Scottish Government

1 Introduction

Purpose

1.1 In December 2003, the EU Commission adopted EC Regulation 21/2004; effective from 9 July 2005. This Regulation is to enable the establishment of an EU wide traceability system for ovines and caprines (sheep and goats) to support on-going disease prevention and any future disease control needs.

1.2 It is important that Scottish sheep and goat keepers comply fully with Reg 21/2004 as it is a cross-compliance element of the new Single Farm Payment Scheme ( SFPS).

1.3 The aim of this consultation is to obtain your views on the minor changes required to our current sheep and goats identification and traceability system to allow us to retain this workable system instead of the double tagging required under 21/2004.

1.4 Other UK Administrations will also be undertaking consultation exercises.

2 Background

2.1 In late 2001, SEERAD became aware that the EU Commission was considering the introduction of an identification and traceability system for sheep and goats. Commission officials were keen to ensure that the possibility of outbreaks of disease - such as the UK 2001 FMD - was reduced as much as possible. In the event of a disease outbreak occurring, the control system they were considering would play a major part in reducing the spread of infection and ideally shorten the time taken to bring the outbreak under control.

2.2 Around the same time, SEERAD were in discussion with our Sheep (& goat) Industry Stakeholder Group ( SISG) members to see how the industry could resume animal movements following FMD. Although keen to progress this, we all resolved to ensure that 'lessons learned' from FMD were incorporated into any new system to minimise the risk of future disease outbreak. The State Veterinary Service ( SVS) were especially focussed on ensuring that the majority of movements onto and off Scottish locations were recorded and notified to a central database. This would allow movement tracings to be undertaken to greatly increase the ability to accurately establish the locations that animals had been or were on.

2.3 The outcome of these domestic discussions was the introduction of the Scottish Animal Movement System ( SAMS) on 18 February 2002. The five main elements of SAMS are:

• Baseline tags and tattoos
• Movement tags
• Replacement tags
• Movement Documents ( MDs)
• Notification of movements to the Scottish Animal Movement Unit ( SAMU)

2.4 In recognition of the importance of the developing EU legislation, industry stakeholders have for over 2 years been heavily involved in discussions with SEERAD on obtaining an outcome from the Commission which was both practical and enforceable for Scotland. SEERAD were represented at EU Council Working Group meetings in Brussels where intense lobbying and discussion with other Member State ( MS) officials ensured they fully understood our concerns on the impracticalities of the initial draft proposal of 21/2004 for the Scottish system. Throughout this process, SEERAD officials continually discussed with industry stakeholders the proposal's progress and any issues that were viewed as being impractical for Scotland due to the specialised and stratified nature of our sheep industry. We also hosted visits from Commission officials and Spanish counterparts who were able to see for themselves the difficulties the draft proposal had for our industry.

2.5 Regulation 21/2004 was finally adopted by the Council of Ministers in December 2003 with most of the elements which would be problematic for the Scottish industry negotiated out. The most important change being that Member States could apply for a derogation to retain their current system instead of the double tagging required under the proposed new EU legislation. Some of the other successes include:

• Removal of the requirement to tag new-born animals within one month of birth
• No recording of the 12 digit baseline tag number for each move
• Delaying the introduction of individual Electronic Identification ( EID) until January 2008 at the earliest

2.6EU veterinary Auditors visited the UK in January this year to assess the existing traceability systems before they could consider granting the above derogation to keep our current system. Only minor failures in the Scottish system were discovered during their visit and we were able to explain how they occurred and that steps would be taken to ensure they were not repeated.

2.7SEERAD and SISG members have been aware for some time that there are other elements of SAMS that require minor changes to comply with the new EC legislation. The EU Auditors also identified the same shortcomings and some additional requirements and these have been included in the revised system. Some of the additional requirements arising from the Audit are still being discussed and are yet to be agreed with SISG members as indicated in the following paragraphs which describe the proposed revised system to be introduced from October 2005.

3. Proposed revised system from October 2005

3.1 Due to the EU delay in responding to the UK derogation application, new Scottish legislation for EC Regulation 21/2004 will not be in place until October 2005. Until then it is critical that keepers continue to comply with the current system. A description of the current system is given in Sections 4-8 along with the minor changes that are likely to be required from October. SEERAD would welcome your views on the revised system and in particular where specific questions are listed. See also Section 10 on page 13

4. Registration of a location where sheep or goats are kept

4.1 Currently it is a legal requirement that any person who starts to keep sheep or goats must within 30 days inform SEERAD via their local Animal Health Office ( AHO). This keeper and holding information will be kept on the central ( GB) holding register. If the holding where animals are being kept does not already have a location identifier ( CPH), then one will be allocated. On receipt of this information, a flock/herd mark will be allocated for each location where sheep and goats are kept. Any change to holding or keeper information must be notified by the keeper to the AHO within 30 days. Markets and abattoirs are also required to meet these registration obligations.

4.2 After 9 July 2005, each keeper must also provide SEERAD with details of their occupation and the type of production (meat or milk) undertaken at the location. Hauliers are exempt from this requirement. An exercise will be undertaken in the coming months to obtain this information from existing keepers.

5. Holding Register (Flock/Herd Book)

5.1 Currently a flock/herd book is required for each CPH (including markets and abattoirs) and should be available at all times for inspection purposes. The system requires that movements on and off the location are recorded in the holding register within 36 hours of the move taking place. Details required are: date of the movement, total number of sheep/goats in the batch, either the temporary mark or the baseline UK flock/herd-mark of each sheep/goat or the unique individual number of each sheep/goat and the holding the animal/s came from or went to. For sheep/goats moving direct from a market the lot number allocated by the market must also be recorded The keeper must also count the number of sheep and goats on the holding on 1 January each year and this must be recorded in the flock book by 31 January; markets and abattoirs are exempt . These records must be kept for 6 years.

5.2 After October 2005: We understand that the requirement for one register per CPH location may be problematic for some keepers. Similarly we know there are some instances where two or more CPHs actually cover one epidemiological unit when only one CPH may be required. An exercise will be carried out to identify these locations to ensure we achieve a balance between what is practical on the ground and disease control needs. Further discussions with SISG members will be held during the consultation period to finalise this aspect of the system. This includes specific meetings with crofting representatives to cover the movements between crofts, common grazings and apportionments. See Section 9.

5.3 The following new information must be kept in the holding register:

5.3.1 Both the CPH and address of the location, the type of production (milk or meat), name and address of keeper (this may differ from the location details). The holding register must also contain details of any replacement tag (see 6.12) that has been applied on the holding; markets and abattoirs are exempt from this as they are not classed as permanent keepers.

5.3.2 Movement off a location including markets - Name of transporter , registration number of the haulage vehicle plus address and/or CPH of the destination location .

5.3.3 Movement onto a location - the CPH of the departure location (address is not sufficient).

5.3.4 Temporary marks are no longer required in the Flock book as they are not official types of identification

5.3.5 The new Regulation requires every permanent keeper (having animals for more than 30 days/year) to record the number of animals on the holding on a specific date each year and provide SEERAD with this inventory data within 30 days. Markets, abattoirs, shows, exhibitions and veterinary practices or clinics are exempt from this requirement.

5.3.6 We are still considering the best date for counting the animals. January 1 is the date that has been traditionally been used but this may be unsuitable for some sectors of the industry.

Question: Is the 1 January date appropriate or can you suggest another date that would suit all industry sectors. See Section 10 on page 13

5.2.7 We are still considering the best method of returning this inventory data to SEERAD; options include e-mail, automated telephone system, fax or by post.

Question: How do you think the inventory return should be sent to SEERAD bearing in mind that not all keepers have access to some of the above methods of communication. See Section 10 on page 13.

5.4 To assist keepers with the above requirements we have included a suggested format for a holding register at Annex C. Following initial comments from SISG members we are investigating the feasibility of allowing movement documents to be used in the holding register instead of duplicate recording. However it is important to remember that if the movement documents are kept for this purpose, they would be required during any official inspections. An inability to provide properly completed MDs to an inspecting officer would be a breach of the holding register requirement of EC Regulation 21/2004 and this may have an impact on any claims under SFPS - see Section 1.2 on page 3.

6. Identification requirements

6.1. Tattoos

6.1.1 Under EU Regulation 21/2004 any animal born after 9 July 2005 can only have an ear tag applied as the primary means of identification; tattoos cannot be used. However they can still be applied for management or pedigree purposes.

6.2 Ear Tag Allocation System ( ETAS)

6.2.1 Initially the keeper will continue to be responsible for ensuring that the individual identification number applied to each animal is unique. Please keep a record of the numbers on the most recent tags you purchase. However in November 2005, GB will be introducing a computerised Ear Tag Allocation System ( ETAS) similar to the cattle system currently operating. This will centrally allocate to ear tag manufacturers a number unique within the UK, thereby taking this responsibility away from the keeper. The current preference in Scotland is for 'leading zeroes' in the tag sequence and SISG members favour keeping this format e.g. UK 541541 000236.

Question: Is it still beneficial to have leading zeroes on our baseline and replacement tags? See Section 10 on page 13

6.3 Approval of Ear tags

6.3.1 The new EU legislation requires all official ear tags to be of a type approved jointly by SEERAD, DEFRA and NAWDEPC (Wales). This is to ensure they reach the minimum standard required by this new Regulation i.e. that they are made of non-degradable material, tamper- proof, easy to read throughout the lifetime of the animal and designed to remain attached to the animal without being harmful to it. They must also not be reusable and the official inscriptions must be non- removable.

6.4 Baseline UK marks - Identification at holding of birth

6.4.1 Currently all animals must be identified with a baseline tag or tattoo before they leave their holding of birth for the first time - this includes moves to any grazing/wintering and onto/off common grazing. A tag must consist of the letters UK, followed by the holding's 6-digit flock or herd mark , and followed by a unique individual number of 6 digits.

6.4.2 After 9 July 2005 the following additional measures will be introduced for all animals born after this date. They must be identified with an approved eartag within nine months of birth for extensively reared or free-range animals (or six months for intensively reared animals) or before they leave their holding of birth, whichever comes first. A tattoo cannot be used for animals born after 9 July 2005.

6.4.3 After October 2005, only animals moving off a holding for the purposes of veterinary treatment and returning directly back do not need a baseline tag/tattoo

6.4.4 Baseline UK tags can be any colour except for red which is reserved for replacement tags (see 6.12 below).

6.4.5 Management information may be applied to these tags provided it does not affect or interfere with the legibility or sequence of the official identification number

6.4.6 Please refer to 6.6.1 for information on older unidentified animals

6.5 Baseline S tags and tattoos (unidentified animals not on their holding of birth)

6.5.1 Currently older animals that are not already baseline tagged or tattooed and not on their holding of birth must have a baseline S mark applied prior to the animal leaving its current holding.

6.5.2 After October 2005, any animal not already baseline tagged or tattooed and not on their holding of birth must have a baseline S tag or tattoo applied before 31 December 2005 or sooner if leaving its current location. Please refer to 6.6.1 for a more detailed explanation.

6.5.3 After October 2005, only animals moving off a holding for the purposes of veterinary treatment and returning directly back do not need a baseline tag/tattoo

6.5.4 Baseline S tags can be any colour except for red which is reserved for replacement tags (see 6.12 below).

6.5.5 Management information may be applied to these tags/tattoos provided it does not affect or interfere with the legibility or sequence of the official identification number.

6.6 Animals born before 9 July 2005 and not currently baseline marked

6.6.1 All animals not already officially identified (tag or tattoo) will have to be baseline tagged before 31 December 2005 even if they are not leaving their current holding before this date. The type of baseline tag or tattoo to be applied depends on where the animal is currently located. See 6.4 and 6.5 above.

6.6.2 This requirement arose from the January 2005 Audit findings. As our current system only requires single tagging the Auditors were concerned about lost tags giving reduced traceability especially on farms where there were also animals that had never been officially tagged. This is an area where SISG members have indicated concerns and further discussions will take place during this consultation period to achieve a practical solution that does not jeopardise our derogation to avoid double tagging.

Question: It is hoped that the tagging of these older unidentified animals could be carried out while the animals have been gathered for other purposes. Is the 31 December date practical in terms of normal animal husbandry issues or can you suggest another date which is more suitable? Please remember that the Auditors will be returning in December this year to ensure we have taken steps to resolve this issue. See Section 10 on page 13

6.6.3 Animals that carry a mark which has the flock/herd number but no individual number should have the mark replaced with a baseline tag. The current tag's flock number will determine which type of baseline tag ( UK or S) should be applied. See 6.4 and 6.5 above.

6.7 From 9 July 2005 - animals to or from a Northern Ireland location

We intend to allow animals moving between Northern Ireland and Scotland to move in accordance with the identification rules in place in the territory of origin. This will mean animals going to NI must carry a minimum of a unique individual identifier - a tag or tattoo if born on or before 9 July 2005 or a tag if born after 9 July 2005. This does not include animals transiting NI to an ROI destination.

6.8 From 9 July 2005 - imported animals born in other Member States before 9 July 2005

6.8.1 An animal born in another Member State ( MS) and brought into Scotland shall retain its original eartag(s) and identification number. However once it is in the UK, in all other respects, the rules that apply will be the same as for a domestic animal.

6.9 From 9 July 2005 - imported animals from a third country (non MS) born before 9 July 2005

6.9.1 Any animal imported from a third country (non MS) which after 9 July 2005 has undergone the checks laid down by Directive 91/496/ EEC and which remains within the UK, shall be identified with an F tag at the holding of destination. This shall be done within a period of 14 days of these checks and certainly before leaving the holding.

6.10 Animals for Intra-community Trade and Export including to ROI

6.10.1 Animals born on or before 9 July 2005 must comply with current identification rules before they can be exported or sent for intra- community trade. They must also comply with relevant export rules.

6.10.2 Animals born after 9 July 2005 and destined for intra-community trade require two identical identification marks to be applied. The first means of ID must be an approved ear tag; the second can be either an ear tag or an electronic ID tag or for goats only, a pastern mark. The rules applying to animals destined for intra-community trade are exactly the same as for domestic animals until such time as they are about to leave the UK. This is the latest point at which the secondary official identifier must be applied to the animal. Animals arriving from another MS must be double tagged before they leave the exporting MS. Once it is in the UK, the rules that apply will be the same as for a domestic animal. The above includes animals to and from the Republic of Ireland that transit through NI.

6.11 Movement Tags

6.11.1 These tags were introduced following FMD and provide a visual way of identifying locations where an animal has been since it left its baseline holding. The Movement tag format is: S followed by the 6 digit Flock Number of the animal's current location e.g. S 542541. No individual number must be applied to this type of tag.

6.11.2 Currently, prior to most types of movement from a location other than where the animal was baseline marked, the keeper must apply a movement tag - this includes all moves to a market. If preferred, the keeper can record the animal's full baseline tag or tattoo number in the holding register and on the movement document as an alternative to applying the movement tag. A maximum of three official tags (combination of baseline and movement type) can be applied. An animal with 3 tags already applied must have its baseline mark details recorded on the movement document before leaving its current location and in the holding register.

6.11.3 After October 2005: For moves from a location other than where the animal was baseline marked. The keeper must apply an approved movement tag for all moves to grazing or wintering and to common grazing on the basis that the animal returns to the original holding. If the animal returns direct to the original location, no further mark is required for either the journey back or for subsequent moves from the original location - as long as the movement tag has not been lost or become illegible.

6.11.4 After October 2005 the following types of moves are exempt from having to apply a movement tag:

• Where the move is from the baseline holding
• Where a move is to grazing, wintering, show and will return to original holding
• Returning to the original location from grazing/wintering or from common grazing where a movement tag had been applied at the original location.
• Short term moves to vets/clinics and for dipping or shearing if returning to the original location.

6.12 Replacement of tags

6.12.1 No means of official identification may be removed without prior official

permission. The replacement requirements for each tag type is as follows:

Baseline tag replacement

6.12.2 Animal still on its holding of birth: If the UK baseline mark has become illegible or has been lost, the keeper must replace it as soon as possible. The two options are to replace it with an eartag bearing an identical mark (if known) or to replace the mark with a UK tag with the same flock mark but a different unique individual number.

6.12.3 Where an animal is not on its holding of birth the keeper should replace the lost UK or S tag as soon as possible. The two options are to apply an eartag bearing an identical number (if known) or to apply an R tag bearing the code UK, followed by the flock or herd mark of the holding on which the identifier is discovered missing or illegible, followed by a 6 digit individual number, followed by the letter R. The identification number must be unique to the animal and the tag must be red. Any animal bearing an R tag is not eligible for intra- community trade

6.12.4 Animals imported before 9 July 2005: As these animals would only have a single identification mark then the replacement rules would be the same as those applying to UK tags and domestic animals (see immediately above).

6.12.5 Animals imported after 9 July 2005: If an animal born in another Member State after 9 July 2005 has been brought into the UK and one of its two identical eartags has become lost or illegible, the missing tag must be replaced with an identical tag.

Movement tag replacement

6.12.6 If a Movement tag has been lost or become illegible the keeper can replace it only if he knows the flock or herd mark on the eartag. The new approved tag must display the same details as the tag being replaced. If the tag details are not known a replacement is not required Format is S 541541.

6.12.7 Information about all replacement tags must be recorded in the holding register (flock book) within 36 hours of the replacement being made.

6.12.8 Operators of markets and slaughterhouses are not obliged to replace lost tags. We propose that the responsibility for replacing tags lost at or on the way to a market rests with the next keeper of the animals.

Question: What are your views on the new keeper being responsible for replacing lost tags? Will this give accurate traceability and how can the industry ensure this action is carried out? See Section 10 on page 13

7. Movement Documents

7.1 Currently keepers need to use a Movement Document ( MD) for most types of sheep and goat moves including 'within-business' moves. Before the journey commences, the keeper at the departure location must provide details of both departure and destination locations, the flock number of the departure location, the total number of sheep travelling and the keeper's contact details. They retain one copy of the MD and the other copy must travel with the animals to the new location where the receiving keeper must check the details given are correct and complete the MD with the date of arrival and their contact details.

7.2 After October 2005 all movements will require the use of movement documents - including common grazing (see section 9), dipping and shearing moves. The only exception is if one location is a veterinary surgery/clinic.

7.3 A re-designed MD to take in the additional EU requirements will be distributed by SEERAD to keepers in early autumn, must be used for all moves. A copy of the proposed new MD is at Annex D At least one copy of the MD must travel with the animals and be handed to the receiving keeper by the haulier.

7.4 As well as the detail required under the current system, the following additional information must be stated prior to departure: CPH of the departure location, name and address of the keeper (this may differ from the animal's departure location), the address and or CPH of the destination location, date of departure and details of the transport used.

SEERAD welcome your commentson suggested changes to the layout and size (A4 or A5) and whether the new MD should be in duplicate or triplicate (extra copy for the haulier?) See Section 10 on page 13

7.5 Receiving keepers will be required to retain a copy of each movement document for a minimum of 6 years.

8. Movement Reporting

8.1 Currently for movements to and from a Scottish market or to a Scottish abattoir the movement data supplied by the keeper is transmitted by the market or abattoir to SAMU (Scottish Animal Movement Unit No separate notification is required by the keeper. Moves to any English or Welsh location are notified by the receiving keeper

8.2 However sheep arriving at a Scottish location from any other Scottish location (other than a market) or from any English or Welsh location must be reported to SAMU by the receiving keeper within 3 days of the animals arriving

8.3 After October 2005 the only types of move which do not have to be reported are when animals move to a vets surgery or clinic or to tattooists. See section 9 on moves involving common grazing.

8.4 Sheep moving to Northern Ireland or another Member State

The keeper at the Scottish departure location has sole responsibility for reporting this type of move to SAMU within 3 days of the move taking place including details of the receiving location. This is in addition to normal export requirements.

8.5 Sheep arriving from Northern Ireland or another Member State

The keeper at the receiving location has sole responsibility for reporting this type of move to SAMU within 3 days of the animals arriving and must provide full details of the departure location.

9 Crofting and common grazing issues

9.1 Following the January 2005 Audit visit, we have been asked to tighten up the current derogation given to crofters on some identification and reporting requirements. These have been highlighted in the appropriate earlier sections of this consultation paper. To ensure the Auditors' required changes can be carried out in an effective and practical manner we will be meeting with crofting representatives during the consultation period to agree a sensible outcome.

10 Partial Regulatory Impact Assessment ( RIA)

10.1 We have assessed the impact the proposed legislation would have on industry and prepared a Partial RIA which is attached at Annex B.

11 Responses

Please see the following list of questions that you may wish to consider responding to. This is only a guide and we would welcome comments on any other areas of this consultation document. Annex E gives details on how to respond.

11.1EC Regulation 21/2004 requires keepers to submit an annual inventory to SEERAD declaring the number of animals present on the holding on a set date. Is 1 January a suitable date for industry ?

11.2 Methods of submitting this data include e-mail, automated telephone system, fax or mail. SEERAD would welcome your views on the best method to ensure that all keepers submit this data accurately?

11.3UK and S baseline tags require a unique individual number - currently this must be a 6 digit number. This sequence often contains leading zeroes e.g. 000234. Would you be content for this format to continue after 9 July 2005 or would you rather tags did not display leading zeroes?

11.4 All animals not already officially identified will have to be baseline tagged before 31 December 2005. Is this a suitable date from a husbandry point of view?

11.5 The keeper at the next location after the market has responsibility for re-tagging sheep that lose their tag on the journey to or at a market. SEERAD would like to hear your views on this issue.

11.6 A new design of movement document is required after 9 July 2005 as more information is required, including compulsory haulier details. Do you think this form should be in duplicate (as currently) or triplicate?

11.7 A new design of movement document is required after 9 July 2005 as more information is required, including compulsory haulier details. Would you find an A5 (current) or A4 size more user-friendly?

11.8 Annex C shows the proposed Herd/Flock Register. Attached to it are Guidance Notes and we would welcome your comments on the clarity of these notes in relation to the keeper's responsibility and required actions.

Livestock ID & Traceability Branch

SEERAD
11 August 2005