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1
Animal Disease
Traceability (ADT)
April 2014
2
Full Traceability (Pre-harvest)
Birth
Premises
Slaughter
Full Traceability
All Production and Points of Commingling
3
U.S. Traceability Without ADT
- No Official ID -
Slaughter or
Current
Location
“Traceback” from Slaughter
Location(s) Before
Slaughter
4
U.S. Traceability with ADT - “Bookend-plus” System
Slaughter (or
current location)
Trace Forward from ID
Location
Location Officially ID’d Interstate Movements
Traceback from
Slaughter
Location Before Slaughter
9 CFR, Part 86 - Traceability for
Livestock Moving Interstate
General Requirements: Livestock moved
interstate must, unless otherwise exempt:
Be Officially Identified Have ICVI or Other Documentation
– Tag Distributions
– Tags Applied
6
Key to Successful ADT – Official ID
 Official Identification Records
Timely retrieval of complete and accurate information
- Maintain cross-reference
of IDs to carcass through
final inspections
- Bag IDs with specimens
and blood samples
7
Key to Successful ADT – Collection of ID at
Slaughter
• Collection of ID at Slaughter
IDs must be cross-referenced to carcass
– ICVIs
o Most valuable when in
electronic media
– Owner/Shipper
Statements and
alternative movement
documents
o Processes vary – some
aspects are not well
established
8
Key to Successful ADT- Movement Records
 Interstate Movement Records
Timely retrieval of complete and accurate information
Challenges and Concerns
9
• Variation in State
requirements
o Buyers express concern
about difficulty of
determining some State
import requirements
o USAHA Resolution
requested “portal” to
provide clear, easy to
interpret State import
regulations
Challenges and Concerns
10
• Manual recording of official ID numbers
o Rule prohibits applying more than one official
eartag with a different number
o Animals need to be restrained to read and
record official ID number
• Owner-shipper statements (OSS)
o Need to determine most effective ways to
administer OSS
Challenges and Concerns (Con’t)
11
Challenges and Concerns (Con’t)
12
● Admin of OSS and other movement docs
● Compliance with the regulations
● Completion of test exercises to establish
national traceability baseline values
o Limited resources
Current ADT
Implementation
Priorities
13
• Tags distributed direct
to producers
o 37 of 41 reporting States
providing NUES tags
direct to producers
Make Official ID Easier
14
● Tagging sites
o 34 of 41 reporting States using tagging sites
● 19 tag makers – 67 official eartag options
• Clarify what
devices are
official
Make Official ID Easier (Con’t)
15
• Clarify what
devices are
official
Make Official ID Easier
16
o Provides education/outreach
and qualifies for veterinary
accreditation certification
and renewal
• Working with Iowa State
University
• Goal to have this completed
this fiscal year
17
Training for Accredited Veterinarians
• NVAP Accredited Veterinarian Training
Module for ADT
18
Traceability Performance Measures
• Measure of time to complete specific
actions needed to process a typical trace
o State that received tag
o Producer that received tag
o From which State animal shipped
o From which premises animal shipped
– #1 and #2 tracked through tag distribution/tags applied
records
– #3 and # 4 tracked through interstate movement
documentation
19
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
o Will we be able to determine where animals
tagged more quickly?
20
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
21
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
22
Monitoring and Compliance
23
Monitoring and Compliance
• Initial focus on communication and education
to ensure regulatory requirements understood
• Will now introduce penalties for repeat
violators
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
24
Monitoring and Compliance (con’t)
25
Monitoring and Compliance (con’t)
• ADT Monitoring and
Compliance
document
- Provides general
guidelines for uniform
enforcement
practices
- Key reference for VS
resources
- Transparency
26
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
27
Official Identification
• Cattle priority
– Are animals requiring official ID properly
identified
– Are records of tag distribution maintained
and/or reported
• Randomly check
28
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
29
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
• Improve Quality of ICVI Data
30
Administration of ICVIs (con’t)
• FSIS requires collecting and linking identification
devices at slaughter
• APHIS included similar requirements in the
traceability rule.
• Slaughter plant responsible
Collection of ID at Slaughter
31
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.
• 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.
Collection of ID at Slaughter
32
• 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
33
Overview and Guidelines for
Noncompliance
• 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
Compliance Summary
Questions?

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Animal Disease Traceability Rules and Implementation

  • 2. 2 Full Traceability (Pre-harvest) Birth Premises Slaughter Full Traceability All Production and Points of Commingling
  • 3. 3 U.S. Traceability Without ADT - No Official ID - Slaughter or Current Location “Traceback” from Slaughter Location(s) Before Slaughter
  • 4. 4 U.S. Traceability with ADT - “Bookend-plus” System Slaughter (or current location) Trace Forward from ID Location Location Officially ID’d Interstate Movements Traceback from Slaughter Location Before Slaughter
  • 5. 9 CFR, Part 86 - Traceability for Livestock Moving Interstate General Requirements: Livestock moved interstate must, unless otherwise exempt: Be Officially Identified Have ICVI or Other Documentation
  • 6. – Tag Distributions – Tags Applied 6 Key to Successful ADT – Official ID  Official Identification Records Timely retrieval of complete and accurate information
  • 7. - Maintain cross-reference of IDs to carcass through final inspections - Bag IDs with specimens and blood samples 7 Key to Successful ADT – Collection of ID at Slaughter • Collection of ID at Slaughter IDs must be cross-referenced to carcass
  • 8. – ICVIs o Most valuable when in electronic media – Owner/Shipper Statements and alternative movement documents o Processes vary – some aspects are not well established 8 Key to Successful ADT- Movement Records  Interstate Movement Records Timely retrieval of complete and accurate information
  • 10. • Variation in State requirements o Buyers express concern about difficulty of determining some State import requirements o USAHA Resolution requested “portal” to provide clear, easy to interpret State import regulations Challenges and Concerns 10
  • 11. • Manual recording of official ID numbers o Rule prohibits applying more than one official eartag with a different number o Animals need to be restrained to read and record official ID number • Owner-shipper statements (OSS) o Need to determine most effective ways to administer OSS Challenges and Concerns (Con’t) 11
  • 12. Challenges and Concerns (Con’t) 12 ● Admin of OSS and other movement docs ● Compliance with the regulations ● Completion of test exercises to establish national traceability baseline values o Limited resources
  • 14. • Tags distributed direct to producers o 37 of 41 reporting States providing NUES tags direct to producers Make Official ID Easier 14 ● Tagging sites o 34 of 41 reporting States using tagging sites ● 19 tag makers – 67 official eartag options
  • 15. • Clarify what devices are official Make Official ID Easier (Con’t) 15
  • 16. • Clarify what devices are official Make Official ID Easier 16
  • 17. o Provides education/outreach and qualifies for veterinary accreditation certification and renewal • Working with Iowa State University • Goal to have this completed this fiscal year 17 Training for Accredited Veterinarians • NVAP Accredited Veterinarian Training Module for ADT
  • 18. 18 Traceability Performance Measures • Measure of time to complete specific actions needed to process a typical trace o State that received tag o Producer that received tag o From which State animal shipped o From which premises animal shipped – #1 and #2 tracked through tag distribution/tags applied records – #3 and # 4 tracked through interstate movement documentation
  • 19. 19 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 o Will we be able to determine where animals tagged more quickly?
  • 20. 20 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
  • 21. 21 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
  • 23. 23 Monitoring and Compliance • Initial focus on communication and education to ensure regulatory requirements understood • Will now introduce penalties for repeat violators
  • 24. 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 24 Monitoring and Compliance (con’t)
  • 25. 25 Monitoring and Compliance (con’t) • ADT Monitoring and Compliance document - Provides general guidelines for uniform enforcement practices - Key reference for VS resources - Transparency
  • 26. 26 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
  • 27. 27 Official Identification • Cattle priority – Are animals requiring official ID properly identified – Are records of tag distribution maintained and/or reported • Randomly check
  • 28. 28 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
  • 29. 29 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
  • 30. • Improve Quality of ICVI Data 30 Administration of ICVIs (con’t)
  • 31. • FSIS requires collecting and linking identification devices at slaughter • APHIS included similar requirements in the traceability rule. • Slaughter plant responsible Collection of ID at Slaughter 31 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.
  • 32. • 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. Collection of ID at Slaughter 32
  • 33. • 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 33 Overview and Guidelines for Noncompliance
  • 34. • 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 Compliance Summary