NAIT compliance criticisms answered
The so-called failure of the NAIT (National Animal Identification & Tracing) system has been a hot topic in the past year.
NAIT has been thrust under the spotlight in the wake of the Mycoplasma Bovis spread, with many suggesting its low compliance rates are a big factor in the rapid escalation of the disease. The role of tracing is to support the identification of where the disease may have spread previously or could have the potential to spread by analysing movement patterns.
However, it is the aspects of the response to the disease through veterinary field presence, diagnosis, testing and farm controls that informs where the disease may actually be in animals or premises and what the risk of further spread might be depending on the nature of the disease, its incubation period and the nature of transmission and animal movement practices.
Some reports appear to indicate the disease may have been present in New Zealand for some time, potentially even within the first few years in which NAIT was being established.
Michelle Edge, Chief Executive of OSPRI which manages NAIT, says although improvements need to be made to the system, much of the criticisms of the online system are now becoming significant distortions of the facts.
“The 70-80% not complying is being conveyed as a national figure and a farm to farm movement recording figure, which is a misinterpretation of the NAIT review report.
“The report presents analysis of data kept within the NAIT system, not measures of performance against this on the ground. For instance, in the report it was identified that the meat processors record, at any one time 90-95% of livestock movements, within 48 hours of occurrence. “
It was important to clarify the report related specifically to the 48-hour NAIT requirement and not the national compliance of the sector says Edge.
“Another example, with deer registration, 85% of deer are auto-registered, meaning they may not register the animals on the farm, but the animals are still tagged and their movement recorded, therefore they’re still traceable and compliant with the other provisions.”
A single figure, based on compliance with one aspect of NAIT, applying to one sector, or a small number of farms is simply not reflective of the entire country’s compliance status.
There were a number of different provisions in the NAIT Act and compliance of each sector occurs at different rates and different times, says Edge.
While perceived and reported anecdotally, that farm to farm compliance may be lower than observed in sale-yards or processing plants, Edge says this is not necessarily a true reflection of the on-ground realities.
“It should be recognised that to measure this, information on the exact number of farm to farm transactions daily would need to be collected for comparison to that recorded within NAIT.”
She says, to effectively report on the nation’s compliance rates, authorities would have to inspect or have a secondary mechanism to validate each and every part of data in the NAIT online system.
“At the moment, we don’t have that capacity. For this to occur, NAIT needs to be integrated with other existing legislative, operational and field enforcement mechanisms.”
The secondary mechanisms Edge refers to are implemented by other nations around the world operating RFID traceability systems, including Australia. They can be broken down into three main types:
- A consignment traceability data comparison, which utilises the animal’s status declaration (ASD) (the piece of paper that travels with the animal in each movement) and provides a direct validation of movement, in other words, that there have been 20 animals on the truck and that they’ve moved from A to B.
- A mandatory registration of the properties and volume of animals held in premises for biosecurity management for comparison against registration, animals held and movement data.
- Physical inspection, which involves the inspectors going out and physically inspecting and validating whether or not the data held in the online system reflects what actually occurred. Sometimes this occurs in the form of national livestock standstill exercise across industry and government to test the effectiveness of the traceability system.
These options were considered in the NAIT review as fundamental aspects towards underpinning the recommendations and future a way forward to enhance the New Zealand biosecurity system.
However, that’s the ‘misnomer’ going on at the moment, says Edge.
“The level of national compliance cannot simply be reported based on the data held in NAIT Whether that is for one single aspect or industry sector or observed by inspecting an insignificant number of premises without examining a wider number of premises and, what is occurring in practice to validate that figure”.
In order to ascertain the level of national compliance, Edge says, investment of more than a billion dollars towards physical resourcing to inspect at least a significant number of premises may be required to assess the thousands of consignments and animals in comparison to NAIT data. This is typical of a user based system and one that requires long term implementation to identify patterns and seasonal changes affecting movements recorded.
“Going forward, we will still be focussing on enhancing compliance through a range of activities to build on past efforts, since this remains a fundamental component of any regulatory program such as NAIT.
“We agree the ongoing need for this, especially the increase in physical field presence of inspectors. Where we can find economies of scale for this investment on behalf of industry and government, we will seek to do so.”
In the coming months, OSPRI will be working with MPI to focus on the issuance of warning letters, reporting on key data fields and then supporting the MPI inspectorate and prosecutors to investigate for further compliance sanctions.
There were options to enhance compliance in the future which would ensure that NAIT is effectively implemented across the entire supply chain.
“We agree that compliance can, and needs to, improve. We will be looking at ways to further invest in this with government and industry.
“We know that many farmers have reported that they find tagging difficult, they find the online system difficult to use, and they are living in remote areas with little or no internet access. The latter part is being raised regularly, however this remains to be an infrastructure issue in rural areas, not something that NAIT itself may resolve in terms of people’s ability to access the internet in remote locations if there is limited telecommunications or internet infrastructure available.
“There are also issues reported with third party providers that are transacting on their behalf and the farmer, that is not directly logging into the NAIT system given they utilise these third party services, is not knowing whether the data entered in NAIT has been captured accurately in their account,” says Edge.
All these aspects had contributed to industry views that complying with NAIT is difficult. Yet, there are many farmers reporting no problems using the system as illustrated by over 1 Million livestock movements recorded in NAIT each month.
Since NAIT is an online database system, NAIT Limited was focused on developing and evolving with future technological advances, where it will become more user-friendly as an online system.
While the requirements to register, tag animals and record movements fundamentally remains the key to traceability.
The NAIT review report had recognised the aforementioned barriers to uptake and compliance and provided several recommendations.
This included standards for information providers and third party systems, tagging application and replacement best practices, more efficient animal registration mechanisms in the online system and the development of new technology platforms for users.
“For greater uptake and compliance in the future, NAIT must be considered as part of daily business and as a fundamental requirement for every commercial entity in the supply chain.
“It should therefore, as indicated in the NAIT review report, be recognised within the legislative framework for both food safety and biosecurity, and built into all licensing and certification of New Zealand product,” says Edge.
It was anticipated, further commercial incentives such as proprietary standards set by international and domestic customers will also include traceability as a key product attribute.
“NAIT should actually be recognised as a market access tool to be widely implemented and for compliance to be driven effectively. In other words, there needs to be “carrots” to complement the “sticks” as observed for the most successful of regulatory programs shared by industry and government.
“Potentially today, the drivers for ‘lifetime’ traceable may not be perceived by industry as being as important as livestock being traceable.”
In spite of the obvious shortcomings in the levels of national inspection and enforcement occurring for NAIT for compliance, Edge says NAIT should be recognised to have assisted in identifying and tracing premises and animals for the Mycoplasma Bovis response. Edge says NAIT has provided over 3000 reports since last July, which have been useful to response efforts and without these, identifying all the infected and suspected premises, animals and their histories could have taken years let alone the impacts on informing decision making and any response action.
“If there was no system like NAIT operating during this response, the situation would be far grimmer. NAIT takes 3-5 minutes to determine premises or animal identification where there is data in the system, and to determine movements recorded.
“If we didn’t have that, the investigators would have had to identify farm locations and contact details of farmers, physically inspect the premises, and collect ASD paper forms to identify the premises that sent animals to or received animals from the infected premises.”
Once they did find a farm, they would have to spend several hours looking at pieces of paper to figure out what the farmer might have done historically. NAIT functioned well when the data was held within the system to report to investigators.
“If biosecurity is the only perceived driver for NAIT, then arguably there are bigger holes in livestock traceability in other species and sectors than those contributing to the NAIT system,” she says.
The next few months meanwhile will be about getting some recognition around traceability, which will involve a few key steps.
First, the need for a combined effort of industry and government in ensuring that NAIT is well implemented as a mechanism for supporting food safety and biosecurity standards across the entire supply chain.
And, she says, “there needs to be recognition between industry and government that NAIT is a legislative and policy framework that transverses the entire supply chain, overseen by Government and implemented by industry, not just an online system in isolation of other standards, requirements and enforcement regimes.”
This meant building NAIT into industry QA programs that drive supplier incentives, and into broader legislation that drives conformance at product verification and certification points, with consideration towards commercial incentives for lifetime traceable product to premises of origin, over and above traceable product.
But for this to be achieved it required joint collaboration of industry and government, otherwise, significant progress would be tough.
“Overseas, meat processing companies provide examples, where they commercially refuse to accept livestock and livestock products that do not conform to all relevant domestic regulation. Other commercial incentives are equally applied in overseas industries, such as saleyard operators charging fees for applying replacement tags, therefore sending a clear message to suppliers,” says Edge.
NAIT Limited for now is focused on implementing the review, including the recommendation for greater compliance enforcement across the supply chain.
The best outcome would see greater field presence to remind users this is a legal requirement, increased reporting to government, and increased enforcement action through combined efforts of industry and government for the investment. A number of other aspects of the review will also be implemented over time to improve uptake of the system and support users in applying NAIT within their daily farming and supply chain practices.
Once changes are made to the system and surrounding supply chain and legislative framework, the next step would be the conduct of a national livestock standstill exercise to see how the system is performing.
Simulations using traceability are an important tool says Edge. The reliability of traceability systems for various endemic and exotic disease conditions needs to be regularly tested by industry and government.
In Australia, exercise DIVA in 2009, tested the national livestock identification system (NLIS) for FMD and the Sheepcatcher and cowcatcher exercises were key examples following this which informed how government would utilise the traceability tool effectively for disease response and where gaps may exist that needed addressing.
Edge says exercises such as these provide, “some real information on the performance of the system against the practices occurring on the ground and at major livestock centres and control points across the supply chain, and that’s going to give real information, not assumed percentages from only localised or minor examples. “