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<strong>National</strong> <strong>Livestock</strong> <strong>Identification</strong> <strong>System</strong><br />

<strong>Alpaca</strong> <strong>and</strong> <strong>Llama</strong><br />

Database Options Review<br />

Rick Beasley<br />

Food Safety Operations (Qld) Pty Ltd<br />

Suite 4, 14 King Street<br />

Caboolture QLD 4510<br />

PO BOX 754,<br />

Caboolture QLD 4510<br />

Ph: +61 7 54993388 Fax: +61 7 54990888<br />

E-mail: admin@fsoq.com<br />

Web. : www.fsoq.com<br />

ABN: 67 085 364 352 ACN: 085 364 352


Contents<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

EXECUTIVE SUMMARY ...................................................................................................... 4<br />

BACKGROUND .................................................................................................................... 5<br />

DEVELOPMENT OF TRACEABILITY IN THE AUSTRALIAN CATTLE INDUSTRY .......... 5<br />

NLIS IMPLEMENTATION .................................................................................................. 6<br />

NLIS IMPLEMENTATION BY SPECIES ............................................................................ 7<br />

Cattle ............................................................................................................................. 7<br />

Sheep <strong>and</strong> Goats ........................................................................................................... 8<br />

Pigs ................................................................................................................................ 9<br />

IDENTIFICATION AND TRACEABILITY IN ALPACAS AND LLAMAS ................................ 10<br />

THE ALPACA AND LLAMA INDUSTRY ORGANISATION .............................................. 12<br />

<strong>Alpaca</strong>s ........................................................................................................................ 12<br />

<strong>Llama</strong>s ......................................................................................................................... 13<br />

INTERFACES WITH EXISTING SYSTEMS ........................................................................ 14<br />

Movement Recording ................................................................................................... 14<br />

Accreditation <strong>and</strong> Health Statuses ............................................................................... 14<br />

Registration Databases ................................................................................................ 14<br />

On–Farm <strong>System</strong>s ....................................................................................................... 15<br />

Abattoir <strong>and</strong> Saleyard <strong>System</strong>s .................................................................................... 15<br />

DATABASE SELECTION .................................................................................................... 16<br />

EXISTING SYSTEMS AND OPTIONS ............................................................................ 16<br />

DATABASE OPTIONS .................................................................................................... 17<br />

NATIONAL LIVESTOCK IDENTIFICATION SYSTEM DATABASE .............................. 17<br />

LIVESTOCK TAG AND TRACE (LTAT) ....................................................................... 19<br />

COMPARISON OF DATABASE OPTIONS ..................................................................... 20<br />

TECHNICAL CONSIDERATIONS ................................................................................ 20<br />

ACCEPTANCE BY REGULATORY AUTHORITIES ..................................................... 24<br />

ACCEPTANCE BY INDUSTRY .................................................................................... 25<br />

DATABASE INTERFACES .......................................................................................... 26<br />

HELPDESK AND USER DOCUMENTATION .............................................................. 27<br />

DATABASE IMPLEMENTATION COSTS .................................................................... 29<br />

Cost Estimate from NLIS ................................................. Error! Bookmark not defined.<br />

Cost Estimate from LTAT ................................................ Error! Bookmark not defined.<br />

Cost Comparison ......................................................................................................... 30<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

ELECTRONIC IDENTIFICATION OPTIONS ....................................................................... 31<br />

DEVICE TYPES .............................................................................................................. 31<br />

Ear Tags ...................................................................................................................... 31<br />

Rumen Bolus ............................................................................................................... 31<br />

Subcutaneous Implants ................................................................................................ 32<br />

Impact on the Database ............................................................................................... 32<br />

CHOICE OF RFID TECHNOLOGIES AND FREQUENCIES ............................................... 33<br />

DEVICE ACCREDITATION AND LICENCING .................................................................... 34<br />

CONCLUSIONS AND RECOMMENDATIONS .................................................................... 35<br />

Database Comparisons ................................................................................................ 35<br />

Database Cost Comparisons <strong>and</strong> Selection ................................................................. 36<br />

<strong>Identification</strong> Options ................................................................................................... 36<br />

Page 3


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

EXECUTIVE SUMMARY<br />

The alpaca <strong>and</strong> llama industries have begun investigating options for the storage<br />

<strong>and</strong> retrieval of data collected in compliance with the <strong>National</strong> <strong>Livestock</strong> <strong>Identification</strong><br />

<strong>System</strong>.<br />

The proposed system is principally required as a regulatory database to store <strong>and</strong><br />

retrieve data relating the animal identification, current location, previous locations<br />

<strong>and</strong> associated animals, death or slaughter <strong>and</strong> statuses. The criteria required for a<br />

successful database to store this information <strong>and</strong> make it available in suitable<br />

formats are listed <strong>and</strong> discussed.<br />

The system adopted has to be acceptable to the alpaca <strong>and</strong> llama industries but also<br />

to governments <strong>and</strong> the broader livestock industries in Australia. It must provide as<br />

many options as possible to allow the recording of data to ensure the maximum<br />

industry participation.<br />

Within the context of existing systems in place in Australia, the options available<br />

have been canvassed. Of the four systems potentially available, it has been<br />

concluded that the only viable systems were the <strong>National</strong> <strong>Livestock</strong> <strong>Identification</strong><br />

<strong>System</strong> (NLIS) database under the Meat <strong>and</strong> <strong>Livestock</strong> Australia (MLA) umbrella or<br />

the <strong>Livestock</strong> Tag <strong>and</strong> Trace (LTAT). Construction of a new database would not be a<br />

viable option.<br />

On all major areas of comparison, the NLIS database appears to be a better option<br />

than the LTAT alternative. There appears to be no reason for the alpaca <strong>and</strong> llama<br />

industries to choose other than the established national traceability database.<br />

When initial indicative costs are compared, the NLIS database option will provide<br />

greater functionality at considerably cheaper costs.<br />

With regard to technology, it is essential the RFID technology used must be the<br />

same as has been adopted by other species. Ear tags are possibly the best<br />

alternative for alpacas. Accreditation of tags by other industries may provide the<br />

basis for alpaca accredited tags. Boluses are more secure but there is some doubt<br />

as to their effectiveness in camelids. Subcutaneous implants are possible for llamas<br />

but with strict limitations.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

BACKGROUND<br />

There is a growing requirement throughout the world to require all foodstuffs to be<br />

able to be traced back to the place or places of production <strong>and</strong> to be able to locate<br />

other product from the same origin where problems are detected. This practice has<br />

changed from a marketing ploy to a requirement as consumers place much greater<br />

focus on product integrity <strong>and</strong> food safety. Increasingly, identification <strong>and</strong> traceability<br />

are becoming a nonnegotiable requirement in all food service areas.<br />

In livestock, the requirements vary, depending on the production process <strong>and</strong><br />

livestock movements. Requirements will be less onerous for intensively raised<br />

species such as pigs <strong>and</strong> poultry which are typically raised in batches <strong>and</strong> there is<br />

little movement of stock except on a batch basis. Traceability to source <strong>and</strong> location<br />

of cohorts create minimal challenges.<br />

DEVELOPMENT OF TRACEABILITY IN THE AUSTRALIAN<br />

CATTLE INDUSTRY<br />

Australia commenced official traceability systems in the 1960’s when the program to<br />

eradicate tuberculosis (TB) <strong>and</strong> brucellosis in cattle commenced. This program was<br />

instituted in response to Australia’s trading partners indicating that they would<br />

eradicate these diseases <strong>and</strong> freedom may become a prerequisite to trade. This<br />

program ran until the early 2000’s when both diseases were officially eradicated.<br />

This program could only have been successful if cattle could be accurately traced to<br />

the last property of residence.<br />

There were two important components of the program. The first was to identify all<br />

properties running cattle with a Property <strong>Identification</strong> Code (PIC) <strong>and</strong> to tie this code<br />

to a specific l<strong>and</strong> area. The second component was the use of a tail tag to link an<br />

animal with the PIC of consignment.<br />

Australia’s cattle industry was responsible for the push for greater traceability <strong>and</strong><br />

more rigorous systems. The Australian cattle industry exports around 70% of total<br />

production <strong>and</strong> maintaining credibility <strong>and</strong> buyer confidence is paramount to the<br />

future viability of the industry. In this regard, the rapid diagnosis <strong>and</strong> eradication of<br />

an exotic disease outbreak is essential to an industry so heavily dependent on<br />

exports.<br />

The initial impetus for a national traceability system in Australia came from industry<br />

rather than government on the basis that such a system could serve industry<br />

interests for disease management <strong>and</strong> commercial market requirements. This type of<br />

system best works on a m<strong>and</strong>atory basis, especially given its large reliance on<br />

exports.<br />

After the successful eradication of brucellosis <strong>and</strong> tuberculosis in the 1990’s, there<br />

was consensus between the cattle industry <strong>and</strong> governments, State <strong>and</strong> Federal,<br />

that the industry needed to further refine <strong>and</strong> develop systems of traceback. While<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

the PIC based tail tag system had provided the basis for TB <strong>and</strong> brucellosis<br />

eradication, these programs had highlighted the deficiencies in such a system,<br />

particularly with long term diseases such as TB. There was a need to identify cattle<br />

individually from property of birth right throughout their life.<br />

This led to research on individual identification technologies through the 1990’s to try<br />

to find technology which could operate effectively in the Australian livestock<br />

industries at a cost that would be acceptable to the industry. The initial impetus for<br />

identification followed a series of residue incidents through the 1980’s <strong>and</strong> 1990’s,<br />

culminating in the “Helix” incident in the mid 1990’s.<br />

Helix was the propriety name of a chemical (Chlorfluazuron) used to control insects<br />

in cotton. During the drought of 1994/1995, cattle were fed cotton trash as a source<br />

of roughage. This trash contained traces of chlorflauzuron which was absorbed by<br />

cattle <strong>and</strong> stored in the fatty tissue. Unfortunately, the chemical was almost totally<br />

resistant to breakdown in the body <strong>and</strong> remained in the animal for very long periods.<br />

After the breaking of the drought, cattle were dispersed widely <strong>and</strong> it was impossible<br />

to know which animals were affected. This led to huge industry costs for testing <strong>and</strong><br />

loss of confidence by importing countries.<br />

This process was hastened when the European Union decided in 1999 that the<br />

system used by Australia for identification <strong>and</strong> traceability did not meet the<br />

requirements of the EU, particularly with regard to the control of use of Hormonal<br />

Growth Promotants (HGP’s). A more rigorous system had to be deployed to avoid<br />

having to exit the market.<br />

A partnership was established between the cattle industry, Federal <strong>and</strong> State<br />

governments, <strong>and</strong> MLA to set up the system, fund it <strong>and</strong> decide on the operational<br />

arrangements. The State governments have the legal responsibility for disease<br />

management <strong>and</strong> are responsible for the development <strong>and</strong> maintaince of the PIC<br />

register <strong>and</strong> the ordering of devices. The federal government has provided some<br />

funding for the system, particularly the development of the NLIS database which has<br />

been developed by Meat <strong>and</strong> <strong>Livestock</strong> Australia on behalf of the industry. This<br />

funding was in the form of matching R&D funding <strong>and</strong> special grants.<br />

There was agreement by the cattle industry <strong>and</strong> governments that the system had to<br />

be able to identify the animal for its lifetime, record its location <strong>and</strong> movements,<br />

record companion animals, record death or slaughter <strong>and</strong> record statuses against<br />

the animal. This was required as the basis of a system which ensured biosecurity,<br />

food safety <strong>and</strong> market access.<br />

NLIS IMPLEMENTATION<br />

An essential part of the development <strong>and</strong> roll out of the NLIS program was the<br />

development of the national traceability performance st<strong>and</strong>ards. These st<strong>and</strong>ards<br />

define the base requirements of the Australian identification <strong>and</strong> traceability systems.<br />

The st<strong>and</strong>ards require that the system can trace back 30 days <strong>and</strong> then trace<br />

forward all companion <strong>and</strong> contact animals for this period within 24 hours. It also<br />

requires that an animal can be traced back to its property of birth <strong>and</strong> identify the<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

present whereabouts of all cohorts within 48 hours. This sets the parameters which<br />

must be delivered by the system.<br />

This led to an expression of interest in 1999 for identification devices which were<br />

machine readable <strong>and</strong> could identify the animal for life. At the conclusion of this<br />

process, it was decided that the basis of the system would be Radio Frequency<br />

<strong>Identification</strong> (RFID) at the internationally agreed animal identification frequency of<br />

134.2 KHz. This was subsequently reviewed <strong>and</strong> restricted to Half Duplex (HDX)<br />

only.<br />

The St<strong>and</strong>ard for Permanent <strong>Identification</strong> Devices was developed to ensure that the<br />

technology was effective in meeting the requirements of industry. This St<strong>and</strong>ard<br />

defined the performance characteristics such as read range, retention rates, printing<br />

requirements, NLIS number format, production integrity, etc.<br />

Each State government then passed complimentary legislation ensuring that the<br />

basis of the program was the same in all states. This legislation made it an offence<br />

to move cattle without NLIS identification or to remove an NLIS device <strong>and</strong> required<br />

all sectors of industry to comply with the reporting requirements <strong>and</strong> record<br />

movements to the database.<br />

The NLIS database has been under constant development <strong>and</strong> enhancement since it<br />

was initially developed in 1999. While there will always be a need to add functionality<br />

or new developments, the database now has all the basic functionality required to<br />

operate as the national traceability system. It operates under a nationally agreed<br />

Terms of Use which specifies the stakeholder groups <strong>and</strong> the access to data <strong>and</strong> the<br />

ability to add or modify data for each of these groups. These Terms of Use are<br />

agreed on by SAFEMEAT which represents all sectors of the industry <strong>and</strong><br />

government.<br />

NLIS IMPLEMENTATION BY SPECIES<br />

Cattle<br />

NLIS was rolled out by the various states starting with Victoria in 1998. Each state<br />

has had slightly different implementation timetables <strong>and</strong> strategies. This resulted in a<br />

difficult situation around Australia with a lack of conformity between states. However,<br />

the program became fully m<strong>and</strong>atory in all states from July 2005 <strong>and</strong> this has meant<br />

that the requirements across Australia are now reasonably consistent.<br />

The program for cattle is that an approved RFID device must be attached to cattle<br />

before they leave their property of birth <strong>and</strong> all movements (property to property or to<br />

saleyards or abattoirs) must be recorded along with reference to the number of the<br />

<strong>National</strong> Vendor Declaration (NVD) associated with the move.<br />

<strong>Identification</strong> can be by an ear tag or a rumen bolus <strong>and</strong> ear tag combination. The<br />

device must be accredited under the St<strong>and</strong>ard <strong>and</strong> carry the NLIS logo which is<br />

licensed by NLIS.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

All movements from one PIC to another must be recorded <strong>and</strong> this information can<br />

be sent to the database in a variety of ways but well over 99.5% of the data is<br />

recorded electronically on the database.<br />

There are now close to 195,000 PICs recorded in the system <strong>and</strong> a PIC is allocated<br />

to every place where livestock are held. However, the vast majority of property<br />

owners do not need to have readers, recording equipment or even a database<br />

account. It is only when cattle move directly from property to property that the<br />

numbers need to be read <strong>and</strong> transferred to the database.<br />

The database now h<strong>and</strong>les about 2.5 million cattle movements a month,<br />

representing around 30 million cattle movements a year. This is a surprisingly high<br />

figure with regard to the total herd numbers which are estimated at around 28 million<br />

head. A total of almost 80 million devices have been recorded in the database since<br />

the inception of the program. Most transactions <strong>and</strong> queries are h<strong>and</strong>led by the<br />

database in well under a minute, making it a real time system.<br />

Cattle also have statuses associated with the device number or the PIC. These<br />

statuses may refer to animal health or chemical residue issues or may be related to<br />

market eligibility or to identify lost or stolen cattle, financial interest or completeness<br />

of traceability.<br />

Sheep <strong>and</strong> Goats<br />

The sheep <strong>and</strong> goat industry have not yet had the pressure applied by export<br />

markets to provide a full traceability system. Although a high proportion of lamb <strong>and</strong><br />

mutton is exported, the majority does not go to sensitive markets. This is beginning<br />

to change, however, <strong>and</strong> systems are now being developed to meet market<br />

requirements.<br />

The system for traceability in sheep <strong>and</strong> goats is quite different to that used for<br />

cattle. The program requires a visual tag identifying the property of birth <strong>and</strong> a paper<br />

based recording, typically a <strong>National</strong> Vender Declaration (NVD). The vendor is<br />

required to list all the PICs of birth on the travel document or, alternatively, retag the<br />

sheep with a transaction tag showing the PIC of the consignor. Recently, a mob<br />

based database has been set up to record the movement of mobs of sheep through<br />

saleyards <strong>and</strong>, ultimately, all movements.<br />

While this system does provide some level of traceability, it does have some<br />

problems, in particular the ability to trace saleyard purchased sheep back to the<br />

consigning property <strong>and</strong> the ability to trace sheep reliably back to property of birth<br />

<strong>and</strong> located companion animals from this property.<br />

The future of sheep identification <strong>and</strong> traceability is currently being intensely<br />

discussed <strong>and</strong> a number of enhancements have been suggested to improve the<br />

current system. Some in the industry believe that these changes will provide the<br />

industry with a system with sufficient integrity while others believe that this can only<br />

be achieved by moving to a system similar to cattle with individual electronic<br />

identification <strong>and</strong> a central database to record movements.<br />

Page 8


Pigs<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

The pig industry has recently started developing identification <strong>and</strong> traceability<br />

systems. The vast majority of pigs in Australia either do not move location or move<br />

as groups through a set movement process. These movements can be recorded with<br />

identification through tattoos. There are a small number of pigs that are traded either<br />

property to property or through saleyards <strong>and</strong> a system has yet to be developed to<br />

trace these pigs in a reliable way.<br />

Page 9


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

IDENTIFICATION AND TRACEABILITY IN<br />

ALPACAS AND LLAMAS<br />

There are a number of drivers that will ultimately require the alpaca <strong>and</strong> llama<br />

industries in Australia to develop a system of identification <strong>and</strong> traceability. These<br />

include disease management, residue control, market eligibility, assurance programs<br />

<strong>and</strong> animal management systems.<br />

In the short term, it will be biosecurity concerns which will drive the implementation of<br />

identification <strong>and</strong> traceability systems. While the value of the alpaca <strong>and</strong> llama<br />

industries may not be great when compared to other livestock industries in Australia,<br />

there are implications <strong>and</strong> threats posed to the major industries by relatively smaller<br />

species groups. To this extent, all livestock industries will progressively be required<br />

to implement systems to protect their own industries <strong>and</strong> also reduce the risk to other<br />

industries. The impact of a disease outbreak in a non-food producing industry was<br />

vividly demonstrated by the recent outbreak of Equine Influenza (EI) which caused<br />

incredible disruption to the equine world <strong>and</strong> cost hundreds of millions of dollars.<br />

As with all of these types of programs, the industry is rarely given a prescriptive<br />

system design but is generally required to meet specific outcomes. In the case of<br />

FMD susceptible species, the outcomes required are tabulated in the Performance<br />

St<strong>and</strong>ards for <strong>Identification</strong> <strong>and</strong> Traceability below. These St<strong>and</strong>ards have been<br />

endorsed by the Primary Industries Ministerial Council (PIMC) <strong>and</strong>, as such, carry<br />

the endorsement of the Commonwealth <strong>and</strong> all States <strong>and</strong> Territory Governments.<br />

<strong>Alpaca</strong>s <strong>and</strong> llamas, being ruminants, are considered likely to be susceptible to FMD<br />

or at least possible spreaders of the disease. To this extent, the species are<br />

included in the FMD AUSVETPLAN <strong>and</strong> would be dealt with as susceptible under<br />

the plan.<br />

Page 10


TABLE 1<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

NATIONAL TRACEABILITY PERFORMANCE STANDARDS<br />

Applicable to all FMD Susceptible <strong>Livestock</strong> Species 1<br />

1.1 Within 24 hours of the relevant CVO 2 being notified 3 , it must be possible to determine the location(s) 4<br />

where a specified animal was resident during the previous 30 days.<br />

1.2 Within 24 hours it must also be possible to determine the location(s) 4 where all susceptible animals<br />

that resided concurrently <strong>and</strong>/or subsequently on any of the properties on which a specified animal has<br />

resided in the last 30 days.<br />

Applicable to Cattle Only 5<br />

2.1 Within 48 hours of the relevant CVO 2 being notified 3 , it must be possible to establish the location(s) 4<br />

where a specified animal has been resident during its life.<br />

2.2 Within 48 hours of the relevant CVO 2 being notified 3 , it must be possible to establish a listing of all<br />

cattle that have lived on the same property as the specified animal at any stage during those animals’<br />

lives.<br />

2.3 Within 48 hours of the relevant CVO 2 being notified 3 , it must also be possible to determine the current<br />

location 4 of all cattle that resided on the same property as the specified animal at any time during those<br />

animals’ lives.<br />

Applicable to All FMD Susceptible <strong>Livestock</strong> Species Except Cattle<br />

(Lifetime traceability excluding the preceding 30 days – addressed by 1.1 <strong>and</strong> 1.2, above)<br />

3.1 Within 14 days of the relevant CVO 2 being notified 3 , it must be possible to determine all locations 4<br />

where a specified animal has been resident during its life.<br />

3.2 Within 21 days of the relevant CVO 2 being notified 3 , it must also be possible to determine the location 4<br />

of all susceptible animals that resided concurrently with a specified animal at any time during the<br />

specified animal’s life.<br />

1<br />

For the purposes of the St<strong>and</strong>ards, ‘FMD Susceptible Species’ means cattle, sheep, goats, <strong>and</strong><br />

domesticated buffalo, deer, pigs, camels <strong>and</strong> camelids.<br />

2<br />

‘The relevant CVO’ means the State or Territory Chief Veterinary Officer, or their delegate, in the<br />

jurisdiction where the specified animal is located or has been traced to.<br />

3<br />

For the purposes of these St<strong>and</strong>ards, the term ‘notified’ means the relevant CVO is aware of an<br />

incident that required tracing.<br />

4<br />

‘Location’ means any definable parcel of l<strong>and</strong> including (but not limited to): any parcel of l<strong>and</strong> with<br />

a Property <strong>Identification</strong> Code, travelling stock routes, saleyards, abattoirs, feedlots, live export<br />

collection depots, show grounds, Crown l<strong>and</strong> <strong>and</strong> transport staging depots.<br />

5<br />

Given the risks posed by BSE, it was considered appropriate to establish separate St<strong>and</strong>ards for<br />

cattle.<br />

Page 11


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

There is no requirement in these St<strong>and</strong>ards for the use of individual electronic<br />

identification or the storage of data in the national database. However, it is difficult to<br />

see how these requirements can be met without using these techniques.<br />

The NLIS <strong>Alpaca</strong>s <strong>and</strong> <strong>Llama</strong>s <strong>National</strong> Consultative Committee made a farsighted<br />

decision in February 2009 to implement a NLIS <strong>Alpaca</strong>s <strong>and</strong> <strong>Llama</strong>s using Radio<br />

Frequency <strong>Identification</strong> (RFID) <strong>and</strong> combining the essentials of individual<br />

identification, movement recording <strong>and</strong> slaughter or death recording.<br />

THE ALPACA AND LLAMA INDUSTRY ORGANISATION<br />

Information provided on the alpaca <strong>and</strong> llama industries show that both are relatively<br />

small industries compared to other livestock industries in Australia. However, both<br />

species have viable numbers <strong>and</strong> overall numbers are increasing since importation<br />

began twenty years ago.<br />

One of the difficulties with both species is that the relevant associations are focused<br />

on pedigree <strong>and</strong> breeding information <strong>and</strong> only contain information regarding<br />

registered animals. There is little known regarding the non-registered animals with<br />

regard to numbers or ownership.<br />

For this reason, it is difficult to accurately assess the number of animals in Australia<br />

<strong>and</strong> the number of properties where they are run. The numbers of registered animals<br />

are known but the numbers of both species which are not registered are estimates.<br />

<strong>Alpaca</strong>s<br />

There are two herd registries in operation in Australia.<br />

International <strong>Alpaca</strong> Registry (IAR)<br />

This is an database run by the Agricultural Business Research Institute (ABRI) on<br />

behalf of the Australian <strong>Alpaca</strong> Association (AAA). This is a database of animal<br />

pedigree, births <strong>and</strong> deaths, ownership <strong>and</strong> changes in ownership. This is the larger<br />

breed registry <strong>and</strong> runs on the ILR2 software <strong>and</strong> has the capability to record animal<br />

movements <strong>and</strong> provide a central registry for both registered <strong>and</strong> unregistered<br />

alpacas.<br />

Australasian <strong>Alpaca</strong> Register (AAR)<br />

This is an alternate alpaca register run on the Optimate software. It also has the<br />

potential to record animal movements <strong>and</strong> provide a central registry.<br />

Information indicates that there are over 80,000 registered alpacas <strong>and</strong> 1,000<br />

registered llamas in Australia residing on about 5,000 farms. In addition, the estimate<br />

is that there are a further 45,000 unregistered alpacas <strong>and</strong> 9,000 unregistered llamas<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

on a further 4,000 farms. This would give a total estimated number of alpacas <strong>and</strong><br />

llamas in Australia of around 160,000 head being run on approximately 9,000 farms.<br />

This data would suggest that the average flock size is in the order of 15 head.<br />

The numbers of registered animals would indicate the largest concentration of<br />

animals is in NSW <strong>and</strong> Victoria, each with about a third of the Australian total.<br />

<strong>Llama</strong>s<br />

Registrations of Australian llamas are held in the Australasian <strong>Llama</strong> Register. This<br />

database is similar to the IAR <strong>and</strong> records pedigree <strong>and</strong> ownership information.<br />

The proportion of llamas registered appears to be considerably lower than the<br />

alpacas. This makes estimates of numbers more difficult as possibly only 10% of<br />

animals <strong>and</strong> owners are registered. While the number of members is around 100, the<br />

total of properties which run llamas is much higher. The estimated numbers in<br />

Australia are around 10,000 head.<br />

The average flock size is smaller than the alpaca industry, possibly an average flock<br />

size of 5 – 10 animals.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

INTERFACES WITH EXISTING SYSTEMS<br />

Movement Recording<br />

Logically, there would appear to be some synergies in recording movement<br />

information in the breed registers <strong>and</strong> the NLIS movement register at the same time<br />

ie recording the data in one system automatically transfers the required data to the<br />

other system.<br />

However, on closer analysis, there does not appear to be any advantage in this<br />

approach for the following reasons:<br />

1. There are three possible registries which can store the data <strong>and</strong> this would<br />

have to be specified<br />

2. Many movements will be of non-registered animals which will not be recorded<br />

in any registry<br />

3. The data set is very different <strong>and</strong> the differing data will cause confusion<br />

4. Not all movements will be as a result of a change of ownership <strong>and</strong> not all<br />

changes in ownership will result in change of location<br />

5. The significant cost in developing the integrated system.<br />

Accreditation <strong>and</strong> Health Statuses<br />

It is essential the NLIS database has the ability to record statuses against individual<br />

properties <strong>and</strong> individual device numbers <strong>and</strong> that the property statuses can set<br />

device statuses.<br />

This functionality will allow a much more rigorous quality assurance <strong>and</strong> animal<br />

health programs to be run <strong>and</strong> monitored within herds. For example, programs like<br />

Q-<strong>Alpaca</strong> can be attached to farms <strong>and</strong> animals on these farms. These statuses can<br />

be changed or updated as animals move from farm to farm.<br />

Similar arrangements can be established for programs such as <strong>Alpaca</strong> Market<br />

Assurance Program or other health, welfare or environmental programs established<br />

in the future.<br />

The advantages of storing these statuses against the farm <strong>and</strong>, more particularly,<br />

against the animal are that these statuses can be automatically updated <strong>and</strong> can be<br />

made available to the current location of the animal (farm, saleyard, abattoir etc).<br />

Registration Databases<br />

When NLIS identification devices are issued, they are immediately added to the<br />

NLIS database account of the PIC of the farm that ordered the devices. These<br />

devices will typically be held by the farm until required for use in an animal.<br />

When the device is applied to an animal which is to be registered with the relevant<br />

registry, the device number will be sent with the other registration details. Typically,<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

this will be the visual (NLIS) number <strong>and</strong> not the electronic (RFID) number. It is<br />

essential that both numbers are recorded in the breed registry.<br />

This is best achieved by the breed registry electronically contacting the NLIS<br />

database with the visual number <strong>and</strong> receiving back the matched electronic number.<br />

This facility currently exists between the NLIS database <strong>and</strong> ABRI for cattle<br />

registrations.<br />

In addition, information regarding replaced lost tags needs to be provided to both the<br />

regulatory database <strong>and</strong> the breed register. The information required by the<br />

regulatory database includes the old number (either visual or electronic) <strong>and</strong> the<br />

replacement tag number.<br />

Similarly, when an animal dies or is slaughtered, the animal should be removed from<br />

both databases.<br />

The information regarding both replacement tags <strong>and</strong> deaths can be automated in<br />

that the data can be transferred automatically from one database to the other (in<br />

either direction). However, the cost of implementing these changes will need to be<br />

examined.<br />

On–Farm <strong>System</strong>s<br />

Where electronic on-farm record keeping systems are in use, information from these<br />

systems can be used to update the regulatory database. For example, when progeny<br />

are added to the on-farm system, the information can be automatically sent to the<br />

central database to update these records. Similarly, when animals are transferred in<br />

or out of the herd, transfer reports can be generated to record the movement in the<br />

central system.<br />

It is not envisaged that on-farm computer systems will have widespread use in the<br />

alpaca <strong>and</strong> llama industries while herd numbers are low. However, interfaces should<br />

be available to allow the required information to be uploaded if producers wish to do<br />

so.<br />

Abattoir <strong>and</strong> Saleyard <strong>System</strong>s<br />

Once again, it is not likely that there will be a great use of data transfers from<br />

saleyards <strong>and</strong> abattoirs in the short term. However, as the industries grow, the<br />

numbers traded through these sectors are likely to increase <strong>and</strong> these sectors will<br />

require interface specifications to automatically update the central database.<br />

Saleyards <strong>and</strong> abattoirs both require the ability to query the statuses associated with<br />

an animal <strong>and</strong> then be able to update the database with movement data <strong>and</strong>, in the<br />

case of abattoirs, slaughter data <strong>and</strong> possibly carcass feedback.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

DATABASE SELECTION<br />

The selection of the most suitable database to hold the regulatory information for the<br />

alpaca <strong>and</strong> llama industries requires that the alternatives are assessed on a number<br />

of aspects. The database must obviously be technically capable of providing the<br />

required functions to the satisfaction of the relevant industries but also to the other<br />

stakeholders, in particular the relevant state regulatory authorities. As the industry<br />

grows, there will be a need for interaction with other sectors such as saleyards,<br />

abattoirs, etc.<br />

In any discussion on suitable databases (or the development of a new purpose built<br />

system), it should be remembered that the purpose of this database is basically<br />

biosecurity, food safety <strong>and</strong> market access. To this extent, the choice of the best<br />

option for a database <strong>and</strong> the functionality required will have to satisfy the various<br />

state <strong>and</strong> federal jurisdictions as the first requirement. The role of the industry<br />

organizations in the development of NLIS is to ensure that the system is practical<br />

<strong>and</strong> suits the operation of the industry <strong>and</strong> provides the maximum additional<br />

advantage to the industries.<br />

The six major criteria used to assess the database supply options are as follows:<br />

1. Technical considerations<br />

2. Acceptance by regulatory authorities<br />

3. Acceptance by industry<br />

4. Database interfaces<br />

5. Helpdesk <strong>and</strong> user documentation<br />

6. Cost<br />

EXISTING SYSTEMS AND OPTIONS<br />

There are a number of existing databases which could potentially be used to record<br />

the essential information required by the alpaca <strong>and</strong> llama industries. Those<br />

identified are:<br />

• <strong>National</strong> <strong>Livestock</strong> <strong>Identification</strong> <strong>System</strong> (NLIS) database<br />

• <strong>Livestock</strong> Tag <strong>and</strong> Trace (LTAT)<br />

• International <strong>Alpaca</strong> Registry (IAR)<br />

• Australasian <strong>Alpaca</strong> Register (AAR)<br />

The only two viable options identified amongst established databases appear to be<br />

the NLIS database operated by <strong>National</strong> <strong>Livestock</strong> <strong>Identification</strong> <strong>System</strong> Ltd under<br />

the umbrella of Meat <strong>and</strong> <strong>Livestock</strong> Australia <strong>and</strong> the <strong>Livestock</strong> Tag <strong>and</strong> Trace<br />

(LTAT) operated by the Victorian Department of Primary Industries.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Both these systems are purpose built to provide a dedicated identification <strong>and</strong><br />

traceability database. They were not developed for another purpose <strong>and</strong> modified to<br />

provide biosecurity services.<br />

The two breed registries (IAR & AAR) do have the potential to record the information<br />

<strong>and</strong> in fact both systems have the ability to record identity <strong>and</strong> track movements.<br />

However, neither registry has been specifically designed as a regulatory database<br />

<strong>and</strong> would need considerable enhancement to be able to meet the requirements of a<br />

central database. These requirements are further discussed later in the report.<br />

Bearing in mind the relatively small size of the industries <strong>and</strong> limited financial<br />

resources, it would not seem prudent to spend additional resources in further<br />

developing these systems to meet the full requirements when there are fully<br />

developed systems currently available.<br />

These systems will also have difficulty in providing the perceived level of<br />

independence required by stakeholders.<br />

The option of building a new database to provide the required system has been<br />

considered but not fully scoped. Depending on the rigor of the system developed,<br />

this option is likely to cost somewhere in the range of $500,000 to $1,000,000 to<br />

produce. The design <strong>and</strong> operation of such as system would be very similar to the<br />

two viable options identified. It would not be possible to justify investment of this<br />

order to produce a new st<strong>and</strong>alone system.<br />

It is also worth noting that the major funding body, Department of Agriculture,<br />

Fisheries <strong>and</strong> Forestry (DAFF) has a strong preference that all animal traceability<br />

data reside in the same national database to ensure the maximum efficiency in<br />

storing the data <strong>and</strong> the minimal response time, across all species, in the case of<br />

disease incursion.<br />

DATABASE OPTIONS<br />

It would appear that there are only two viable options that would be suitable for the<br />

alpaca <strong>and</strong> llama breeds to use as a traceability database. These are the NLIS<br />

database <strong>and</strong> the Victorian government LTAT system. This is not surprising as both<br />

these databases have been specifically developed as traceability databases <strong>and</strong><br />

require little or no modification or increased functionality to provide the alpaca <strong>and</strong><br />

llama requirements.<br />

NATIONAL LIVESTOCK IDENTIFICATION SYSTEM DATABASE<br />

The first use of the NLIS program in Australia commenced with the cattle industry.<br />

The industry, in consultation with State <strong>and</strong> Federal governments <strong>and</strong> other industry<br />

stakeholders, decided to move from a mob based system to individual identification.<br />

This was accelerated by the 1998 decision of the Victorian government to provide<br />

industry with one million tags at no cost <strong>and</strong> also the audit by the European Union in<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

1999 which concluded that the traceability arrangements for the Australian cattle<br />

industry did not meet the EU requirements.<br />

As a result of a potential ban on exports to the EU, the cattle industry <strong>and</strong><br />

government hastily agreed to implement the NLIS on a limited basis to supply<br />

product to the EU from a “closed” system. This required the establishment of a<br />

database to record device issue, movements <strong>and</strong> eligibility. The interim database<br />

was commenced in the middle of 1999 <strong>and</strong> was operational by November of that<br />

year. Development was carried out by external developers under management by<br />

MLA.<br />

Once the basic functionality of the system had been established, MLA decided to<br />

request expressions of interest from organizations interested in developing the full<br />

system. After a full evaluation of responses, it was decided that MLA would continue<br />

to manage the ongoing development using the initial company Catjes Pty Ltd. This<br />

arrangement continued until 2006 when the development team was employed<br />

directly by MLA <strong>and</strong> development was brought in-house.<br />

The database has evolved over the last 10 years with increasing complexity <strong>and</strong><br />

functionality. While the system has a lot of functions that will not be required by the<br />

alpaca <strong>and</strong> llama industries at present, it is far more economical to turn off these<br />

functions rather than having to build them at some future date. An example of this is<br />

the carcass feedback section which allows for carcass data to be uploaded by the<br />

abattoir <strong>and</strong> made available to the breeder <strong>and</strong> consignor.<br />

The database operates under an industry agreed Terms of Use (ToU) which<br />

determine who can view data, who can add data, who can change data, etc. This is<br />

of critical importance since the data held is from a variety of sources including<br />

producers, saleyards, abattoirs <strong>and</strong> government. The discussion is not about who<br />

owns the data but who has access to it.<br />

The database has been operating now for 10 years. The range of functions <strong>and</strong><br />

interactions has progressively been increased over this period. All the functionality<br />

has been fully tested, both before release <strong>and</strong> then in operation, for a considerable<br />

period of time.<br />

Funding for the development of the database has come from levies collected from<br />

the red meat industries (cattle sheep <strong>and</strong> goats) <strong>and</strong> funding from the federal<br />

government. This funding has been from federal R&D matching funding or special<br />

funding through DAFF.<br />

In early 2009, the NLIS portion of MLA was transferred to an autonomous company,<br />

still within the overall umbrella of MLA. The new body is called <strong>National</strong> <strong>Livestock</strong><br />

<strong>Identification</strong> <strong>System</strong> Ltd. It now operates under its own board although this board is<br />

MLA nominated. This should not result in large changes to the operation of the<br />

system but will give the new organization greater autonomy, particularly with those<br />

groups outside of the cattle <strong>and</strong> sheep industries which pay levies to MLA.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

LIVESTOCK TAG AND TRACE (LTAT)<br />

The <strong>Livestock</strong> Tag <strong>and</strong> Trace (LTAT) database is a relatively new database,<br />

developed <strong>and</strong> operated by the Victorian Department of Primary Industries.<br />

The Victorian DPI began encouraging the use of RFID devices in sheep in 2007. The<br />

use was promoted as a flock management aid rather than as a regulatory tag to take<br />

the place of the currently approved visual NLIS tags. The sheep industry was deeply<br />

suspicious that this was the “thin end of the wedge” <strong>and</strong> would lead to m<strong>and</strong>atory<br />

electronic tagging. The industry was deeply opposed to this on the basis of the cost<br />

relative to the average value of the animals. The industry consequently put pressure<br />

on MLA to not allow the entry of sheep RFID data into the NLIS database.<br />

It is essential to have a database to underpin the use of RFID tags. At a minimum,<br />

the database must record the issue of the devices <strong>and</strong> the movements from one<br />

property to another. Given the industry block on using the existing database, the<br />

Victorian DPI had little choice but to build their own database system to support their<br />

policy initiative.<br />

Subsequently, the Victorian DPI has amended their legislation to allow sheep to<br />

move without having to record the movement on a group basis or have a transaction<br />

tag applied if they had NLIS RFID tags applied <strong>and</strong> they were correctly recorded on<br />

the database.<br />

The Victorian DPI decided to build more than the basic database required <strong>and</strong><br />

designed almost a replica of the NLIS database in terms of the functionality.<br />

The team that designed <strong>and</strong> built this system were largely members of the same<br />

team as were involved in building the NLIS database. Consequently, there are<br />

similarities between the two systems. With a few minor differences, the two systems<br />

are designed to provide almost identical functions.<br />

The Victorian system does have the advantage of having been designed <strong>and</strong> built<br />

nearly 10 years later than the NLIS database. Although it does reflect some changes<br />

to technology over this period <strong>and</strong> does incorporate some design enhancements, it is<br />

surprisingly similar to the older system.<br />

Funding for the LTAT system has been from the Victorian government without<br />

assistance from industry funds or federal funding.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

COMPARISON OF DATABASE OPTIONS<br />

TECHNICAL CONSIDERATIONS<br />

It is not intended to give a detailed technical discussion of existing or, potentially, a<br />

purpose built system at this point. However, it is important that the system has the<br />

technical capability to be able to operate effectively <strong>and</strong> that data can be stored <strong>and</strong><br />

recovered efficiently. The system also needs to be secure <strong>and</strong> an adequate data<br />

backup <strong>and</strong> redundancy arrangements are in place.<br />

The major technical considerations are as follows:<br />

o Operating system<br />

o Operating database<br />

o Web server<br />

o Coding language<br />

o Hardware<br />

o Hosting<br />

o Change <strong>and</strong> development control<br />

o Modularity of code <strong>and</strong> ease of change<br />

o Level of documentation<br />

o Technical support<br />

o <strong>System</strong> performance <strong>and</strong> scalability<br />

o User documentation<br />

The basic technical specifications <strong>and</strong> considerations of the two systems are shown<br />

below in Tables 2 <strong>and</strong> 3.<br />

Page 20


TABLE 2<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Technical Description of the NLIS <strong>System</strong><br />

Area NLIS<br />

Operating <strong>System</strong> Windows Server 2003<br />

Operating Database SQL Server 2005<br />

Database Upgrade Planned upgrade in 2011<br />

Web Server IIS6<br />

Coding Language C++/ASP.Net/C#<br />

Web Service Support Currently supports SOAP messages over http POST.<br />

Web service implementation planned in 2010.<br />

Suitable Hardware • High availability clustered infrastructure to maximize performance<br />

<strong>and</strong> minimize downtime.<br />

• Separate development, QA, pre-production <strong>and</strong> production<br />

environments.<br />

Hosting Centre Externally hosted in a managed data centre.<br />

Disaster Recovery Centre Externally hosted in a managed data centre.<br />

Change Control Process ISO9001 certified change control process engaging industry<br />

stakeholders.<br />

Development Control ISO9001 certified process based on an agile methodology.<br />

Modularity of Code High level of modularity in a three-tier architecture.<br />

Ease of Extension of New<br />

Functions<br />

<strong>System</strong> modularity provides easy addition of new functions.<br />

Implementation of new functions is achieved through configuration<br />

changes or custom development, depending on requirements.<br />

Rapid development environment <strong>and</strong> modular website design allows<br />

Ease of Change of Web<br />

Site<br />

for easy change to the website.<br />

Ease of Change of Easy modifications supported through an extensive suite of automated<br />

Database<br />

regression tests.<br />

Number of Releases Fortnightly releases are performed in accordance with change control<br />

processes. Releases are undertaken during defined maintenance<br />

windows to maximize availability.<br />

Testing Processes In accordance with ISO9001 certified development process, carried<br />

out by dedicated internal QA resources<br />

Planned Development 2009/2010 development program in place for major enhancements.<br />

Changes<br />

Minor enhancements released in accordance with change control<br />

process.<br />

Level of Documentation Extensive – business, functional, technical <strong>and</strong> user documentation<br />

available.<br />

External Party<br />

Extensive. External documentation in use by numerous third party<br />

Documentation<br />

software integrators.<br />

Developer Team Size Development team of eight, plus business analysis <strong>and</strong> QA resources.<br />

Technical Support The NLIS contract with the external hosting provider includes<br />

(Hardware)<br />

hardware, operating system software <strong>and</strong> network infrastructure<br />

technical support to defined service levels.<br />

Technical Support NLIS development team provides technical support for the NLIS<br />

(Software)<br />

application. NLIS Technical Support Officer provides third level<br />

support <strong>and</strong> is an escalation point for Helpdesk <strong>and</strong> third party<br />

integrators.<br />

After Hours Support 24 hour monitoring <strong>and</strong> Helpdesk for infrastructure <strong>and</strong> system<br />

availability. Escalation processes are in place to engage the NLIS<br />

team in the event of an alert.<br />

User Helpdesk available 8am – 6pm Monday to Friday.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Area NLIS<br />

<strong>System</strong> Performance 99.95% of transactions are processed in under 30 minutes. Carcase<br />

Feedback is batched <strong>and</strong> processed every 2 hours.<br />

Scalability Designed on highly scalable architecture. Scalability testing is<br />

undertaken to ensure system performance meets forecast usage.<br />

<strong>System</strong> Uptime<br />

99.95%<br />

Expectations<br />

Range of Functionality • <strong>Livestock</strong> traceability<br />

• Residue <strong>and</strong> disease management<br />

• Market eligibility statuses<br />

• Carcase feedback<br />

• Compliance monitoring<br />

• Management reporting<br />

• Account management<br />

• <strong>System</strong> administration<br />

• User privacy, governed by Terms of Use<br />

• <strong>System</strong> management alerts <strong>and</strong> extensive logging <strong>and</strong> audit<br />

Training Material <strong>and</strong> User<br />

Documentation<br />

trail<br />

Extensive user documentation targeted for specific types of user.<br />

Page 22


TABLE 3<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Technical Description of the LTAT <strong>System</strong><br />

Area LTAT<br />

Operating <strong>System</strong> MS Windows Server 2008<br />

Operating Database MS SQL Server 2005<br />

Database Upgrade MS SLQ Server 2008 in 2010<br />

Web Server MS IIS 6.0<br />

Coding Language C#<br />

Web Service Support All major interfaces<br />

Suitable Hardware Purchased in 2008<br />

Hosting Center Contracted DPI Controlled<br />

Disaster Recovery Center DPI Internal<br />

Change Control Process Project Team<br />

Development Control DPI Vic Controlled<br />

Modularity of Code Each transaction is modularly implemented<br />

Ease of Extension of New<br />

Functions<br />

Very Easy<br />

Ease of Change of Web<br />

Site<br />

Modular Design<br />

Ease of Change of<br />

Database<br />

Improved entity relationships<br />

Number of Releases New release every 6 weeks average<br />

Testing Processes Developer Supplied<br />

Planned Development<br />

Changes<br />

18 month development plan<br />

Level of Documentation Good – St<strong>and</strong>ardized documentation formats<br />

External Party<br />

Documentation<br />

Good – Smaller volume<br />

Developer Team Size 6<br />

Technical Support<br />

(Hardware)<br />

Internal DPI<br />

Technical Support Internal DPI<br />

(Software)<br />

After Hours Support Available<br />

<strong>System</strong> Performance Processing targets of 20 mins per transaction<br />

Scalability Designed for in excess of 400 Million animals<br />

<strong>System</strong> Uptime<br />

Expectations<br />

99.9%<br />

Range of Functionality Moderate – expecting to increase<br />

Training Material <strong>and</strong> User<br />

Documentation<br />

Under development<br />

While the tables above are designed to highlight the differences between the two<br />

systems, the differences that would be noticed by a system user would be minimal.<br />

Generally, the differences will be most noticeable if changes to the base system to<br />

incorporate new system user requirements were to be required. The newer, more<br />

modular design of LTAT should make major modifications easier <strong>and</strong> cheaper<br />

although recent changes to the NLIS system have improved this area. However,<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

given that there would not appear to be any major changes required to either system<br />

to incorporate the needs of the alpaca <strong>and</strong> llama industries, this difference would<br />

seem to be theoretical.<br />

One substantial advantage that the NLIS database has is the fact that it has been<br />

operated for a much longer period of time <strong>and</strong> this therefore fully “battle hardened”.<br />

No amount of desk testing will ever find all the potential problems <strong>and</strong> conflicts that<br />

will arise with the public release of a new system. Virtually all of the NLIS database<br />

has been used for many years <strong>and</strong> is now fully field tested <strong>and</strong> stable.<br />

ACCEPTANCE BY REGULATORY AUTHORITIES<br />

The proposed regulatory database will, by definition, be used extensively by the<br />

various regulatory authorities, both State <strong>and</strong> Federal. A very important aspect of the<br />

selection of a suitable database will be the acceptance by these authorities of the<br />

system used.<br />

Ultimately, a high proportion of the data held in the system will be provided by the<br />

regulatory authorities or will be subject to regulatory control. The State <strong>and</strong> Federal<br />

jurisdictions are going to have to be satisfied that any system used provides the<br />

following characteristics:<br />

• The system is secure <strong>and</strong> the data is safely stored<br />

• The system has sufficient redundancy <strong>and</strong> the data is securely backed up <strong>and</strong><br />

can be restored fully <strong>and</strong> quickly if required<br />

• The business rules agreed on by industry <strong>and</strong> government are reflected in the<br />

code <strong>and</strong> operation of the system<br />

• The required data can be accessed quickly in time of emergency <strong>and</strong> the data<br />

is in a format which allows rapid interrogation, underst<strong>and</strong>ing, dissemination<br />

<strong>and</strong> transfer into other associated systems<br />

• Ideally, all species should be kept in a single database to avoid duplication of<br />

enquiries <strong>and</strong> to ensure the most efficient tracking in the event of an<br />

emergency disease event<br />

• The system interfaces with other existing systems such as the individual State<br />

PIC registers<br />

• There is no cost placed on the regulatory authorities in terms of usage costs<br />

or modifications to their existing systems<br />

• There must be the maximum amount of flexibility, simplicity <strong>and</strong> user support<br />

built in to the system to allow stakeholders to meet their regulatory<br />

requirements<br />

• Reports required to ensure compliance must be able to be generated in a<br />

format that allows adequate monitoring<br />

• The ability to automatically export data on a regular basis to mirrored<br />

databases set up in a number of states <strong>and</strong> federally<br />

Unless the system proposed by the alpaca <strong>and</strong> llama industries meets these<br />

requirements, it is unlikely that the system will receive the endorsement of the<br />

regulatory authorities.<br />

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NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

As previously noted, the program is basically being looked at in terms of biosecurity<br />

<strong>and</strong>, as such, must be acceptable to Federal <strong>and</strong> State governments as “fit for<br />

purpose”.<br />

In this regard, the NLIS database should meet all expectations of the regulatory<br />

authorities, having been developed with input <strong>and</strong> consultation from government <strong>and</strong><br />

industry since the start of the system. The system currently meets all the<br />

requirements for the NLIS cattle program <strong>and</strong> should therefore be able to meet any<br />

regulatory requirements for the alpaca <strong>and</strong> llama industries that may negotiated with<br />

government.<br />

In addition, the NLIS has a very large number of reports able to be run by regulatory<br />

authorities. These reports have been specifically built to satisfy the government<br />

requirements to check <strong>and</strong> monitor both an industry <strong>and</strong> an individual stakeholder<br />

level. These reports will be able to be run for other species.<br />

The NLIS database has been set up to automatically update state “mirrored”<br />

databases on a daily basis. This allows the data to be stored <strong>and</strong> accessed in a<br />

number of locations <strong>and</strong> allows states to integrate this data into their own systems.<br />

The Victorian LTAT system, by comparison, is difficult to judge as it is still under<br />

construction. It would be reasonable to assume that, being constructed by a state<br />

department, the system will suit the requirements of the state regulators. However,<br />

there are a number of areas which are not currently constructed including the<br />

regulatory reports <strong>and</strong> connection to mirrored systems.<br />

As LTAT has been developed in isolation from all regulatory bodies except the<br />

Victorian department, there is no guarantee that it will satisfy other states <strong>and</strong> there<br />

is no existing mechanism to allow other jurisdictions to have input or influence over<br />

development or enhancement.<br />

Another factor is the willingness of other states to accept a database run by one<br />

state to be the national database for a species. It is likely that some states would be<br />

looking to a more independent national system.<br />

The States <strong>and</strong> the Federal government will also be looking for a single database to<br />

hold all animal identification <strong>and</strong> traceability data. This will build further pressure for<br />

the NLIS database to become the national repository.<br />

ACCEPTANCE BY INDUSTRY<br />

A regulatory database must be configured <strong>and</strong> delivered in such a way that the<br />

industries covered by the program are happy that the system provides the industries<br />

with a service which is effective. The model being developed in Australia involves<br />

each industry group having a degree of autonomy over the type of system that is<br />

developed <strong>and</strong> some control of the business rules governing their system.<br />

Page 25


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

In some countries around the world, the traceability database is run by the<br />

government. This generally removes the cost of developing <strong>and</strong> running the<br />

database from industry resources but the final system will be set up to satisfy the<br />

government requirements which are often much narrower than what may be required<br />

by industry.<br />

To be acceptable to the relevant industries, the system must be robust <strong>and</strong> secure<br />

<strong>and</strong> the performance must be adequate to meet the needs of the industry. Issues of<br />

data ownership (or more importantly, access) must be resolved. Most industries are<br />

not comfortable with a commercially owned database holding a great deal of<br />

commercially sensitive data.<br />

In this regard, an industry owned private company such as Meat <strong>and</strong> <strong>Livestock</strong><br />

Australia is ideally placed to develop <strong>and</strong> run this type of database on behalf of<br />

industry. MLA is seen as an independent body separate from government but<br />

without having commercial pressures.<br />

It is reasonable to assume that industry would object to any NLIS type system being<br />

totally run <strong>and</strong> controlled by government let alone one state government. It would<br />

require a lot of negotiation with regard to access, functionality <strong>and</strong> funding for this to<br />

become a national system.<br />

In this regard, it is unlikely that the LTAT system will continue to operate in the longer<br />

term. It is likely that the data currently being collected for sheep <strong>and</strong> goat<br />

identification will ultimately be transferred to the NLIS database.<br />

Any use of LTAT is then likely to be short term. Industries such as the alpacas <strong>and</strong><br />

llamas will need to be mindful of the possible additional costs if they were to choose<br />

the LTAT option <strong>and</strong> LTAT was to be subsequently folded into the NLIS system.<br />

DATABASE INTERFACES<br />

It is important that any system used or developed has the maximum flexibility in<br />

terms of adding data or querying data.<br />

Data uploads will typically come from producers, third parties, device manufacturers,<br />

regulatory authorities <strong>and</strong> potentially from saleyards <strong>and</strong> abattoirs. Each sector will<br />

have specific database access requirements but the important interfaces which<br />

should be available are:<br />

• Web based access, allowing data to be entered on screen through a web<br />

browser. This should be further enhanced to include a downloaded data set<br />

with the ability to be able to add or alter data from this listing<br />

• CSV <strong>and</strong> XML file formats to allow uploads from spreadsheets of other<br />

software systems<br />

• Paper based transfer information is going to have to be accepted but may be<br />

subject to commercial charges<br />

• Access by mobile phone<br />

Page 26


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

In addition to data uploads, stakeholders need to be able to query the database to<br />

the extent allowed by the business rules. It is essential that these queries are<br />

available by a variety of methods, including all those listed above with the exception<br />

of paper based.<br />

The NLIS database has developed these interfaces in consultation with industry over<br />

the last 10 years. Electronic systems used in saleyards <strong>and</strong> abattoirs have<br />

developed automatic systems to query <strong>and</strong> upload to the database.<br />

Recording of transfer information by paper based systems is highly inaccurate <strong>and</strong><br />

expensive compared to electronic lodgment. However, in order to allow all producers<br />

a method of being able to send data to the system, it is essential to have the option<br />

available. The NLIS database has continued to offer the service but now charges a<br />

commercial fee of $10.00 per sheet (up to 20 entries) plus a $4.00 order fee. While<br />

this has reduced the volume being received, there are still a significant number of<br />

these forms being used. This service does not have to be attached to the database<br />

<strong>and</strong> could be provided by a commercial service.<br />

The NLIS Express system has been developed to allow most stakeholder groups to<br />

both query the database <strong>and</strong> upload data by use of nothing more than a mobile<br />

phone, either with or without a tag reader.<br />

By contrast, LTAT only has the options of entering material into the web pages or<br />

using web services. This means that any files that are constructed in a spreadsheet<br />

or in a CSV or XML format would have to cut <strong>and</strong> pasted into the web page or set up<br />

for web services upload. Web services is only an option for larger, commercial<br />

software systems <strong>and</strong> will not suit most property transfers. This will cause some<br />

difficulties <strong>and</strong> will preclude the use of the current mobile phone query <strong>and</strong> update<br />

service.<br />

HELPDESK AND USER DOCUMENTATION<br />

As with any new system, there will be a need for help desk resources to be available<br />

at a high level initially <strong>and</strong> at a reduced level on an ongoing basis. It is essential that<br />

the help desk is manned for at least office hours on week days.<br />

The help desk operators will need an intimate knowledge of the operation of the<br />

NLIS program, differences between states <strong>and</strong> the operation of the underlying<br />

database. Most queries will be routine <strong>and</strong> involve talking new users through the<br />

particular process they are attempting such as setting up accounts or recording<br />

transfers. However, advice will have to be provided on the whole range of issues<br />

surrounding the implementation of a new program including:<br />

• Legislative requirements<br />

• <strong>Identification</strong> methods, options <strong>and</strong> techniques<br />

• Account creation<br />

• Database access options<br />

• Recording movements<br />

• Recording deaths<br />

Page 27


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

• Recording replacement tags<br />

• Correcting errors<br />

• Downloading data from the database<br />

• Running reports<br />

• Reconciliation of property records with the database account<br />

• Defining user problems with new code releases<br />

• Recommending database enhancements<br />

While basic helpdesk operators can be trained within a few weeks, most operators<br />

will require many months to become fully proficient.<br />

While there are obvious advantages in having the helpdesk in close contact with the<br />

database development team, there is no reason why they have to be situated in the<br />

same physical location or even work for the same organization.<br />

One option to consider would be for the industry organizations to provide help desk<br />

services rather than relying on the database provider.<br />

The provision of detailed <strong>and</strong> well constructed user guides will reduce the<br />

dependence on the help desk. These guides should be sent to every new account<br />

holder when new accounts are opened. While these guides are relatively expensive<br />

to develop <strong>and</strong> print, they will be a more economical option than increased help desk<br />

staff.<br />

The NLIS database has a well established helpdesk of about 10 operators. These<br />

operators have developed considerable skills over the years <strong>and</strong> there are a number<br />

of specialist operators who deal with specific areas such as account creation,<br />

saleyards, abattoirs, tag manufacturers etc. The help desk offers a service from 7am<br />

to 6pm (AEST) weekdays. Emergency support is available after hours for larger<br />

operations such as abattoirs.<br />

There would be very little retraining of the current helpdesk required as the system<br />

would operate in almost exactly the same way for other species as it does for cattle.<br />

NLIS have developed very good user manuals <strong>and</strong> other user documentation. While<br />

this has been specific to the cattle industry, it will be relatively easy to modify this<br />

material for other species.<br />

At this stage, LTAT does not have a dedicated helpdesk with account creation <strong>and</strong><br />

user queries being supported by the database development team. Any establishment<br />

of a dedicated helpdesk will depend on decisions regarding the long term future of<br />

the system. Any marked increase in usage would result in the need to employ<br />

specialist help desk staff.<br />

LTAT also does not have any user documentation developed. Any user manuals<br />

would have to be developed from scratch <strong>and</strong> this would take considerable time <strong>and</strong><br />

resources.<br />

Page 28


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

It would be possible to separate the development of user manuals <strong>and</strong> the helpdesk<br />

from the database. While this is not the preferred option, it may be worth exploring in<br />

some circumstances.<br />

DATABASE IMPLEMENTATION COSTS<br />

A major consideration will be the cost of implementing a regulatory database to<br />

satisfy the needs of the alpaca <strong>and</strong> llama industries.<br />

The costs should be looked at in three areas:<br />

1. Upfront costs. These costs will include any “once only” costs associated with<br />

the development or modification of the system to accommodate the<br />

requirements of the new industry participants<br />

2. Hosting costs. This will include the ongoing costs to store the data <strong>and</strong><br />

provide the ongoing system requirements<br />

3. Help desk <strong>and</strong> user documentation. The costs of providing user support both<br />

in user documentation <strong>and</strong> support helpdesk for phone <strong>and</strong> email support<br />

An estimation of costs was provided by the two database service providers based on<br />

the following base assumptions:<br />

• There will be no need to add any additional functionality to the system to<br />

accommodate the alpaca <strong>and</strong> llama industries. There may be changes<br />

needed to add another species but the functionality required will be the basic<br />

requirements of device issue, transfer, statuses <strong>and</strong> death (<strong>and</strong> ultimately<br />

slaughter)<br />

• Statuses will be different to those applied to cattle but will use the same<br />

functionality as is currently available (device based <strong>and</strong> PIC based)<br />

• While actual numbers are difficult to predict, the best estimate is:<br />

o <strong>Alpaca</strong>s 100,000 head on just over 6,000 PIC’s<br />

o <strong>Llama</strong>s 10,000 head on around 1,000 PIC’s<br />

• It is estimated that 70% of PIC’s will also run cattle or sheep<br />

• At this stage there is no official slaughter at abattoirs but this may develop<br />

over the next few years<br />

• There are not a lot of movements between PIC’s in terms of total numbers but<br />

the average transfer number will be very small.<br />

• Helpdesk will require proportionally less callers than cattle if user<br />

documentation is well prepared <strong>and</strong> easy to follow, <strong>and</strong> computer literacy is<br />

higher.<br />

Some or all of these assumptions may be shown to be wrong as the system<br />

develops but they will allow a basis for comparison between the two systems.<br />

Page 29


Cost Comparison<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Some of the costing information provided for comparison purposes was given on a<br />

confidential basis. Therefore, the details of the costings have not been included in<br />

this report. However, it is worth noting the NLIS Ltd indicative proposal was<br />

significantly less than that presented by LTAT, both in terms of upfront <strong>and</strong> ongoing<br />

costs.<br />

Page 30


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

ELECTRONIC IDENTIFICATION OPTIONS<br />

DEVICE TYPES<br />

There are a number of ways that the electronic transponder can be attached to an<br />

animal. Each has its own set of advantages <strong>and</strong> disadvantages. The commonly<br />

available options are as follows:<br />

Ear Tags<br />

This is the most commonly used method of identification of farm animals. The<br />

transponder is normally integrated into the female portion of a two piece tag. This is<br />

then applied with tagging pliers to the ear with the transponder on the inside of the<br />

ear. There are variations of these tags with one piece tags or tags with the<br />

transponder in the male pin.<br />

To meet integrity requirements of m<strong>and</strong>atory systems, ear tags must be constructed<br />

in a way that makes them tamper evident ie they cannot be removed from one<br />

animal <strong>and</strong> applied to another with evidence of tampering.<br />

The advantages of ear tags are that they are generally the cheapest option <strong>and</strong> they<br />

are relatively easy to apply. The disadvantages are that some tag loss is inevitable,<br />

tags can be removed <strong>and</strong> replaced <strong>and</strong> the visual impact that the tag may have,<br />

particularly on show animals.<br />

Rumen Bolus<br />

The rumen bolus consists of the transponder (in a glass encapsulated form) being<br />

fitted into a ceramic block. The bolus is applied down the throat of the animal with a<br />

specific applicator. The bolus moves from the rumen into the reticulum where it<br />

lodges for the life of the animal. The size of the ceramic block can be varied to<br />

ensure that the size <strong>and</strong> specific gravity is suitable for the species.<br />

For regulatory <strong>and</strong> practical purposes, there does need to be a visual indicator that<br />

the animal carries a bolus <strong>and</strong> a visual number that can be read without a reader.<br />

The advantages of the bolus are the permanency once identified <strong>and</strong> almost<br />

complete resistance to tampering. The disadvantages are that the application<br />

requires more sophisticated restraint <strong>and</strong> equipment <strong>and</strong> a little more skill in<br />

application. Because a tag is also required, the cost tends to be a little higher than<br />

an electronic ear tag. A good quality reader is required to be able to read boluses.<br />

Page 31


Subcutaneous Implants<br />

NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

These are widely used for companion animals <strong>and</strong> horses where there is no chance<br />

of the transponders entering the food chain. Field experience has shown that glass<br />

encapsulated implanted transponders can move around the body <strong>and</strong> pose a threat<br />

to product contamination in edible species.<br />

The advantages are that costs can be lower if they do not have to be applied with<br />

veterinary assistance <strong>and</strong> relative tamper resistance. Disadvantages include the<br />

need for an ear tag <strong>and</strong> the skill needed to implant, the risk of infection <strong>and</strong> rejection<br />

of the implant <strong>and</strong> the risk of the transponder breaking.<br />

Impact on the Database<br />

The choice of identification options will have no impact on the database as long as<br />

the visual number is in the st<strong>and</strong>ardized 16 character form <strong>and</strong> the electronic number<br />

is also in the 16 character ISO format. Once the number has been read in a<br />

st<strong>and</strong>ardized format, it makes no difference as to whether the number is the visual<br />

number or an electronic number <strong>and</strong> whether this is read from an ear tag, bolus or<br />

subcutaneous implant.<br />

Page 32


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

CHOICE OF RFID TECHNOLOGIES AND<br />

FREQUENCIES<br />

There is a range of frequencies at which radio frequency devices can operate.<br />

Generally, they can be broken down into low frequency (125 KHz, 134.2KHz) high<br />

frequency (13.56 MHz) <strong>and</strong> ultra high (~1000 MHz). It is important to note that each<br />

frequency has advantages <strong>and</strong> disadvantages. Individual technology proponents are<br />

prone to list the advantages without necessarily mentioning the downside.<br />

Internationally, there is a group within the ISO organization which looks after the<br />

area of animal identification. This group has decided that the best all round<br />

frequency is the low frequency 134.2 KHz frequency. They have produced st<strong>and</strong>ards<br />

(ISO 11784 <strong>and</strong> 11785) for this frequency which ensure compatibility between<br />

equipment from various manufacturers.<br />

This st<strong>and</strong>ard contains provision for both Full Duplex (FDX-B) <strong>and</strong> Half Duplex<br />

(HDX). In Australia, only HDX is used for NLIS purposes but FDX-B is widely used<br />

for companion animals.<br />

Every country which has set st<strong>and</strong>ards for RFID in livestock have used the low<br />

frequency 134.2 KHz st<strong>and</strong>ard. It is important that this is used in alpacas <strong>and</strong> llamas<br />

as this will ensure that current reading equipment on cattle <strong>and</strong> sheep farms can also<br />

be used for these species.<br />

This is also the only frequency where animal tags <strong>and</strong> boluses are commercially<br />

available. It is also the only frequency where readers suitable for livestock use are<br />

available.<br />

Page 33


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

DEVICE ACCREDITATION AND LICENCING<br />

It is essential that devices used within the NLIS program meet certain st<strong>and</strong>ards <strong>and</strong><br />

are produced in a way that ensures the integrity of the system.<br />

To ensure that this is the case, the NLIS has a Technical Working Group (TWG)<br />

comprised of members with expertise in device manufacture <strong>and</strong> use. This group<br />

assesses the devices <strong>and</strong> the results of field testing to ensure that the performance<br />

of devices is adequate <strong>and</strong> meets the industry st<strong>and</strong>ards.<br />

The TWG reports to the St<strong>and</strong>ards Committee of NLIS which reviews the technical<br />

input from the TWG <strong>and</strong> also looks at the wider issues of industry expectations <strong>and</strong><br />

requirements. The St<strong>and</strong>ards Committee then makes recommendations to NLIS with<br />

regard to the licencing of the device <strong>and</strong> the use of the NLIS logo.<br />

The St<strong>and</strong>ards Committee is also responsible for the development <strong>and</strong> maintaince of<br />

the various St<strong>and</strong>ards <strong>and</strong> protocols in use for devices used in the various species.<br />

These St<strong>and</strong>ards define the technology, device characteristics, performance,<br />

longevity <strong>and</strong> auditing of production systems.<br />

NLIS is responsible to ensure that devices continue to meet their requirements with<br />

regard to the St<strong>and</strong>ards. It is also responsible to ensure that the production system<br />

operates under ISO accreditation <strong>and</strong> that data integrity is maintained.<br />

When a new device is presented to NLIS for accreditation, it goes firstly to the TWG<br />

for review of the physical characteristics. Once the TWG are satisfied with the<br />

design, transponder, print quality, tamper evidence etc., the device can go into field<br />

testing. This is carried out using a trial protocol which requires the devices to be<br />

tested for three years with provisional accreditation available at six months with<br />

satisfactory results.<br />

It will be difficult <strong>and</strong> expensive for the alpaca <strong>and</strong> llama industries to run field trials<br />

to accredit devices specifically for their industries. It is possible that using existing<br />

accreditations for other species such as sheep may be a viable option.<br />

Page 34


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

CONCLUSIONS AND RECOMMENDATIONS<br />

The following conclusions <strong>and</strong> recommendations are provided for the consideration<br />

by the alpaca <strong>and</strong> llama industries.<br />

Database Comparisons<br />

1. The choice of databases is effectively between the NLIS system <strong>and</strong> the<br />

Victorian LTAT system<br />

2. In terms of the technical considerations, there are differences but these are<br />

unlikely to be noticed by the user or markedly affect the implementation of an<br />

alpaca <strong>and</strong> llama system<br />

3. The NLIS system has been in operation longer <strong>and</strong> has a credible history of<br />

availability <strong>and</strong> performance.<br />

4. It is essential that the system is acceptable to regulatory authorities. In this<br />

regard, it is more likely that the NLIS system will be preferred.<br />

5. It is likely that the industry will find the NLIS database a more acceptable<br />

option with regard to the neutrality of industry ownership.<br />

6. In terms of interfaces with existing systems, the NLIS system has more<br />

established interfaces with more industry sectors <strong>and</strong> published interface<br />

specifications.<br />

7. The addition of alpacas <strong>and</strong> llamas will not greatly impact the existing<br />

helpdesk at NLIS while LTAT would have to provide dedicated resources or<br />

the helpdesk would have to outsourced.<br />

8. There is a compelling case for one national animal traceability database.<br />

There is doubt as to the long term future of the LTAT system. Any investment<br />

in this system may be at least partially wasted if the system has to ultimately<br />

change to the NLIS database.<br />

Recommendation<br />

The NLIS database is a proven system <strong>and</strong> has all the required functionality<br />

available. It is the accepted national traceability database. In virtually every<br />

aspect, the NLIS database offers the best option for the alpaca <strong>and</strong> llama<br />

industries.<br />

Page 35


NLIS ALPACA AND LLAMA DATABASE OPTIONS REVIEW<br />

Database Cost Comparisons <strong>and</strong> Selection<br />

1. Cost estimates are indicative only <strong>and</strong> require detailed analysis to define the<br />

cost more accurately.<br />

2. Taking into account all the component cost estimates, the NLIS option will be<br />

considerably cheaper than the LTAT option.<br />

3. Based on the indicative number of animals <strong>and</strong> the operating costs, it is likely<br />

that the ongoing cost of NLIS will be in the order of $0.50 per head per year.<br />

Recommendation<br />

The NLIS database offers considerably lower costs <strong>and</strong> has the full functionality<br />

<strong>and</strong> interfaces available. The NLIS database offers by far the best option to<br />

support NLIS (<strong>Alpaca</strong> <strong>and</strong> <strong>Llama</strong>s)<br />

<strong>Identification</strong> Options<br />

1. The technology selected must be the same as other species in Australia to<br />

ensure compatibility with existing equipment.<br />

2. The use of NLIS accredited ear tags seems to be the best option for the<br />

alpaca industry. The industry will need to look at whether it needs to trial tags<br />

for the species or use accreditations from other industries such as sheep.<br />

3. The use of subcutaneous implants by the llama industry could be acceptable<br />

but the technology needs to the same as other species (HDX <strong>and</strong> ISO<br />

11785/11786). This would preclude any use of llamas for human<br />

consumption.<br />

Recommendation<br />

It is recommended that the alpaca <strong>and</strong> llama industries adopt the same<br />

technology base as that adopted by the cattle, sheep <strong>and</strong> goat industries. The<br />

best option for accreditation of ear tags will be to use the tags already accredited<br />

for cattle or sheep.<br />

Page 36

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