Recently, the CFIA released a document summarizing the comments they received during the Spring 2015 Consultation period for proposed traceability regulations under the Health of Animals Act.
While many of CNGF’s comments were reflected in the document, there were a number of areas CNGF felt it was necessary to follow up on. This article outlines the key points in CNGF’s letter of response to the CFIA, dated December 21, 2015.
CFIA is proposing a 24 hour tag activation requirement. This would mean that tags applied to goats would need to be reported to the administrator as ‘activated’ or applied within 24 hours. CNGF has emphasized that we do not support this proposed requirement for a number of reasons. First, tags will generally be applied to goats before they are moved off the farm of origin, so the movement reporting for those goats will be the tag activation. Additionally, a 24 hour tag activation is an unrealistic requirement as producers in rural and remote areas often have unreliable Internet and cell phone service, which can hamper the timeliness of reporting to the database. In CNGF’s view, tag activation is a movement, so it should be subject to the seven day reporting period as the other movement activities. In addition, a 24 hour activation requirement could impede the speed of commerce without providing any additional assurances or benefits from an emergency management perspective.
CNGF also expressed concerns with a proposed requirement for producers to tag animals for CFIA disease investigation purposes. CNGF is concerned that this is an expense that producers cannot absorb and that the majority of producers will not have an inventory of tags on farm in sufficient quantities to tag all their livestock at a given time. Additionally, disease investigations for goats would most likely be scrapie related and would result in complete depopulation of the herd, an already costly and distressing event for those producers.
With respect to identifiers, CNGF reiterated that producers need the option of using a herd mark or non-RFID identifier. Requiring RFID tags to the exclusion of non-RFID tags would be cost-prohibitive for many goat producers. As CNGF has indicated in previous discussions with CFIA, the value of a goat is significantly less than the value of some other livestock species, and requiring costly RFID tags will financially impact goat producers in a negative way. Many small abattoirs are already reading non-RFID identifiers and this is a non-issue. It is CNGF’s view that industry, not government, should designate the types of identifiers that will best meet the needs of producers.
During the consultation period the question was posed from CFIA whether pet livestock should be included in the regulations. CNGF has pointed out the CFIA needs to clearly define the term ‘pet’ in this context to move forward with meaningful discussion about the inclusion of pet livestock. CNGF reiterated the need to clearly define ‘pet’.
A proposed requirement is that animals that are a result of cross breeding between species subject to the regulations would also be subject to the regulations. CNGF had commented that there are goat/sheep crosses with difference in disease investigation actions. At the time, CFIA’s response was that this would be referred to CFIA vets for further review. In its recent letter to CFIA, CNGF asked whether there has been follow up related to this item.
Finally, CNGF commented on a proposal to repeal the current exemption for operators of abattoirs to report the identification number on foreign indicators. This would mean that reporting activities associated with foreign tags would fall on industry with no tag sale revenues to offset these costs. If imports of goats were numerous, this could be a major expense that the goat sector could not absorb.
CNGF will continue to engage with CFIA at every opportunity on the proposed traceability regulations, advocating for the goat industry in Canada. Producers need to be kept informed of the regulations they will be required to follow, and CNGF will make every effort to keep producers up to date.