Your local retailer of CCIA-approved cattle tags has until the end of this week to decide whether to continue selling under a new dealer agreement starting Monday.
Previous agreements, under which local veterinary offices and other eligible retailers have sold CCIA (Canadian Cattle Identification Agency) radio-frequency identification (RFID) tags to producers, are terminated effective Feb. 3, as the CCIA reworks its tag distribution system.
That new system places responsibility for CCIA tag distribution to tag retailers in the hands of one distributor for all of Canada.
It also promises a new e-commerce service through which producers can buy their tags online.
Specifically, according to CCIA chairman Dr. Pat Burrage in an email, the new system calls for a “producer-direct e-commerce site where producers can order tags online, the tags are directly issued to their CLTS database account and delivered to the shipping address of their choice.”
Also, starting next year, the new system will levy an annual fee on tag dealers, to fund future audits of their work.
The new retailer agreements raise other question marks for tag dealers, however, as to whether they’ll be able to meet the new requirements.
The CCIA, in a Dec. 12 letter to dealers, said it has been working on “improving the integrity of the data it collects and stores on behalf of Canadian producers” and has “reviewed opportunities” in the current tag network to “improve the quality of the data submitted to the Canadian Livestock Tracking System (CLTS) database.
The letter notifies dealers that, starting Feb. 7, all CCIA-approved livestock tags will be delivered through a single approved distributor: CDMV, a St. Hyacinthe, Que.-based veterinary supply distributor operating nationwide.
The new agreement also requires CCIA tag dealers to keep their database, including backup copies of data, located solely in Canada, with no “direct or indirect dependencies on other databases or systems that are located outside Canada.”
That may pose problems for tag dealers whose current data storage doesn’t fit the new bill.
Case in point: Dr. John Ayres of the Norsask Veterinary Group, which operates clinics at Warman and Rosthern, Sask., north of Saskatoon, said his server containing data on tag sales has been “in my office, in Canada,” but the clinics’ software provider was U.S.-based and has had “periodic access” for maintenance.
According to Ayres, when he asked CCIA about that aspect of the new dealer agreement, he was asked in return whether the third-party service provider can see the files stored on the system. “I said ‘Yes, they have to.'”
According to Burrage, who’s also a large-animal veterinarian (and CCIA-approved tag dealer) at Bluffton in central Alberta, that aspect of the new dealer agreement comes from CCIA’s own agreement with the Canadian Food Inspection Agency (CFIA), which oversees CCIA’s operation of the national cattle traceability system,
CFIA, he said in an email, “requires CCIA to ensure that all aspects of the CCIA database and database processing for the CCIA database reside in Canada.”
The CCIA, he said, is “required to ensure that the same standards apply to all CCIA-approved tag dealers as related to data management and security,” so dealers “must ensure all data collected for the purposes of the sale, distribution or issuance of approved CCIA RFID tags remains in Canada.”
Generally, he said, “this obligation is met once the collected data has been reported to the CCIA database.”
It’s CCIA’s understanding, Burrage added, that CFIA added the new requirement to the dealer agreement in response to the U.S. government’s Patriot Act, which “reduces the restrictions on law enforcement agencies’ ability to search telephone, e-mail communications, medical, financial, and other records without the owner’s or the occupant’s consent or knowledge.”
Thus, he said, the CCIA agreement’s privacy and security requirement “is designed to protect the confidentiality of Canadian regulatory operator data.”
The new agreement also requires tag dealers to ensure they communicate with every member of the public in “English or French according to the preference of that member” and actively provide services to the public in both English and French “as per the preference of their customers.”
It also requires the “quality of their communications and services to the public in each of the English and French languages” be be “comparable to the quality of their communications and services to the public in the other of those languages.”
From where Ayres — a past-president of the Saskatchewan Veterinary Medical Association — sits, that aspect of the new agreement could be a deal-breaker if enforced. Having to provide that level of service in areas of Canada where a dealer’s customers are all English-speaking — or all French-speaking — could be difficult for some sellers, he said.
That language requirement is also based on a CFIA requirement, Burrage said via email.
However, Burrage added, “the reality in each tag dealer location is that business will carry on as it has.
“Though there are some bilingual regions in Canada in which this requirement is critical to producers purchasing approved CCIA RFID tags, most tag dealers are already serving their markets and meeting their clienteles’ needs in their preferred official language.”
No new dealers will be accepted during CCIA’s transition to the single-distributor model. The agency said it also expects no new dealers to be approved until after the new distribution model is “fully established.”
CCIA said in the letter it requires dealers who “operate in a professional manner and can communicate information” about the agency, the national ID program and approved tags to customers — and who also are “dedicated to complying with the regulatory scheme that surrounds the program.”
To that end, the agency’s new fee schedule, due to take effect in 2015, is meant to “support an audit program of authorized CCIA dealers going forward,” which would include monitoring the activities of the tag dealer network.
More details on the new annual fee to be paid by tag dealers are expected this fall, CCIA said in its letter.
While not specifically mentioned in the letter to dealers, CCIA has had reports of some previously-approved tag dealers either late or lacking in their data entry tying the specific tag numbers to the producers who buy the tags.
The new agreement won’t “directly” address those issues, Burrage said, but it “serves to remind the tag dealer network of their contractual and regulatory obligations, which in turn should improve reporting.”
Also, he said, the new dealer license fees will help fund “more rigorous monitoring of tag dealer record keeping as well as an increased audit program of authorized CCIA-approved tag dealers going forward, to improve overall data integrity and accuracy of the traceability data CCIA is responsible to collect.”
As it stands, Ayres said, “basically I have until the end of (January) to decide if I’m in or out” of the dealer agreement, as do many other vet clinics that sell CCIA-approved tags.
In Norsask’s case, he said, selling the tags to producers has been considered more of a customer service than a commercial for-profit venture: “I’m not going to retire on CCIA tags.”
On top of the planned annual fee, the new agreement now also requires tag dealers to carry both commercial general liability insurance and “errors and omissions” liability insurance, Ayres noted.
With the Feb. 3 cutoff coming up fast, he said, the Norsask clinics have already liquidated their inventories of tags and aren’t likely to resume selling tags anytime soon.
CCIA has said it won’t provide refunds for any tags retailers have remaining in stock if they decide not to operate under the new agreement.
— Dave Bedard is the daily news editor for the AGCanada.com Network in Winnipeg.