Review of Comments

Comments on the Canadian Regulations Amending the Health of Animals Regulations

We discovered this morning that the comments submitted during the consultation for the proposed amendments to the Canadian Regulations Amending the Health of Animals Regulations (Identification and Traceability) have been published.

Our review is ongoing, but the highlights from our perspectives are:

• Many producers are, legitimately, concerned about the imposed costs for additional equipment, services, and effort. We agree; current digitization products are expensive to acquire and disruptive to use for most livestock operations. This is why we created Flokk.
• There is broad and consistent feedback from fairs and exhibitions resisting the reporting of arrival/departure of animals. We find this regrettable; our agricultural institutions should lead the adoption of industry best practices, not resist them. Flokk will be an active partner with fairs, exhibitions, and 4H clubs and looks forward to providing them affordable and easy to use tools they can use to take their leadership role in Canada’s traceability system.
• There is broad dissatisfaction with the performance of current Electronic IDentity (EID) (RFID ear tag) products. We have heard these concerns ourselves from producers on many occasions. Solutions are emerging; Shearwell now offers the CCIA approved Loop Tag that is more resistant to pull out, and HerdWhistle Technologies Inc. is doing innovative work in high frequency EID tags and readers.

The fundamental issue with EID tags for most producers is they bear the cost burden of application but lack any tools to realize benefit from them. This drives them, rationally, to use the lowest cost solution they can secure, and suppliers have responded accordingly. By making EID’s affordable and simple to use for every day herd management tasks Flokk will motivate producers to explore, and pay for, better solutions. Finally, we would suggest that what is being overlooked is a broader view of the support Canada’s livestock producers need to be successful.

Taken in isolation, adoption of new technology and practices solely to meet traceability requirements is a hard sell. But it requires little additional effort, equipment, or change in practice over that necessary to secure mandatory traceability requirements to also:

1. Support a producers participation in existing sustainability initiatives (e.g. CRSB Certified) and,
2. Be ready to delver the reporting and certification necessary to monetize emerging sustainability solutions (e.g. enteric methane mitigation).

Flokk is actively engaged with the CFIA and the CCIA, and is a CRSB member. We are actively exploring the collaborations and partnerships necessary to realize a comprehensive and strategic outcome for cow/calf producers. We would love hear from those who have interest in participating.