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    CFIA paper text only

    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.

    #2
    So who pays for it?

    Comment


      #3
      I like his comments always on the money. This year Line will be East and West in Saskatchewan. Ha were wet again. Oh well theirs always next year. Good luck to all.

      Comment


        #4
        Won't work and we don't need it. If they force it on us everybody pays right down to the consumer. Why raise cattle and give up your life to a mob of bureaucrats? Traceability could make the CWB look like a shining beacon of freedom. Doesn't make sense for the Conservative government to take the top 2 in agriculture in opposite directions. HT

        Comment


          #5
          "Won't work and we don't need it."
          Glad your forward thinking isn't leading the industry, HT. Do you want to remove all the barb wire and go back to the open range as well?

          Comment


            #6
            http://www.thestarphoenix.com/columnists/kevin_hursh.html

            Hursh has realistic comments in paper as well. maybe it's time to get on the bus.

            Comment


              #7
              Good logical comments, BTW Larry, the bite is on at Keely, in Wigins Bay get going. As soon as we finish reseeding I am gone.

              Comment


                #8
                I just love buying those RFID tags. Picked up $600 worth last week and I think I will be short.
                When the program was first pitched I was a supporter for all the reasons GF gives. That must be near 20 yrs now and all I see is expense,extreme inconvenience when shipping,and no identifiable benefits.
                They are there to appease non tariff barriers and they only take our product if the politicking is right or the multi-nationals lobby a deal favorable to them.
                We should be negotiating those trade deals now when product is short.

                Comment


                  #9
                  Larry, Wary, Hairy, Gary, Dairy, Terry, Fairy, Perry. Big Frickin Deal, wouldn't listen to one word of drivel from this Joke if'n my life depended on it.........

                  Comment


                    #10
                    My forward "thinking" might not be leading the industry at the moment but that could change. Just depends whether we can put the brakes on your "dreaming in technicolor."

                    I am not part of the group that want to roll up the fences and turn the great plains into a buffalo pasture. They want control of property without owning it. Hmmm...why does that seem familiar?

                    Comment


                      #11
                      Sooner listen to Larry than the stuff that comes from the head office in Winnipeg.

                      Comment


                        #12
                        I wonder if the CWB will have to stop
                        paying shills to post on this site when
                        they lose 80% of our grain for them to
                        market?
                        Larry is always worth the read.

                        Comment


                          #13
                          Having been flooded for the last week and now having my road washed out has put me in the frame of mind to respond to this.
                          The beaurocrats and their ways of creating jobs for their offspring should be told firmly and unequivocally be told to piss off. We have no need of more regulation and all it will do is cost us time and us and the consumer/taxpayer more dollars.

                          GF, you told me once that you came to Canada partially for the freedom it offered, why do you insist on encouraging those you can influence to take that freedom you appreciated away one piece at a time? In your little world of controled pasture grazing I would imaging that it would not be difficult keeping track of where every individual animal is grazing every day. In my situation there are some cattle I may NOT see from the time they go to grass until they come out of the bush sometime in the fall.

                          And you want us all to follow the leader?

                          F the leader!

                          Comment


                            #14
                            Agreed, Larry is always worth the read. I pay for the daily newsletter and find it very valuable. I have compared with other newsletters, marketing updates etc and Weber Commodities is my choice.

                            Comment


                              #15
                              Gto...

                              Did you ever learn anything your mother taught you?

                              Comment

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