Meat Notice 2020-02_Rev 1 – Sourcing of animals from PICs with “Cotton Trash (CTP)” or “Cotton Trash Warning (CTW)” status

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NSFS reference: 12.1

Issue date: 2 August 2023

Date of effect: Immediate

Contact officer:

Jason Lucas
Director – Export Meat Program
02 6272 5761

Dugald MacLachlan
Director Residues and Microbiology Policy
02 6272 3183

Distribution categories

• Central and regional office
• Department on-plant officer(s)
• Managers, export meat establishments
• State/Territory regulatory authorities
• Approved Islamic organisations

Purpose

This notice provides export-registered establishments with instructions on livestock assessment, handling, slaughter and testing requirements for animals which have been delivered to the establishment and have been identified as having access to, or potentially having accessed, cotton trash from approved gins for use as a form of feed for livestock.

Feeding cattle cotton trash has in the past been associated with a number of residue incidents; DDT, dieldrin and heptachlor in the mid-1980s, chlorfluazuron in the mid-1990s and endosulfan in the late 1990s to early 2000s. These chemicals are no longer used in the cotton industry and while the risks associated with feeding cotton trash are not significantly different compared to other forage and fodder, the processing sector has taken a precautionary approach to managing animals fed cotton trash.

This Meat Notice was updated in December 2023 to provide clarity of roles and responsibilities and further, in Appendix 4, around commercial arrangements for testing and freight costs.

Scope

This notice applies to export-registered slaughtering establishments processing cattle and sheep.

Definitions

The following table defines terms used in this notice.

Term	Definition
Cotton trash	Cotton trash (synonyms: gin trash, cotton gin trash) is made up of leaves, sticks, soil, lint cotton and cotton seed fragments which have been separated from the cotton during processing.
Cotton Trash (CTP) status	A status applied to PICs which have accepted delivery of cotton trash to the property.
Cotton Trash Accessed (CTA) status	A status applied to individual NLIS devices of cattle that have or may have accessed cotton trash.
Cotton Trash Warning (CTW) status	A status applied to a PIC without a Cotton Trash (CTP) status receiving livestock from a PIC with a known CTP status.
Livestock Production Assurance (LPA)	The Livestock Production Assurance (LPA) program is the Australian livestock industry’s on-farm assurance program covering food safety, animal welfare and biosecurity. It provides evidence of livestock history and on-farm practices when transferring livestock through the value chain.
National Livestock Identification System (NLIS)	The National Livestock Identification System (NLIS) is Australia’s system for the identification and traceability of cattle, sheep and goats.
Property Identification Code (PIC)	Eight character alphanumeric code allocated by the state/territory government to a property used for agricultural purposes.
Radio frequency identification (RFID)	RFID devices are NLIS approved livestock identification devices applied to individual animals. When scanned the devices return a unique identification number.
SAFEMEAT	A partnership between the red meat and livestock industry and the state and federal governments. This partnership ensures that Australian red meat and livestock products achieve the highest standards of safety and hygiene from the farm to consumer.

Background

LPA accredited livestock producers have access to cotton trash from approved gins (see Appendix 1) for use as a form of feed for their livestock. This is permitted under a strict protocol developed by industry and approved by SAFEMEAT¹.

It is the intention of the cotton trash protocol that livestock that have not completed the required 60-day Animal Feed Interval are not presented for slaughter.

Properties that have had cotton trash delivered for use as mulch or stock feed will have a “Cotton Trash” (CTP) status applied to their PIC on the NLIS. The “Cotton Trash Accessed” (CTA) status will be applied to livestock with individual NLIS devices that are held or have been held on PICs with an active CTP status.

When livestock with a CTA status are moved on to a different property that does not have CTP status applied to its PIC, the  PIC  receiving the livestock from a CTP PIC will be assigned a “Cotton Trash Warning” (CTW) status. (See Appendix 2)

Assigned statuses will remain attached to the PIC or NLIS RFID device as follows (Note: refer to NLIS Terms of Use² document for up to date details of how the statuses are managed):

Status	Description	Removal Criteria
CTP (PIC status)	Cotton Trash	will remain attached to the PIC until the LPA Administrator verifies that the producer no longer has cotton trash available on the property and the 60 day period on feed not containing cotton trash has been completed.
CTA (Device status)	Cotton Trash Accessed	will remain attached to animals with individual NLIS RFID devices until either: the property no longer has cotton trash available and this is verified to the LPA Administrator followed by a 60 day interval on feed not containing cotton trash; OR the animals move to a property that does not have CTP status. The animal’s CTA status will be removed 60 days after the movement date is recorded in NLIS.

¹ Refer to the LPA Alternative Feedstuffs (Cotton Trash) protocol on the MLA website.

² Refer to NLIS Terms of Use, Edition 1.23, section 14.9 Statuses. Terms of use PDF available at the NLIS website.

Establishment Livestock Assessment

Livestock identified in pre-slaughter inspections (i.e. documentation reviews and NLIS database PIC early warning status checks) as coming from a CTP status PIC, or having a CTA device status, or where the actual cotton trash status (on the NLIS database) is unclear, are to be withheld from slaughter. (See Appendix 3)

Animals consigned from a PIC with a CTW status must be withheld from slaughter unless it can be confirmed that the animal(s) does not have CTA status. Confirmation of individual animal status can be determined by:

• scanning its individual NLIS RFID device and querying the NLIS database for CTA status, or
• querying the NLIS database using the NLIS number (printed on the NLIS RFID device) to check for CTA status, or
• obtaining suitable confirmation³ from the vendor of the animals (i.e. from the CTW PIC) to demonstrate the animal(s) does not have active CTA status⁴.

Animals consigned from a CTW status PIC that do not have an active CTA device status may be slaughtered. Animals with CTA status must be withheld from slaughter until the 60 day period on feed not containing cotton trash has expired.  (See Appendix 3)

Where an animal(s) with a CTA status has been inadvertently slaughtered and its carcase is identified on the slaughter line (e.g. by RFID device scanning) the sampling, testing and disposition requirements specified in Appendix 4 apply.

When a CTA status carcase is identified on the slaughter line at a department supervised (i.e. Tier 2) establishment, the department On Plant Veterinarian (OPV) must be informed immediately of the NLIS status breach and must oversee the sampling process and product segregation.           
Livestock withheld from slaughter due to cotton trash status may only be removed from the export establishment in accordance with the relevant state/territory regulations. The OPV must be informed when withheld livestock are to be moved off a Tier 2 establishment.

³ Because CTW status means there is at least one animal on the vendor’s PIC with a CTA status, the confirmation should be additional to the “No” box being ticked for Q4 on the cattle NVD. Suitable confirmation may be supplied in documents presented with the NVD or by other methods.

⁴ Note: where an animal has an individual RFID the animal’s device status will subsequently be confirmed by slaughter floor scanning of the RFID device.

Responsibilities

Establishment management must:

1. Check the Cotton Trash (CTP) and Cotton Trash Warning (CTW) status of PICs consigning animals for slaughter to ensure animals are not subject to an active Cotton Trash Accessed (CTA) status.
    
2. For animals individually identified on NLIS, scan each animal/carcase’s RFID device to check their Cotton Trash Accessed (CTA) status.
    
3. At a Tier 2 establishment, upon such animals being brought onsite for slaughter, or slaughtered, immediately notify the On-plant Veterinarian and provide details of the lot and the number of affected animals.
    
4. Animals sourced from PICs with the CTP status, or individually identified with NLIS devices carrying the CTA status (both of which include animals within the required 60 day period on feed not containing cotton trash) must either be:
    
   1. withheld from slaughter; OR
   2. if inadvertently slaughtered, the carcases and carcase parts of all animals in the consignment⁵ must be retained by the operator and tested (refer to Appendix 4).
       
5. Animals sourced from PICs with the CTW status must either be:
    
   1. withheld from slaughter; OR
   2. prior to slaughter, each animal’s individual NLIS RFID device, or NLIS number, must be checked against the NLIS database to determine its CTA status, or suitable confirmation must be obtained from the vendor to confirm the animal(s) do not have active CTA status. Animals without the CTA device status may be slaughtered.
       
6. Liaise with state/territory authorities when seeking to remove livestock withheld from slaughter due to cotton trash status from the export establishment, and ensure all state/territory livestock movement requirements are met. At Tier 2 establishments, notify the OPV prior to movement of livestock off the establishment.
    
7. If animals with CTA status are inadvertently slaughtered:
    
   1. at Tier 2 establishments, immediately notify the On-plant Veterinarian and provide details of the lot and the number of affected animals
   2. operator to retain all carcasses⁵ and carcase parts, collect samples in accordance with the sampling plan (refer Appendix 4, A.) and dispatch the samples to the approved laboratory (Symbio Laboratory, 52 Brandl Street, Eight Mile Plains QLD 4113) for testing after the OPV has entered the required data into the NRS IMS system
   3. retain the National Vendor Declaration (NVD) or Post Sale Summary (PSS) that accompanied the animal on receival of the animal at the establishment and, at Tier 2 establishments, provide a copy to the OPV, along with details of the body number, RFID number (or NLIS number) and other required details for data entry into the NRS IMS system and reporting to the department. The NVD/PSS and carcase details should be retained until any subsequent investigations are completed.

⁵ Where a mixed consignment includes animals with individual NLIS devices, only those with an active CTA status need to be retained and subject to the sampling plan for testing as per Appendix 4, A. Sampling requirements.

Departmental On-plant Veterinarians will:

1. Provide establishment management with a copy of this meat notice as soon as possible.
    
2. Verify the establishment’s approved arrangement complies with the requirements of this meat notice and has a detailed procedure to check the cotton trash status of consigning PICs before slaughter.
    
3. Verify that carcases of animals individually identified with NLIS devices are scanned prior to carcase breakdown.
    
4. Verify that carcases and carcase parts of animals inadvertently slaughtered with the CTA status are retained by the operator and tested in accordance with the sampling plan and other requirements of this meat notice. Note that the final post mortem disposition of the retained carcases and parts is withheld until the laboratory test results are obtained and reviewed by the OPV.
    
5. Where an animal with the CTA status has been inadvertently slaughtered, ensure that the establishment has retained the NVD or PSS and carcase details and send a scanned copy of these documents via email to the department’s Food Safety Unit (FoodSafetyUnit@aff.gov.au).
    
6. Conduct data entry and dispatch through NRS IMS for samples collected by the establishment. Samples are to be sent direct to the laboratory.
    
7. Review the test result in consultation with the ATM and advise the establishment management on the disposition of retained carcases and carcase parts.

Area Technical Managers will:

1. Review the establishment’s approved arrangement and verify that it covers all of the elements described in this meat notice.
    
2. Approve or not approve the arrangement as per their findings.
    
3. Verify through audits occupier compliance with the requirements of this meat notice.
    
4. Review laboratory test results and provide advice to the On-plant Veterinarian and the establishment management regarding disposition of retained carcases and carcase parts.

NRS

1. Establish an ‘on-demand’ testing program for cotton-trash in the IMS.
    
2. Provide technical assistance to the OPV around data entry requirements in IMS for this program.
    
3. Receive laboratory results from the laboratory and provide the results to the OPV via the department’s establishment email address.

Export Meat Program will:

1. Forward the details and supporting documentation of NVD breaches to LPA and the relevant state/territory regulatory authority.
    
2. Liaise with the relevant state/territory authority as required.

Jason Lucas
Director
Export Meat Program