Animal Disease
Traceability (ADT)
April 2014
1
Full Traceability (Pre-harvest)
Birth
Premises
All Production and Points of Commingling
Full Traceability
2
Slaughter
U.S. Traceability Without ADT
- No Official ID -
Location(s) Before
Slaughter
“Traceback” from Slaughter
3
Slaughter or
Current
Location
U.S. Traceability with ADT - “Bookend-plus” System
Location Officially ID’d
Interstate Movements
Trace Forward from ID
Location
4
Slaughter (or
Location Before Slaughter current location)
Traceback from
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
Key to Successful ADT – Official ID
Timely retrieval of complete and accurate information
 Official Identification Records
– Tag Distributions
– Tags Applied
6
Key to Successful ADT – Collection of ID at
Slaughter
IDs must be cross-referenced to carcass
•
Collection of ID at Slaughter
- Maintain cross-reference
of IDs to carcass through
final inspections
- Bag IDs with specimens
and blood samples
7
Key to Successful ADT- Movement Records
Timely retrieval of complete and accurate information
 Interstate Movement Records
– 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
Challenges and Concerns
9
Challenges and Concerns
• 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
10
Challenges and Concerns (Con’t)
• 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
11
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
o Limited resources
12
Current ADT
Implementation
Priorities
13
Make Official ID Easier
• Tags distributed direct
to producers
o 37 of 41 reporting States
providing NUES tags
direct to producers
● Tagging sites
o 34 of 41 reporting States using tagging sites
● 19 tag makers – 67 official eartag options
14
Make Official ID Easier (Con’t)
• Clarify what
devices are
official
15
Make Official ID Easier
• Clarify what
devices are
official
16
Training for Accredited Veterinarians
• NVAP Accredited Veterinarian Training
Module for ADT
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
Traceability Performance Measures
• Measure of time to complete specific
actions needed to process a typical trace
o
o
o
o
–
–
18
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
o Will we be able to determine where animals
tagged more quickly?
19
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
20
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
21
Monitoring and Compliance
22
Monitoring and Compliance
• Initial focus on communication and education
to ensure regulatory requirements understood
• Will now introduce penalties for repeat
violators
23
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
24
Monitoring and Compliance (con’t)
• ADT Monitoring and
Compliance
document
- Provides general
guidelines for uniform
enforcement
practices
- Key reference for VS
resources
- Transparency
25
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
•
26
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
27
Administration of ICVIs
• Organize process to review ICVIs with State
Animal Health officials
• Properly completed by the accredited
veterinarian
–
–
–
–
–
–
28
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
29
Administration of ICVIs (con’t)
• Improve Quality of ICVI Data
30
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.
31
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.
32
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
33
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
Questions?