A live exporter warned the Federal Government that sheep were at risk of being involved in "catastrophic accidents" and enduring poor animal welfare conditions unless it banned old ships.
In a document obtained by the ABC, Western Australian exporter Wellard called on the government to remove a clause that allowed "substandard ships" to continue to carry livestock.
The report warned exporters used old ships because they were cheaper and that created a "clear financial disincentive to build new ships with higher animal welfare standards".
The exporter produced the document before almost 2,500 sheep dying in an Emanuel Export shipment to the Middle East in August last year.
Footage of that incident emerged last month, prompting the newly appointed Agriculture Minister David Littleproud to demand immediate reviews into the incident and trade.
After obtaining the report, the ABC contacted Wellard and senior executive Fred Troncone confirmed its authenticity.
"The reputation of our industry rests on how well our industry is regulated," he said.
When the Wellard report was produced, Victorian National MP Darren Chester was the minister for infrastructure, which has oversight of maritime regulations.
Mr Chester lost his seat in Cabinet last year and is now responsible for the veterans affairs portfolio.
The ABC yesterday contacted Mr Chester's office for an interview but he was unavailable.

Long-held welfare concerns become a reality

More than a decade ago, the federal government changed shipping standards to ensure export vessels had sufficient ventilation systems.
Ensuring there is airflow in livestock pens is one way to prevent heat stress among animals.
"When that regulation was implemented they said 'look all new vessels built from 2004 must meet this new standard'," Mr Troncone said.
"However, all the vessels that were already in operation prior to that date didn't really have to meet that new standard."
The changes did not come with a so-called sunset clause that would have scrapped those exemptions and forced all operators to meet the new standards.
"In reality that has never happened, the grandfathering clause remains in that piece of regulation," Mr Troncone said.
The Wellard report proposed three major reforms for the live export industry.
They include a sunset clause on the grandfathered provisions, a ban on double-tiered vessels and a 25 to 30-year age limit on livestock vessels.
The company last year wanted the sunset clause to take effect by the end of 2018 but now want it to happen immediately.

Overhaul of standards needed for industry to survive

Western Australia's Agriculture Minister Alannah MacTiernan said she backed Wellard's calls for a sunset clause but wanted it to be phased in "over a number of years".
She also wants federal authorities to bring in stricter animal welfare conditions, including fewer sheep in pens onboard and independent observers on every shipment.
"There has been no incentive for many of these operators to invest in vessels that meet the minimum standards introduced more than 10 years ago," Ms MacTiernan said.
Wellard has spent hundreds of millions of dollars building purpose-built ships for live exports.
Unlike Emanuel Exports, the company linked to more than 5,000 sheep deaths at sea in the last year, Wellard owns the ship it uses for export.
Its recommendations would force out of operation the ships linked to the recent mass deaths — the Awassi Express is 28 years old and the Al Messilah is 38 years old.
Emanuel Exports used the Al Messilah to send 68,000 sheep to the Middle East this week.
The report also argued there were enough younger ships with permission to carry Australian livestock that could cater for all of the nation's sheep and cattle exports.
"I think it's really important that we win the confidence of the public back, demonstrate that we are doing a great job, be open to scrutiny and demonstrate we have a right to be here and provide a very valuable service for both producers and consumers overseas."
The ABC did not source the document from Wellard or Ms MacTiernan.
Wellard's publicly expressed concerns about old live export ships date back as early as 2005.
Former Nationals leader Warren Truss twice held the infrastructure portfolio in the years since, as have Labor's Anthony Albanese and now Nationals backbencher Barnaby Joyce.
In a statement, the Australian Maritime Safety Authority (AMSA) confirmed it self-initiated a review into shipping standards last May.
A spokesperson said AMSA had expected to hold public consultations in the coming weeks.
But those consultations are now on hold until it receives the findings of a snap review the Agriculture Minister David Littleproud initiated last month.
That review is expected to be released later this month.