AM: All sheep in this mob had an alternative method (AM) to mulesing used (may contain non mulesed sheep).

Mixed reaction to AM category solution

Non-mulesed Merino breeder Mark Murphy welcomed the proposed AM category.

“I think it is fantastic, common sense is starting to prevail, it is a lot better option.”

Western District wool grower and Merino apparel manufacturer Peter Small said the new AM option is an improvement on the NM1/NM2 proposal.

But he queried whether AWEX should make a decision on the issue while the pain profile work on the mulesing alternative, sheep freeze branding, had not been finished.

“If it comes out that the process is virtually painless, why couldn’t it be classified as just as good as non-mulesed?

“With the work still being done, it is premature to rush in – because in 12 months’ time they might have to go through this all again,” he said.

“Why not just leave it alone until there is more information?

“I think they are prematurely trying to solve a problem before it can be solved.”

Mr Small said with the current Australian mulesing definition specifying that shears are used, this meant alternatives not using shears could be defined as ‘non-mulesed.’

“I think they are creating more problems than they know how to solve.”

Mr Small said it appeared there was a lack of consensus among AWEX directors on the NM definition question.

“The way it is all unfolding it appears that way.”

WoolProducers wants AWEX to wait

WoolProducers Australia chief executive officer Jo Hall said the body was concerned that AWEX was going to a third round of consultation.

“It appears to me that this new round of consultation indicates that there is not consensus among the AWEX board about what to do with this issue.

“Our second submission to this process called for AWEX to delay making a decision at least until the pain assessment trials were done for freeze branding, so that there was the required information to make an informed decision on this.

“One of our concerns is that what happen if the pain assessment trial for freeze branding come back as unfavourable?” she said.

“We can’t really see that given the cost of that procedure that growers would use it if it is going to be just as painful as mulesing.

“So any decisions to amend categories now could be just causing a lot of confusion unnecessarily,” she said.

Ms Hall said having an extra AM category for freeze branding which does not involve shears, rather than defining it as non-mulesed, was conceding and by default, changing the definition of mulesing.

“This definition has been in place for years and and has been endorsed by all state governments through the Animals Welfare Standards and Guidelines process.

“There has been tens of millions of dollars of growers’ and taxpayers’ money has been spent on alternatives, thinking that that was the issue industry had to address.

“To now bring in the need to identify breech modification is a massive shifting of the goal posts,” she said.

“While AWEX isn’t proposing to change the definition of mulesing, they are proposing to change the definition of non-mulesing, which in effect, has implications for the definition of mulesing.

“And quite frankly, I don’t believe that this is solely the call of AWEX to make,” she said.

“There is a need for far more information from the industry supply chain on this; it’s a really big decision to make and I’m not sure it is the remit of AWEX to making the call.”

Third consultation to ‘get it right’ – Mark Grave

AWEX chief executive officer Mark Grave rejected the contention that there was a lack of consensus among AWEX directors on the NM NWD question.

“It demonstrates that the board wants to consult with industry and to get it right.

“We need to get it right and we are not shying away from that.”

He said AWEX had tried to be very consultative throughout the process. He said the shorter timeframe for submissions on the latest NWD draft was because the issues were known and he believed most people will come to their view quickly.

The consultation is open to all industry stakeholders, he said.

“It is really about trying to contain it and get the feedback as quickly as possible.. that’s what we are aiming to do.”

Although Sheep Central believes AWEX’s Industry Services Advisory Committee did not consider the latest 161 submissions, yesterday’s update said the AWEX board has accepted ISAC recommendations to replace NWD/Mulesing Status code ‘PR’ with ‘AA’ (Analgesic and/or Anaesthetic), where a registered AA product has been used, and  reformat Ceased Mulesing to improve clarity and reduce errors. The definition of CM is unchanged.

“The review of the NWD and the issues surrounding the declaration are challenging and complex.

“The challenge lies in keeping the NWD user friendly whilst delivering meaningful data to the diverse range of stakeholders and customers of Australian wool,” the update said.

Feedback/submissions on the latest NWD draft must be received by the close of business on Friday 28 February 2020. Submissions must be in writing and include the name and address of the author/organisation. Emails are preferred and encouraged to ensure submissions are received by the closing date.

Feedback and enquiries can be sent to Mark Grave, Chief Executive Officer, Australian Wool Exchange Limited, (02) 9428 6110, email [email protected], address PO Box 651, North Ryde, NSW 1670.

Click here to see the latest proposed NWD draft.


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  1. Brian Calderwood, February 21, 2020

    What about a bit of support for the 87 percent of people who still mules. Stop supporting the small minority and support animal welfare that involves mulesing.

  2. Jim Gordon, February 21, 2020

    Jo Hall, you are making a lot of sense. Emotion and self interest is what drives humans. This is ok on a personal level; however, not ok on a community level. If one is in a position of decision making for a community — ie. the wool industry — the emotion and self interest needs to be parked.
    AWEX decision makers, what are you trying to achieve? In my opinion; a rock-solid statutory declaration from wool growers that can be completely trusted by the trade, to be truthful, accurate and hold the highest integrity.
    Simplicity, integrity and participation.
    Simplicity: NM: Sheep that have not been mulesed.
    CM: Mulesing has ceased in this flock of sheep
    PR: Sheep that have had pain relief administered at mulesing.
    BM: Sheep that have had breech modifications, with the application of nitrogen.
    M: Sheep that have been mulesed without pain relief.

    Integrity: The process to police the NWD needs to be clear and easy for the AWEX staff. How does one determine if pain relief has been administered?
    Participation: Have the NWD easy to complete and be recognised by the trade as a useful declaration.

  3. Peter Small, February 20, 2020

    The Australian wool industry risks yet again, turning an issue of critical importance to our customers into a political bun fight. This time it’s the Nation Wool Declaration (NWD).
    Wool growers and their wool brokers should put aside their self-interest and consider the matter from the markets point of view. To achieve efficient flock management, those of us at the production end of the wool pipeline understand the reality that many flocks for some time are going to require removal of undesirable skin folds from the breech of the sheep. However, following adverse publicity by animal rights organisation, some 25 years ago, there was a serious backlash by the consumer, particularly in the Northern Hemisphere, against garments manufactured from wool where the sheep has undergone the mules operation.
    To pacify the market in 2004, the Australian wool industry undertook to cease mulesing by 2010. This we failed to do, causing much distress to early stage processors and their customers, spinners, weavers and knitters. Growers must understand that Australia’s inability to satisfy the market with non- mulesed wool, whilst giving a premium to the relatively small number of growers who can supply non-mulesed, has resulted in serious consequences:
    1. Many important brands deserting wool, perhaps for ever.
    2. Australia losing its pre-eminence as the world’s “price discovery” market for greasy wool.
    3. Australia always regarded as the world’s quality producer of fine wool, now sells at a discount to other Southern Hemisphere greasy wool markets. Growers should be alarmed by these developments.
    But now the current argument regarding the NWD risks inadvertently redefining the definition of mulesing by changing the definition of non-mulesing. The mulesing definition has been widely accepted for years and endorsed by all state governments through their Animal Welfare Standards and Guidelines process as “Removal of skin from the breech and/or tail of a sheep using mulesing shears”.
    How stupid would we be as an industry to undo this accepted definition, particularly as we as wool growers and taxpayers have invested many millions of dollars in attempting to overcome the problem of surgical mulesing, – blood and pain?
    Logic should surely determine that the Australian wool industry should stick to the widely-accepted definition of mulesing and solve the two abhorrent problems in the consumers mind, blood and pain. To this objective, WoolProducers Australia CEO Jo Hall has declared, “There has been tens of millions of dollars of growers’ and taxpayers’ money been spent on alternatives, thinking that that was the issue industry had to address.”
    Some growers have solved the problem of pain and blood through genetics by breeding sheep that do not require mulesing. Admirable whilst this may be, Australia is not producing enough of this wool type to satisfy the market.
    If technology, which we have all invested in, can solve the problem, then our industry should also embrace such solutions. Currently, freeze branding is solving the blood issue, but a definitive answer to pain is still awaiting the result of current research.
    Surely it would be prudent for AWEX to put aside a decision on this matter until these research results are known. The risk of damage from uninformed agro-political argument is just too great. Surely the objective must be to increase the supply of non-mulesed wool (NM) by whatever means science can deliver — genetics or technology.

    • Donald Cameron, February 25, 2020

      “Surely the objective must be to increase the supply of non-mulesed wool by whatever means science can deliver: genetics or technology?”

      The lawmakers of Canberra have in their hands the quickest and most efficient method to increase the supply of non-mulesed wool; the stroke of a pen.

      Most alternatives appear to be fiddling while Rome burns. “Many important brands deserting wool, perhaps forever.”

      Mulesing is seen as an existential threat to the wool industry for there’s no turning back once buyers make the decision to reject mulesed wool, and their number will only increase with time.

  4. Stephen Barratt, February 20, 2020

    Mulesing saves thousands of sheep per year. All AWEX is doing is sending us back to were we were before mulesing started. We would have to crutch sheep twice a year even with the better chemicals that we have today, because of the dags on their breech. Where we live it is easy to miss sheep mustering and they could die from flystrike.

  5. Donald Cameron, February 20, 2020

    The sooner the word mulesing disappears from the English language the better, for the wool industry. Widely abhorred by wool buyers and retail customers alike, mulesing is discredited by countless thousands of others. The so-called “pain relief” produced by those wishing to profit from mulesing has not stopped an increasing number of wool buyers announcing their refusal to buy wool from mulesed sheep.

    • Stephen Barrett, February 20, 2020

      I believe in mulesing sheep, so don’t try to tell me what l need to do. Stop pandering to animal activists.

  6. Chick Olsson, February 19, 2020

    A sensible move by AWEX. More consultation is vital here, and most importantly, our customers are demanding that AM is an option so as to not pollute the NM category. And for all those people who aren’t aware of liquid nitrogen (LN) technology. It has been around for ages, but its after-effects are highly painful and prone to infection like any other surgery.

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