ISSUE:
e-NLIS: Are
you for or against it
THE POLL: The e-NLIS poll is a simple 'For' or 'Against' argument given the already wide debate about it's circumstances and possible deficiencies. If you have a positive view about e-NLIS given what you know and despite any present shortcomings, vote FOR. If you are unhappy about important aspects of the e-NLIS proposal vote AGAINST. (Poll results updated daily). If you would like to contribute a few words of comment to support your position, we'll publish the best of them below. (No names required, just sign with your profession and town, eg "Cattleman / Bourke".)
The animal ID debate in Australia is over. As of July 1 2005, all cattle changing ownership must carry a registered RFID ear tag. The only exception being cattle moving directly off the property of birth directly to a meat processing plant. Although debate is over, sentiments still run high amongst those who opposed the scheme for the many reasons expressed below. The USDA debate begins However the debate in the USA has just begun to warm up. After four years of investigation into alternate devices and possible implementation programs, the USDA has proposed a voluntary RFID tag system be in place by 2009. It is likely the very same arguments for and against U.S. animal-ID (called NAIS) will be aired in the forthcoming USA public debate as were run in the Australian lead up to enabling legislation that made it law here. U.S. producers researching the web about animal-ID have discovered the Cattlefacts site and the wealth of viewpoints about the topic expressed on our 'Issues' page during the debate here. Some have chosen to register their opinions about the U.S. animal-ID proposal with us. Cattlefacts is happy to provide another forum for anyone wishing to express their views about the U.S. animal-ID proposal.
NAIS
about big company $$$$
Small operators the real target:
We are from the US and the farmers and regular producers do not want this. It is for getting rid of the small operators and not to control disease. Our government is even claiming it will control tracebacks for diseases that have long been declared gone. We have 36,000 die of regular flu every year but 200 world wide bird flu cases since 1997 is called a pandemic? Get real. Trace back is still more efficient with brands and normal already in place methods. In America the USDA is actually in partnership with the companies like Monsanto and others and holds the patents and lic. to the big global companies and then turns around and regulates the competition out of business, that is, the small producers. All our export problems come from laws not enforced by USDA on manufacturers of feeds and processing plants which do not follow regulations and get a free ride from USDA and FDA. NAIS allows for these freeloaders to pass on liability to the small producers if passed or we will be fined out of business. Please fight for your freedom to farm and ranch and make a living...vote against. Nils. We are behind you one hundred percent. (Cattle Producer – Oklahoma)
NLIS:
more costly red tape i.e. When cattle sent to sale even if they are clean of chemicals and they are put in with some ones which are not, you will then be libel as you declared them to be free and the buck stops with you. Power lines through a property are treated, who is responsible for them. The power company has an easement, so will we have to fence off power lines? I think the Buck stops with us again. Cost like this, we as a small producer cannot afford and will be forced out. So much for Australia's fair go for all WE can not to risk our reputation in the world by gambling an unproved unworkable system. We are against this stupidity that will destroy our industry many peoples lives. (Cattle Producer – Roma, QLD)Electronic cattle tagging now -
we are next! Industry cost befefit study required Against But: Debate is over- Move on The NLIS tags are dear and unless you have shares in the companies that produce them
you are going to wear significant annual costs. Why are these tags so dear and how much
influence are the companies that make them having on pro-NLIS bodies like CCA? (Johnathon
Tully, District Finance Manager, Elders Rural Bank - Longreach) A new slant on NLIS push We are also cynical enough to think MLA's approach is mainly to
get producers to tell them how many cattle are out there and who's got what. Questions
that they've never had answered, particularly in the case of where their levy comes from,
and if it's being paid. Fundamental questions you would imagine but ones they have no idea
of. (Cattle producer - Nth Qld) Track record pathetic Quality assured politicians? Its another con We must lead the world Will cost $35 per beast Unproven technology & more costs Needlessly adds costs Will harm our competitiveness New LPA ,NVD/Waybills No NLIS for direct shipment Producers to 'Carry the bucket' It's a fraud Just another waste of producer resources Unnecessary cost Only beneficiary Producers have their head in the sand Change for the sake of change Does it work in Victoria? Hasn't worked in UK Too Many Vested Interests Who's kidding who? e-NLIS: More work needed: I feel that NLIS certainly will have a time and place in Australian cattle production however I am certain that the time is not now. Having studied this issue for sometime I agree that a reliable trace back system is required and that in the current world of electronic gizmos and gadgets, it would appear that e-NLIS is the way to go. This would be fine if the following conditions were met:
Unworkable & unviable: Will break industry economically. we already have the best system available out of all of our trading partners. NLIS is unworkable and unviable. (Producer - Nth Qld) Cumbersome, fallible and foolish: expensive, cumbersome, designed for studs and small cattle producers. Highly fallible, therefore undeliverable on a National Scale. Foolish. Driven by people with a record for imposing costs on their fellow cattleproducers. (Cattle producer - Dunkheld, Vic) Boundaries Idea: As the situation presently stands I am against e-NLIS; all in favor of working towards a workable identification system BETTER than what it is now. I would love to see another form of protection for our markets in boundaries being created so that the entire country would not be affected in the instance of a single break out in Tasmania / WA/ the Kimberleys/ NT/ The Gulf'/ etc. This is something that should be done with urgency! It would seem to be a much simpler way of providing some protection until the NLIS problems can be sorted out, and complementary to NLIS in any case. (Cattle producers - CQ)
(Australian Beef Association) Response to NSW Agriculture Regulatory Impact Statement and Draft Regulation on NLIS Mandatory NLIS will be a major cost and administrative impost on the cattle industry. Tags alone will cost in the order of $30 million per year. This is only 16% of the $186 million that we estimate the scheme will cost NSW producers annually. The technology proposed has not been proven to work under extensive conditions anywhere in the world. Australia is moving into a mandatory adoption of a regulatory system that hasnt even been successfully trialled anywhere in the world. Despite the huge scale of this undertaking, there has been no comprehensive system analysis, no national cost benefit analysis and consequently no informed industry consultation and debate. In its current state NLIS is unnecessary, unproven, unenforceable and un-auditable. It is undeliverable by the vast majority of cattle producers. Why NLIS? Advocates of NLIS claim it will:
Advocates of NLIS are mainly technocrats, multi-national tag and reader manufacturers and some enthusiastic and impractical veterinary bureaucrats. Support from processors is a knee jerk reaction to current disease fears, without any research and is conditional on their costs being funded by government or producers. No significant producer organisation is unconditionally supporting mandatory NLIS. They are asking for Government funding as in the other mandatory sites --EU, Botswana and Quebec Province. Should NSW support Mandatory NLIS? Absolutely not. NSW is in danger of committing itself and NSW beef producers to a program that has no clear benefits for industry. Japan is now illustrating that trace back is not consumer protection or disease control. NSW is in danger of committing itself and NSW beef producers to an extremely expensive and technically unproven technology. ABA estimates NLIS Australia wide will cost $7 billion over a decade. MLA has refused to do a cost benefit analysis. Peak Councils including CCA and AMIC and their state counterparts, particularly VFF, that support mandatory NLIS have opposed a cost benefit analysis. This makes us wonder if pecuniary interests rather than the good of industry, are driving this program. The requirement to inform the database of any lost tag on property within 7 days of discovery is Big Brother as in UK without Big Brother paying for it. With a minimum 60% of the NSW 80,000 odd tail tag holders being computer illiterate and rarely mustering their cattle to identify any lost tags (the current tag can only be read by an expensive reader in a suitable set of yards) this is "mission absurd". It is why Victoria is not doing it. Good yards are a missing ingredient on over 50% of the NSW tail tag holdings. One Beef Cattle Officer estimates that only 15% of his area have head bails suitable to safely and accurately insert the RFID tags. Does NSW need NLIS for food safety and trace back? Absolutely not.
Does NSW intend to replace firebrands, tattoos, and earmarks with RFID tags as a permanent ID? If so, the project is hopelessly flawed as 50% of tags can be expected to be lost over a ten-year lifespan of a cow. They can also easily be cut out and replaced. Is the US going to require RF tagging for trace back following BSE? Individual ID is being discussed but it is not a high priority in the US. Secretary of Agriculture, Ann Venneman has stated that they will study various technologies but not move until they are convinced that there are technologies that successfully address the real needs of customers. The US developed Optibrand (retinal imaging for ID) is showing far more practicality for livestock than RFID technology. Japan and Korea are demanding that the US (and Canada) test all animals for BSE to re-enter their markets. BSE tests cost about US$30 per carcase. One processor has already agreed to provide it. NLIS and EU A few years ago, the Chairman of Cattle Council offered the EU the NLIS system to assure them beef from Australia was HGP free and the EU accepted. Despite a $100 to $150 per head premium for EU cattle, Australia has not filled its 7,000 ton quota (80% last year) for some years. Argentina, plagued with FMD and with no trace back system, now provides over 28,000 tons to Europe. The cost of NLIS compliance exceeds the cash premium. We have priced ourselves out of the market. Under the title of "IDEA" the EU began a one million head, four year trial of RFID similar to our NLIS in 1998. The only report we can obtain (the preliminary one) states that their readability of data is running at 82% for electronic tags, 86% for rumen bolus and 62% for injectible transponders. "However, recommendations of a reliable electronic identification system for animal identification must consider other factors such as the tamper proof nature of the system (possibility of identification change between animals) AND USE ON ANIMALS IN EXTENSIVE CONDITIONS, in addition to the retention and recovery efficiency of the electronic tags. Furthermore these conclusions are drawn from only a fraction of the data to be collected over the course of the IDEA project". This is in the market that Cattle Council continually maintains requires our NLIS!! Mandatory ID - global situation No beef importing country, notably the US, Japan and Korea is requesting that Australia have individual ID. What countries actually have individual ID? Europe has a Government funded paper passport system which was designed to try and stop fraud in their highly subsidised market. Hundreds of government inspectors are involved. Government pays but it is destroying the UK beef producer. The EUs million head RFID tag trial summary is above. Quebec Province, The Canadian Government with encouragement from tag manufacturers has spent over $20 million to tag 1.2 million cattle. The situation is reported to be chaotic. Canada (apart from Quebec province) has adopted bar code tags. Twenty five percent of tags disappeared from the database in two years and is now moving to RFID tags and a database. It is baulking at the practicality and cost of recording of stock movement. (A system similar to NLIS). The Canadians estimate it would cost about $40 per head to operate. Victoria, Australia has had compulsory tagging on some classes of cattle for more than two years. Victorian bureaucrats, who run the system, report scanning at saleyards and abattoirs is working well. Independent visitors report a 20% reweighing of cattle pens in saleyards. Victoria is not following any movements from store sales or between properties, which makes the system a Claytons one, as was their first fiasco when they paid for tags for producers to apply but had no readers. To date, there has not been an independent audit to verify the performance, integrity, or cost of the system. The true position in Victoria is unknown. USA has no trace back system at all. Since the BSE case they are considering a system. USDA did a cost benefit analysis on individual ID for the pig industry and came up with a cost of $1billion/annum. Botswana has three million cattle. Government fully funds the use of rumen bolus to try to stop illegal movement of cattle from disease-ridden Zimbabwe. Japan has had no regulatory trace back system and is now testing each beast slaughtered for BSE. They are working with individual tag introduction in their intensive industry. There are No Benefits The NSW Draft Regulation and Regulatory Impact Statement are frightening in their inaccuracy and impracticality. There are NO BENEFITS for commercial producers. NSW Agriculture claims benefits of $24.5 million for Enhanced Response, $27.0 million for Enhanced Export Market Access and $3.2 million for Retained access. These are essentially the same thing counted as a benefit three times. These categories are absurd. The US, Japan and Korea have not granted access to Canadian beef despite identification of the offending cow. To claim trace back facilitates access is commercial rubbish as has been illustrated by our EU position. The claims are further rendered meaningless in the context of the US BSE event. The US has traced back the BSE positive animal and located herd mates and progeny. Yet North Asia maintains its ban on North American beef. Japan and Korea are demanding the US and Canada test all cattle as a condition of access to their markets. North Asia has not been satisfied with successful trace back or the US undertaking to remove SRM from animals over 30 months of age. There is no reason to assume Japan and Korea would not ask the same of Australia. BSE tests cost about A$35 per head. NSW Agricultures analysis on FMD and Blue Tongue acknowledges that while sheep, wild pigs are not tagged, cattle NLIS will have limited benefits to our customers. The claimed saving of $3 million on reduced cost of transaction identifiers is not evident as the current NVD and tail tag system is being retained. The claimed saving of $139,000, as NLIS replaces management tags is ridiculous, as management tags are still required in the paddock and in most producers yards because the RFID tags cant be read by eye beyond a few metres. The claimed saving of $844,000 in reduced stock theft underrates the intelligence of thieves. Cattle thieving is a highly organised crime. Cutting out and replacing tags is a simple operation. The claimed savings of $1,354,000 for 'improved herd productivity' has no basis in fact. All additional handling and time delays reduce the weight gain and meat quality of cattle. Victorian processors are now not required to provide HSCW (originally a core benefit promoted by NLIS advocates). NLIS will not provide or facilitate carcase feedback that is not available already, as processors are refusing to provide it unless it is paid for. The NSW Agriculture Report Understates the Costs NSW Agricultures estimates of costs add up to only 7% of our estimates - based on a practical assessment and discussions with UK and Canadian officials. NSW Agriculture document stated that it will cost $268,000 (presumably 2 officer equivalents) to police what will amount to be an estimated 14,000 NLIS transactions a day. Research into RFID systems in general commerce shows a minimum 3-5% error rate (520 errors/day) plus a minimal tag loss of 2% giving 800 errors per day. On UK figures, at least 50 officer equivalents will be required to police NLIS in NSW. Most Producers will not voluntarily buy readers nor will they pay to transport stock to saleyards or pay associated scanning charges. The recording of movements from property to property will require enforcement. (Victoria isnt even trying). Fifty officer equivalents will cost $7 million per year, at least. RLPBs will not deliver this as unpaid extra work. Agents in Victoria are charging buyers an average $2 per head to read tags at store sales to cover scanning and administrative costs. This is reasonable charging for additional labour and time but producers must also put a value on additional labour and time required by the scheme. Cost Summary Cost per animal Forgone weight gains and actual weight losses (shrink) through additional handlings on farm, between farms and in saleyards (av. 3% - 12 kgs liveweight @ $1.70) $20.00 Government enforcement and administration- $1.40 Readers: estimate 20,000 needed @ $2,000 plus yard
adaption Total annual cost per head per year: $37.28 Cost to NSW per year (five million head) $186.40 million Cost/Befit ($ million)
Cost Benefit Difference We believe that there is no financial benefit to producers and a $186 million recurring annual cost. USDA individual ID pig cost benefit figures and Canadian estimates supports us. This program could sink the Australian beef industry in its battle with cheap South American production and chicken. In the event of a disease or residue problem, it could leave the industry unable to cover the cost of testing, as is being demanded by Japan and Korea. Summary This is a commercial and political time bomb set to explode in NSW after 2005 when the proposed system is planned to start. It will also have major repercussions for government and bureaucrats. Queensland has already moved their start back to a 2005 and their Implementation Committee Chairman has publicly stated that there will only be some use of individual ID in Queensland due to practicalities. This is commonsense but destroys the "national" part of NLIS. Recommendation ABAs position is:
Author and contact John Carter-Tel 02 4832 1179 VOTE: AGAINST e-nlis | FOR e-nlis |
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