Full traceability for cattle is once again set to move full-steam ahead as the Canadian Food Inspection Agency (CFIA) renews its push to develop regulations that require mandatory premises identification and animal movement reporting. These two components, together with mandatory animal identification, in place for cattle since July 1, 2001, constitute an internationally recognized traceability system for animal health and food safety purposes.
The impetus for this renewed enthusiasm is the result of several positive meetings with key Agriculture and Agri-Food Canada (AAFC) and CFIA officials late last year where long-serving industry representatives on the Cattle Implementation Plan (CIP) committee became convinced that CFIA is now prepared to align its regulations with recommendations detailed in the CIP.
“Industry is 100 per cent behind the CIP, it always has been,” says longtime committee chair Steve Primrose, a cattle buyer and feedlot and cow-calf operator from Lethbridge, Alta., who has represented the Canadian Livestock Dealers Association and the Canadian Cattle Identification Agency (CCIA) on the CIP committee since its inception.
“Government is 100 per cent moving forward in tandem with industry. It’s looking like the regulations will align with the CIP but interpretation of some of the points from industry’s perspective and the government’s perspective might end up being different. The wording will be important. We know we have our points made to the CFIA and Minister MacAulay is aware of the plan.
“This is one situation where all of industry, and the provincial and federal governments have to buy in with everyone working toward the same goal or it won’t work.”
Volumes could be written about what went on behind the scenes to get the Cattle Implementation Plan to this point since 2011 when then agriculture minister Gerry Ritz called the cattle industry and government to a summit in Saskatoon to agree on a plan to turn full traceability into a reality.
The result was a step-by-step plan to create a voluntary, phased-in approach for premises identification (PID) and movement reporting.
Seventeen major industry groups finalized the details with government consultation and presented what they believed was a final plan to CFIA in 2012 to begin preparing the regulations.
The plan mapped the transition from a proven traceback system, based on cattle identification tags, to a full movement reporting system which appreciates the realities of how cattle are handled and shipped and the limitations of the current technology.
Obviously there have been some delays since then. One big hurdle, says Primrose, occurred when AAFC pushed the implementation of premises ID onto the provinces. It has taken until now to get every province on board, and none have 100 per cent of their producers signed up.
Another setback occurred in 2014, when CFIA went off the Plan and proposed introducing a requirement to read tags in and out of every site with a different PID. The industry balked. This wasn’t in the CIP all had agreed to.
“The beef cattle industry has so many moving parts and since the applied research project to test reading equipment at sales venues across the country showed there isn’t a system that can get 100 per cent (of RFID numbers), the thinking is we can get a big chunk and that’s better than nothing,” Primrose says.
Delegations were sent to other countries to examine different tag reading technologies, but the consensus always came back to the agreed upon CIP as being the best way forward for Canada.
“The CIP has always been about working together to get an understanding of what’s needed and what we can do, and it has always been about the money. Especially now with government cutbacks, there is only a small pool of money, so we have to make sure traceability is affordable. There’s no sense having an elaborate scheme (if) nobody can afford it.”
The CIP is updated every couple of years as circumstances and technology change, so it has always been a work in progress, but it’s now at the point where not much more can be done until the regulations lay out what will be required.
Once the regs are written, Primrose says the industry focus will shift to one of making producers aware of their responsibilities under the new rules. Industry associations can spearhead this effort and Primrose views the mobile field representative program in Aberta as a good example to follow. The CIP recommends a similar nationwide approach for movement reporting.
Defining the cost-sharing principles for implementation and the ongoing cost of traceability as well as negotiating an accord to ensure future governments honour the principles of the CIP are a few issues currently being looked at by industry representatives.
“Our understanding is that when legislation for movement reporting is introduced it will be as agreed in the CIP,” says Saskatchewan rancher Pat Hayes, another CIP committee member.
“What we have to do now as an industry is to make sure we can meet it. It’s important that industry is doing its part by using PID numbers and movement documents to prove CIP works over the next three to five years, or we might end up with an elaborate version,” he says.
While there is general agreement on using the current CIP to craft the regulations, there are still federal-provincial jurisdictional issues to do with premises ID and movement reporting to be resolved, plus a few grey areas surrounding when RFID tags need to be read.
Hays says a substantial investment will also be needed to develop an electronic manifest that ties in with CCIA’s Canadian Livestock Tracking System database and employee training at locations required to read and report RFID numbers to the CLTS database.
A manifest, or movement document, in paper or electronic form, will need to accompany cattle transported from the farm of origin, linked premises or linked commingling premises (private and public community pastures, Crown grazing lands). Producers may choose to link their primary premises to other owned, leased or commingling premises to identify one animal health unit in a PID database.
At a minimum the proposed manifest would require the shipper’s PID, species, head count, loading or unloading date, and license plate of the transport. Each province may include additional information as needed to facilitate commerce.
It wouldn’t be mandatory to report this information to the CLTS database when shipping cattle because all of it will be reported along with the receiver’s PID when the RFID numbers are read at the next farm, feedlot or other intermediate site.
Federally and provincially registered packing plants, dead-stock operators, renderers and exporters, are already required by regulation to read and report RFID numbers to retire them from the CLTS database.
“The CFIA suggests a review three years after the regulations come into force, but industry has asked for five years to get PID databases populated and movement documents in place to create a baseline,” says Saskatchewan rancher and current CCIA chair Mark Elford.
All are in agreement that the first move from the farm of origin or its linked premises will be caught on the movement document. The first reading of RFID numbers to be reported to the CLTS database would be after the cattle are read at the receiving premises, the exception being for sales venues.
Manifests are already in use in Saskatchewan, Alberta, and British Columbia, administered by inspection agencies. It will be a much bigger change for producers, marketers and transporters operating from Manitoba, Ontario and the Maritimes. Quebec already has its own system.
One issue Elford says CFIA is working on, is the tag-reading requirement for cattle crossing provincial borders. Many ranches operate on both sides of a border and in some places cattle graze freely in pastures that span borders. In Saskatchewan, almost all cattle cross the Alberta border to feedlots or packing plants, so there should be no need to handle them when the tags will be read by the receiver.
Simply put, mandatory use of a movement document is a tradeoff for not having to read RFID tags again at sales venues when shipping cattle, says Rick Wright of Virden who represents the Livestock Markets Association of Canada (LMAC) and the CCIA on the CIP committee.
Reading tags at locations where cattle are normally handled in large groups not only slows down trade, but creates bottlenecks that contribute to stress and shrink. Even one per cent additional shrink amounts to a significant loss on each animal for every producer. The losses become staggering when multiplied across a couple of thousand animals per sale at every sale across the country during the busy fall run.
Another important project will test the ability of the CLTS database to accept information from scanned movement documents. Vendors at a November symposium gave assurances that they could create software to scan and automatically upload the required information.
The CFIA has also indicated intermediate sites would not be held responsible for manifests not filled in correctly by producers.
“As an industry, we have to work together to get this done in three years and we might be able to string it out to five. If we don’t, we won’t have a choice,” Wright says. “From Manitoba east, it will take time and a lot of education to get producers and everyone up the line on board with movement documents. It won’t happen without a lot of effort.”
Larry Witzel, of the Ontario Livestock Exchange, who also represents LMAC on the CIP committee, says some preliminary work on manifests is already being done in Ontario. In the past, Ontario markets, dealers and truckers relied on their own documents to collect the basic information they needed to transact business. About two years ago, Beef Farmers of Ontario, and the provincial cattle feeders, markets, dealers and trucker associations along with Ontario Agriculture got together to create one common manifest for deliveries of cattle, bison, sheep and goats to markets, dealers and assembly yards, and another for the delivery of those species to farms, feedlots and packing plants. These manifests ask for the same key information that will be required when movement reporting becomes mandatory.
Currently Ontario manifests are voluntary but uptake by the producers has been progressing, albeit slowly.
More than 50 per cent of Ontario producers have voluntarily registered their PID already.
“The CIP is designed so that we aren’t duplicating what others down the line are doing because it all comes down to cost,” says Witzel.
“I’m hopeful that the regulations will follow the CIP because we need to get to that sweet spot for traceability where we can efficiently get what the CFIA needs to do the job of traceback, but not at a high, high cost for producers, industry or government, regardless of how the cost-sharing works out. If it can be low cost and efficient, it will be a win-win for everyone. It is difficult to do, but hopefully we are getting there because whatever we end up with will be in place for future generations because these things can’t be changed easily after they are in regulation.”
The CIP roadmap was vetted through the CCIA board, which represents all industry sectors, but it is not a lobby group, and last summer the CIP committee felt it needed to provide a more consistent message on traceability in Ottawa, so the Canadian Cattlemen’s Association (CCA), the producers’ chief lobbyist, and well-known on Parliament Hill, took on this role.
CCA executive vice-president Dennis Laycraft and president Dan Darling, led the industry delegation at the meetings with the CFIA last fall that appeared to put full traceability back on the rails.
“We do feel there is an effort to try to get the regulations moving, but making regulations is a long process,” cautions Laycraft. “It could be spring, summer or into fall before we see them.”
He views the Cattle Implementation Plan as a good foundation that gives the industry the capability to handle situations and yet allows people to operate in a practical way. The CCA will be working with LMAC and all associations representing the other sectors on the CIP committee to focus on the most practical method possible to capture RFID numbers. Electronic manifests will become an important tool to capture the rest of the information needed to follow the cattle because it is the best way to create fast data.
Now that the ball is rolling again, the CCA will focus its lobbying efforts on moving the CIP along and making sure the regulations align with it, while keeping provincial cattle organizations informed and engaged. Meanwhile, officials must be reminded of the limitations to today’s technology when it comes to tag retention and reading individual tags under varying conditions without compromising the industry’s concern for animal welfare and meat quality.
“We can’t apply perfect solutions to imperfect problems,” says Laycraft. “The CIP is a work in progress. If we get the right process moving forward, industry will be strong and competitive and we will strengthen the traceback system.”
A copy of the Cattle Implementation Plan can be found on canadaid.ca.