An open letter to the IMO demanding changes to the livestock trades

Having created one of the world’s greatest exposés in the history of shipping journalism, Australian vet Dr Lynn Simpson has penned this open letter to the secretary general of the International Maritime Organization.

Dear Secretary General Ki Tack Lim,

I wish to raise some concerns regarding the safety, welfare and health of seafarers and live cargo on live animal export vessels worldwide.

I have sailed extensively on livestock vessels, for many companies, under many flags, as a shipboard veterinarian to many destinations. Over my decade of seafaring on these vessels I was often concerned regarding a number of potential and proven crew safety issues.

Vessel stability

Livestock is a dynamic cargo much in the same way passengers are, and the impact of the movement of livestock on the ship and the ship’s motion effects the livestock are both essential considerations for the proper carriage of livestock. It is essential that the stability of the vessel be calculated to ensure:

1. The ships as sufficient stability for the entire voyage noting there are significant weight changes with the consumption of fodder and water. The vessel is also subject to the dynamic effects of wind, potential movement of bulk fodder, free surface effects of wash down, free surface effects of tanks as well as the movement of livestock.

2. The ship cannot be too ‘stiff’ as a rapid roll will injure animals and make working in the pen spaces difficult and dangerous;

3. The ship cannot be too ‘tender’ as the safety issues associated with a slow roll will be accentuated by the movement of livestock in pens.

The free surface issues can be addressed based on intact stability data but there are no mandatory requirements in SOLAS that require the combined impact of animal movement, fodder movement and wind heel to be calculated. Nor is there anything to require the vessel not be too ‘stiff’.

Australia does have such requirements in Marine Orders 43 (section 11 and Schedule 3) but I can find no evidence of such requirements elsewhere.

Gas production by livestock

Live animal export cargo ships go to a range of destinations of extreme temperature difference including but are not limited to the Middle East and Russia. Environmental temperature can influence the amount of gas production on livestock ships.

The crews on these ships generally work on deck from 6:00 to 18:00 with the requisite meal and coffee breaks. For the bulk of the day they are on deck in designated areas to look after allocations of live animals. During this time crew are exposed to potentially toxic levels of gases.

Ammonia (NH3). The international safe working level for humans and the safe housing levels of airborne NH3 for animals (OIE Standards, Animal Welfare animal housing standards) are 25ppm. During extreme heat, or unexpected mechanical ventilation failures that 25ppm level is often exceeded making the environment toxic/ chronically or acutely damaging for both crew and live cargo.

Carbon dioxide (CO2). CO2 from animal expiration builds up with excessive heat and or ventilation deficiencies and the environment can rapidly deplete of oxygen making the deck environment toxic and life threatening to both the crew and the live animals. It is estimated that approximately 500 kg of CO2 is produced per adult cattle per long haul (greater than 10 days) voyage.

Methane (CH4): Crew and livestock are also exposed to methane (CH4) produced by the animal’s digestive system. Whilst methane is non-toxic, it is extremely flammable.

These gases are produced from the live cargo and their sewerage buildup. Monitoring of potential toxic/ dangerous levels of these gases is not currently undertaken on live export vessels as per vessels such as car carriers during vehicle operation.

I would suggest 24/7 monitoring and data logging of these gas levels may provide an improved safety, health and welfare outcome for both crew and live cargo.

Sensible heat

Sensible heat radiated from both the deck environment and the animals themselves can be a safety concern to both crew and live animals. Excess exposure has the known capacity to lead to dehydration and heat stress.

All ships of course have hot areas, namely the engine room. Engine room crews generally work a four-hour duty and get respite in the engine control room when possible.

Many deck crew spend time in the fodder tanks, physically ‘trimming’ the tanks by shovels to ensure fodder moves to the lowest point of the fodder tank to be engaged in the auger to raise it via pipes to the roof level to then fall by gravity to feed troughs or pipes on deck.

These tanks are especially hot to work in and maximum safe exposure times should be considered.

I would suggest electronic 24/7 monitoring and data logging of livestock deck temperatures may provide an improved safety health and welfare outcome for both crew and live cargo. Relative humidity data is of utmost monitoring for animal health.

These ships currently have one disposable wet bulb/ dry bulb thermometer in a central area of each deck. These are read once daily for the noon report all ships must send. My concern is that the temperature being taken before noon in preparation for sending the noon report is not indicative of the daily maximum temperatures endured by both crew and livestock on loaded voyages.

This information is inadvertently used erroneously by the Australian Department of Agriculture for animal health parameters and research. It does not indicate the maximum extreme temperatures to which the crew and animals are exposed.

Maritime security – alarms (fire, piracy, abandon ship)

An anomaly of livestock ships is the noise they create. There is noise from the mechanical ventilation, noise from the fodder and water delivery and when there is a blackout it becomes clear that there is much noise from the livestock that is usually masked by mechanical support systems.

A concern I have had is that alarms cannot be heard/ easily heard over the normal background noise on deck on many of these ships.

Environmental issues

Livestock sewerage and body discharge: MARPOL provides clear advice in Annex IV on where ships can discharge flows from livestock spaces but can be ambiguous regarding where dead animals can be discharged and in what form.

Live animal export ships must wash the decks and discharge sewerage into the sea for heat stress/ gas buildup mitigation strategy. (When loaded for cattle ships, when unloaded for both sheep and cattle ships on their return voyage).

Most ships are fitted with holding tanks for the containment of flows from livestock spaces and these should be discharged at an ‘approved moderate rate’ as specified in the vessels certification.

The problem is on large ships where drainage systems can get overwhelmed and effluent discharged directly into the ocean rather than via the approved arrangement. This can only be avoided with effective large volume drainage systems. Currently vessels have been known to wash our decks and discharge sewerage at night to avoid detection of the discoloration in their wake and all the ships I’ve sailed on have always washed directly into the sea with no livestock sewerage treatment or holding before discharging livestock sewerage.

Considering that most live export vessels do not use onboard holding tanks, it would be reasonable to conclude they are undertaking practices considered in contravention by the International Convention for the Prevention of Pollution.


All but one of my voyages has been conducted under Australian safety standards. To the best of my knowledge and experience these are among, if not the strongest safety standards for Live Animal Export Crew and ships in current legislation.

‘Marine Orders, Part 43, Cargo & Cargo Handling-Livestock’ (MO 43), is managed by the Australian Maritime Safety Authority (AMSA).

I would request that the IMO considers initiating an international standard for the carriage of livestock by sea integrating ‘MO43’ with the OIE animal Health and welfare shipping standards.


Dr Lynn Simpson
BSc, BVMS, MVSc (Veterinary Epidemiology/Surveillance)


To access all of Lynn’s articles for Splash please click here and bear in mind every ship she travelled on, and has written about, is still trading.


Splash is Asia Shipping Media’s flagship title offering timely, informed and global news from the maritime industry 24/7.


  1. Thank you so much Splash, for running this series from the vet, Lynn Simpson. How does the industry that ships live animals get away with failing to control all of these risks? Comparatively, I can’t think of another branch of shipping that is so under-regulated, surely live animal export ships give the rest of the shipping industry a bad name, and should be stopped!

  2. Admirable. I have read Dr Simpson’s articles with great interest and it seems to me that she knows exactly what she is talking about.

    I would like to think that the IMO may take note.

  3. Truth is, this is an industry which will always cut corners wherever it possibly can , and these dreadful ships are easy pickings for this, the areas that need to be seen are kept well out of sight to all but a handful of insiders. So, aside from some very occasional, notified well in advance, lax inspection ‘processes’/box ticking demonstrations, including out of Australia, the operators are left alone to do whatever they like.

    No wonder the animals suffer, though we never hear the true extent of it, and so too we hear little about the suffering of the crew who are very often nothing more than slaves.

    Thanks again to Dr Simpson for her efforts at casting a glimmer of light into this cruel, bloody and shadowy world.

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