How you can make a submission

To support farmers in making their individual submissions to MPI, a template of DairyNZ positions on the key proposed changes is now available below. The template is editable, and we encourage you to change and add detail to reflect your views. We appreciate this template is quite technical, but we wanted to support you in navigating the extensive changes being proposed.

Word template with key proposed changes Email template with key proposed changes

Submission deadline is 5pm on 30 June 2022

Submissions should be emailed to: animal.consult@mpi.govt.nz by the deadline.

Remember: the template provided only contains the key proposed changes, you can read the full proposed code here. We will continue to work on a more comprehensive DairyNZ submission which will cover all of the proposed changes.

Please be aware that any submission becomes public information and can be requested under the Official Information Act 1982.

Key proposed changes

Outlined below are the key proposed changes to minimum standards (MS) and regulations (Reg). This is not a comprehensive list of all the new or proposed changes to minimum standards and regulations, it also does not include example indicators (EI) and recommended best practice (RBP) standards. For this reason, it is recommended that you also read the full draft code.

Note: some proposed MS have also been recommended to become regulations. Other regulations are standalone.

• Body Condition Score (BCS) proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  BCS must not fall below 3.5 or go above 8.		MS: When the BCS of any animal falls below 3 urgent remedial action must be taken.

• Calf rearing proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  All newborn calves removed from their mother must be offered sufficient good colostrum/colostrum substitute as soon as possible after, but within 2 hours of being removed, to ensure that any calves that have not sucked from their dam receive colostrum within 24 hours after birth.		MS: To ensure their welfare newborn calves must receive sufficient colostrum or good quality commercial colostrum substitute.
  For the first 3 weeks after birth calves must be fed a suitable good quality liquid feed at a rate of no less than 20% of their body weight divided into no less than 2 feeds per day.		RBP: Colostrum, milk, or milk replacer should be fed at a rate of 10-15% BW/d for 1 week, preferably divided into not less than 2 feeds/day.
  A calf must be given suitable liquid feeds that satisfy MS 6a, until the rumen has developed sufficiently to allow it to utilise solids as the sole feed source but must not be fully weaned off milk before 6 weeks of age.		MS: A calf must be given suitable liquid feeds until the rumen has developed sufficiently to allow it to utilise solids as the sole feed source.

• Lying surface, lying space and Intensive winter grazing (IWG) proposed changes

  Note: MS are not exclusive to IWG, but the Reg are.

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Dairy Cattle must have sufficient space for all animals in a herd to lie down and rest comfortably at the same time.		No MS, but EI: stocking density, lying surface and area allocated for lying are sufficient for dairy cattle to lie in a normal posture.
  Dairy cattle must have access to a compressible well-drained surface so they are able to lie and rest comfortably for sufficient periods each day to meet their behavioural needs.	Dairy cattle kept in IWG systems must have access to a well-drained lying area (ie. No surface water pooling) of 10m2/cow.	As above.
  Where a change of feed is incorporated into the diet it must be introduced gradually and abrupt changes must be avoided.		MS: Feeding must be managed so that any injury and/or conditions resulting in ill health, as a consequence of the food or feeding methods, are minimized. RBP: the same as the proposed new MS.
  	Where animals are managed in IWG clean drinking water is available in the grazing area at all times.	MS: All dairy cattle must have access to a daily supply of drinking water sufficient for their needs and that is not harmful to their health.
  Calving cows must be provided with a compressible well-drained surface and effective shelter at least 14 days prior to expected calving date to prevent calves being born into unsuitable conditions.	Calving cows must be provided with a compressible well-drained surface and effective shelter at least 14 days prior to expected calving date to prevent calves being born into unsuitable conditions.	RBP: calving paddocks should provide dry ground, shelter, and protection from adverse weather.
  Persons in charge of dairy cattle must have a documented contingency plan in place to address any anticipated adverse events which can negatively affect the welfare of animals.		RBP: Farmers should make an assessment of the risks of their susceptibility to floods, storms and droughts and develop contingency plans for these events, if necessary.

• Electro-immobilisation devices proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Electroimmobilisation devices must not be used.	Electroimmobilisation devices must not be used.	Electro-immobilisation devices must be used only in a manner that allows animals to breathe normally, demonstrate normal responses to pain and must not be used in place of pain relief when undertaking painful husbandry procedures or significant surgical procedures.

• Electrified top and backing gates proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Electrified backing and top gates must not be used.	Electrified backing and top gates must not be used.	No MS, but RBP: backing gates should be used carefully. They should not be used in a manner likely to result in pain, injury or distress.

• Transport proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Dairy cattle must not be selected for transport to saleyards or slaughter for the first 7 days after giving birth.		No MS/EI/RBP.
  Dairy cattle must undergo suitable preparation for the intended journey including: i) Dairy cows transported to saleyards or slaughter must receive sufficient and effective mineral supplementation prior to transport to prevent metabolic complications. ii) Lactating dairy cattle transported to saleyards or slaughter must be milked as close to transport as possible. iii) Dairy cattle must not be held off green feed for more than 6 hours prior to transport if lactating or for more than 12 hours prior to transport if dry. iv) Water and roughage must be available in collection areas at all times until the point of loading.	i, ii and iv proposed as regulations	MS: (a) The person in charge must examine the selected dairy cattle prior to transport, to ensure that all animals are fit and healthy for transportation. (b) All dairy cattle, including calves, must be fit enough to withstand the journey without suffering unreasonable or unnecessary pain or distress. (these remain in the draft code, those proposed are additional).
  Animals to be culled from the herd must be identified in a timely manner so they can be selected and prepared for transport appropriately.		As above
  	Maximum transport time of 8 hours; Slaughter within 24 hours from last milking; Prohibiting transport to slaughter of lactating end of life dairy cattle via salesyards and via Cook Strait.	*NAWAC would like feedback on these proposed regs, but they will not be developed until the commercial slaughter and transport codes are reviewed.

• Shade proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  All Dairy Cattle must be provided with shade or other means to minimise the risk of heat stress due to warm and/or humid conditions.		All classes of dairy cattle must be provided with the means to minimise the effects of adverse weather.
  Photosensitive animals must be provided with protection from exposure to direct sunlight.		RBP: same as the proposed new MS.

• Heat load threshold proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  	Recommending development of a regulation around a threshold for heat loading at which mitigation must be applied - no specific proposal at present but would like feedback from public consultation.

• Shelter proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  All dairy cattle must be provided with shelter or other means to minimise the risk of cold stress due to cold and/or wet conditions.		All classes of dairy cattle must be provided with the means to minimise the effects of adverse weather.

• Farm facilities proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Farm facilities, equipment and technologies used with animals must be designed, constructed, maintained and used in a manner that minimises the likelihood of distress, pain or injury to animals.		Farm facilities must be constructed, maintained and operated in a manner that minimises the likelihood of distress or injury to animals.
  Dairy Cattle that do not adapt to new technologies must be provided with alternative management.		n/a

• Off-paddock facilities proposed changes

  Proposed MS	Proposed regulation	Current relevant MS/EI/RBP
  Where dairy cattle are kept in off-paddock facilities for more than 12 hours a day for more than 3 consecutive days they must be provided with a well drained lying area with a compressible surface or bedding maintained to avoid manure accumulation.		Where dairy cattle are kept in off-paddock facilities for more than 16 hours a day for more than 3 consecutive days they must be provided with a well-drained lying area with a compressible surface or bedding maintained to avoid manure accumulation.
  River stones must not be used as a surface cover or bedding substrate in off-paddock facilities.		No MS/EI/RBP – reference in general information that calves kept on stones spend less time lying and playing and are colder than calves reared on other surfaces.

• Care of recumbent cows proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Hip clamps must be padded, used in conjunction with a chest strap and must only be used if the cow can promptly support some of her own weight.		MS: If hip clamps are used they must be removed if the cow cannot promptly support her own weight.
  Cows lifted with hip clamps or other devices must be supervised at all times and the number of lifting sessions and their duration must not cause unnecessary pain, injury or distress or exceed what is necessary to help cows to stand.		As above.

• Disease and injury control proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Persons in charge of dairy cattle must have a working relationship with a practising large-animal veterinarian.		MS: professional advice must be sought where there is any significant injury or disease.
  A documented animal health and wellbeing plan must be in place and implemented and must be updated regularly under veterinary guidance.		RBP: Every herd operator should have an animal health plan drawn up and updated regularly with their vet.

• Selection and breeding proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  The animal welfare impacts of animal selection and breeding objectives must be monitored for favourable and unfavourable consequences, and the results incorporated into future objectives, so as to minimise the risks to animal welfare.		No directly relevant MS/EI/RBP. However there is RBP standards under selection of animals for mating to risk the risk of calving difficulty.

• Humane slaughter proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  Any animal rendered insensible by a captive bolt or shot to the brain must receive a secondary procedure to ensure death occurs before recovery from stunning (e.g. bleeding out or pithing).		RBP: All dairy cattle should be bled out as soon as possible after they have been rendered insensible.

• Quality assurance system proposed changes

  Proposed MS	Proposed regulation	For reference: current relevant MS/EI/RBP/Reg where applicable
  (a) Each commercial farm must have a fully documented and auditable quality assurance system that ensures compliance with the minimum standards required by this Code of welfare. (d) The documented system must be verified using performance-based audits on at least an annual basis. Corrective actions must be completed as required by the audits.		RBP: to ensure that standards of animal welfare and husbandry are maintained, each farm should have a quality assurance system that provides documented procedures.