A Legislative and Regulatory Framework for Traceability
What It Means for Stakeholders
A Concept and Consultation Paper
PREPARED BY: The Canadian Food Inspection Agency
Please note that this draft paper is being provided for discussion purposes only.
This paper represents the initial thoughts and discussions that are taking place at
the CFIA.
Canadian Food Inspection Agency
Contents
Introduction...................................... ...................................... p. 3
Benefits.......................................... ........................................ p. 4
Context........................................... ........................................ p. 4
Technology and Traceability...................................... ............ p. 5
Reporting and Record Keeping.……………….………............ p. 6
Scenarios......................................... ....................................... p. 7
Elements of a Traceability Framework................................... p. 8
Introduction
Traceability is defined as the
ability to follow an item or group
of items - including animals,
plants, food products and
agricultural inputs such as feed,
seed or ingredients - from one
point in the supply chain to
another. For the purposes of
this concept and consultation
paper, the focus will be farm-to-
slaughter traceability of livestock
and poultry species.
The federal government proposes to develop a new federal statute and/or amend existing legislation
and regulations to implement a federal framework for farm-to-slaughter traceability for cattle, sheep,
hogs and poultry separate from food and agricultural inputs. This paper seeks to engage stakeholders
and obtain their views regarding the proposed legislative and regulatory framework for traceability.
This proposal forms part of a long-term plan to establish traceability for the agriculture and agri-food
sector. The paper contains two emergency management scenarios which illustrate the objectives of
this proposal, as well as sample provisions for a legislative and regulatory framework.
In 2006, federal, provincial and territorial (FPT) Ministers of Agriculture committed to phase-in a
National Agriculture and Food Traceability System, and mandated the Industry Government
Advisory Committee (IGAC) to provide a forum for cooperation and coordination among
governments and industry. In the summer of 2009, that commitment was strengthened, and
2011 was set as the target for the implementation of a mandatory, Canada-wide traceability
system for livestock and poultry sectors.
Personal and confidential
information is anticipated to
be collected under the new
framework. The framework
will have strong provisions
for the protection of this
information. These
provisions will outline
authorized access to, and
intended uses of,
traceability information,
and will prescribe penalties
for misuse and unauthorized
disclosure.
The proposed approach is in line with international guidelines
established by the World Organisation for Animal Health. The aim
is to build on global best practices to develop a system for cattle,
hogs, sheep, and poultry, and eventually other livestock species
such as bison, cervids and goats that maximizes protection of
Canadians, agricultural livestock populations, and long term,
sustainable economic benefits for Canadian producers.
It is important to recognize that a legislative framework for
traceability is enabling as it permits the establishment of
regulations for a species (or multiple species). A specific
regulation could address one or more of the three pillars of
traceability: animal identification, premises identification, and
movement and other event reporting. With enabling legislation in
place, regulations can be phased in as the traceability system in
Canada is built. This phased approach will lead to a traceability
framework that is implemented in consultation with stakeholders.
Objective:
To create an enabling legislative and regulatory framework
to support the management of animal and related human
health issues, to facilitate a rapid response to emergencies
resulting from disease outbreaks, natural and other
disasters in the livestock and poultry sectors, and to
enhance food safety by collecting, reporting, holding and
sharing timely, accurate and relevant traceability
information among authorized users.
Benefits of a Legislative and Regulatory Framework
The proposed legislative framework will strengthen the development of traceability in Canada and
will enable governments to better prepare for, and rapidly respond to, animal health issues that
may occur in the livestock and poultry sectors.
The following elements of traceability will strengthen Canada’s existing framework:
• consistent and detailed identification of locations across Canada where animals are
kept, assembled or disposed of;
• identification of additional livestock and poultry species (including horses, cervids and
goats);
• information reporting on livestock and poultry movements and commingling;
• information reporting on the identification of conveyances that transport livestock and
poultry; and
• knowledge of the location of non-commercial operations.
Benefits of a national legislative/regulatory framework for traceability include:
• real time access to information under a well-managed traceability system that can
dramatically reduce the animal health, human health and economic impacts of
emergencies;
• reduced response time and rapid containment of animal disease outbreaks;
• rapid identification of implicated animals in an animal health emergency and the ability
to pinpoint the location of animals or animal products that may have been moved from
affected premises, come into contact with affected animals or products, or otherwise be
at risk due to an outbreak;
• enhanced safety of the food supply; and
• reduced public health risks due to zoonosis.
Beyond being a tool to help with animal health, human health and food safety issues, traceability
could provide additional benefits to industry through reduced economic impacts of animal health
emergencies and improved access to international markets. Markets increasingly demand
traceability for livestock, livestock products, and plant-based foods. Further, market driven and
industry-led traceability initiatives could offer opportunities for value-added activities, including
age verification, grading information leading to optimized breeding decisions and on-farm
efficiencies that can improve the competitiveness of the Canadian industry. Traceability can be
leveraged into new opportunities for growth and international competitiveness, which ultimately
supports the long term sustainability of the sector.
Context - Federal, Provincial and Industry Initiatives
Discussion in Canada on animal identification, an element of traceability, began in 1990 with the
creation of the National Advisory Board on Animal Identification. This was later transformed into
the Livestock Identification Working Group. In 1998, with strong leadership from the cattle and
bison industries, the Canadian Cattle Identification Agency (CCIA) was created to co-ordinate
livestock identification and traceability initiatives. In 2001, the federal government, under the
authority of the Health of Animals Act, introduced regulations for national cattle and bison
identification. With strong leadership from the sheep industry, these regulations were expanded
to include sheep identification in 2004. While federal funding has supported the initiation and
development of national systems, ongoing industry commitment has driven daily maintenance
and operations.
In 2000, Québec became the first province to formalize its commitment to mandatory
traceability. Its National Assembly adopted two bills; the Food Products Act and the Animal
Health Protection Act, governing traceability activities in the province. In 2001, Agri-Traçabilité
Québec (ATQ), a not-for-profit industry-government partnership, was created to lead provincial
agricultural traceability initiatives. This resulted in a comprehensive and mandatory reporting
regime for animal identification, premises identification and movement reporting beginning with
cattle in 2002, sheep in 2004 and cervids in 2009.
Alberta is the second province to commit to mandatory traceability. The Animal Health Act is
Alberta’s primary animal disease control legislation. The provisions for livestock identification
and premises identification provide a foundation for implementing province-wide traceability.
The Alberta Livestock Identification and Commerce Act governs reporting of movement for
certain species of livestock. The Ministry of Agriculture and Rural Development (ARD) works
with the CCIA and Livestock Identification Services Ltd. (LIS) to collect information related to
traceability.
At the FPT Ministers' meeting in 2009, all provinces except Saskatchewan agreed to a
mandatory livestock and poultry traceability framework by 2011. Many provinces, including
Saskatchewan, are continuing to develop provincial traceability frameworks. Some are
developing legislation to mandate traceability, while others are taking a voluntary approach.
The proposed legislative and regulatory framework outlined in this paper will be developed in
consideration of existing provincial policies and standards and will not duplicate existing
provincial approaches. Consistent participation by federal, provincial and industry stakeholders
is key to the success of this initiative.
Technology and Traceability
In Canada, industry groups and data service providers, including the CCIA and Agri-Traçabilité
Québec (ATQ), play an important role in technology decision making. They build and administer
systems that collect and manage traceability information.
Traceability systems centralize and distribute information about the identities of commodities,
their locations, and how they are moved. Producers have traditionally used tags, tattoos,
brands, and paper and computer-based logbooks to track the characteristics and movement of
their animals. Under the current Health of Animals Regulations, the Minister of Agriculture and
Agri-Food has the authority to approve tag technologies. A new legislative and regulatory
framework could provide the government with additional authorities to approve new
technologies that may be used in the future, and to develop a national information portal for
traceability data.
Traceability - Reporting and Record Keeping
Reporting of information to a database as opposed to keeping records is a hallmark of
traceability systems. In situations where only record keeping exists rather than information
reporting, the CFIA would need to contact all of the premises and transporters that may be
implicated in a disease outbreak, have them pull their records and send them to CFIA or visit
these sites to examine the records — a time-consuming process that could cost animal lives
and may permit the rapid spread of disease. Information reported to a database can mitigate
these issues, and is, therefore, an essential component of the proposed framework. Existing
data collected in Canada by organizations such as the CCIA and ATQ provides emergency
responders with a significant base of information. The proposed traceability system will enable
the collection of additional information that can lead to a faster and more effective response,
and will facilitate proactive planning and preparedness activities that can mitigate the impacts of
an emergency.
Consider an animal disease outbreak, which could result in:
• risks to human health
• vast quarantine zones
• large-scale culling of animals
• severe restrictions or bans on exports
• a shutdown of some agricultural operations.
The costs could be significant, with implications for tourism, agriculture, and other industries.
Incomplete and difficult-to-track records during health emergencies have costs, not just in
animal lives, time, money, and risks to human health, but also in terms of Canada’s reputation
and its international trade access, as Canadian producers experienced with the discovery of
BSE in Canada.
The following two scenarios further illustrate the potential impact that an animal disease
outbreak or bio-terrorism event would have on Canadian agriculture, as well as the benefits of a
well developed national traceability system.
Scenarios
Scenario #1: Bovine Spongiform Encephalopathy (BSE)
In the case of BSE, as few as
one animal may test positive for
the disease, which may result in
many more animals being
culled. A traceability system
could provide emergency
responders with traceable herd
information, including
information on the birth cohort
and farm of origin of implicated
animals that could reduce the
impact of such an occurrence.
Without traceability, emergency responders may need to cast a wide net in both space and time
in order to effectively contain the disease. All animals that are possibly implicated must be
included: all possible farms of origin and a wide window of birthdates. With traceability, including
animal identification, premises identification, and movement reporting, governments would be
better equipped to respond rapidly to a BSE event and would have the information necessary to
target any implicated animals. This effective use of traceability data may save money and
animal lives due to the targeted and effective nature of the response.
BSE or "Mad Cow Disease"is a progressive, fatal
disease of the nervous system of cattle. It is what is known
as a transmissible spongiform encephalopathy (TSE).
Other TSEs include scrapie in sheep, chronic wasting
disease in deer and elk, and Creutzfeldt-Jakob disease in
humans. Although the exact cause of BSE is unknown, it
is associated with the presence of an abnormal protein
called a prion. There is no treatment or vaccine currently
available for the disease.
Scenario #2: Hypothetical Foot-and-Mouth Disease Outbreak
“Foot-and-mouth disease (FMD) is a severe, highly infectious viral disease of cattle, swine,
sheep, goats, and other ruminant species. FMD is not a threat to human health. Infection is
characterized by large blisters in the mouth, on the teats, and between the toes that burst to cause
painful raw sores and even loss of the hooves. Animals cannot eat, drink, or walk, nor can they be
milked. FMD virus rarely kills animals, but the recovered animal usually loses its productivity of
milk or meat. FMD-infected animals shed enormous amounts of virus, and this easily infects other
animals in direct contact—by inhalation of virus-infected aerosols or ingestion of excretions from
an infected animal—and at a distance—by virus contamination of water, feed, and bedding or by
virus carried for many miles in atmospheric plumes of aerosol droplets. FMD is the most
infectious virus known; it is some 20 times more infectious than human smallpox. FMD virus
remains viable in the bone marrow of frozen carcasses for months. Cattle that have recovered
from disease—and perhaps some vaccinated animals that were subsequently exposed to live
virus—may also carry FMD virus in their throats for long periods and be sources of infection for
other animals. Left unchecked, FMD virus will spread through all the susceptible animals in a
country.1”
As evident from the 2001 outbreak of foot-and-mouth disease in the United Kingdom, the
disease could be introduced by something as simple as one unreported incident of a
notifiable disease and accidental feeding of infected and untreated waste. The disease could
pass from one infected animal to the rest of the herd on that farm, and
then to other animals at other premises.
An outbreak in Canada of highly infectious foot-and-mouth disease
would be a national disaster with massive implications for agriculture
and tourism unless governments have the tools to respond quickly,
accurately, and effectively. A record keeping system would be
insufficient for the CFIA’s efforts to manage an FMD outbreak. By the
time all of the necessary records were pulled, analyzed, and quarantine
zones were established, all of Canada could be implicated in the
emergency. The speed and efficiency by which this virus can spread
could impact the agriculture operations of the entire country.
An FMD outbreak would have a significant negative impact on the
livestock industry due to loss of production, loss of export markets, and
loss of animals. However, an established traceability system could allow
for a rapid response and an immediate, targeted quarantine of
implicated animals.
It is estimated
that an FMD
outbreak could
cost the Canadian
economy $10–50
billion.
In a large-scale
FMD outbreak,
effective disease
control and zoning
strategies could
reduce the impacts
on the Canadian
economy by an
estimated $28
billion.
1 Centaur Science Group, 2004.
2 Some of these elements are already in place under P. XV of the Health of Animals Regulations, but are included here
for completeness
3 For the purposes of this paper, “animal” or “animals” refer to livestock and poultry species.
Elements of a Traceability Framework
1. Animal identification
.. The use of approved identifiers (tags, documents), which are applied to an animal and
reported to a database.
2. Premises identification
.. The allocation of a unique identifier which corresponds to a defined geographical
location.
3. Movement and event reporting
.. The reporting of animal movements and other events to a database.
4. Authorized use and sharing of information
.. Will define authorized access to, and intended uses of, traceability information.
5. Compliance and enforcement
.. The principles and actions to be followed with the goal that regulated parties operate in
full compliance with the proposed traceability system.
6. Reporting and record keeping
.. Standards and protocols for the reporting of traceability information.
1. Animal identification2
The current Health of Animals Act and the attendant regulations prescribe national animal
identification requirements for cattle, sheep and bison. Consistent with the intent of the existing
system, the proposed framework would provide enabling legislative authority for elements of
animal identification. This authority would permit the development of specific regulatory
requirements, which may include the following:
1.1 Ability to require the reporting of transactions (e.g. sale) related to approved identifiers
(e.g. ear tags).
1.2 Ability to confirm the identity of an animal3 by determining if an identification tag has been
applied to an animal and has been activated; ability to maintain identification and
knowledge of an animal’s location along the farm-to-slaughter continuum.
1.3 Ability to identify animals in groups, to obtain knowledge of their location, and to maintain
group identification along the farm-to-slaughter continuum.
1.4 Ability to link the identity of an animal/group with their location of birth/origin, and to link
their movements along the farm-to-slaughter continuum.
4 For the purposes of this paper, “Linked Premises” are all those premises which are considered as a single
epidemiological (animal health) unit because of the regular movement of animals/products between them.
5 For the purposes of this paper, “custodian” refers to a person who owns or has possession, care or control of an
animal or group of animals.
1.5 Ability to determine attributes such as the date of birth or age of the individual animals
through their ID numbers.
1.6 Ability to require the identification (individual/group) of imported animals in a manner that
is consistent with the identification of domestic animals.
2. Premises identification
Premises identification is a critical part the traceability system. For a robust traceability system,
the proposed framework would provide enabling legislative authority for establishing elements of
premises identification. This authority would permit the development of specific regulatory
requirements, which may include the following:
2.1 Knowledge of the location where animals are kept, assembled or disposed of, as well as
locations that are registered as “linked4.” “Location” could also include a conveyance
used in the transportation of animals (e.g. a truck).
2.2 Ability to require the custodians5 to identify the location(s) of their animals.
2.3 Knowledge of the custodian of a particular location.
2.4 Knowledge of association between location ID and animal species as well as location ID
and operation types (e.g. a farm, a feedlot, an abattoir, or a barn).
2.5 Interoperability among various databases. This is the ability to cross-reference the
identification numbers of a given location (custodian, premises and building) as allocated
by provincial and other traceability-related databases.
Although this framework is national in scope, it would permit the utilization of existing provincial
and/or territorial regulations governing premises identification. This framework will also allow for
provincial/territorial implementation of a national requirement.
3. Movement and other event reporting
Movement reporting is essential to a national traceability system. The proposed framework
would provide enabling legislative authority for establishing elements of reporting associated
with animal movements and other events (e.g. tag activation). This authority would permit the
development of specific regulatory requirements, which may include the following:
3.1 Knowledge of the location, premises (e.g. land parcel) or building level, where animals
are kept, assembled or disposed of and where they were kept or assembled prior to their
current location.
3.2 Ability to establish which other animals/groups of a particular species came in contact
with others during movement from one location to another.
3.3 Ability to require transporters, importers, exporters and other custodians of animals to
report movement information, including date, time and individual or group identifier of all
individual or group movements and corresponding ID numbers of locations when animals
are moved and the identification of conveyance used in the movement.
3.4 The ability to require the reporting of domestic movement information of animals imported
from outside Canada in the same way as Canadian animals.
3.5 The ability to require custodians to report individual movements or group movements in a
pre-defined and standardized manner and format.
4. Authorized use and sharing of information
The current animal identification program in Canada mandates the collection of personal and
confidential information. Similarly, some provinces also require regulated parties to report
personal and confidential information. The proposed traceability framework would build on these
existing requirements, and could require the collection of additional information through the use
of authorized administrators such as the CCIA. To address stakeholders’ concerns about the
protection of information, there would be provisions outlining authorized access to and intended
uses of traceability information stored in these databases. These provisions would be designed
to restrict access to personal information and ensure confidentiality. There would also be
restrictions put in place to further safeguard privacy. More specifically:
4.1 The framework will have provisions that clearly define authorized and appropriate uses of
traceability information. The information collected under this framework will only be used
for those purposes. It will also provide provisions restricting access to information for
unauthorized purposes.
4.2 The framework will enable access to traceability information for use by provincial and
federal governments, as well as other entities entrusted to manage animal and related
human health issues.
4.3 The framework will facilitate the transfer of information among authorized users.
4.4 The provisions, where required, could allow for access to aggregate and non-personal
information contained within the traceability systems for purposes other than
management of animal health issues and emergencies; including: animal demographic
studies, analysis of disease trends, simulations of disease outbreaks.
5. Compliance and enforcement
A new legislative and regulatory framework would have provisions to promote compliance by
regulated parties. It would clearly outline violations and create offences for contraventions of the
provisions in the framework. To provide discipline and to mitigate the risk of unauthorized use
and disclosure of information, the framework could have provisions for creating offences and
penalties for unauthorized uses and disclosures of traceability information. The framework's
provisions would permit the following:
5.1 Creating prohibitions and violations, e.g. no one can move an animal that is not properly
identified.
5.2 Ability to develop and employ a compliance and enforcement program prescribing
responsibilities for all stakeholders, defining contraventions of those provisions and
adding provisions for explicit offences and penalties, where required.
5.3 Creating offences and penalties for unauthorized uses and disclosures of traceability
information. This would address industry’s concerns about the intended uses of
information by governments, and would mitigate the risk of unauthorized use and
disclosure of information.
'
6. Reporting and record keeping
In order to outline specific requirements for information reporting and record-keeping, the
framework’s provisions will permit:
6.1 The reporting of animal and premises identification, and reporting of movement
information in a format and manner prescribed by the regulations.
6.2 On-site compliance verification and audits of parties submitting data to administrators.
The framework could also include provisions that require the owners or custodians of
animals to keep records corresponding to the data submitted to administrators.
6.3 Recording and retaining information that may be used to confirm the attributes of any
given animal.
6.4 Provisions that clearly articulate guidelines and schedules for the retention and
disposition of any personal and confidential data that is collected under a traceability
framework. This would address privacy concerns and enhance compliance with
archiving guidelines for information collected under a federal legislation or regulation.
Additional considerations for a traceability framework
Cost-sharing
Cost-sharing, as a national principle in the development of traceability systems, recognizes that
the benefits of traceability may be realized by both governments and industry. Industry and
government will work together to develop a cost sharing framework, which will recognize the
costs and benefits of traceability in the Canadian context, and the need for a financially
sustainable system for industry and governments. Recognizing existing contributions from
producers and governments, the cost-sharing framework will address short and long-term
traceability costs, cost sharing issues and factors that will enable the development and
maintenance of a cost-effective and financially sustainable system.
Standards
For quality, completeness and interoperability of data, the government will establish standards
for traceability systems. These standards could be incorporated by reference into a traceability
framework. The system will need flexibility to allow for the evolution of those standards,
possibly resulting from technological changes and innovations in collecting traceability
information. The following are examples of potential standards:
• Technical standards relating to submission of data to administrators, e.g. data format
definition.
• Technical standards for validating data, including format (DOB: YYYY/MM/DD) and
type (e.g. alpha, numeric, alphanumeric).
• Standards for data administrators in business continuity planning, including
requirements for backups.
• Standards for auditing and evaluation of administrators’ databases to verify
completeness, correctness and validity of the data stored therein.
• Technical documentation for the proper operation of the centralized portal.
• Standards to allow for interoperability among various databases.
• Performance standards and service level agreements for databases containing
traceability information.
Management of a Single-Window Information Portal
The implementation of a national traceability portal is a key component of Canada’s proposed
framework. The portal would provide authorized users with a single point of access to
information about the characteristics, origins and movements of animals, as maintained in a
number of provincial and industry databases. With the development of a portal, authorized users
could have access to consolidated data in real-time, compiled from multiple sources, and cross-
referenced with geo-positioning tools in order to achieve the most rapid, targeted, and effective
method for controlling a disease outbreak.
The development and operation of the portal by governments will be dependent on a number of
factors including:
• authority provided by legislation/regulations to collect information.
• agreements and information-sharing with provinces, data administrators and other
parties holding traceability data.
• adoption of appropriate data standards and interoperability among the databases.
What It Means for Stakeholders
A Concept and Consultation Paper
PREPARED BY: The Canadian Food Inspection Agency
Please note that this draft paper is being provided for discussion purposes only.
This paper represents the initial thoughts and discussions that are taking place at
the CFIA.
Canadian Food Inspection Agency
Contents
Introduction...................................... ...................................... p. 3
Benefits.......................................... ........................................ p. 4
Context........................................... ........................................ p. 4
Technology and Traceability...................................... ............ p. 5
Reporting and Record Keeping.……………….………............ p. 6
Scenarios......................................... ....................................... p. 7
Elements of a Traceability Framework................................... p. 8
Introduction
Traceability is defined as the
ability to follow an item or group
of items - including animals,
plants, food products and
agricultural inputs such as feed,
seed or ingredients - from one
point in the supply chain to
another. For the purposes of
this concept and consultation
paper, the focus will be farm-to-
slaughter traceability of livestock
and poultry species.
The federal government proposes to develop a new federal statute and/or amend existing legislation
and regulations to implement a federal framework for farm-to-slaughter traceability for cattle, sheep,
hogs and poultry separate from food and agricultural inputs. This paper seeks to engage stakeholders
and obtain their views regarding the proposed legislative and regulatory framework for traceability.
This proposal forms part of a long-term plan to establish traceability for the agriculture and agri-food
sector. The paper contains two emergency management scenarios which illustrate the objectives of
this proposal, as well as sample provisions for a legislative and regulatory framework.
In 2006, federal, provincial and territorial (FPT) Ministers of Agriculture committed to phase-in a
National Agriculture and Food Traceability System, and mandated the Industry Government
Advisory Committee (IGAC) to provide a forum for cooperation and coordination among
governments and industry. In the summer of 2009, that commitment was strengthened, and
2011 was set as the target for the implementation of a mandatory, Canada-wide traceability
system for livestock and poultry sectors.
Personal and confidential
information is anticipated to
be collected under the new
framework. The framework
will have strong provisions
for the protection of this
information. These
provisions will outline
authorized access to, and
intended uses of,
traceability information,
and will prescribe penalties
for misuse and unauthorized
disclosure.
The proposed approach is in line with international guidelines
established by the World Organisation for Animal Health. The aim
is to build on global best practices to develop a system for cattle,
hogs, sheep, and poultry, and eventually other livestock species
such as bison, cervids and goats that maximizes protection of
Canadians, agricultural livestock populations, and long term,
sustainable economic benefits for Canadian producers.
It is important to recognize that a legislative framework for
traceability is enabling as it permits the establishment of
regulations for a species (or multiple species). A specific
regulation could address one or more of the three pillars of
traceability: animal identification, premises identification, and
movement and other event reporting. With enabling legislation in
place, regulations can be phased in as the traceability system in
Canada is built. This phased approach will lead to a traceability
framework that is implemented in consultation with stakeholders.
Objective:
To create an enabling legislative and regulatory framework
to support the management of animal and related human
health issues, to facilitate a rapid response to emergencies
resulting from disease outbreaks, natural and other
disasters in the livestock and poultry sectors, and to
enhance food safety by collecting, reporting, holding and
sharing timely, accurate and relevant traceability
information among authorized users.
Benefits of a Legislative and Regulatory Framework
The proposed legislative framework will strengthen the development of traceability in Canada and
will enable governments to better prepare for, and rapidly respond to, animal health issues that
may occur in the livestock and poultry sectors.
The following elements of traceability will strengthen Canada’s existing framework:
• consistent and detailed identification of locations across Canada where animals are
kept, assembled or disposed of;
• identification of additional livestock and poultry species (including horses, cervids and
goats);
• information reporting on livestock and poultry movements and commingling;
• information reporting on the identification of conveyances that transport livestock and
poultry; and
• knowledge of the location of non-commercial operations.
Benefits of a national legislative/regulatory framework for traceability include:
• real time access to information under a well-managed traceability system that can
dramatically reduce the animal health, human health and economic impacts of
emergencies;
• reduced response time and rapid containment of animal disease outbreaks;
• rapid identification of implicated animals in an animal health emergency and the ability
to pinpoint the location of animals or animal products that may have been moved from
affected premises, come into contact with affected animals or products, or otherwise be
at risk due to an outbreak;
• enhanced safety of the food supply; and
• reduced public health risks due to zoonosis.
Beyond being a tool to help with animal health, human health and food safety issues, traceability
could provide additional benefits to industry through reduced economic impacts of animal health
emergencies and improved access to international markets. Markets increasingly demand
traceability for livestock, livestock products, and plant-based foods. Further, market driven and
industry-led traceability initiatives could offer opportunities for value-added activities, including
age verification, grading information leading to optimized breeding decisions and on-farm
efficiencies that can improve the competitiveness of the Canadian industry. Traceability can be
leveraged into new opportunities for growth and international competitiveness, which ultimately
supports the long term sustainability of the sector.
Context - Federal, Provincial and Industry Initiatives
Discussion in Canada on animal identification, an element of traceability, began in 1990 with the
creation of the National Advisory Board on Animal Identification. This was later transformed into
the Livestock Identification Working Group. In 1998, with strong leadership from the cattle and
bison industries, the Canadian Cattle Identification Agency (CCIA) was created to co-ordinate
livestock identification and traceability initiatives. In 2001, the federal government, under the
authority of the Health of Animals Act, introduced regulations for national cattle and bison
identification. With strong leadership from the sheep industry, these regulations were expanded
to include sheep identification in 2004. While federal funding has supported the initiation and
development of national systems, ongoing industry commitment has driven daily maintenance
and operations.
In 2000, Québec became the first province to formalize its commitment to mandatory
traceability. Its National Assembly adopted two bills; the Food Products Act and the Animal
Health Protection Act, governing traceability activities in the province. In 2001, Agri-Traçabilité
Québec (ATQ), a not-for-profit industry-government partnership, was created to lead provincial
agricultural traceability initiatives. This resulted in a comprehensive and mandatory reporting
regime for animal identification, premises identification and movement reporting beginning with
cattle in 2002, sheep in 2004 and cervids in 2009.
Alberta is the second province to commit to mandatory traceability. The Animal Health Act is
Alberta’s primary animal disease control legislation. The provisions for livestock identification
and premises identification provide a foundation for implementing province-wide traceability.
The Alberta Livestock Identification and Commerce Act governs reporting of movement for
certain species of livestock. The Ministry of Agriculture and Rural Development (ARD) works
with the CCIA and Livestock Identification Services Ltd. (LIS) to collect information related to
traceability.
At the FPT Ministers' meeting in 2009, all provinces except Saskatchewan agreed to a
mandatory livestock and poultry traceability framework by 2011. Many provinces, including
Saskatchewan, are continuing to develop provincial traceability frameworks. Some are
developing legislation to mandate traceability, while others are taking a voluntary approach.
The proposed legislative and regulatory framework outlined in this paper will be developed in
consideration of existing provincial policies and standards and will not duplicate existing
provincial approaches. Consistent participation by federal, provincial and industry stakeholders
is key to the success of this initiative.
Technology and Traceability
In Canada, industry groups and data service providers, including the CCIA and Agri-Traçabilité
Québec (ATQ), play an important role in technology decision making. They build and administer
systems that collect and manage traceability information.
Traceability systems centralize and distribute information about the identities of commodities,
their locations, and how they are moved. Producers have traditionally used tags, tattoos,
brands, and paper and computer-based logbooks to track the characteristics and movement of
their animals. Under the current Health of Animals Regulations, the Minister of Agriculture and
Agri-Food has the authority to approve tag technologies. A new legislative and regulatory
framework could provide the government with additional authorities to approve new
technologies that may be used in the future, and to develop a national information portal for
traceability data.
Traceability - Reporting and Record Keeping
Reporting of information to a database as opposed to keeping records is a hallmark of
traceability systems. In situations where only record keeping exists rather than information
reporting, the CFIA would need to contact all of the premises and transporters that may be
implicated in a disease outbreak, have them pull their records and send them to CFIA or visit
these sites to examine the records — a time-consuming process that could cost animal lives
and may permit the rapid spread of disease. Information reported to a database can mitigate
these issues, and is, therefore, an essential component of the proposed framework. Existing
data collected in Canada by organizations such as the CCIA and ATQ provides emergency
responders with a significant base of information. The proposed traceability system will enable
the collection of additional information that can lead to a faster and more effective response,
and will facilitate proactive planning and preparedness activities that can mitigate the impacts of
an emergency.
Consider an animal disease outbreak, which could result in:
• risks to human health
• vast quarantine zones
• large-scale culling of animals
• severe restrictions or bans on exports
• a shutdown of some agricultural operations.
The costs could be significant, with implications for tourism, agriculture, and other industries.
Incomplete and difficult-to-track records during health emergencies have costs, not just in
animal lives, time, money, and risks to human health, but also in terms of Canada’s reputation
and its international trade access, as Canadian producers experienced with the discovery of
BSE in Canada.
The following two scenarios further illustrate the potential impact that an animal disease
outbreak or bio-terrorism event would have on Canadian agriculture, as well as the benefits of a
well developed national traceability system.
Scenarios
Scenario #1: Bovine Spongiform Encephalopathy (BSE)
In the case of BSE, as few as
one animal may test positive for
the disease, which may result in
many more animals being
culled. A traceability system
could provide emergency
responders with traceable herd
information, including
information on the birth cohort
and farm of origin of implicated
animals that could reduce the
impact of such an occurrence.
Without traceability, emergency responders may need to cast a wide net in both space and time
in order to effectively contain the disease. All animals that are possibly implicated must be
included: all possible farms of origin and a wide window of birthdates. With traceability, including
animal identification, premises identification, and movement reporting, governments would be
better equipped to respond rapidly to a BSE event and would have the information necessary to
target any implicated animals. This effective use of traceability data may save money and
animal lives due to the targeted and effective nature of the response.
BSE or "Mad Cow Disease"is a progressive, fatal
disease of the nervous system of cattle. It is what is known
as a transmissible spongiform encephalopathy (TSE).
Other TSEs include scrapie in sheep, chronic wasting
disease in deer and elk, and Creutzfeldt-Jakob disease in
humans. Although the exact cause of BSE is unknown, it
is associated with the presence of an abnormal protein
called a prion. There is no treatment or vaccine currently
available for the disease.
Scenario #2: Hypothetical Foot-and-Mouth Disease Outbreak
“Foot-and-mouth disease (FMD) is a severe, highly infectious viral disease of cattle, swine,
sheep, goats, and other ruminant species. FMD is not a threat to human health. Infection is
characterized by large blisters in the mouth, on the teats, and between the toes that burst to cause
painful raw sores and even loss of the hooves. Animals cannot eat, drink, or walk, nor can they be
milked. FMD virus rarely kills animals, but the recovered animal usually loses its productivity of
milk or meat. FMD-infected animals shed enormous amounts of virus, and this easily infects other
animals in direct contact—by inhalation of virus-infected aerosols or ingestion of excretions from
an infected animal—and at a distance—by virus contamination of water, feed, and bedding or by
virus carried for many miles in atmospheric plumes of aerosol droplets. FMD is the most
infectious virus known; it is some 20 times more infectious than human smallpox. FMD virus
remains viable in the bone marrow of frozen carcasses for months. Cattle that have recovered
from disease—and perhaps some vaccinated animals that were subsequently exposed to live
virus—may also carry FMD virus in their throats for long periods and be sources of infection for
other animals. Left unchecked, FMD virus will spread through all the susceptible animals in a
country.1”
As evident from the 2001 outbreak of foot-and-mouth disease in the United Kingdom, the
disease could be introduced by something as simple as one unreported incident of a
notifiable disease and accidental feeding of infected and untreated waste. The disease could
pass from one infected animal to the rest of the herd on that farm, and
then to other animals at other premises.
An outbreak in Canada of highly infectious foot-and-mouth disease
would be a national disaster with massive implications for agriculture
and tourism unless governments have the tools to respond quickly,
accurately, and effectively. A record keeping system would be
insufficient for the CFIA’s efforts to manage an FMD outbreak. By the
time all of the necessary records were pulled, analyzed, and quarantine
zones were established, all of Canada could be implicated in the
emergency. The speed and efficiency by which this virus can spread
could impact the agriculture operations of the entire country.
An FMD outbreak would have a significant negative impact on the
livestock industry due to loss of production, loss of export markets, and
loss of animals. However, an established traceability system could allow
for a rapid response and an immediate, targeted quarantine of
implicated animals.
It is estimated
that an FMD
outbreak could
cost the Canadian
economy $10–50
billion.
In a large-scale
FMD outbreak,
effective disease
control and zoning
strategies could
reduce the impacts
on the Canadian
economy by an
estimated $28
billion.
1 Centaur Science Group, 2004.
2 Some of these elements are already in place under P. XV of the Health of Animals Regulations, but are included here
for completeness
3 For the purposes of this paper, “animal” or “animals” refer to livestock and poultry species.
Elements of a Traceability Framework
1. Animal identification
.. The use of approved identifiers (tags, documents), which are applied to an animal and
reported to a database.
2. Premises identification
.. The allocation of a unique identifier which corresponds to a defined geographical
location.
3. Movement and event reporting
.. The reporting of animal movements and other events to a database.
4. Authorized use and sharing of information
.. Will define authorized access to, and intended uses of, traceability information.
5. Compliance and enforcement
.. The principles and actions to be followed with the goal that regulated parties operate in
full compliance with the proposed traceability system.
6. Reporting and record keeping
.. Standards and protocols for the reporting of traceability information.
1. Animal identification2
The current Health of Animals Act and the attendant regulations prescribe national animal
identification requirements for cattle, sheep and bison. Consistent with the intent of the existing
system, the proposed framework would provide enabling legislative authority for elements of
animal identification. This authority would permit the development of specific regulatory
requirements, which may include the following:
1.1 Ability to require the reporting of transactions (e.g. sale) related to approved identifiers
(e.g. ear tags).
1.2 Ability to confirm the identity of an animal3 by determining if an identification tag has been
applied to an animal and has been activated; ability to maintain identification and
knowledge of an animal’s location along the farm-to-slaughter continuum.
1.3 Ability to identify animals in groups, to obtain knowledge of their location, and to maintain
group identification along the farm-to-slaughter continuum.
1.4 Ability to link the identity of an animal/group with their location of birth/origin, and to link
their movements along the farm-to-slaughter continuum.
4 For the purposes of this paper, “Linked Premises” are all those premises which are considered as a single
epidemiological (animal health) unit because of the regular movement of animals/products between them.
5 For the purposes of this paper, “custodian” refers to a person who owns or has possession, care or control of an
animal or group of animals.
1.5 Ability to determine attributes such as the date of birth or age of the individual animals
through their ID numbers.
1.6 Ability to require the identification (individual/group) of imported animals in a manner that
is consistent with the identification of domestic animals.
2. Premises identification
Premises identification is a critical part the traceability system. For a robust traceability system,
the proposed framework would provide enabling legislative authority for establishing elements of
premises identification. This authority would permit the development of specific regulatory
requirements, which may include the following:
2.1 Knowledge of the location where animals are kept, assembled or disposed of, as well as
locations that are registered as “linked4.” “Location” could also include a conveyance
used in the transportation of animals (e.g. a truck).
2.2 Ability to require the custodians5 to identify the location(s) of their animals.
2.3 Knowledge of the custodian of a particular location.
2.4 Knowledge of association between location ID and animal species as well as location ID
and operation types (e.g. a farm, a feedlot, an abattoir, or a barn).
2.5 Interoperability among various databases. This is the ability to cross-reference the
identification numbers of a given location (custodian, premises and building) as allocated
by provincial and other traceability-related databases.
Although this framework is national in scope, it would permit the utilization of existing provincial
and/or territorial regulations governing premises identification. This framework will also allow for
provincial/territorial implementation of a national requirement.
3. Movement and other event reporting
Movement reporting is essential to a national traceability system. The proposed framework
would provide enabling legislative authority for establishing elements of reporting associated
with animal movements and other events (e.g. tag activation). This authority would permit the
development of specific regulatory requirements, which may include the following:
3.1 Knowledge of the location, premises (e.g. land parcel) or building level, where animals
are kept, assembled or disposed of and where they were kept or assembled prior to their
current location.
3.2 Ability to establish which other animals/groups of a particular species came in contact
with others during movement from one location to another.
3.3 Ability to require transporters, importers, exporters and other custodians of animals to
report movement information, including date, time and individual or group identifier of all
individual or group movements and corresponding ID numbers of locations when animals
are moved and the identification of conveyance used in the movement.
3.4 The ability to require the reporting of domestic movement information of animals imported
from outside Canada in the same way as Canadian animals.
3.5 The ability to require custodians to report individual movements or group movements in a
pre-defined and standardized manner and format.
4. Authorized use and sharing of information
The current animal identification program in Canada mandates the collection of personal and
confidential information. Similarly, some provinces also require regulated parties to report
personal and confidential information. The proposed traceability framework would build on these
existing requirements, and could require the collection of additional information through the use
of authorized administrators such as the CCIA. To address stakeholders’ concerns about the
protection of information, there would be provisions outlining authorized access to and intended
uses of traceability information stored in these databases. These provisions would be designed
to restrict access to personal information and ensure confidentiality. There would also be
restrictions put in place to further safeguard privacy. More specifically:
4.1 The framework will have provisions that clearly define authorized and appropriate uses of
traceability information. The information collected under this framework will only be used
for those purposes. It will also provide provisions restricting access to information for
unauthorized purposes.
4.2 The framework will enable access to traceability information for use by provincial and
federal governments, as well as other entities entrusted to manage animal and related
human health issues.
4.3 The framework will facilitate the transfer of information among authorized users.
4.4 The provisions, where required, could allow for access to aggregate and non-personal
information contained within the traceability systems for purposes other than
management of animal health issues and emergencies; including: animal demographic
studies, analysis of disease trends, simulations of disease outbreaks.
5. Compliance and enforcement
A new legislative and regulatory framework would have provisions to promote compliance by
regulated parties. It would clearly outline violations and create offences for contraventions of the
provisions in the framework. To provide discipline and to mitigate the risk of unauthorized use
and disclosure of information, the framework could have provisions for creating offences and
penalties for unauthorized uses and disclosures of traceability information. The framework's
provisions would permit the following:
5.1 Creating prohibitions and violations, e.g. no one can move an animal that is not properly
identified.
5.2 Ability to develop and employ a compliance and enforcement program prescribing
responsibilities for all stakeholders, defining contraventions of those provisions and
adding provisions for explicit offences and penalties, where required.
5.3 Creating offences and penalties for unauthorized uses and disclosures of traceability
information. This would address industry’s concerns about the intended uses of
information by governments, and would mitigate the risk of unauthorized use and
disclosure of information.
'
6. Reporting and record keeping
In order to outline specific requirements for information reporting and record-keeping, the
framework’s provisions will permit:
6.1 The reporting of animal and premises identification, and reporting of movement
information in a format and manner prescribed by the regulations.
6.2 On-site compliance verification and audits of parties submitting data to administrators.
The framework could also include provisions that require the owners or custodians of
animals to keep records corresponding to the data submitted to administrators.
6.3 Recording and retaining information that may be used to confirm the attributes of any
given animal.
6.4 Provisions that clearly articulate guidelines and schedules for the retention and
disposition of any personal and confidential data that is collected under a traceability
framework. This would address privacy concerns and enhance compliance with
archiving guidelines for information collected under a federal legislation or regulation.
Additional considerations for a traceability framework
Cost-sharing
Cost-sharing, as a national principle in the development of traceability systems, recognizes that
the benefits of traceability may be realized by both governments and industry. Industry and
government will work together to develop a cost sharing framework, which will recognize the
costs and benefits of traceability in the Canadian context, and the need for a financially
sustainable system for industry and governments. Recognizing existing contributions from
producers and governments, the cost-sharing framework will address short and long-term
traceability costs, cost sharing issues and factors that will enable the development and
maintenance of a cost-effective and financially sustainable system.
Standards
For quality, completeness and interoperability of data, the government will establish standards
for traceability systems. These standards could be incorporated by reference into a traceability
framework. The system will need flexibility to allow for the evolution of those standards,
possibly resulting from technological changes and innovations in collecting traceability
information. The following are examples of potential standards:
• Technical standards relating to submission of data to administrators, e.g. data format
definition.
• Technical standards for validating data, including format (DOB: YYYY/MM/DD) and
type (e.g. alpha, numeric, alphanumeric).
• Standards for data administrators in business continuity planning, including
requirements for backups.
• Standards for auditing and evaluation of administrators’ databases to verify
completeness, correctness and validity of the data stored therein.
• Technical documentation for the proper operation of the centralized portal.
• Standards to allow for interoperability among various databases.
• Performance standards and service level agreements for databases containing
traceability information.
Management of a Single-Window Information Portal
The implementation of a national traceability portal is a key component of Canada’s proposed
framework. The portal would provide authorized users with a single point of access to
information about the characteristics, origins and movements of animals, as maintained in a
number of provincial and industry databases. With the development of a portal, authorized users
could have access to consolidated data in real-time, compiled from multiple sources, and cross-
referenced with geo-positioning tools in order to achieve the most rapid, targeted, and effective
method for controlling a disease outbreak.
The development and operation of the portal by governments will be dependent on a number of
factors including:
• authority provided by legislation/regulations to collect information.
• agreements and information-sharing with provinces, data administrators and other
parties holding traceability data.
• adoption of appropriate data standards and interoperability among the databases.
Comment