Thank you, Stephen.
Thank you for having us here today.
As Stephen said, livestock transport is very specialized. Livestock drivers are responsible for many other duties besides those involved in hauling dry goods. For that reason, our members engage in specialized training. It usually includes an in-class component, an on-the-road component, and then some experience with an experienced driver. Many years ago, livestock drivers used to come from a farming background. From farm consolidation, this pool of labour is no longer available. That has made training even more important.
One of our main initiatives at CTA is to work to develop a national training program for drivers. The main tenet of this program is that it must be recognized as the standard to transport livestock in Canada throughout the supply chain. The content will include animal behaviours, needs and skills required to transport, and relevant regulations. This program will be delivered in a method consistent with driver learning habits, including online content with interactive components, in-class parts, and audits.
This course will be available across the country and will take into account regional differences. It will also include a secure database, so that various stakeholders throughout the supply chain can verify whether a driver possesses the required training to haul different species of animals. As I said, we are working with supply chain partners. This training is demanded throughout the supply chain, from our customers to the end consumer.
A second issue is that of data traceability. CTA is engaged through the IGAC, the Industry Government Advisory Committee on traceability, on the development of a traceability framework. CTA is supportive of this initiative, as the increased level of information that will be available to drivers assists us in performing our duties.
The one issue we have with fully supporting traceability is tag responsibility. Currently, it is prohibited to transport an animal that is not bearing an approved tag. Transporters are therefore expected to only transport animals that are bearing an approved tag. If an animal that is not bearing a tag is found to be transported or arrives at a facility without a tag, the transporter is subject to AMPs fines. These AMPs fines are quite often detrimental to small operations.
For numerous reasons, it is impractical to hold transporters responsible for this. For one, the RFID tag is small, and it is difficult to ascertain its existence visibly. It may actually be unsafe for the driver to get close enough to a large cattle beast, for instance, to inspect its ear, and pickups most often occur in the dark, so it's very difficult to check visibly for the presence.
The tags are also applied either by the owner or the tagging facility, not the transporter. During pickups, drivers are responsible for many things, including loading, sorting, herding the animals, etc., to ensure safe transport. This is their number one priority—safe transport. Adding the additional responsibility of tagging really takes away from their focus on fulfilling all of their core duties.
There are some issues with CFIA, while I'm on the subject of AMPs. Our members are somewhat frustrated at times with the way that inspectors seem to apply regulations. CTA supports the idea that inspectors must have a certain degree of decision-making authority in their method of applying regulations; however, there is some frustration with their inconsistent approach. For instance, some of our members feel that, in the west, there is a tendency to use perhaps an educational approach, whereas the experience of members in the east is that inspectors are more likely to apply an AMP.
As I said before, AMPs are very detrimental to a small livestock business. We suggest that CFIA increase their use of educational enforcement, particularly when dealing with an individual who does not have a previous offence.
The last item I want to discuss is CTA's food safety project.
About eight years ago, CTA developed a trucking food safety program with the support of CFIA and AFAC. The program is a “hazard analysis critical control point” program. Its basis is to identify and eliminate hazards before food can become contaminated. The program includes core elements that all carriers have in place, and then a series of product-specific modules that carriers can add depending on what they haul.
CTA has always believed that the program will have more credibility in the market if it has formal recognition. However, until last year, a recognition process for off-farm HACCP programs did not exist. That void has now been filled with a new CFIA recognition process.
When this recognition program was put into play, CTA applied to AFAC for funding to upgrade its program with the goal of seeking formal recognition. Our application was submitted in June and we are pleased to say we did receive support.
The project is now under way, and we have a carrier advisory committee in place and work has begun to automate the process to deliver a carrier program. The project is scheduled to be completed in February 2013, when we hope to work for the recognition process with CFIA.
Again, thank you for your time.