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Has traceability fallen off the track?

“What happened to recommendations from the cattle summit in Saskatoon?” was the big question of the day at the Livestock Markets Association of Canada’s annual conference this summer, after two senior Canadian Food Inspection Agency (CFIA) officials explained the reasons behind a new epidemiological assessment of three movement reporting options that weren’t in the cattle implementation plan agreed to by the industry.

The peer-reviewed study contracted by the CFIA raised some serious questions coming as it did after the first round of formal consultation with industry late last year that kicked off the regulation-making process for movement reporting and premises identification.

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The national cattle traceability summit in 2011 was a milestone in many people’s minds because everyone had a will to get something started and compromises were made all around, says Rick Wright of Virden, Man. Wright and Larry Witzel of Ontario represent LMAC on the industry-government advisory committee (IGAC) on traceability. Both also sit on the cattle implementation plan (CIP) working group that is charged with hammering out the details of what was agreed to at the first summit. Wright is also a director of the Canadian Cattle Identification Agency (CCIA).

After the summit 17 industry groups from across the country signed on in support of the cattle implementation plan as the road map to traceability.

“That’s why it was such a shock when government started popping these other options at us without industry input,” says Wright. It raised concerns about whether full traceability was still as important to government as it had been at the outset.

“So it sort of woke a sleeping dog,” Wright says. “It was more than a goodwill gesture on the part of the CFIA to let Veronica and Eric come to the conference. We heard, yes, traceability is still important to government and the CFIA is still listening to industry. We are very appreciative of that because it left us with a much better feeling.”

Veronica McGuire, executive director, program regulation and trade policy, and Eric Aubin, national regulatory and policy officer for livestock and meat traceability, heard first hand from LMAC members as well as CCIA and Canadian Cattlemen Association reps that the industry still supports the original implementation plan. It may not be perfect, but it’s a good starting point and the industry wants to at least give it a good try, and then address any gaps that may become apparent.

McGuire and Aubin explained that the epidemiological study was conducted to gather information for a preliminary cost-benefit analysis in preparation for a second round of consultation with industry planned for later this year. Aubin says a cost-benefit analysis at this early stage is an unusual step. It is normally a treasury board requirement for all proposed regulatory packages. If that final analysis doesn’t demonstrate that the benefits outweigh the costs, it will be much more difficult to bring the regulations forward and get them approved by the minister and cabinet committee.

There’s still a long way to go and there will be opportunities for further industry input as the regulation-making process plays out over the next 18 months or so. The time to engage through your industry association is now, McGuire advises, assuring people that every comment is read to take industry views on board as a fundamental element in the decision-making process.

It’s a slow, complex, rigorous process, she says. Proposals have been circulated, but no final decisions have been made.

“Our objective is to put in place the best system possible, get it right, effective and affordable,” McGuire says.

Controversial study

Lot (group) movement, siting, and lot movement with passive reading were evaluated for use at all intermediate sites, which include every place cattle might be from when the ID tag is applied at the farm of origin (including linked premises) to when tags are retired at slaughter, the rendering plant or export.

The agreed-to cattle implementation plan, the CIP, on the other hand, considers how animals typically enter these commingling sites and the most appropriate and cost-efficient way to handle movement reporting at each without disrupting usual business practices. The key, Wright says, is to make it as painless as possible so it becomes an everyday part of doing business.

The option of lot movement reporting accompanied by a manifest-type document is recommended in the CIP, but it is to be phased in, and only apply at entry to market sites (auction markets, buying stations, assembly yards, electronic auctions).

The siting option being proposed requires the reading of tags to report a given animal on a given day at all intermediate sites. The CIP recommends this system be phased in and only at entry to feedlots because animals typically go through the chute shortly after arrival, and for transient sites, such as fairs, 4-H, vet clinics and AI centres where individual animal handling is the norm.

The CIP considers community pastures and grazing leases as linked premises if the producer so chooses. The important point is that producers would be able to verify the whereabouts of their cattle during the summer grazing season, Wright explains. Reading tags on large groups of cattle isn’t feasible at many of these locations because handling facilities are bare bones at best, particularly where cattle are trailed in, and many such sites don’t have power available.

The first consultation document recommends that premises identification be made mandatory at the national level, and that location be reported whenever cattle move to premises with a different number. Wright says the industry had no qualms with this because premises identification is a basic requirement for full traceability.

The real kicker was the third option, which was ranked best overall by the CFIA. It proposed lot reporting with passive tag reading at all intermediate sites. Industry would be responsible for installing the readers and supporting software, ensuring the system is operational, and reporting whatever tag numbers are captured. CFIA is hoping that, with improved tags and readers over time, the read rate will consistently reach 100 per cent, but operators would not be fined for lower read rates.

The CIP does not support reading individual tags at markets or buying stations, Wright stresses. On top of that, passive reading has never before been presented as an option.

“All through the research projects we were told that anything less than 100 per cent was unacceptable and if that couldn’t be achieved it wasn’t worth the expense of installing the equipment,” he says.

Nor did the study take into account, as stated in the CIP, that the vast majority of cattle coming into markets on a group manifest would go to feedlots where tags would be read and reported as they move in, and again when they are retired at packing plants, renderers or when exported.

The CIP is built on “move-in” reporting, therefore, farms that purchase animals for backgrounding, grassing or as potential breeding stock would need to report those tag numbers.

The CFIA’s objective is to have rapid access to accurate up-to-date information for animal health and food safety investigations. Given that producers have anted up for individual animal identification and CFIA has full access to the information for disease control purposes, Wright says the LMAC’s stand is whomever benefits from movement reporting should pay for it.

Earlier research demonstrated reading tags at auction markets is expensive, didn’t meet the read rate required and provided no benefit for markets and buying stations.

“If holes in the CIP are of real concern to the CFIA, then government should make a long-term commitment to traceability by installing the equipment and taking responsibility for the overhead and ongoing operating costs,” he says.

A copy of the CIP is available on the CCIA website.

Busy year ahead

A demographic study looking into where the cattle come from and go to from the various intermediate sites will also be done to weigh any identified risks.

The document to be prepared for the second consultation with industry will address gaps identified in the first round by industry and factors not in play on the first go-round.

“So through committees and the second round of consultations we will discuss what we will do if costs outweigh benefits, but we can’t just continue to say we can’t have full traceability because we don’t have premises identification,” Aubin states.

Feedback from the second round will be reviewed early in 2015, when they will start drafting regulations that must get past the ministers involved, cabinet committee and treasury board based on how well they will promote safety, mitigate risk, affect industry and Canada’s trade obligations.

After that the proposed regulations and cost-benefit analysis will be published in Canada Gazette Part I, and opened to public comment for 30 to 60 days.

After the comments are reviewed and changes made the final version will be published in Canada Gazette Part II bringing the regulations into force, most likely in 2016.

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