Flexibility cuts both ways in traceability discussion

Sep 13, 2013

Freedom is a good thing, but sometimes too many options can cause problems. This was among the findings in the ongoing conversation on traceability in the U.S. cattle industry.

A recently released white paper found variations in states’ traceability program represent challenges to a comprehensive traceability rule. The release followed up presentations from the early August “Joint Forum on Animal Disease Traceability” conference hosted by the National Institute for Animal Agriculture.

“This Forum provided a platform for much-needed interaction between those impacted by the animal traceability rule,” said symposium co-chair Victor Velez, of the California Department of Food and Agriculture. He described the forum as stakeholders coming together and having a candid discussion about the challenges of implementing comprehensive animal disease traceability (ADT) program.

“A lot was learned from this exchange,” Velez said.

A main point that came out of the forum and was highlighted in the white paper was the double-edged sword of flexibility. On the one hand, mandatory ADT rules give states the responsibility to develop and implement their own traceability programs. But while this provides for regional needs, it also creates a problematic level of variation.

Federal rules—the Traceability for Livestock Movement Interstate rule, as published in the Jan. 9 2013 Federal Register (Vol. 78, No. 6)—give a required minimum national standards for traceability. Generally speaking, livestock moved interstate must be officially identified and accompanied by an Interstate Certificate of Veterinary Inspection (ICVI) or some other identifying documentation.

Each state is free to implement traceability programs which meet or exceed the minimum federal rules. State-specific ADT programs are overseen and enforced by both state and federal offices.

When different states interpret those minimums differently, however, it’s a problem. For example, some states accept brands as official identification, while some do not. Others have movement agreements with some states, but not others. This can slow down trade.

A survey of 41 states and their ADT programs completed in July showed a lot of variety. Some of the more noteworthy findings of the survey include:

• 39 states make electronic ICVIs available; two do not.

• 32 states utilize Owner Shipment Statements; nine do not.

• 25 states have commuter herd agreements with other states, 23 have alternative identification agreements and 20 have agreements for movement documents other than ICVI and Owner-Shipper Statements.

• 19 out of 41 States accept brands as official identification: five accept them in all cases and 14 in limited cases.

• 31 out of 41 States breed registries as official identification: 15 accept breed registries in all cases, 11 accept them in limited cases and five did not indicate if breed registries are accepted in all cases or in limited cases.

• Some States require official identification for cattle not covered by the Federal rule: Nine States require official identification on steers and spayed heifers under 18 months of age entering their State and 16 require official identification for sexually intact beef animals under 18 months of age.

• States do not use the same primary animal health IT system: 12 States use Surveillance Collaboration Services (SCS) provided by USDA APHIS VS; four States use Core One obtained direct from Trace First; 13 States use USA- Herds; and 10 Sates use a State-developed system. One State did not provide an IT system name.

USDA’s Animal and Plant Health Inspection Service (APHIS) is in charge of enforcing compliance to the federal minimums. APHIS is also currently working on a document to unify each state’s system. It has yet to be released and no projected date of release was available at the time of publishing.

The problem of sentiments

Another challenge raised by forum participants is that not everyone embraces the mandatory ADT program. As one might expect, the issue of cost and who will/should bear the burden of improved traceability programs is a big stumbling block for many. This latter point was highlighted as a major priority in the whitepaper.

“Producers are concerned that the cost of implementation will fall directly on the producer segment, and potentially disproportionately on the auction yard segment. Full implementation could slow the speed of commerce, or actually impede commerce in general. In other words, if barriers to entry in a specific state are too difficult, buyers and sellers may intentionally ignore commerce with that state.”

Though not mentioned by the whitepaper, this potential could further exacerbate already flagging participating in the negotiated cattle markets. This could worsen the issues with price discovery. Diminished auction yard participation could also cause economic and professional harm to auction yards, especially small ones.

The very issue of “mandatory” can be a problem within the agricultural community. The culture of rugged independence for which farmers and ranchers are often known comes into conflict with government mandates. The paper pointed out that, while voluntary recordkeeping and individual-animal identification has increased in the beef world since the 2003 discovery of Bovine Spongiform Encephalopathy, voluntary and market-driven systems in other industries have had success.

“While programs such as the USDA-funded Scrapie program [for sheep] and the swine industry’s voluntary premises identification program achieved 80 percent involvement, ADT is different as it is mandatory—and mandatory makes a difference.”

Potential solutions

Recommendations which came out of the forum focused largely on understanding and communication between stakeholders.

Especially important was everyone having a “what can we do to make this work” attitude.

Outreach to producers was stressed in many places as essential for the successful improvement of ADT programs. Things like one on-on visits with livestock markets and sale barn veterinarians, informational inserts with producer checks, and state animal health officials speaking at producer meeting were all recommended as best ways to reach producers effectively on the topic.

Overall, recommendations for improving efforts for a more complete and streamlined ADT program included a focus on statelevel resolutions, cooperation between states, minimized cost, greater access to information for producers and stakeholders, and a cooperative, communicative mindset.

“Positive progress for animal traceability has been made to varying degrees across the country,” concluded the paper. “It is important for states and industry to continue to dialogue to develop solutions for issues identified during the forum. The ultimate goal is for the U.S. to have an effective animal health traceability system.” — Kerry Halladay, WLJ Editor