dr. neil hammerschmidt - usda update on implementation of adt
DESCRIPTION
USDA Update on Implementation of ADT - Dr. Neil Hammerschmidt, USDA, from the 2014 NIAA Annual Conference titled 'The Precautionary Principle: How Agriculture Will Thrive', March 31 - April 2, 2014, Omaha, NE, USA. More presentations at http://www.trufflemedia.com/agmedia/conference/2014_niaa_how_animal_agriculture_will_thriveTRANSCRIPT
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Animal Disease Traceability (ADT)
April 2014
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Full Traceability (Pre-harvest)
Birth Premises
Slaughter
Full Traceability
All Production and Points of Commingling
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U.S. Traceability Without ADT
- No Official ID -
Slaughter or Current Location
“Traceback” from Slaughter
Location(s) Before Slaughter
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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
Example
– Tag Distributions
– Tags Applied
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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
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Key to Successful ADT – Collection of ID at Slaughter
• Collection of ID at Slaughter
IDs must be cross-referenced to carcass
– ICVIso Most valuable when in
electronic media
– Owner/Shipper Statements and alternative movement documentso Processes vary – some
aspects are not well established
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Key to Successful ADT- Movement Records
Interstate Movement Records
Timely retrieval of complete and accurate information
Challenges and Concerns
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• Variation in State requirementso 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
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• Manual recording of official ID numbersoRule prohibits applying more than one official
eartag with a different numbero Animals need to be restrained to read and
record official ID number
• Owner-shipper statements (OSS)oNeed to determine most effective ways to
administer OSS
Challenges and Concerns (Con’t)
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Challenges and Concerns (Con’t)
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● Admin of OSS and other movement docs● Compliance with the regulations● Completion of test exercises to establish
national traceability baseline valueso Limited resources
Current ADT
Implementation
Priorities
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• Tags distributed direct to producerso 37 of 41 reporting States
providing NUES tags direct to producers
Make Official ID Easier
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● Tagging siteso 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)
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• Clarify what devices are official
Make Official ID Easier
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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
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Training for Accredited Veterinarians • NVAP Accredited Veterinarian Training
Module for ADT
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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 tago From which State animal shippedo From which premises animal shipped
– #1 and #2 tracked through tag distribution/tags applied records
– #3 and # 4 tracked through interstate movement documentation
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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 madeo Will we be able to determine where animals
tagged more quickly?
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Tag RetirementAmes 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
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Proposed Rule to Replace 9 CFR 71.20Approved Livestock Facilities
• Need to update existing regulation – initially based on brucellosis and TB program activities
• Traceability regulations references “Approved Livestock Facility” for specific exemptions
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Monitoring and Compliance
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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
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Monitoring and Compliance (con’t)
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Monitoring and Compliance (con’t)• ADT Monitoring and
Compliance document- Provides general
guidelines for uniform enforcement practices
- Key reference for VS resources
- Transparency
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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
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Official Identification • Cattle priority
– Are animals requiring official ID properly identified
– Are records of tag distribution maintained and/or reported
• Randomly check
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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
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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
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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
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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
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• 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
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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?