A growing number of cattle producers are worried that the Department of Veterinary Services (DVS) is killing the Botswana Meat Commission (BMC) and the Botswana beef industry while the Minister of Agriculture appears powerless to stop it.
This comes after DVS wrongly permitted the importation and feeding of an EU banned cattle feed additive to BMC’s own feedlot cattle, permitted the export of beef from such cattle to the EU and of signed fraudulent EU export certificates in which DVS falsely attested to compliance with EU regulations when DVS knew, or ought to have known, that the exported beef contaminated with the EU banned cattle feed additive did not comply with EU regulations. This resulted in the BMC recalling 100 tonnes of its beef that was amongst the first to be exported to the EU since the BMC was recently relisted by the EU. The cash strapped BMC is reported to be facing a loss of about P70 million as a result of the blunder.
As explained to the Sunday Standard by a senior MOA official. “To protect human and animal health in the EU, DVS as the Central Competent Authority is responsible for guaranteeing that all beef exported to the EU fully complies with EU regulations on meat / plant hygiene, animal welfare and animal identification / traceability. Every shipment of beef to the EU requires a DVS issued export certificate in which DVS has attested to such compliance based on its system of official controls.”
“Official controls” are defined in EU regulations as any form of control (e.g. sample testing of BMC beef for pathogens, LITS etc.) that the competent authority performs for the verification of compliance with EU regulations The credibility of DVS’ EU export certificates is, therefore, a function of the credibility of the system of official controls which DVS employs to verify compliance with EU regulations such as the LITS (Livestock and Trace-back System) ” which ultimately is a function of the credibility of DVS itself.
This is the second time in less than two years that DVS has been guilty of issuing fraudulent EU export certificates which has done great damage to DVS’ and Botswana’s credibility. During its January 2011 inspection, the EU found that the DVS operated LITS was so dysfunctional it could not be relied upon to support DVS’ guarantee of compliance with EU identification and traceability regulations. This notwithstanding, DVS had been issuing EU export certificates falsely attesting to its own compliance as operator of the LITS with such EU regulations. This prompted the EU in its 08 March 2011 letter to the DVS Director to give DVS an unprecedented ultimatum i.e. if DVS did not formally request the EU to delist BMC’s two abattoirs by 22 March 2011, the EU would unilaterally delist them. The EU letter also made the following extraordinary statement: “… In addition, the Commission inspection services have noted major problems regarding identification, movement control and traceability of cattle and meat. These deficiencies undermine the validity of the guarantees regarding animal health that are essential to protect the livestock of the European Union and put in question the credibility of the certificates issued by the competent authority.”
Both the UK High Commission funded 2012 Lewis Grant Report and the 2011 EU Final Inspection Report found that DVS does not have a proper system of official controls the lack of which resulted in the BMC being shut out of the EU market for twenty months at a cost to the BMC and producers of over P400 million. It has also resulted in the LITS data on 450,000 communal cattle, representing 23% of the 2 million green zone cattle, being lost from the LITS data base leaving such cattle in limbo, not able to be moved or sold. As a result, many of these cattle will die on the veld which will represent a huge economic loss to the individual small scale producer, to the BMC and to the beef industry as a whole.
An industry insider told Sunday Standard that, “without a proper system of official controls, DVS blunders along making up extreme ad hoc commercially irrational rules in response to one self-inflicted EU compliance crises after another. And to avoid being held accountable, DVS has cunningly convinced the Minister of Agriculture and the Office of the President that the EU is at fault for imposing too many and too onerous compliance requirements and that the BMC is at fault for not complying with such EU requirements. This is absurd because any BMC failure to comply actually reflects DVS’ failure to enforce compliance which it has the statutory authority and obligation to do. In fact, if DVS had a proper system of official controls, it would be easy for BMC to comply with EU regulations and for DVS to guarantee such compliance. DVS’ refusal to implement the recommendations in the Lewis Grant Report (i.e. to replace the current antiquated and counterproductive system of official controls with a modern EU compliant system of official controls based on the UK model) is therefore inexplicable.”
With regard to the current crisis, DVS’ flawed system of official controls was readily apparent. In terms of Article ll, Section 2 of EU Regulation No 1831/2003 which came into effect on 22 September 2003, antibiotics (otherwise known as Ionophores) for use as a cattle feed additive to increase feed conversion efficiency by up to 8%, were banned as from 1 January 2006. In anticipation of the ban coming into effect, the EU issued a press release on 22 December 2005 to explain the reason for the ban: “An EU-wide ban on the use of antibiotics as growth promoters in animal feed enters into effect on January 1, 2006. The last 4 antibiotics which have been permitted as feed additives to help fatten livestock will no longer be allowed to be marketed or used from this date. The ban is the final step in the phasing out of antibiotics used for non-medicinal purposes. It is part of the Commission’s overall strategy to tackle the emergence of bacteria and other microbes resistant to antibiotics, due to their overexploitation or misuse.
“Markos Kyprianou, Commissioner for Health and Consumer Protection, said: “This ban on antibiotics as growth promoters is of great importance, not only as part of the EU’s food safety strategy, but also when considering public health. We need to greatly reduce the non-essential use of antibiotics if we are to effectively address the problem of micro-organisms becoming resistant to treatments that we have relied on for years. Animal feed is the first step in the food chain, and so a good place to take action in trying to meet this objective.”
“Antibiotics have been widely used in animal production for decades worldwide. Added in low doses to the feed of farm animals, they improve their growth performance. However, due to the emergence of microbes resistant to antibiotics which are used to treat human and animal infections (“anti-microbial resistance”), the Commission decided to phase out, and ultimately ban, the marketing and use of antibiotics as growth promoters in feed. Antibiotics will now only be allowed to be added to animal feed for veterinary purposes. This decision was based on opinions from the Scientific Steering Committee, which recommended the progressive phasing out of antibiotics used for growth stimulation, while still preserving animal health.
“The EU has already banned antibiotics used in human medicine from being added to animal feed. The new Feed Additives Regulation 1 completed measure with the total ban on antibiotics as growth promoters from January 1 2006. On that date, the following 4 substances will be removed from the EU Register of permitted feed additives: Monensin sodium used for cattle for fattening; Salinomycin sodium used for piglets and pigs fattening; Avilamycin used for piglets, pigs for fattening, chickens for fattening and turkeys; Flavophospholipol used for rabbits laying hens, chickens for fattening, turkeys, piglets, pigs, calves and cattle for fattening This measure is in line with the Commission’s overall Strategy to combat the threat to human, animal and plant health posed by anti-microbial resistance.
DVS’ latest EU compliance failure confirms the finding of the FAO’s (United Nations’ Food & Agriculture Organization) Botswana Beef Value Chain Study which has identified DVS’ fatally flawed LITS, and therefore by necessary implication DVS itself, as the single biggest barrier to market entry for Botswana cattle producers.
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Protected behind a wall of obfuscation, deception and secrecy, and by a Minister of Agriculture whose unflinching loyalty to his PS and other senior officials in the face of overwhelming evidence of their incompetence defies comprehension, cattle producers are wondering if there is a future in the cattle industry as long as it’s business as usual at DVS.
“People tend to blame the BMC for falling cattle prices when DVS is actually to blame which only becomes apparent when one looks at the dynamics of the Botswana beef value chain.” stated an agriculture economist who did not wish to be identified. “DVS’ mismanagement of the LITS and its fraudulent certification of EU exports lost us the EU market, and consequently most other markets access to which depended on Botswana’s EU listing. The BMC’s loss of its export markets created a surplus of beef which the BMC had to dump in South Africa at below market prices. This put downward pressure on South African beef prices which was reflected in lower weekly RMAA (Red Meat Abattoir Association) prices for carcasses. This in turn drove down BMC prices which were linked to the RMAA prices as part of the BMC’s regional export price parity policy. And without the EU price premium of 30% over RSA and given the added cost of operating at less than 50% capacity utilization, the BMC was forced to abandon regional price export parity further driving down producer prices. DVS, and not the BMC, is, therefore, primarily to blame for lower BMC producer prices and poor BMC financial performance.
As the Ministry of Agriculture seems incapable or unwilling to restructure DVS, there is a growing cry amongst farmers for a task force be set up under the NSO (National Strategy Office) to look at the restructuring of DVS including the outsourcing of the LITS to an independent industry driven non-profit organization as has been done in Australia and New Zealand both of which export to the EU.