WAG consultation - Implementation of Electronic Identification for Sheep & individual recording for Sheep & GoatsThe 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
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?
Question 3 Should WAG reserve the colour yellow to be used solely with the electronic tag?
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?
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?
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?
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
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