WAG consultation - Implementation of Electronic Identification for Sheep & individual recording for Sheep & Goats

The following is the respone from CLA Wales to the above WAG consultation on EID.

COUNTRY LAND AND BUSINESS ASSOCIATION

Consultation on the implementation of Electronic Identification for Sheep and individual recording for Sheep and Goats

Introduction

• The Country Land and Business Association (CLA) represents 38,000 land managers and rural businesses in England and Wales who between them own some 50% of the rural land. A considerable number of these are involved with sheep and/or goats and at their insistence we have been very involved in the discussions leading up to this consultation. During this process we have had a great deal of interest and feedback from many of our members who regard this as a matter of considerable important.

 

• Whilst considering the whole process the CLA has struggled to find some reasonable justification for introducing individual recording of sheep and goats and we are saddened to report that we have not been able to find any. The whole process is disproportionate to any results achieved and is unlikely in our view to provide any meaningful improvement in traceability. Indeed the reliance on unproven technology is likely to lead to a decrease in effective traceability.

 

• Having looked at our replies to consultations held earlier in this decade it appears government has ignored industry fears and has instead proceeded on their unwise course hoping that information technology will rescue them. We are now left having to work out some way of imposing a regulation which is not fit for purpose, and compounds this by having obviously been written by officials who lacked any real knowledge of how the UK sheep industry functions.

 

• That being said the CLA would like to acknowledge the hard work that has been done by the current 'Livestock (Sheep and Goats) Identification Team' in their attempts to implement the 'least worst option'. It is with sadness we note that had Ministers and senior Defra personnel shown similar determination back in 2003, we would not be facing the bureaucratic nightmare that now looms over us.

 

• The CLA would also note that the process shows the inflexibility of EU processes. That such a system should be forced through even though it has been shown to be unwanted, unneeded and unworkable has shown a total lack of democratic accountability.

The Questions

Question 1. Do you agree that WAG should implement the slaughter derogation? This would restrict the movement of finished lambs identified with a single 'slaughter' tag to a dedicated slaughter 'section' of a market (with the option to return home unsold) or to an abattoir , either direct or via a collection centre. If you do not agree please explain why and identify your preferred option.

 

The CLA agrees that the implementation of the slaughter derogation to its fullest extent is probably the least damaging option available. Whilst we can understand worries that some in the industry will not take up the option of an electronic batch tag for lambs to be sold store, we consider that the losses to the industry in these circumstances will be less than would be incurred by insisting that all lambs must have full EID at slaughter. We feel the risk is that NOT implementing this derogation to the full could drive many producers out of the industry leading to a diminishing throughput which would be economically disastrous to many markets and abattoirs.

 

Question 2. Do you agree that the slaughter tag should not include an individual number because of the increased recording burden this would impose on keepers throughout the movement chain?

 

Yes

 

Question 3 Should WAG reserve the colour yellow to be used solely with the electronic tag?

 

Yes

 

Question 4. Do you agree that WAG maintains the current rules for goats and the use of the slaughter derogation remains unaltered for goats?

 

Yes, with the proviso that Government be prepared to revisit this aspect of the derogation in the future should circumstances change.

 

Question 5: Do you agree WAG should implement the simplified replacement rules? If not please explain why and what your proposals are.

 

We have given considerable thought to the replacement rules and consider the simplified replacement rules to be the least unwieldy option available to us within the parameters prescribed by the regulation

 

Question 6. Do you agree that the use of injectable transponders should not be authorised until such time as public health issues have been addressed?

 

The CLA feels this stance is entirely reasonable.

 

Question 7. Do you agree that where a bolus is applied the match up non electronic ear tag should be black with distinguishable letters and numbers?

 

Yes

 

Question 8. Do you agree that where a bolus is used a tattoo should not be allowed?

 

Why not if the keeper finds it useful.

 

Question 9. Do you agree that we should only authorise the use of electronic identifiers and reading equipment, which conform to both the minimum requirements and the Technical Guidelines?

 

Yes

 

Question 10.  Do you agree that the format of the paper record should be as in annex B?

 

 

Question 11. Do you agree that contingency arrangements should be put in place at markets and abattoirs to ensure that normal trading practices are not disrupted in the event of power or equipment failure?

 

There must be provision for these arrangements to be put in place, but the CLA would suggest that they may have to be different at different establishments and should be agreed locally between each establishment and its' local authority, with Defra/WAG available to step in as an arbitrator where agreement cannot be reached.

 

Question 12. Do you agree that if a central database exists, its use should be voluntary but those individuals who wish to take advantage of the exceptions would be required to report all their movements to the central database?

Conclusions

• Frankly the CLA feels the regulation being imposed on the industry is a step backwards in traceability and should be challenged at the highest level. Individual ID for sheep and goats currently throws up too many problems, especially in the UK where flock numbers are several times larger than in other member states and our system is radically different from theirs.

 

• Lack of political will to challenge the EU on this issue seems to have led to a pathetic and unproven belief that technology can solve the problems. The situation reminds us of the tale of the Emperor's new clothes, where in this case the Emperor is not merely naked but displays spindly shanks and a pot belly to a less than admiring world.

 

• "In our view, it is not too late to hold the Commission to account on three bases:

 

1. There was no proper impact assessment of the regulation prior to its enactment.

 

2. The UK is disproportionately affected without any commensurate benefit.

 

3. The regulation militates against the principle of subsidiarity.

 

The CLA asks that WAG take legal advice on the prospect of a formal challenge to the imposition of the regulation with a view to a declaration that it is invalid".

 

WAG should work at EU level to scrap the whole idea of individual ID for sheep and goats. It is bad governance of the worse order, reflective of an obdurate and over-bureaucratic system and an unaccountable, inflexible and insensitive political elite out of touch with reality. In short a disgrace.

 

Country Land & Business Association Ltd

16 Belgrave Square, London, SW1X 8PQ

 

&

 

Hoddell Farm, Kinnerton,

Presteigne, Powys, LD8 2PD.                                                            29 July 2009