WSGA Position Paper Re: Traceability - December, 2006
In general terms, the WSGA supports the resolutions adopted by CCA in August 2006 regarding principles for traceability and age verification (see following).
RESOLUTION 6 - TRACEABILITY
THAT THE CCA ADOPT THE FOLLOWING PRINCIPLES OF TRACEABILITY FOR THE DEVELOPMENT OF A NATIONAL SYSTEM FOR THE CANADIAN BEEF CATTLE INDUSTRY:
A. THE SCOPE OF TRACEABILITY FOR BEEF CATTLE:
i. SHALL NOT IMPEDE OR DELAY COMMERCE
ii. COSTS OF THE SYSTEM MUST NOT RESULT IN THE INDUSTRY BECOMING NON-COMPETITIVE
iii. THE TECHNOLOGY MUST BE CAPABLE OF READING ID AT A RATE WHICH ACCOMMODATES NORMAL COMMERCE
iv. TOLERANCE RANGES FOR READABILITY MUST BE ACCEPTABLE TO THE INDUSTRY STANDARDS
v. PRODUCER INFORMATION MUST REMAIN CONFIDENTIAL
B. THAT THE CCA SUPPORTS THE CCIA DEFINITION OF PREMISE ID FOR THE BEEF CATTLE INDUSTRY AS THE HOME QUARTER OR HEADQUARTERS OF THE REGISTERED OPERATOR
C. THE CCA DEFINES TRACKING MOVEMENT OF BEEF CATTLE AS ONLY THOSE POINTS OF MOVEMENT IN THE LIFE OF AN ANIMAL WHERE A CHANGE OF PREMISE TAKES PLACE AND THAT AT THESE POINTS DATA IS SUBMITTED UPON THE ARRIVAL OF THE ANIMAL
RESOLUTION 7 – AGE VERIFICATION
THAT THE CCA SUPPORTS THE PRINICIPLE OF AGE VERIFICATION AND WILL STRONGLY ENCOURAGE PRODUCERS TO VOLUNTARILY PARTICIPATE IN THE PROGRAM
WSGA offers their interpretations and clarifications of the CCA resolutions as follows:
1. Regarding competitiveness, the benefits derived from a traceability system must exceed the costs of that system. Further, those benefits need to accrue to the party in the production chain who is bearing the cost. In other words the eventual traceability system and associated system of commerce must be capable of transferring benefits in an efficient manner to the individual who added the value that resulted in the benefit. An obvious case in point is age verification. The current market system combined with the current RF technology is too cumbersome to efficiently transfer sufficient benefits back to the primary producer (who initially added the value by entering a birth date). As a result uptake of AV has been slower than desired. Potential solutions include a streamlined process for data capture and data entry, and a less intrusive tracking system. These would reduce the costs of the overall system and its operation. However, low frequency passive RFID does not lend itself to these solutions.
2. The speed of commerce and its impedance are referred to in general terms but are not defined. Large packing plants operate at line speeds of in excess of 300 head per hour. Auction market volumes in the busy season often exceed 4500 animals per day. That day will consist of unloading, sorting, selling, reassembling into new outgoing lots, and shipping those lots so the initial 4500 head result in 22,500 events in a 24 hour period. Normal commerce in auction markets currently involves animals moving five or six abreast down twelve foot wide alleys at a brisk walk or trot. Again current RFID mandated by CCIA / CFIA is incapable of tracking under these conditions. Our industry needs a technological solution that suits our system of commerce. Such technologies may already be available and used in other industries but they will require adaptation to the livestock industry.
3. Industry standards for readability have not really been established. However, we do know what the tolerance range is for the end market in the case of Japanese exports. They require 100% read and accuracy to meet their specifications. That requirement, combined with the points outlined regarding transfer of benefits, result in requirement for a system with very high read rates at all tracking locations. Current read rates of 85 to 98 percent in a single file system with passive low frequency RFID are simply unacceptable.
4. Confidentiality of producer information is discussed but not clarified. Original provisions in the CCIA system required strict confidentiality with release of producer information only to authorized agencies and only in the event of food safety or reportable disease occurrences. As we move toward age verified, source verified, production practice verified marketing the confidentiality policy may need to be broadened to allow producers to selectively release their information to certain other parties. However, WSGA believes that producer confidence in the system will break down if entities such as processors or governments are granted widespread access to the database, and in that regard we support recent CCIA decisions to refuse to provide information to certain government agencies. Confidentiality needs to be clearly understood by all stakeholders – producers and their customers, processors, CCIA, and government agencies.
WSGA envisions a traceability system in which the primary producer’s role is simplified to that of ensuring the animals leaving their herd are appropriately tagged and in which the data capture / data transfer associated with that tag are automated. Technology currently exists to read the tag being inserted into the animal’s ear and to attach to that unique ID various information such as date, time and GPS coordinates. The associated information can then be electronically uploaded to databases such as CCIA. The current situation of manual data capture and entry is far too time consuming and error prone. Beyond the herd of origin WSGA anticipate a tracking system which captures data such as ID and age in a stress free, low cost, non invasive manner. This data capture may be required at multiple sites even within the same location. As previously mentioned in the auction market situation it may be desirable to capture this data at incoming, at point of sale (after sorting, including sorting in the auction ring), and at outgoing (after reassembly of lots). The extended read range and multiplicity (ability to read multiple tags exposed to the antenna at one time) that newer RF technologies offer will be instrumental in achieving the envisioned system.
The low frequency passive RFID currently mandated for the cattle industry is rapidly becoming outdated. Other industries have moved to higher frequencies and / or active RF to achieve very similar goals to those outlined by CCA and envisioned by WSGA. These newer technologies are currently under investigation for adaptation to livestock identification purposes. Indeed, Teleflex corporation attended CCIA’s technical committee meeting last fall to discuss adaptation of their ultra high frequency active tags to our industry. They currently use their UHF semi-active tags to track automobiles through toll gates at highway speeds. A number of conditions have changed since the cattle industry selected low frequency passive RF technology. For example, batteries are much more reliable and lower cost than they were when that decision was taken. Similarly our industry is moving towards value added applications for our tag system that were not the priority when passive RFID was selected. Some of these applications may require read / write capabilities that the currently approved technology does not permit. Given the changing priorities, it may be time to reconsider the choice of technology rather than to further the entrenchment of the previously chosen technology. Indeed AAFRD hosted a workshop last spring where an IBM representative did openly question the choice of technology for the cattle industry.
WSGA is concerned that a combination of government incentives and a push by some tracking technology entities may result in widespread adoption of a system which cannot meet the principles outlined above. Those principles are, in effect, the specifications the cattle industry has set out for trace-through technology. As witnessed previously in the CCIA system, widespread adoption of an outdated technology significantly delays adoption of newer technology. If the current technology had a positive cost / benefit ratio the free market system would have already adopted it. The sale barn in Joplin, MO has been offering an essentially identical system for several years now and has been unable to achieve significant market penetration. More specifically, the combination of the Alberta traceability initiative, the Canada Traceability Initiative Program and the federal cost shared reader program along with a professed desire to “bring the current tracking technology system into auction markets on a full scale basis” may lead to adoption of, in WSGA’s opinion, a technologically outdated tracking system. Development and adaptation of new technologies is in part driven by market potential of the resulting product. It may be more appropriate for governments and industry to encourage such new technologies by a series of incentives than to support uptake of an existing technology which the free market has not adopted in the absence of support programs outside of the marketplace.
WSGA is committed to advancing livestock tracking and value-adding. In fact, we have been involved in tracking since our inception in 1896 with our support at that time for a central brand registry. We trust that this document will be used in the spirit intended – that of ensuring the eventual tracking system adopted in Canada will be accurate, efficient and of net benefit to our industry.
In general terms, the WSGA supports the resolutions adopted by CCA in August 2006 regarding principles for traceability and age verification (see following).
RESOLUTION 6 - TRACEABILITY
THAT THE CCA ADOPT THE FOLLOWING PRINCIPLES OF TRACEABILITY FOR THE DEVELOPMENT OF A NATIONAL SYSTEM FOR THE CANADIAN BEEF CATTLE INDUSTRY:
A. THE SCOPE OF TRACEABILITY FOR BEEF CATTLE:
i. SHALL NOT IMPEDE OR DELAY COMMERCE
ii. COSTS OF THE SYSTEM MUST NOT RESULT IN THE INDUSTRY BECOMING NON-COMPETITIVE
iii. THE TECHNOLOGY MUST BE CAPABLE OF READING ID AT A RATE WHICH ACCOMMODATES NORMAL COMMERCE
iv. TOLERANCE RANGES FOR READABILITY MUST BE ACCEPTABLE TO THE INDUSTRY STANDARDS
v. PRODUCER INFORMATION MUST REMAIN CONFIDENTIAL
B. THAT THE CCA SUPPORTS THE CCIA DEFINITION OF PREMISE ID FOR THE BEEF CATTLE INDUSTRY AS THE HOME QUARTER OR HEADQUARTERS OF THE REGISTERED OPERATOR
C. THE CCA DEFINES TRACKING MOVEMENT OF BEEF CATTLE AS ONLY THOSE POINTS OF MOVEMENT IN THE LIFE OF AN ANIMAL WHERE A CHANGE OF PREMISE TAKES PLACE AND THAT AT THESE POINTS DATA IS SUBMITTED UPON THE ARRIVAL OF THE ANIMAL
RESOLUTION 7 – AGE VERIFICATION
THAT THE CCA SUPPORTS THE PRINICIPLE OF AGE VERIFICATION AND WILL STRONGLY ENCOURAGE PRODUCERS TO VOLUNTARILY PARTICIPATE IN THE PROGRAM
WSGA offers their interpretations and clarifications of the CCA resolutions as follows:
1. Regarding competitiveness, the benefits derived from a traceability system must exceed the costs of that system. Further, those benefits need to accrue to the party in the production chain who is bearing the cost. In other words the eventual traceability system and associated system of commerce must be capable of transferring benefits in an efficient manner to the individual who added the value that resulted in the benefit. An obvious case in point is age verification. The current market system combined with the current RF technology is too cumbersome to efficiently transfer sufficient benefits back to the primary producer (who initially added the value by entering a birth date). As a result uptake of AV has been slower than desired. Potential solutions include a streamlined process for data capture and data entry, and a less intrusive tracking system. These would reduce the costs of the overall system and its operation. However, low frequency passive RFID does not lend itself to these solutions.
2. The speed of commerce and its impedance are referred to in general terms but are not defined. Large packing plants operate at line speeds of in excess of 300 head per hour. Auction market volumes in the busy season often exceed 4500 animals per day. That day will consist of unloading, sorting, selling, reassembling into new outgoing lots, and shipping those lots so the initial 4500 head result in 22,500 events in a 24 hour period. Normal commerce in auction markets currently involves animals moving five or six abreast down twelve foot wide alleys at a brisk walk or trot. Again current RFID mandated by CCIA / CFIA is incapable of tracking under these conditions. Our industry needs a technological solution that suits our system of commerce. Such technologies may already be available and used in other industries but they will require adaptation to the livestock industry.
3. Industry standards for readability have not really been established. However, we do know what the tolerance range is for the end market in the case of Japanese exports. They require 100% read and accuracy to meet their specifications. That requirement, combined with the points outlined regarding transfer of benefits, result in requirement for a system with very high read rates at all tracking locations. Current read rates of 85 to 98 percent in a single file system with passive low frequency RFID are simply unacceptable.
4. Confidentiality of producer information is discussed but not clarified. Original provisions in the CCIA system required strict confidentiality with release of producer information only to authorized agencies and only in the event of food safety or reportable disease occurrences. As we move toward age verified, source verified, production practice verified marketing the confidentiality policy may need to be broadened to allow producers to selectively release their information to certain other parties. However, WSGA believes that producer confidence in the system will break down if entities such as processors or governments are granted widespread access to the database, and in that regard we support recent CCIA decisions to refuse to provide information to certain government agencies. Confidentiality needs to be clearly understood by all stakeholders – producers and their customers, processors, CCIA, and government agencies.
WSGA envisions a traceability system in which the primary producer’s role is simplified to that of ensuring the animals leaving their herd are appropriately tagged and in which the data capture / data transfer associated with that tag are automated. Technology currently exists to read the tag being inserted into the animal’s ear and to attach to that unique ID various information such as date, time and GPS coordinates. The associated information can then be electronically uploaded to databases such as CCIA. The current situation of manual data capture and entry is far too time consuming and error prone. Beyond the herd of origin WSGA anticipate a tracking system which captures data such as ID and age in a stress free, low cost, non invasive manner. This data capture may be required at multiple sites even within the same location. As previously mentioned in the auction market situation it may be desirable to capture this data at incoming, at point of sale (after sorting, including sorting in the auction ring), and at outgoing (after reassembly of lots). The extended read range and multiplicity (ability to read multiple tags exposed to the antenna at one time) that newer RF technologies offer will be instrumental in achieving the envisioned system.
The low frequency passive RFID currently mandated for the cattle industry is rapidly becoming outdated. Other industries have moved to higher frequencies and / or active RF to achieve very similar goals to those outlined by CCA and envisioned by WSGA. These newer technologies are currently under investigation for adaptation to livestock identification purposes. Indeed, Teleflex corporation attended CCIA’s technical committee meeting last fall to discuss adaptation of their ultra high frequency active tags to our industry. They currently use their UHF semi-active tags to track automobiles through toll gates at highway speeds. A number of conditions have changed since the cattle industry selected low frequency passive RF technology. For example, batteries are much more reliable and lower cost than they were when that decision was taken. Similarly our industry is moving towards value added applications for our tag system that were not the priority when passive RFID was selected. Some of these applications may require read / write capabilities that the currently approved technology does not permit. Given the changing priorities, it may be time to reconsider the choice of technology rather than to further the entrenchment of the previously chosen technology. Indeed AAFRD hosted a workshop last spring where an IBM representative did openly question the choice of technology for the cattle industry.
WSGA is concerned that a combination of government incentives and a push by some tracking technology entities may result in widespread adoption of a system which cannot meet the principles outlined above. Those principles are, in effect, the specifications the cattle industry has set out for trace-through technology. As witnessed previously in the CCIA system, widespread adoption of an outdated technology significantly delays adoption of newer technology. If the current technology had a positive cost / benefit ratio the free market system would have already adopted it. The sale barn in Joplin, MO has been offering an essentially identical system for several years now and has been unable to achieve significant market penetration. More specifically, the combination of the Alberta traceability initiative, the Canada Traceability Initiative Program and the federal cost shared reader program along with a professed desire to “bring the current tracking technology system into auction markets on a full scale basis” may lead to adoption of, in WSGA’s opinion, a technologically outdated tracking system. Development and adaptation of new technologies is in part driven by market potential of the resulting product. It may be more appropriate for governments and industry to encourage such new technologies by a series of incentives than to support uptake of an existing technology which the free market has not adopted in the absence of support programs outside of the marketplace.
WSGA is committed to advancing livestock tracking and value-adding. In fact, we have been involved in tracking since our inception in 1896 with our support at that time for a central brand registry. We trust that this document will be used in the spirit intended – that of ensuring the eventual tracking system adopted in Canada will be accurate, efficient and of net benefit to our industry.