Sheep EID tolerances, or not?
5th September 2011
Concerns are high as we start the breeding sheep sale season and industry has still not been informed, by Defra, if a tolerance will be acceptable against 100% reading and recording requirements under EU Regulation 21/2004.
We are all aware that achieving 100% read accuracy 100% of the time is an impossible ask, for many different reasons, as the early breeding shearling and ewe lamb sales have proved. Following the last discussion held between EU Commission officials and UK government it is clear that a tolerance will only be acceptable under very restricted circumstances.
Following these discussions the press releases made by our Scottish associates would suggest that because, firstly, they require all their sheep to be identified with an electronic tag (two identifiers for breeding sheep and a single electronic slaughter tag for store and finished lambs) and, secondly, they have a database that the Commission is prepared to consider a tolerance against the need for 100% accuracy. In England and Wales we do not have either a database or the requirement to electronically identify all our sheep.
As an industry we have been fighting against the implementation of EU Regulation 21/2004 for several years now; however the LAA realised some considerable time ago that the fight against implementation was lost, so we moved to phase two where we looked at the options available to us to mitigate the concerns we all had, with an emphasis on achieving the best outcome for the UK sheep industry and ensuring that sheep farmers single farm payments were not put at an unacceptable risk.
It was our belief that two of the most important considerations were that the introduction of the electronic slaughter batch tag was one "tool" that needed to be put in the box, and that the development of a national database which could be used to make the reporting of movements more accurate and timely were essential.
We have worked to assist in the development of a national database, this work being carried out on the basis that the database would be owned and governed by industry, that it's use would not cost the sheep farmer any more than the current movement notification system does, and that government would bear the costs of running the "statutory" part of the database through them buying the information that they require. We believed that this work was essential to ensuring that our sheep industry did not become burdened with unnecessary costs and recording requirements that we saw clearly approaching on the horizon, and at an uncomfortable speed.
We are now faced with the exact situation that we have striven to avoid, and our Scottish associates have successfully avoided it. In this I am referring to the implementation and acceptance from the EU Commissioners of a workable tolerance in read accuracy.
Our Scottish associates implemented a system that only permits the use of electronic tags and they have developed, and are using, a database for the reporting of movement data. The LAA has pushed for the English and Welsh sheep industries to opt for a very similar system. Unfortunately we have not had the support that was needed to fully secure either option.
Our concern now lies with how industry moves forward. Suggestions have been made that average read rates at approved CPRC's should be used to formulate an accepted tolerance level, but the question has to be asked as to who will be responsible for the costs of collecting such data, collating it and providing the required regular statistics. It is clear that such a service would be exceptionally expensive to administer and deliver, and now that such proposals have been left until the backend sales have all started it means that historic data will also be needed.
The LAA has fought all along for a simple, straightforward solution which would safeguard the livelihoods of sheep producers. This cannot be achieved without industry taking a long-term view. We have continually stated the need to move to provide a database to protect single farm payments. Action is needed now to avoid penalties and LAA members are prepared to carry on the fight, on behalf of their sheep producer clients, but we need support from industry in order to progress further.