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1 Introduction
Purpose
1.1 In December 2003, the
EU Commission adopted
EC Regulation
21/2004; effective from 9 July 2005. This
Regulation is to enable the establishment of an
EU wide traceability system for ovines
and caprines (sheep and goats) to support on-going disease
prevention and any future disease control needs.
1.2 It is important that Scottish sheep and goat
keepers comply fully with Reg 21/2004 as it is a
cross-compliance element of the new Single Farm Payment
Scheme (
SFPS).
1.3 The aim of this consultation is to
obtain your views on the minor changes required to our
current sheep and goats identification and traceability
system to allow us to retain this workable system instead
of the double tagging required under 21/2004.
1.4 Other
UK Administrations will also be
undertaking consultation exercises.
2 Background
2.1 In late 2001,
SEERAD became aware that the
EU Commission was considering the
introduction of an identification and traceability system
for sheep and goats. Commission officials were keen to
ensure that the possibility of outbreaks of disease - such
as the
UK 2001
FMD - was reduced as much as possible.
In the event of a disease outbreak occurring, the control
system they were considering would play a major part in
reducing the spread of infection and ideally shorten the
time taken to bring the outbreak under control.
2.2 Around the same time,
SEERAD were in discussion with our Sheep
(& goat) Industry Stakeholder Group
(
SISG) members to see how the
industry could resume animal movements following
FMD. Although keen to progress this, we
all resolved to ensure that 'lessons learned' from
FMD were incorporated into any new
system to minimise the risk of future disease outbreak. The
State Veterinary Service (
SVS) were especially focussed on
ensuring that the majority of movements onto and off
Scottish locations were recorded and notified to a central
database. This would allow movement tracings to be
undertaken to greatly increase the ability to accurately
establish the locations that animals had been or were
on.
2.3 The outcome of these domestic
discussions was the introduction of the Scottish Animal
Movement System (
SAMS) on 18 February 2002. The five main elements of
SAMS are:
- Baseline tags and tattoos
- Movement tags
- Replacement tags
- Movement Documents (
MDs)
- Notification of movements to the Scottish Animal
Movement Unit (
SAMU)
2.4 In recognition of the importance of
the developing
EU legislation, industry stakeholders
have for over 2 years been heavily involved in discussions
with
SEERAD on obtaining an outcome from the
Commission which was both practical and enforceable for
Scotland.
SEERAD were represented at
EU Council Working Group meetings in
Brussels where intense lobbying and discussion with other
Member State (
MS) officials ensured they fully
understood our concerns on the impracticalities of the
initial draft proposal of 21/2004 for the Scottish system.
Throughout this process,
SEERAD officials continually discussed
with industry stakeholders the proposal's progress and any
issues that were viewed as being impractical for Scotland
due to the specialised and stratified nature of our sheep
industry. We also hosted visits from Commission officials
and Spanish counterparts who were able to see for
themselves the difficulties the draft proposal had for our
industry.
2.5 Regulation 21/2004 was finally adopted
by the Council of Ministers in December 2003 with most of
the elements which would be problematic for the Scottish
industry negotiated out. The most important change being
that Member States could apply for a derogation to retain
their current system instead of the double tagging required
under the proposed new
EU legislation. Some of the other
successes include:
- Removal of the requirement to tag new-born animals
within one month of birth
- No recording of the 12 digit baseline tag number
for each move
- Delaying the introduction of individual Electronic
Identification (
EID) until January 2008 at the
earliest
2.6EU veterinary Auditors visited the
UK in January this year to assess the
existing traceability systems before they could consider
granting the above derogation to keep our current system.
Only minor failures in the Scottish system were discovered
during their visit and we were able to explain how they
occurred and that steps would be taken to ensure they were
not repeated.
2.7SEERAD and
SISG members have been aware for some
time that there are other elements of
SAMS that require minor changes to
comply with the new
EC legislation. The
EU Auditors also identified the same
shortcomings and some additional requirements and these
have been included in the revised system. Some of the
additional requirements arising from the Audit are still
being discussed and are yet to be agreed with
SISG members as indicated in the
following paragraphs which describe the proposed revised
system to be introduced from October 2005.
3. Proposed revised system from
October 2005
3.1 Due to the
EU delay in responding to the
UK derogation application, new Scottish
legislation for
EC Regulation 21/2004 will not be in
place until October 2005. Until then it is critical that
keepers continue to comply with the current system. A
description of the current system is given in Sections 4-8
along with the minor changes that are likely to be required
from October.
SEERAD would welcome your views on the
revised system and in particular where specific questions
are listed.
See also Section 10 on page 13
4. Registration of a location
where sheep or goats are kept
4.1 Currently it is a legal requirement that
any person who starts to keep sheep or goats must within 30
days inform
SEERAD via their local Animal Health
Office (
AHO). This keeper and holding
information will be kept on the central (
GB) holding register. If the holding
where animals are being kept does not already have a
location identifier (
CPH), then one will be allocated. On
receipt of this information, a flock/herd mark will be
allocated for each location where sheep and goats are kept.
Any change to holding or keeper information must be
notified by the keeper to the
AHO within 30 days. Markets and
abattoirs are also required to meet these registration
obligations.
4.2 After 9 July 2005, each keeper must also
provide
SEERAD with details of their occupation
and the type of production (meat or milk) undertaken at the
location. Hauliers are exempt from this requirement. An
exercise will be undertaken in the coming months to obtain
this information from existing keepers.
5. Holding Register (Flock/Herd
Book)
5.1 Currently a flock/herd book is required
for each
CPH (including markets and abattoirs)
and should be available at all times for inspection
purposes. The system requires that movements on and off the
location are recorded in the holding register within 36
hours of the move taking place. Details required are: date
of the movement, total number of sheep/goats in the batch,
either the temporary mark or the baseline
UK flock/herd-mark of each sheep/goat or
the unique individual number of each sheep/goat and the
holding the animal/s came from or went to. For sheep/goats
moving direct from a market the lot number allocated by the
market must also be recorded The keeper must also count the
number of sheep and goats on the holding on 1 January each
year and this must be recorded in the flock book by 31
January; markets and abattoirs are exempt . These records
must be kept for 6 years.
5.2 After October 2005: We understand that the
requirement for one register per
CPH location may be problematic for some
keepers. Similarly we know there are some instances where
two or more
CPHs actually cover one epidemiological
unit when only one
CPH may be required. An exercise will be
carried out to identify these locations to ensure we
achieve a balance between what is practical on the ground
and disease control needs. Further discussions with
SISG members will be held during the
consultation period to finalise this aspect of the system.
This includes specific meetings with crofting
representatives to cover the movements between crofts,
common grazings and apportionments. See Section 9.
5.3 The following new information must be
kept in the holding register:
5.3.1 Both the
CPH and address of the location, the
type of production (milk or meat), name and address of
keeper (this may differ from the location details). The
holding register must also contain details of any
replacement tag (see 6.12) that has been applied on the
holding; markets and abattoirs are exempt from this as they
are not classed as permanent keepers.
5.3.2 Movement off a location including
markets - Name of transporter
, registration number of the haulage vehicle plus
address and/or
CPH of the destination location .
5.3.3 Movement onto a location - the
CPH of the departure location (address
is not sufficient).
5.3.4 Temporary marks are no longer
required in the Flock book as they are not official types
of identification
5.3.5 The new Regulation requires every
permanent keeper (having animals for more than 30
days/year) to record the number of animals on the holding
on a specific date each year and provide
SEERAD with this inventory data within
30 days. Markets, abattoirs, shows, exhibitions and
veterinary practices or clinics are exempt from this
requirement.
5.3.6 We are still considering the best
date for counting the animals. January 1 is the date that
has been traditionally been used but this may be unsuitable
for some sectors of the industry.
Question: Is the 1 January date appropriate or can you
suggest another date that would suit all industry
sectors. See Section 10 on page 13
5.2.7 We are still considering the best
method of returning this inventory data to
SEERAD; options include e-mail,
automated telephone system, fax or by post.
Question: How do you think the inventory return should be sent
to
SEERAD bearing in mind that not all
keepers have access to some of the above
methods of communication. See Section 10 on page
13.
5.4 To assist keepers with the above
requirements we have included a suggested format for a
holding register at
Annex C. Following initial comments from
SISG members we are investigating the
feasibility of allowing movement documents to be used in
the holding register instead of duplicate recording.
However it is important to remember that if the movement
documents are kept for this purpose, they would be required
during any official inspections. An inability to provide
properly completed
MDs to an inspecting officer would be a
breach of the holding register requirement of
EC Regulation 21/2004 and this may have
an impact on any claims under
SFPS - see Section 1.2 on page 3.
6. Identification
requirements
6.1. Tattoos
6.1.1 Under
EU Regulation 21/2004 any animal born
after 9 July 2005 can only have an ear tag applied as the
primary means of identification;
tattoos cannot be used. However they can
still be applied for management or pedigree purposes.
6.2 Ear Tag Allocation System (
ETAS)
6.2.1 Initially the keeper will continue
to be responsible for ensuring that the individual
identification number applied to each animal is unique.
Please keep a record of the numbers on the most recent tags
you purchase. However in November 2005,
GB will be introducing a computerised
Ear Tag Allocation System (
ETAS) similar to the cattle system
currently operating. This will centrally allocate to ear
tag manufacturers a number unique within the
UK, thereby taking this responsibility
away from the keeper. The current preference in Scotland is
for 'leading zeroes' in the tag sequence and
SISG members favour keeping this format
e.g.
UK 541541 000236.
Question: Is it still beneficial to have leading zeroes on
our baseline and replacement tags? See Section 10 on
page 13
6.3 Approval of Ear tags
6.3.1 The new
EU legislation requires all official ear
tags to be of a type approved jointly by
SEERAD,
DEFRA and
NAWDEPC (Wales). This is to ensure they
reach the minimum standard required by this new Regulation
i.e. that they are made of non-degradable material, tamper-
proof, easy to read throughout the lifetime of the animal
and designed to remain attached to the animal without being
harmful to it. They must also not be reusable and the
official inscriptions must be non- removable.
6.4 Baseline
UK marks - Identification at holding
of birth
6.4.1 Currently all animals must be identified
with a baseline tag or tattoo before they leave their
holding of birth for the first time - this includes moves
to any grazing/wintering and onto/off common grazing. A tag
must consist of the letters
UK, followed by the holding's 6-digit
flock or herd mark
, and followed by a unique individual
number of 6 digits.
6.4.2 After 9 July 2005 the following additional
measures will be introduced for all animals born after this
date. They must be identified with an approved eartag
within nine months of birth for extensively reared or
free-range animals (or six months for intensively reared
animals) or before they leave their holding of birth,
whichever comes first.
A tattoo cannot be used for animals born after 9 July
2005.
6.4.3 After October 2005, only animals moving
off a holding for the purposes of veterinary treatment and
returning directly back do not need a baseline
tag/tattoo
6.4.4 Baseline
UK tags can be any colour except for red
which is reserved for replacement tags (see 6.12
below).
6.4.5 Management information may be
applied to these tags provided it does not affect or
interfere with the legibility or sequence of the official
identification number
6.4.6 Please refer to 6.6.1 for
information on older unidentified animals
6.5 Baseline S tags and tattoos (unidentified
animals not on their holding of birth)
6.5.1 Currently older animals that are not
already baseline tagged or tattooed and not on their
holding of birth must have a baseline S mark applied prior
to the animal leaving its current holding.
6.5.2 After October 2005, any animal not already
baseline tagged or tattooed and not on their holding of
birth must have a baseline S tag or tattoo applied before
31 December 2005 or sooner if leaving its current location.
Please refer to 6.6.1 for a more detailed explanation.
6.5.3 After October 2005, only animals
moving off a holding for the purposes of veterinary
treatment and returning directly back do not need a
baseline tag/tattoo
6.5.4 Baseline S tags can be any colour
except for red which is reserved for replacement tags (see
6.12 below).
6.5.5 Management information may be
applied to these tags/tattoos provided it does not affect
or interfere with the legibility or sequence of the
official identification number.
6.6 Animals born before 9 July 2005 and not
currently baseline marked
6.6.1 All animals not already officially
identified (tag or tattoo) will have to be baseline tagged
before 31 December 2005 even if they are not leaving their
current holding before this date. The type of baseline tag
or tattoo to be applied depends on where the animal is
currently located. See
6.4 and
6.5 above.
6.6.2 This requirement arose from the
January 2005 Audit findings. As our current system only
requires single tagging the Auditors were concerned about
lost tags giving reduced traceability especially on farms
where there were also animals that had never been
officially tagged. This is an area where
SISG members have indicated concerns and
further discussions will take place during this
consultation period to achieve a practical solution that
does not jeopardise our derogation to avoid double
tagging.
Question: It is hoped that the tagging of these older
unidentified animals could be carried out while the
animals have been gathered for other purposes. Is the
31 December date practical in terms of normal animal
husbandry issues or can you suggest another date which
is more suitable? Please remember that the Auditors
will be returning in December this year to ensure we
have taken steps to resolve this issue. See Section 10
on page 13
6.6.3 Animals that carry a mark which has
the flock/herd number but no individual number should have
the mark replaced with a baseline tag. The current tag's
flock number will determine which type of baseline tag (
UK or S) should be applied. See
6.4 and
6.5 above.
6.7 From 9 July 2005 - animals to or from a
Northern Ireland location
We intend to allow animals moving between Northern
Ireland and Scotland to move in accordance with the
identification rules in place in the territory of origin.
This will mean animals going to
NI must carry a minimum of a unique
individual identifier - a tag or tattoo if born on or
before 9 July 2005 or a tag if born after 9 July 2005. This
does not include animals transiting
NI to an
ROI destination.
6.8 From 9 July 2005 - imported animals born in
other Member States before 9 July 2005
6.8.1 An animal born in another Member
State (
MS) and brought into Scotland shall
retain its original eartag(s) and identification number.
However once it is in the
UK, in all other respects, the rules
that apply will be the same as for a domestic animal.
6.9 From 9 July 2005 - imported animals from a
third country (non
MS) born before 9 July 2005
6.9.1 Any animal imported from a third
country (non
MS) which after 9 July 2005 has
undergone the checks laid down by Directive 91/496/
EEC and which remains within the
UK, shall be identified with an F tag at
the holding of destination. This shall be done within a
period of 14 days of these checks and certainly before
leaving the holding.
6.10 Animals for Intra-community Trade and
Export including to
ROI
6.10.1 Animals born on or before 9 July 2005 must
comply with current identification rules before they can be
exported or sent for intra- community trade. They must also
comply with relevant export rules.
6.10.2 Animals born after 9 July 2005 and
destined for intra-community trade require two identical
identification marks to be applied. The first means of
ID must be an approved ear tag; the
second can be either an ear tag or an electronic
ID tag or for goats only, a pastern
mark. The rules applying to animals destined for
intra-community trade are exactly the same as for domestic
animals until such time as they are about to leave the
UK. This is the latest point at which
the secondary official identifier must be applied to the
animal. Animals arriving from another
MS must be double tagged before they
leave the exporting
MS. Once it is in the
UK, the rules that apply will be the
same as for a domestic animal. The above includes animals
to and from the Republic of Ireland that transit through
NI.
6.11 Movement Tags
6.11.1 These tags were introduced
following
FMD and provide a visual way of
identifying locations where an animal has been since it
left its baseline holding. The Movement tag format is: S
followed by the 6 digit Flock Number of the animal's
current location e.g.
S 542541. No individual number must be
applied to this type of tag.
6.11.2 Currently, prior to most types of
movement from a location
other than where the animal was baseline
marked, the keeper must apply a movement tag -
this includes all moves to a market. If preferred, the
keeper can record the animal's full baseline tag or tattoo
number in the holding register and on the movement document
as an alternative to applying the movement tag. A maximum
of three official tags (combination of baseline and
movement type) can be applied. An animal with 3 tags
already applied must have its baseline mark details
recorded on the movement document before leaving its
current location and in the holding register.
6.11.3 After October 2005: For moves from
a location
other than where the animal was baseline
marked. The keeper must apply an approved movement
tag for all moves to grazing or wintering and to common
grazing on the basis that the animal returns to the
original holding. If the animal returns direct to the
original location, no further mark is required for either
the journey back or for subsequent moves from the original
location - as long as the movement tag has not been lost or
become illegible.
6.11.4 After October 2005 the following
types of moves are exempt from having to apply a movement
tag:
- Where the move is from the baseline holding
- Where a move is to grazing, wintering, show and
will return to original holding
- Returning to the original location from
grazing/wintering or from common grazing where a
movement tag had been applied at the original
location.
- Short term moves to vets/clinics and for dipping or
shearing if returning to the original location.
6.12 Replacement of tags
6.12.1 No means of official identification
may be removed without prior official
permission. The replacement requirements for each tag
type is as follows:
Baseline tag replacement
6.12.2 Animal still on its holding of
birth: If the
UK baseline mark has become illegible or
has been lost, the keeper must replace it as soon as
possible. The two options are to replace it with an eartag
bearing an identical mark (if known)
or to replace the mark with a
UK tag with the same flock mark but a
different unique individual number.
6.12.3 Where an animal is
not on its holding of birth the keeper
should replace the lost
UK or S tag as soon as possible. The two
options are to apply an eartag bearing an identical number
(if known)
or to apply an R tag bearing the code
UK, followed by the flock or herd mark
of the holding on which the identifier is discovered
missing or illegible, followed by a 6 digit individual
number, followed by the letter R. The identification number
must be unique to the animal and the tag must be red. Any
animal bearing an R tag is not eligible for intra-
community trade
6.12.4 Animals imported before 9 July
2005: As these animals would only have a single
identification mark then the replacement rules would be the
same as those applying to
UK tags and domestic animals (see
immediately above).
6.12.5 Animals imported after 9 July 2005:
If an animal born in another Member State after 9 July 2005
has been brought into the
UK and one of its two identical eartags
has become lost or illegible, the missing tag must be
replaced with an identical tag.
Movement tag replacement
6.12.6 If a Movement tag has been lost or
become illegible the keeper can replace it only if he knows
the flock or herd mark on the eartag. The new approved tag
must display the same details as the tag being replaced. If
the tag details are not known a replacement is not required
Format is S 541541.
6.12.7 Information about all replacement
tags must be recorded in the holding register (flock book)
within 36 hours of the replacement being made.
6.12.8 Operators of markets and
slaughterhouses are not obliged to replace lost tags. We
propose that the responsibility for replacing tags lost at
or on the way to a market rests with the next keeper of the
animals.
Question: What are your views on the new keeper being
responsible for replacing lost tags? Will this give
accurate traceability and how can the industry ensure
this action is carried out? See Section 10 on page
13
7. Movement Documents
7.1 Currently keepers need to use a
Movement Document (
MD) for most types of sheep and goat
moves including 'within-business' moves. Before the journey
commences, the keeper at the departure location must
provide details of both departure and destination
locations, the flock number of the departure location, the
total number of sheep travelling and the keeper's contact
details. They retain one copy of the
MD and the other copy must travel with
the animals to the new location where the receiving keeper
must check the details given are correct and complete the
MD with the date of arrival and their
contact details.
7.2 After October 2005 all movements will require the use of
movement documents - including common grazing
(see section 9), dipping and shearing moves. The
only exception is if one location is a veterinary
surgery/clinic.
7.3 A re-designed
MD to take in the additional
EU requirements will be distributed by
SEERAD to keepers in early autumn, must
be used for all moves.
A copy of the proposed new
MD is at
Annex D At least one
copy of the
MD must travel with the animals and be
handed to the receiving keeper by the haulier.
7.4 As well as the detail required under
the current system, the following additional information
must be stated prior to departure:
CPH of the departure location, name and
address of the keeper (this may differ from the animal's
departure location), the address and or
CPH of the destination location, date of
departure and details of the transport used.
SEERAD welcome your
commentson suggested changes to the layout and size (A4 or A5)
and whether the new
MD should be in duplicate or triplicate
(extra copy for the haulier?) See Section 10 on page
13
7.5 Receiving keepers will be required to
retain a copy of each movement document for a minimum of 6
years.
8. Movement Reporting
8.1 Currently for movements to and from a
Scottish market or to a Scottish abattoir the movement data
supplied by the keeper is transmitted by the market or
abattoir to
SAMU (Scottish Animal Movement Unit No
separate notification is required by the keeper. Moves to
any English or Welsh location are notified by the receiving
keeper
8.2 However sheep arriving at a Scottish
location from any other Scottish location (other than a
market) or from any English or Welsh location must be
reported to
SAMU by the receiving keeper within 3
days of the animals arriving
8.3 After October 2005 the only types of move
which do not have to be reported are when animals move to a
vets surgery or clinic or to tattooists. See section 9 on
moves involving common grazing.
8.4 Sheep moving to Northern Ireland or another Member
State
The keeper at the Scottish departure location has sole
responsibility for reporting this type of move to
SAMU within 3 days of the move taking
place including details of the receiving location. This is
in addition to normal export requirements.
8.5 Sheep arriving from Northern Ireland or another
Member State
The keeper at the receiving location has sole
responsibility for reporting this type of move to
SAMU within 3 days of the animals
arriving and must provide full details of the departure
location.
9 Crofting and common grazing
issues
9.1 Following the January 2005 Audit
visit, we have been asked to tighten up the current
derogation given to crofters on some identification and
reporting requirements. These have been highlighted in the
appropriate earlier sections of this consultation paper. To
ensure the Auditors' required changes can be carried out in
an effective and practical manner we will be meeting with
crofting representatives during the consultation period to
agree a sensible outcome.
10 Partial Regulatory Impact Assessment (
RIA)
10.1 We have assessed the impact the
proposed legislation would have on industry and prepared a
Partial
RIA which is attached at
Annex B.
11 Responses
Please see the following list of questions that you may
wish to consider responding to. This is only a guide and we
would welcome comments on any other areas of this
consultation document.
Annex E gives details on how to respond.
11.1EC Regulation 21/2004 requires keepers
to submit an annual inventory to
SEERAD declaring the number of animals
present on the holding on a set date. Is 1 January a
suitable date for industry ?
11.2 Methods of submitting this data
include e-mail, automated telephone system, fax or mail.
SEERAD would welcome your views on the
best method to ensure that all keepers submit this data
accurately?
11.3UK and S baseline tags require a unique
individual number - currently this must be a 6 digit
number. This sequence often contains leading zeroes e.g.
000234. Would you be content for this format to continue
after 9 July 2005 or would you rather tags did not display
leading zeroes?
11.4 All animals not already officially
identified will have to be baseline tagged before 31
December 2005. Is this a suitable date from a husbandry
point of view?
11.5 The keeper at the next location after
the market has responsibility for re-tagging sheep that
lose their tag on the journey to or at a market.
SEERAD would like to hear your views on
this issue.
11.6 A new design of movement document is
required after 9 July 2005 as more information is required,
including compulsory haulier details. Do you think this
form should be in duplicate (as currently) or
triplicate?
11.7 A new design of movement document is
required after 9 July 2005 as more information is required,
including compulsory haulier details. Would you find an A5
(current) or A4 size more user-friendly?
11.8
Annex C shows the
proposed Herd/Flock Register. Attached to it are Guidance
Notes and we would welcome your comments on the clarity of
these notes in relation to the keeper's responsibility and
required actions.
Livestock
ID & Traceability Branch
SEERAD
11 August 2005
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