Mr. Martin Blake:

I thank the Chairman for the invitation and I welcome the opportunity to attend. I am accompanied by Ms Paula Barry Walsh, deputy chief veterinary officer; Mr. Martin Farrell, principal officer in animal identification and movement division; and Ms Maria Dunne, principal officer in meat and milk policy divisions.

I propose briefly to set out the objectives of a sheep identification and traceability system, reflect on the current system in place and set out the rationale for change. In addition, I will describe the proposed new arrangements and outline the benefits and costs that are associated with these new proposals.

The ability to identify and trace animals is critical from an animal health, food safety and animal welfare perspective. Systems like this support the development of and the veracity of assurances associated with animal and herd health programmes; support disease control activities, including trace back and trace forward; support food safety assurances in areas such as food-chain information and trace back and trace forward in respect of biological, chemical or environmental contaminants in the food chain; and bring accountability in respect of animal welfare.

Traceability is, therefore, important from the individual farmer’s perspective in protecting and promoting his or her own within farm interests and at industry and indeed societal level, where the actions of one or a few can jeopardise the industry and, indeed, society as a whole. Good identification and traceability systems support the optimisation of productivity at farm level in areas such as breeding, nutrition, animal health and animal welfare and at industry and societal level in meeting consumers', both domestic and international, and citizens expectations regarding food safety, traceability and quality. It also supports the targeting and optimising the deployment of resources in risk management interventions by both the industry players and also by the State. The advancement of new technologies in recent years provides newer and better tools to support these objectives.

The current system we have in place for identification and traceability of sheep goes back to 2010. It is grounded in Council Regulation (EC) No. 21/2004. The default position is that sheep must be identified using an electronic identification, EID, system, that is, either an EID tag or a bolus set. However, there is a derogation available for member states where they may authorise an alternative system in respect of sheep less than 12 months of age that are intended for slaughter and that are not intended for intra-community trade or for export to third countries. The derogated alternative system is expected to deliver the equivalent levels of assurance regarding traceability.

To summarise, sheep must be identified by the age of nine months, or six months in intensive sheep production facilities, or when leaving the holding; be identified with an EID set on reaching 12 months of age; have an EID set of tags if they are presented for slaughter, irrespective of age; by way of derogation they may be identified by way of a single slaughter tag, if less than 12 months of age, where they are moving directly from the holding of origin to slaughter plant; and by way of derogation, they may be identified with a single mart tag, if less than 12 months of age, where being sold at a mart. That is the current system.

A number of further scenarios play out in respect of the animals sold at marts depending on their future destination. This depends on whether they are going for slaughter, further fattening or breeding. There are also further additional requirements in respect of loss of tags, in differing circumstances, and in relation to imported animals.

With regard to accompanying documentation, the Department provides specific dispatch documents to individual registered flock owners. This is pre-printed with name, address, flock number and flock identifier, which must be used for any movement of sheep off farm. It is necessary that the individual 12 digit number of all sheep being moved is clearly and legibly entered on to the document. This includes the necessary food chain information declaration that must be signed by the farmer.

In addition, all flock owners are required to maintain a flock register in which they record the date of tagging, movements onto and off the farm, replacement tags and on-farm deaths. The system is complex, with multiple and different scenarios associated with the movement and trading of sheep, which gave rise to the Department to produce a 44 page step by step guide, which was provided some years back.

Moving on to the rationale for change, the current system necessitates the manual transcription of a series of individual 12 digit tag numbers at each point of transaction along the supply chain. This provides a significant ongoing challenge in the context of an effective traceability system. The challenges posed have been recognised over years, with a number of instances relating to animal health, environmental contamination and animal medicines, posing particular difficulties for the Department and, therefore, for the industry in tracing back and forward along the supply chain. While the events in question were all dealt with and eventually contained, the system was found to be particularly ineffective and raised specific concerns in the context of the country’s ability to effectively deal with a widespread food safety event or a widespread contagious exotic disease. A number of internal and external audits have also highlighted concerns about the effectiveness of the current system.

Further issues arise in the context of the single farm payment inspections, where numerous non-compliances, potentially contributing to the application of penalties, have been identified due to errors in the accuracy or correctness of data recorded in dispatch documents or flock registers.

The Department has also experienced increased detailed inquiries from countries with which we have been seeking to develop market access for Irish sheepmeat, in relation to identification and traceability of sheep. It is clear to us that the increased focus on the effectiveness and robustness of traceability from a food safety perspective by these countries is informed by systems that other potential supply countries have in place. These issues have informed commitments in a number of strategic documents which all signalled the need to improve the current system. There is a commitment in A Programme for a Partnership Government to strengthen food safety and traceability and maintain at highest standards. The FoodWise industry document commits to underpin and further improve Ireland’s sheep traceability system and the National Farmed Animal Health Strategy commits to further develop and improve the sheep identification system to better support animal health and food safety assurances and controls.

The main elements of the proposed new arrangement may be summarised as follows: the extension of the requirement for EID to all sheep as the standard default position; the implementation of a derogation in respect of sheep less than 12 months of age moving directly from holding of origin to slaughter, which would require a single EID tag rather than an EID set; marts and slaughter plants to act as central points of recording, CPR, thus removing the administrative burden on farmers to transcribe the individual 12 digit tag numbers of each sheep onto the dispatch documents; and the use of a single colour tag to better enable the upgrading of animals if they are kept for breeding rather than going for slaughter.

The benefits and costs of the new arrangements can be summarised along the following lines. It will definitely simplify the system, with reduced complexity associated with tag types and re-tagging of animals currently. The electronic capture of data will provide readable and accurate records, thus enabling real traceability in respect of the identity of sheep moved. There will be a reduced administrative burden on farmers in completing dispatch documents where they only have to insert the total number of sheep rather than having to transcribe each individual sheep tag number. There will be a reduction in errors for farmers at farm level, which currently contribute to penalties under the single farm payment scheme. There will be a reduced burden on farmers purchasing breeding sheep less than 12 months of age at marts, as the animals will already be identified electronically, and there will be no need for further re-identification when they reach 12 months of age. It will provide a robust on-farm infrastructural tool across the industry that can be leveraged in areas such as breeding, nutrition and animal health to maximise on-farm productivity. There will be a reduced administrative burden on marts in that all sheep arriving will be identified electronically. There will be a reduced administrative burden and errors for dealers purchasing animals at marts for further feeding, as they will all be identified electronically, and there will be no need for further re-identification. There will be a reduced administrative burden for slaughter plants in that all sheep arriving for slaughter will be identified electronically. Critically, it will improve the industry's and the State's capacity to effectively respond in a timely, targeted, focused and accurate way to critical animal health and food safety incidents and events. It will underpin the country’s capability in relation to animal health strategies in the context of animal health programmes, surveillance and control. It will provide the industry with a robust, effective and verifiable traceability system, which can stand scrutiny nationally and internationally from a food safety assurance perspective. It will facilitate the Department, acting on behalf of the industry, in engaging more proactively in seeking and achieving new market access for Irish sheep and sheep products.

In order to achieve these benefits there are, indeed, additional costs for the industry. Farmers will incur extra costs associated with EID tags. For instance, it can be seen in the marketplace at the moment that the marginal cost of an EID tag over a conventional tag is in the region 75 cent. Marts and slaughter plants will need to invest in technology and infrastructure in order to be in a position to act as central points of recording.

Recognising, in particular, the upfront cost to farmers, the Minister has announced a once-off support payment of up to €50 per farmer to assist in the transition from purchasing conventional tags to buying EID tags. It is estimated that this will cost the Exchequer up to €2 million.

In addition, the purchase of electronic identification readers and associated software has been included as a measure supported under the targeted agricultural modernisation scheme, TAMS. This is budgeted to cost in the region of €1 million. While tag readers are not essential in the management of a sheep flock, they are invaluable if a farmer seeks to leverage the benefit of EID in effective management, be it in relation to breeding, nutrition, health or husbandry of his or her flock. This specific support is additional to the sheep welfare scheme, which provides further targeted direct support to the sheep sector in the region of €19 million which falls to be paid in respect of 2017. I mention in the context of the knowledge transfer programmes under the Rural Development Programme 2014-2020 that 4,000 sheep farmers are participating, with a payment of €750 per farmer for those participating.

The Minister and Department officials have met with and have been in contact with the various stakeholders over recent weeks since the announcement in respect of some specific concerns in order to work through practical issues that still remain.