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Animal Disease Traceability (ADT) April 2014. Full Traceability (Pre-harvest). Birth Premises. All Production and Points of Commingling. Slaughter. Full Traceability. U.S. Traceability Without ADT - No Official ID -. Slaughter or Current Location. Location(s) Before Slaughter.
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Animal Disease Traceability (ADT) April 2014
Full Traceability (Pre-harvest) Birth Premises All Production and Points of Commingling Slaughter Full Traceability
U.S. Traceability Without ADT - No Official ID - Slaughter or Current Location Location(s) Before Slaughter “Traceback” from Slaughter
U.S. Traceability with ADT - “Bookend-plus” System Interstate Movements Location Officially ID’d Slaughter (or current location) Location Before Slaughter Traceback from Slaughter Trace Forward from ID Location
9 CFR, Part 86 - Traceability for Livestock Moving Interstate General Requirements: Livestock moved interstate must, unless otherwise exempt: Be Officially IdentifiedHave ICVI or Other Documentation Example 5
Key to Successful ADT – Official ID Timely retrieval of complete and accurate information – Tag Distributions – Tags Applied • Official Identification Records
Key to Successful ADT – Collection of ID at Slaughter - Maintain cross-reference of IDs to carcass through final inspections - Bag IDs with specimens and blood samples IDs must be cross-referenced to carcass • Collection of ID at Slaughter
Key to Successful ADT- Movement Records Timely retrieval of complete and accurate information – ICVIs • Most valuable when in electronic media – Owner/Shipper Statements and alternative movement documents • Processes vary – some aspects are not well established • Interstate Movement Records
Challenges and Concerns • Variation in State requirements • Buyers express concern about difficulty of determining some State import requirements • USAHA Resolution requested “portal” to provide clear, easy to interpret State import regulations
Challenges and Concerns (Con’t) • Manual recording of official ID numbers • Rule prohibits applying more than one official eartag with a different number • Animals need to be restrained to read and record official ID number • Owner-shipper statements (OSS) • Need to determine most effective ways to administer OSS
Challenges and Concerns (Con’t) • Admin of OSS and other movement docs • Compliance with the regulations • Completion of test exercises to establish national traceability baseline values • Limited resources
Make Official ID Easier • Tags distributed direct to producers • 37 of 41 reporting States providing NUES tags direct to producers • Tagging sites • 34 of 41 reporting States using tagging sites • 19 tag makers – 67 official eartag options
Make Official ID Easier (Con’t) • Clarify what devices are official
Make Official ID Easier • Clarify what devices are official
Training for Accredited Veterinarians • NVAP Accredited Veterinarian Training Module for ADT • Provides education/outreach and qualifies for veterinary accreditation certification and renewal • Working with Iowa State University • Goal to have this completed this fiscal year
Traceability Performance Measures • Measure of time to complete specific actions needed to process a typical trace • State that received tag • Producer that received tag • From which State animal shipped • From which premises animal shipped • #1 and #2 tracked through tag distribution/tags applied records • #3 and # 4 tracked through interstate movement documentation
Traceability Performance Measures (Con’t) • States are to complete trace exercises as part of the ADT cooperative agreements • National baseline values for each activity to be calculated in June 2014 • Measuring the same activity over time will reflect if progress is being made • Will we be able to determine where animals tagged more quickly?
Tag Retirement Ames project objectives: • Developing appropriate SOPs for data entry • Evaluating cost of data collection • Evaluating data entry technology products Status: • Start date goal: May 1, 2014 • 1-year duration
Proposed Rule to Replace 9 CFR 71.20 Approved Livestock Facilities • Need to update existing regulation – initially based on brucellosis and TB program activities • Traceability regulations references “Approved Livestock Facility” for specific exemptions
Monitoring and Compliance • Initial focus on communication and education to ensure regulatory requirements understood • Will now introduce penalties for repeat violators
Monitoring and Compliance (con’t) Who is responsible? • APHIS VS is directly responsible for enforcement of the traceability regulation • Same as other federal regulations • Each district needs to cover key aspects of the regulation • Uniform approach State support and cooperation • Partnership ideal • Acknowledge opportunities vary from one state to another
Monitoring and Compliance (con’t) • ADT Monitoring and Compliance document - Provides general guidelines for uniform enforcement practices - Key reference for VS resources - Transparency
Monitoring and Compliance (con’t) • Focus on the key functions/priorities: • Official ID • ICVIs • Collection of identification • Less emphasis: • Areas with less return to traceability • “Gray” areas • Issues still being worked out; e.g., owner-shipper statements
Official Identification • Cattle priority • Are animals requiring official ID properly identified • Are records of tag distribution maintained and/or reported • Randomly check
Administration of ICVIs • Organize process to review ICVIs with State Animal Health officials • Properly completed by the accredited veterinarian • Species • Number of animals • Purpose the animals are to be moved • Address animals shipped from • Address where the animals are destined. • Names of the consignor and the consignee
Administration of ICVIs (con’t) • Properly completed by the accredited veterinarian (con’t) • Official identification number of each animal, unless the species-specific requirements for ICVIs provide an exception: • If official ID not required, the ICVI must state the exemption that applies. • If official ID numbers do not have to be recorded, must state that all animals are officially identified. • Coordinate oversight with the State Animal Health Official
Administration of ICVIs (con’t) • Improve Quality of ICVI Data
Collection of ID at Slaughter • FSIS requires collecting and linking identification devices at slaughter • APHIS included similar requirements in the traceability rule. • Slaughter plant responsible All man-made identification devices affixed to covered livestock unloaded at slaughter plants after moving interstate must be removed at the slaughter facility with the devices correlated with the animal and its carcass through final inspection or condemnation by means approved by [FSIS]. If diagnostic samples are taken, the identification devices must be packaged with the samples and be correlated with the carcasses through final inspection or condemnation by means approved by FSIS. When no samples are taken, the identification devices are to be made available to APHIS after the carcass passes inspection.
Collection of ID at Slaughter • VS personnel must review compliance with these requirements. • All federally-approved slaughter plants are to be visited quarterly (at a minimum) by VS personnel who will observe and report compliance with slaughter collection requirements. • The ADT Monitoring and Compliance document provides a checklist for VS staff to use during site visits.
Overview and Guidelines for Noncompliance • Initial Evaluation of an Alleged Violation • Determination of the Seriousness of Alleged Violations and Subsequent Enforcement and Compliance Action • Initial Evaluation of an Alleged Violation • Enforcement and Compliance Actions *See pages 11-14 in the compliance document
Compliance Summary • Continue to inform stakeholder of the regulatory requirements • Initiate formal actions when appropriate • Focus investigations on priorities • Official ID • ICVIs • Collection of ID at slaughter • Repeated violations