OFA provided the Canadian Food Inspection Agency (CFIA) with comments regarding the proposed amendments to the Health of Animals Regulations (Identification and Traceability). OFA recognizes the importance of livestock identification and traceability in mitigating the impact of disease outbreaks, food safety issues and natural disasters. We support modernizing and streamlining regulatory requirements to improve compliance with livestock traceability. However, OFA noted concerns that several of the proposed amendments in this consultation would negatively impact the livestock sector.
OFA supports expanding traceability requirements for goats and cervids under the regulations, as they share diseases with currently regulated species.
OFA supports the need for movement reporting requirements for regulated species. OFA understands and supports the need for an efficient response to disease outbreak and agrees that the current allowable time to report of 30 or 60 days for reporting is too long. However, we are concerned that the proposed timeframe of seven days to report is too short and recommend a longer period to report an event to increase compliance.
OFA is strongly opposed to the movement reporting requirements for fairs, exhibitions, and veterinary hospitals. The proposed changes would hold fairgrounds responsible to collect and record animal movements to and from fairgrounds within seven days to the responsible administrator. OFA supports the Ontario Association of Agricultural Societies in their belief that the burden of data collection and reporting should fall on the farm of origin and animal owner and should not fall upon agricultural societies. Additionally, OFA believes the farm of origin should also be responsible in ensuring that all animals sent to fairgrounds have approved/intact/undamaged indicators.
OFA believes that the proposed regulations place significant undue burden on livestock haulers or carriers to be responsible for this information and record keeping, and recommends a shorter record-keeping timeline of 6 months.
OFA supports the proposed change to require Premises Identification Numbers (PIDs) when reporting movement of livestock to the administrator. OFA supports modernizing the definition of animal indicators by replacing the word “tag” with “approved indicator” to support the development of innovation in the sector, such as new technologies and digital solutions. However, it is important that consideration is given to existing sector traceability initiatives, such as PigTRACE, to ensure that the proposed amendments to the HAR do not negatively impact the reputation and usefulness of such programs already in place.
OFA is concerned about the associated costs that would be borne by the livestock industry by the proposed regulatory amendments. OFA recommends and supports the use of funding programs and grants to ensure compliance with these regulations and lessen the burden of costs to the livestock industry associated with the proposed amendments.
Previous related OFA submissions: