14 October 2013

National Livestock Identification System - Consultation Regulation Impact Statement – Standing Council on Primary Industries

On 11 October 2013, ABARES published a Consultation Regulation Impact Statement (RIS) on potential changes to improve the National Livestock Identification System (NLIS) for sheep and goats. The consultation RIS notes that NLIS for sheep and goats currently does not enable tracing of animals to the standards required under the National Livestock Traceability Performance Standards. Accurate and timely livestock traceability is important for managing biosecurity, food safety, and animal welfare risks.

The consultation RIS seeks feedback on the identified options for improving the NLIS, the proposed method for economic analysis and other aspects of the document. Three options for improving the current NLIS have been analysed:

Option 1: Enhanced mob-based system—enhancement of the existing mob-based system with improvements in the verification and enforcement of business rules throughout the supply chain.

Option 2: Electronic Identification (EID) system—the electronic tagging of animals with exemptions for sheep and goats sold directly from their property of birth to abattoirs or export depots.

Option 3: EID system without exemptions.

The Consultation RIS does not identify any preferred option for implementation.

Following the public consultation process, the impact analysis of the options will be revised and updated with a view to making a recommendation on a preferred option to the Standing Council on Primary Industries (SCoPI) as part of the Decision stage RIS.

The public consultation on these proposals runs for eight-weeks, closing 5pm AEDT Friday, 6 December 2013. Further information on the consultation process can be found here.

The consultation RIS was prepared by ABARES for the Standing Council on Primary Industries and assessed as adequate by the Office of Best Practice Regulation.

1 comment to National Livestock Identification System – Consultation Regulation Impact Statement – Standing Council on Primary Industries

  • These comments are in relation to Issue 3.other viable options..
    to possibly more readily enhance the update of options 2 or 3 by producers and processors.

    1) Co-operation required by producers, livestock agents and processors.

    Co operation is best achieved if there are choices under a compulsory system.
    Choice of tag types and preferences very important and not just based on costs.
    use of EID tags in industry should be viewed in cost benefit analysis approach…. not just the price of the eid tags.
    factors such as retention, transponder functionality and management usability of the eid tags are extremely important.Ease and reliability of application are other factors.
    Each tag factor/type has its own characteristics which producers are very aware of and to decrease choice in preference to lowest tendered price tag even though NLIS approved device takes away the producers ownership of the traceability functionality as many farmers view the application of a predetermined tag type as an infringement of their capacity to make their own choice given their previous preferences.They may need to apply another management tag for flock differentiation and race drafting of sheep …. a common sheep practice if a particular GVT sponsored eid tag may not not fit their own management requirements. Tag losses are seen as a difficulty on some farms where as a consequence animals are tagged just prior to shipment off the property to save costs of lost tags and time in sorting animals with lost tags.
    Market driven tag choice with range of prices under an umbrella of a compulsory EID tag system will appease considerable producer opposition to compulsory EID tag traceability.

    2) Functionality
    producers need to have the usual attributes of visual tags for day to day management combined with eid attributes… so the one tag will provide all functionality. Application of tags at lamb marking is imperative to keep labour costs down ( improve productivity) and tag losses must be minimal by animal sale time to decrease labour costs and costs associated with drafting lost tag animals and re tagging.
    Processors must be able to electronically read each eid tag and group carcass/meat to the farm of origin. Effective paddock to plate traceability must be available to customers/consumers both nationally and internationally and farm of origin with description be a part of the marketing from all farm enterprises. Farm enterprise classifications should be established and scheme implement based on animal welfare. production and management systems.This should be included in the options 2 & 3 then all parties then have some ownership in the traceability.. and focus is not only about FMD outbreak but also about supporting all market sectors in the marketing of the produce.

    EID ag prices

    The eid tags prices quoted in this document are difficult to achieve without subsidisation.
    Transponder prices have been reduced due to mass production amortization and a recent second manufacturer producing HDx technology. The tag costs quoted in your document would indicate transponder costs to be below their production costs.
    EID tag prices could be lowered 20% with the implementation of FDxB technology which meets the same ISO standards as the current technology. Readers under the standard can work to dual technology ( ie HDx and FDxB ). there are some disadvantages such as shorter read distances however, multiple animal read systems could still be developed so FDxB could be introduced along side the current HDx system. This would further reduce EID tag costs.
    The EID tag price of $1.30 is realistic for eid tags sold in millions that have retention rates approaching 100% as this price would allow for the costs of the transponders, quality and longevity plastic materials to withstand high UV and last 6=8 years ( provide whole of life traceability status) , cover manufacture costs, laser marking and a commodity margin required to stay in business.

    In summary, a micro cost benefit analysis needs to be performed for the producers to realise the benefits they gain and you need to include their labour in that analysis and a macro cost benefit analysis for the industry as a whole for effective traceability ( 98%) as per your requirements and a cosy benefit analysis for end consumers benefits.
    EID tag choice is of primary importance for participant’s willingness compliance.

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