Stud Merino Breeders’ Association of W.A.(Inc)
PO Box 135 Claremont WA 6910
Tel. (08) 9384 6466
Fax. (08) 9384 2606
Email: office@merinowa.com.au
www.merinowa.com.au
Sheep & Goat NLIS Regulation Impact Statement (RIS)
Response to the Regulation Impact Statement discussion paper
Stud Merino Breeders Association of WA
November 2013
INTRODUCTION
The Stud Merino Breeders Association of Western Australia (SMBAWA) is the state body
for the Stud Merino Industry in Western Australia with a membership in excess of Two
Hundred Forty and its extensive individual client list gives the SMBAWA a reach across
merino sheep growers within WA.
POSITION
SMBAWA is in support of Option 1.
Enhanced mob-base system
Enhancement of the existing mob-base system with improvements in verification and
enforcement of business rules throughout the supply chain.
SMBAWA rejects Option 2 & 3
These options have an unacceptable financial impost on industry with no guarantee of a better
outcome.
ISSUE RESPONSE
Issue 1:
ABARES is seeking advice on the adequacy of the current National Livestock Identification
System for sheep and goats in meeting the traceability requirements of the National Livestock
Traceability Performance Standards in reducing the biosecurity, food safety, market access
and animal welfare risks.
Response
 SMBAWA is concerned that there does not seem to be any national uniformity of
sheep identification and documentation, as it is a National Livestock Identification
System improvements in these areas should be made.
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Education, a better understanding of the requirements on how to fill out NVD
correctly and lodging a mob base movement on the NLIS data base will go a long way
to improving the traceability requirements.
Implementation of a requirement for a destination PIC on the NVD would give better
traceability forward and back to the properties.
Include another duplicate page on the NVD as the Agents copy to assist with PIC to
PIC transfers
Issue 2:
ABARES is seeking assistance to refine the documentation and verification and compliance
activities required to implement all options.
Response
 SMBAWA is concerned with option 2 & 3 with implementation of individual ID with
the use of RFID tags on sheep & Goats. In compliance with NLIS movements using
individual ID we do not believe the technology is robust enough to handle high
volume through put up to 30,000 to 40,000 animals in short periods of time at
multiple stages.
 Experience from some of our members who use RFID tags have found that they do
not always read and there have been times when the tags have miss read giving a
different number also the retention of tags is a problem through shearing.
 Electronic scanners can be unreliable with different body size and wool lengths of
sheep and the ability to quickly identify miss readers and remove when high volume
flow through is critical would be a logistical problem adding to the cost.
 Option 1 with a mob-base transfer on NLIS data base should also be accompanied
with a faxed or scanned copy of the NVD.
Issue 3:
ABARES is seeking suggestions on any other viable option for improving the National
Livestock Identification System for sheep & goats and information on how they might meet
the National Livestock Traceability Performance Standards.
Response
 SMBAWA at no stage would support an individual animal ID system in sheep &
goats
Issue 4:
ABARES seeks comment on the proposed methodology for the benefit cost analysis for the
decision RIS
Response
 SMBAWA questions the assumption that FMD is likely to occur once or twice in 100
years and that the implementation of option 2 or 3 will have a significant saving to
industry if FMD does occur compered to option 1.
 The cost to industry to implement option 2 or 3 over a 100 years for a proposed 8%
increase in traceability for the short term and 5% over the long term is not acceptable
 Money would be better spent on prevention activities of FMD to decrease the
potential outbreak of FMD in Australia.
 SMBAWA also questions whether any state department would have the resources
available to analyse the NLIS data in the event of an outbreak of FMD
Issue 5:
ABARES seeks the advice on measures and associated cost necessary to achieve that target
for each option.
Response
 SMBAWA believes that the associated costs with option 2 or 3 are under estimated in
the RIS document. Cost of tags in WA are $1.50 and at no stage should an assumption
be made that the price will come down which is suggested in the RIS, to submit an
assumptions that tags will reduce by 10 to 20% per annum would mean tags would be
free after 5 to 10 years. It should be assumed that the price will increase, given a CPI
average of about 2% the price of tags in 10 years will be about $1.80.
 Experience with the loss of RFID tags is high and would add significantly to the cost
in replacements.
 Start-up costs for producers is similar with hardware technology whether they have
small or large number of sheep or goats.
 Replacement cost of technology and scanners etc. has not been accounted for as life
of equipment is limited.
 The RIS suggests that there would be a time saving with option 2 or 3 thus saving on
labour costs, it is the view of SMBAWA that it will be the reverse in the extra time
necessary to scan animals prior to leaving the property, into and out of sale yards and
feedlots, into abattoirs and onto other properties etc. Costs of labour and time would
increase many times over compared to option 1 filling out mob-based NVD and
transfer.
Example:
A trial at Kojonup WA with two men achieved an average read time of 6 seconds per
head with a hand held scanner loading out 500 sheep which included pushing into a
race for reading. It would be assumed that it will take about 50 minutes extra time
before loading for two men compared to 4 minutes to write out NVD and perhaps 10
minutes to enter on the NLIS data base for one man. This is a significant time and cost
which has not been allowed for in option 2 or 3 and has the potential to be duplicated
many times over the animals life.
 Extra costs for option 1 would be needed in better education of producers to meet the
standards required.
Issue 6:
ABARES seeks up-to-date information on the level of traceability both for short run and
lifetime tracing that could be achieved under the three options and any other proposed options
Response
 Mob-base system would give simular or better traceability than options 2 or 3 due to
the likelihood of some animal being missed with scanners.
Issue 7:
ABARES seeks opinions on how the alternative options to the current National Livestock
Identification System for sheep and goats may influence the operation of the Export Supply
Chain Assurance System.
Response
 SMBAWA believe that it will have no benefit to the ESCAS process
 RFID tags like all other tags can be removed or changed so will have no benefit with
ESCAS compliance
 It would be another impost on the importing country which could encourage then to
look else ware for their supply of sheep
Issue 8:
ABARES seeks opinion on potential animal welfare benefits from improving the current
National Livestock Identification System for sheep & goats
Response
 SMBAWA suggests that animal welfare would suffer with an individual ID system as
animals would need handling as individuals rather than a mob increasing time in
yards and stress levels
Issue 9:
ABARES seeks information on the extent and frequency of food safety incidents and how
reductions in this may differ between a mob-based and the Electronic ID tracing systems.
Response
 WA has not had a high number of residue violations and the Dept. has had no
problem tracing them under the mob-based system.
Issue 10:
ABARES seeks opinions on likelihood and extent of trade restrictions that the European
Union may impose on basis of a lack of equivalence
Response
 If markets require electronic ID then let the market explore and implement the
requirements and let producers voluntarily use RFID tags to meet such markets.
 Option 2 or 3 should not be based on the suggestion that Australia may be missing out
on export markets by not having electronic tags.
Issue 11:
ABARES invite submissions about improvement in producer productivity from adopting an
electronic identification system.
Response
 Some stud stock producers have already implemented an RFID system to enhance
their productivity and data recording. This in general is only on a small and affordable
scale where resources are focused on seed stock production which will in turn be
passed onto commercial flocks.
 The RIS option 2 or 3 would only have a small saving on the system which is needed
to do productivity gain and pedigree recording
 The cost of implementing a RFID system to large commercial enterprises would
outweighs any profit that might be gained by such a system.
Issue 12:
ABARES invites comment and seeks relevant data and additional information in order to
refine these costs estimates.
Response

SMBWA believes the cost analysis in the implementation of option 2 and 3 are
inconclusive and false as the assumptions in relation to tag prices and technology goes
against commercial business reality.

Labour cost have not been accounted for in real time it would take industry to
implement options 2 & 3 and would suggest that labour costs to industry would be
greater than 19$m/year in option 3 not 3.4$m/year as indicated.
Summary
SMBAWA believe the mob-based NLIS system with national uniformity and better
producer compliance will achieve the expected National Livestock Traceability
Performance Standards.
Education will be the key driver to achieve such an outcome without the excessive
expense to Industry.
The sheep industry in Australia has been on the decline for many reasons but mainly
financial and the expense of implementation a mandatory RFID tagging system would
see a further decline.
Individual ID of sheep & goats would make compliance more difficult for producers
and industry as every animal will have to be scanned correctly. Scanning large
numbers of animals will be logistically more difficult not to miss some animals.
Kevin Keatley
President
Stud Merino Breeders WA.