Confidentiality and producer liability continue to be top concerns of livestock producers when it comes to animal disease traceability (ADT), according to feedback they shared during a recent series of public meetings and comment period conducted by the Animal & Plant Health Inspection Service (APHIS).
A new report issued by APHIS summarizes the most recent feedback the agency received during nine public meetings held across the country in April through July 2017. It was acknowledged by meeting attendees and in written comments that the general ADT framework has been successful at improving the official identification of covered livestock and the documentation of interstate movement and the availability of those records.
The report summarized that the issues of confidentiality and security of information systems remain. Producers indicated support for changes made when ADT was implemented that placed more responsibility for holding their information at the state level.
Producer liability also remains a concern. While earlier discussions on animal identification primarily focused on tracing diseased animals to an individual premises that may not have been responsible for the animal when it was infected, more current discussions also noted concerns over liability related to injury of animals or personnel when working cattle for tagging, manually reading tags, etc.
Cost is on the list of concerns as well, as attendees and commenters said the cost of traceability must be distributed across all sectors of the industry. “In particular, if electronic ID (EID) technology is implemented as the only method of official ID, the cow/calf industry should not cover the cost when the entire industry benefits,” the APHIS report stated. "Commenters noted that other sectors would contribute significantly to the cost of the infrastructure for EID, and as a result, the cost to implement EID would not be borne by the cow/calf sector alone."
Along similar lines, costs for small producers to comply with an enhanced traceability regulation should also be considered. Producers that sell their beef products direct to consumers provided many written comments that expressed their concerns about the cost and burden associated with animal ID, in particular electronic methods. Individuals from this sector also noted that their animals are already traceable from custom slaughter facilities back to their premises.
Overall, the report also cited comments that said APHIS should administer ADT for animal disease control eave marketing opportunities to Agricultural Marketing Service (AMS) programs and the private sector. However, feedback also acknowledged the need for the U.S. to have a national traceability program to meet international trading partners’ requirements for animal disease control and felt that the two topics are linked.
The inclusion of beef feeders in the official identification requirement was the primary topic of discussion at the public meetings. While a large number of stakeholders acknowledged that beef feeders need to be included in the official requirements at some point, the consensus was to address the gaps in the current framework -- which covers beef breeding cattle over 18 months of age and all dairy cattle -- before expanding the official requirements to beef feeder cattle, the report added.
Cost remains the primary concern of producers and representatives from other sectors of the industry regarding EID, and both the reader infrastructure and tags need to be addressed. However, the use of EID would provide substantial savings due to the increased efficiency associated with the technology.
To achieve better traceability, most individuals support the need to apply official identification at the birth premises for animals that are covered by the official regulation. If that is not practical, they support tagging at the change of ownership or the first point of commingling versus at the time of first interstate movement, provided that the animals are traceable to the birth premises. Since beef cattle under 18 months of age would remain exempt until determined otherwise, adult beef animals would be officially identified when first shipped after 18 months of age for ownership change or commingling.
Feedback from the meetings clearly indicated that industry feels the current framework is too flexible and that there are too many exemptions, which causes confusion regarding the regulations.
There was strong consensus that there needs to be more standardization and uniformity of state import requirements, the report added. Preparing interstate certificates of veterinary inspection (ICVIs) has become very complicated. Individuals referenced the requirement by some states to record official identification numbers of dairy steers on ICVIs as one example of how state regulations differ from the federal regulation and from one state to another.
The summary of feedback will also be included as part of the "Animal Disease Traceability (ADT) Summary of Program Reviews & Preliminary Next Step Recommendations" document that will be presented by APHIS at the Traceability Forum -- co-hosted by the National Institute for Animal Agriculture and the U.S. Animal Health Assn. -- on Sept. 26-27, 2017, in Denver, Colo.
Read the full report at www.aphis.usda.gov/traceability/downloads/summary-of-feedback-adt-program.pdf.