Summary of submissions on the cattle and deer device standards September 2014

Transcription

1 Summary of submissions on the cattle and deer device standards September 2014 Clause # Who Submission Comment Action General 2 NZ Stock and Station Agents Association (NZSSAA) Unclear why changes to standards are being made, particularly to updating visual information elements Information provided in Invitation to Comment Media release on final versions to be provide information on the changes and why 2 NZSSAA Deer are mostly scanned by wand, rather than panel readers which should have a bearing on development of device standards 2 NZSSAA Recommend further review of the technical issues in their submission before progressing 7 Leader Strongly supportive of moving to NAIT number only recording and ordering Allflex Should provide clarification of what is involved in being provisionally approved and approved Noted Noted, but (subject to responses to individual issues raised) also note the issues identified are existing standards (i.e. have not changed) Noted Not relevant for Introduction section, more detail is provided in section 7 of the standard with reference to NAIT Electronic Identification Approval Process document for detail Include definition of provisionally approved and approved in the glossary Allflex Formatting of table and key has split numbers Ensure final version format correct 3.12 (C) 3.11 (D) 6 Allflex Notes that standards are set by ISO and devices (not tags) tested and certified by ICAR (ie ICAR do not set standards). Suggests change in wording as follows: Agree ICAR test and approve devices Accept the proposed wording or a variance 3.12 Devices must be encoded with the relevant manufacturer s code and have

2 Conformance and Performance certification issued by the International Committee on Animal Recording (ICAR) 3.14 (C) 3.13 (D) 6 Allflex Suggests wording should be changed to be clear relates to RFID: 3.14 The female portion of the NAIT Device must contain the RFID transponder. The Act is very clear, and the standard as well, that the Standards are for RFID devices 3.7 (C) 1 Jane & David Field Visual information should be on the male portion of the tag as cannot read visual information on female under normal stick management H&S issues with larger/older bulls RFID tags, not designed for visual information 1 Jane & David Field Allow male portion of tag to have management information as would reduce number of tags in animals (they use two management tags plus NAIT and LIC) RFID tags, not designed for visual information. Also NAIT Management tags invalid from 1 July 2015, so only require two, others presumably for own purposes Leader White female portion should be seen visually from front of animal RFID tags, not designed for visual information This relates to how the device is fitted rather than the device itself? Livestock Improvement Corporation (LIC) Agree Noted 7 Leader Agree, there is need to move to order by NAIT number only Noted 7 Leader Need to be clear that can order and use up to Noted Also need to be clear in

3 30 June 2015 communications that can continue to use devices after June 30 if issued before that date LIC Agree in principle to stopping TRAKA and having replacement tag, but note there are material implementation issues as 1. Require change in behaviour of farmers who have just got use to NAIT system 2. What happens to left over tags (number of farmers bulk purchased on basis of previous NAIT information) Recommend further discussions to determine extent of issue, suggest defer introduction 31 December LIC Agree to removing ability to print a participant-coded birth id tag without a year code LIC management tag phased out but proposes 31 December Suggest discussion NZSSAA Propose only one type of transponder (i.e. either HDX or FDX). Believe would improve read rates as equipment only need to be tuned to read one tag type. One tag type consistent with Australian NLIS. Requests information to support two tag type option NZSSAA Why low frequency tags and not high frequency given advances HF technology. Relates only to issue of new tags, any in farmers have already purchased can be used, although rapidly decreasing need anyway as everything in theory should be tagged from birth Noted Relates only to issue of new tags, any in farmers barn can be used, although rapidly decreasing need anyway as everything in theory should be tagged from birth Agree there is case for only one type of transponder, but current commitment to both will continue until wider work to be done on durability (see below) No proven commercial tag available Amend table to include TRAKA footnote No change to date of entry but comms to be clear at this stage

4 Requests information to support low frequency Leader Future option for considering use of recycled components not prevented 3.17 (C) 3.16 (D) 6 Allflex Tamper proof is not the same as tamper evident as implied. Suggest removing tamper proof as nothing truly is Remove tamper proof and provide more detailed description of what we mean by tamper evident in the Glossary Allflex 1. Signs of aging need not be an issue, and unrealistic with current materials 2. Life time durability is indeterminate and unrealistic with current materials for the few animals that may live up to 15 years Suggest 10 years is a realistic retention time and still cover the lifetime of bulk of animals included within NAIT, and amend as following: 4.1 Under New Zealand conditions, physical deterioration must not significantly affect device retention for a period of 10 years NZSSAA Refers to absence of electromagnetic interference Notes that saleyards have considerable steel construction which means that performance standard really needs to consider how to address this in future 2 NZSSAA 99.5% NAIT devices must be machine readable is too high the Aleis system (which most saleyards use) guarantees 98%. Valid, but not critical at this stage as only in early years of use. Propose further research and evidence to be provided for consideration at later date. Understand that this relates to use high frequency devices which are currently not available. NAIT is comfortable with requirements set in standard at present are appropriate. Relates to preferences how wish to manage stock through readers rather than performance of NAIT devices.

5 How can there be difference? 2 NZSSAA moving freely at a rate of up to 2 metres per second in single file past a reading point with a portal width of 0.8 metres many sale yards have running faster, wider, and four abreast 6 Allflex Suggests that tests of tags could be manipulated by using reader types not normally used in NZ to meet standard, therefore suggests that be amended to the following: 4.2 In the absence of electromagnetic interference, 99.5% of NAIT devices must be machine readable, under New Zealand field conditions, without duplication, or omission in cattle moving freely, at a rate of 2 metres per second, in single file in a race with a width no less than 800mm, past a single sided / single reader, which is commonly, commercially accepted within the New Zealand cattle industry Allflex Life of the animal implies 100% success. This is just not realistic for electronics and will result in a fail at trial with even one failure, therefore propose including a threshold of 99.75% Leader From the proposed changes, the retention protocol of < 2% loss over the first 6 months seems to suggest it can be used to overcome Relates to preferences how wish to manage stock through readers rather than performance of NAIT devices. Note that issue of what are NZ conditions (when consider NZSSAA submission in this area as well) is creating some confusion/ambiguity which could create environment for gaming test processes. However do not consider the level of detail proposed helpful in Standard, will review and update the NAIT Electronic Identification Approval Process. Noted but relates to wider life time and durability issues which require further research and evidence to be presented (see comment on 4.1 above) 2% recognises that some animals will try best to get rid of in early days and easier for tag to come out Will address as part of review of the NAIT Electronic Identification Approval Process document Address as part of review of the NAIT Electronic Identification

6 any critics if survey data supplied is rejected for being on animals for a short period. NAIT seems to be suggesting with these figures that the first 6 months are the most important. Hopefully this does not jeopardize approval or make future data more difficult to get. Look to provide greater clarity in the NAIT Electronic Identification Approval Process document Approval Process document Allflex Rolling average can be interpreted several ways (examples given and detailed below table). Requires clarification Allflex Reference to life time (as comments on 4.1). propose 4.7 Printing on the NAIT device shall remain visually readable for a minimum of 10 years Allflex Accept intent of clause but needs more detail on what is involved Need to provide clarity in supporting material Valid, but not critical at this stage as only in early years of use. Propose further research and evidence to be provided for consideration at later date. Address as part of review of the NAIT Electronic Identification Approval Process document Develop administrative procedures/sop for complaints, suspension, revocation, reinstatement to be made publically available by end of year Federated Farmers Support clarification of suspension, revocation, reinstatement capability and performance requirement under 5.4 for complaints, product recall and replacement procedures but propose that NAIT develop thresholds and criteria for triggering and implementing investigations Develop administrative procedures/sop for complaints, suspension, revocation, reinstatement to be made publically available by end of year 5.2.f 6 Allflex Notes that standards are set by ISO and devices (not tags) tested and certified by ICAR (ie ICAR do not set standards). Suggests Agree ICAR test and approve devices Standards updated

7 change in wording as follows: The Licensee must ensure that RFID numbers are structures to conform to ISO and that the device has Performance and Conformance certification issued by the International Committee on Animal Recording (ICAR) 5.2.h 6 Allflex Propose editorial changes to reflect intent better: The Licensee must describe the physical properties of an approved NAIT device, including the weight, dimensions, etc and also list of the discrete components that make up the device (including the materials of the discrete components). A device is approved as a complete unit and once NAIT approved, components cannot be substituted without prior written agreement from NAIT Allflex Suggest we should include a time frame for response from NAIT. (6 weeks = 30 working days) Agree Agree, but in some instances may need to be preliminary response with notification of anticipated timeframe for conclusion Use proposed language Amend Standards Beef & Lamb NZ NAIT to consider if maintaining a record of NAIT participant complaints about particular devices may provide a mechanism for quickly identifying issues associated with the quality of NAIT devices Establish register and also develop administrative procedures/sop for complaints, suspension, revocation, reinstatement 6 Allflex Agree with need but often complaints are generic and may not relate to a company s product at all, therefore manufacturer should Valid point, but do need to know of all reports even if turns out not to be Extend to 20 working days, and be clear in guidance what

8 only have obligation to report verified and extend period from 10 to 20 working days from the particular company information we require NAIT should approve the product recall and replacement procedure 6 5 LIC Agree all but also ref letter 16 July to LIC and response to NAIT on production, registration and use of replacement devices Agree duplicate tags be destroyed No reuse of tags Replacement tags must be marked as such in NAIT registry Need more time to work though how will work in LIC system NAIT should only set out what expectations of outcomes and not approve procedures, noting that failure to demonstrate have adequate product recall and replacement procedure when audited will be a compliance issue Noted. Business rules to be developed and published by 5 December 2014 No change, detail of outcomes required to be set in guidance NAIT team to work with LIC (and others as needed) to facilitate transition 5 5 LIC Agree all Noted