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Firearm Act Review 2016 WAPPA submission

  • 1st  February 2016

    Law Reform Commission of Western Australia Level 12, Westralia Square
    141 St Georges Terrace PERTH WA 6000
    Via email to: firearmsreview@justice.wa.gov.au

    Project 105 - Firearms Act 1973
    Thank you for the opportunity to comment on the Firearms Act 1973 Review. The West Australian Pork Producers Association (Inc) (WAPPA) promotes and safeguards the interests of Western Australian pork producers. We make representation on issues that will enhance the ability of the industry to meet its obligations, be productive and continue to grow its reputation with consumers and the community as responsible livestock producers. This submission relates to Proposal 6: “that the definition of ‘firearm’ in the Firearms Act 1973 (WA) be amended to specifically exclude captive bolts”.
    Pork producers are committed to a high level of animal welfare and are very motivated to ensure humane treatment of the animals in their care.  Consumers and the general public also demand high standards of welfare. A significant aspect of animal husbandry of any kind is the ability to humanely destroy animals in a timely manner.
    Whilst there are several methods of acceptable emergency euthanasia under the Model Code of Practice for the Welfare of Pigs, the use of a captive bolt is a preferred method for many pork producers as it rapidly renders the animal unconscious and is therefore very humane. It is also safe for users. As noted in the discussion paper a captive bolt currently falls under the definition of ‘firearm’ and as such requires a licence. The need for a licence presents an obstacle to more generalised use in the humane destruction of pigs. Whilst there is a limited exemption within the current law, it is considered too narrow in that it may not apply to the broad range of circumstances where it may be necessary to slaughter an animal and therefore does not provide the confidence necessary for producers and others.
    Wider access to captive bolts for euthanasia instead of rifles would also help producers manage health and safety risks on farm as they are a safer option compared to the potential risks of discharging firearms in proximity to other staff and in confined spaces.
    A recent example demonstrated the benefits of easier access to captive bolts when a truck carrying pigs rolled over. Several pigs were injured and need to be euthanized. It was not possible to discharge a rifle in the environment where they were. A captive bolt gun would have been an effective and humane choice if a licence was not required.
    As is noted in the Review of the Firearms Act 1973 (WA) Discussion Paper, Queensland, Victoria, New  South Wales, South Australia, and the Australian Capital Territory and Northern
    Territory have excluded captive bolts from the definition of ‘firearm’ and it is understood that Tasmania will soon follow suit. The United Kingdom also excludes captive-bolt stunning devices used in the slaughter of animals.1 It is also understood that New Zealand does not include “captive bolts” in the definition of ‘firearm’. As an industry we are unaware of any negative consequences that have been experienced due to the exemption in any of these jurisdictions.
    WAPPA strongly supports the proposal to remove captive bolts from the definition of ‘firearm’ under the Western Australian Firearms Act 1973 for the reasons outlined above.
    We look forward to the conclusion of the Review. Yours faithfully

    Jan Cooper Executive Officer