LPA Alternative Feedstuffs
Alternate Feedstuff (Cotton Trash)
Livestock Production Assurance (LPA) accredited livestock producers are now able to feed their livestock cotton trash or use cotton trash as mulch under a strict protocol developed by industry.
The protocol will ensure livestock fed cotton trash continue to meet Australia’s Food Standards, as well as the requirements of more than 100 markets globally for Australian red meat. It will ensure livestock being fed, or that have had access to, cotton trash do not enter the food chain within the 60-day Export Animal Feed Interval.
By adhering to the protocol, producers wishing to access cotton trash will be able to maintain their LPA accreditation.
The protocol requires producers to source cotton trash only from approved gins and will trigger a Cotton Trash Accessed (CTA) status being applied to all the livestock on the PIC as well as a Cotton Trash PIC (CTP) status being applied to the PIC on the NLIS database.
The steps to access cotton trash under LPA are:
1. Producer contacts approved cotton gin
2. Gin checks producer LPA accreditation via the LPA Service Centre
3. Producer completes Alternate Feedstuff Declaration (Cotton Trash) and provides a copy to:
- Supplying gin to secure order
- LPA Administration
4. Gin delivers cotton trash accompanied by a completed Commodity Vendor Declaration to the producer
5. Gin lodges copy of Alternate Feedstuff Declaration (Cotton Trash) with LPA Administration to initiate NLIS status
6. The PIC is automatically assigned a CTP status and the individual devices are automatically assigned a CTA status on the NLIS database.
7. Producer files the Commodity Vendor Declaration and Alternate Feedstuff Declaration as per LPA record keeping requirements
Removal of Accessed Cotton Trash status on NLIS
Livestock destined for slaughter or live export that have had access to cotton trash must under all circumstances graze on clean feed, on a property clear of Cotton Trash for a minimum of 60 days prior to slaughter or export.
If Cattle reside on a Cotton Trash PIC the PIC must be declared clean of Cotton Trash by an approved auditor, producers must submit a Clean Feed Verification Form, signed by an approved Auditor to LPA Administration to initiate this clean feed period.
If Cattle are moved from a Cotton Trash PIC to a clean PIC they must reside there for 60 days from the date of the movement date recorded on the NLIS database, prior to slaughter or export. A Cotton Trash Warning (CTW) status will be applied to a clean PIC that receives livestock with a Cotton Trash Accessed (CTA) status applied to their tags. This status does not prevent or impact on the sale of other livestock at the clean PIC, only the livestock with Cotton Trash Accessed (CTA) status are affected.
All livestock will only have their cotton trash status automatically removed once they have been grazing on a clean PIC for 60 days, this PIC must have NOT had access to Cotton Trash or has been declared clean as outlined above. The clean feed period will commence on the date recorded on the ‘Clean Feed Verification Form’, provided the Approved Auditor was able to verify that livestock had been grazing on clean feed from the verfied date.
The CTP status will only be removed from the PIC when:
- the PIC is free of Cotton Trash and this has been verified by an approved auditor via the Clean Feed Verification Form; and
- no livestock with a CTA status remain on the PIC (either have been sold or have completed the 60 day verified clean feed period as above).
- 30/11/2018 - Producer finishes feeding cotton trash
- 03/12/2018 – Producer organises authorised auditor verification
- 03/12/2018 – Producer submits verification to LPA Administration, which triggers 60 days on clean feed countdown, from the verfied date
- Animals are suitable to slaughter or export, 60 days from the verified date.
|Status||When applied||When removed|
CTP – PIC status
When a PIC receives cotton trash from an approved gin and completes the Alternative Feedstuff Declaration (submitted to LPA).
Once the PIC has been verified by an approved auditor to be clean of cotton trash (requires a Clean Feed Verification form to be submitted to LPA) and has no livestock with a CTA status assigned to that PIC.
CTA – livestock device status
When a CTP status is applied to a PIC (as above) ALL livestock assigned to that PIC are assigned a CTA status.
Requires a 60 days clean feed period:
CTW – PIC status
Assigned when livestock that have a CTA status are moved on to a PIC and that PIC does not have CTP status
Automatically removed when the last CTA status animal is moved off the PIC.(Please note that a CTW status does not prevent or impact on the sale of other livestock at the PIC, only the livestock with CTA status are affected).
Access to cotton trash for livestock feed has not been permitted by industry since 2005.
During the 1980s and 1990s, some export markets stopped importing Australian beef because chemical residues were detected in beef from livestock that had been fed cotton trash or had grazed on farms where cotton was planted and treated with chemicals such as Endosulfan, which is no longer registered for use in Australia.
The protocol has been developed because continued drought across eastern Australia over the past two years has increased pressure on producers to access emergency drought feed for livestock, including cotton trash.
Producers should consider management of livestock expected to go direct to slaughter or live export carefully with the requirement of 60 days on clean feed and an independent audit factored into planning.
There is a risk that livestock which have been fed cotton trash and been slaughtered prior to the completion of a clean-feed period will result in chemical residue levels that exceed those stipulated by market access requirements.
There is also some commercial risk in feeding livestock by-products such as cotton trash with some buyers not wishing to purchase such livestock.
By adhering to the protocol, producers wishing to access cotton trash will be able to maintain their Livestock Production Assurance accreditation and our red meat industry will continue to meet the expectations of global markets.
It is recommended that before feeding cotton trash to livestock, livestock producers contact their buyer or processor and receive confirmation that they are willing to accept livestock which have had access to cotton trash.
The red meat and cotton industries have amended their MOU to allow cotton trash to be used as a source of livestock feed or mulch by LPA accredited producers from 30 November 2018. These arrangements will remain in place until otherwise determined by the red meat and cotton industries.
Sheep can be fed cotton trash under the same provisions as cattle.
The Cotton Trash Accessed (CTA) status will remain attached to your PIC until a point in time that you no longer have cotton trash available on your property and this has been verified through an Approved Auditor and written verification is provided to the LPA Administrator. Providing this verification will automatically trigger a 60 day countdown until the status is removed on the NLIS database.
The Cotton Trash Warning status will remain attached to a clean PIC until the Accessed Cotton Trash status is removed from the livestock – either 60 days from when they arrived at the clean PIC or 60 days from the Clean Feed Verification date at the original PIC. The Cotton Trash Warning status does not prevent or impact on the sale of other livestock at the clean PIC, only the livestock with Accessed Cotton Trash status are affected.
The Cotton Trash Accessed (CTA) status will be assigned to all devices and animals registered to your PIC at the time that the PIC status is applied. Any new animals moving onto your PIC while the PIC status is in place, will also be assigned an Accessed Cotton Trash status.
The device based status will remain attached to the animals indefinitely, or until such time as an auditor verifies that the animals are grazing on clean feed and cannot access cotton trash during the 60 day clean feed period.
Should the animals with a device-based Accessed Cotton Trash status move to a property that does not have a Cotton Trash Accessed (CTA) status, the device-based status will remain with those animals for 60 days after the movement date recorded on the NLIS database.
If the animals are moved off your PIC mid-way through the 60 day clean feed period to a PIC with no status, the devices will continue to register the status until the 60 day period is up, at which point the device based status will be automatically removed.
The statuses allow potential buyers to view any risks associated with the livestock before they are purchased. By querying the status of a PIC or individual animals, buyers can assess whether they are happy to receive consignments of livestock that have been fed cotton trash or have been grazing on properties that have acquired cotton trash.
The Cotton Trash Accessed (CTA) status will be assigned to all devices and animals registered to your PIC at the time that the PIC status is applied. Any new animals moving onto your PIC while the PIC status is in place, will also be assigned an Cotton Trash Accessed (CTA) status.
The device based status will remain attached to the animals indefinitely, unless the animals move off your property onto a property that has not accessed cotton trash, and in this case the status will remain attached to the animals for 60 days after the movement date recorded on the NLIS database.
Property statuses may also be removed following verification by an Approved Auditor that the animals are grazing on clean feed and cannot access cotton trash during the 60 day clean feed period.
If the animals are moved off your PIC mid-way through the 60 day period to a PIC with no status, the devices will continue to register the status until the 60 day period is up, at which point the device based status will be automatically removed.
Livestock must graze on clean feed for a period of 60 days before the status is removed. This clean feed period must be verified by an Approved Auditor. The commencements of the Clean Feed Period can occur prior to the audit being undertaken, providing that the management plan implemented by the producer provides sufficient evidence to substantiate verification that the livestock have been grazing on clean feed from the stated date, by the Approved Auditor.
Independent audits can be completed by an Approved Auditor. Currently AUS-MEAT is the only Approved Auditor for clean feed period audits. Contact AUS-MEAT on telephone 07 3361 9200, fax 07 3361 9222 or email email@example.com
The producer will be required to lodge the verification received following the audit with LPA Administration (firstname.lastname@example.org) within two days of the verification being provided.
This clean feed period must be verified by an Approved Auditor. When the Approved Auditor is contracted is the decision of the producer, although they are encouraged to do so prior to commencing the clean feed period. The commencements of the Clean Feed Period can occur prior to the audit being undertaken, providing that the management plan implemented by the producer provides sufficient evidence to substantiate verification that the livestock have been grazing on clean feed from the stated date, by the Approved Auditor.
It is up to the individual auditors to set the fees for audits. Currently AUS-MEAT is the only Approved Auditor for clean feed verification audits. Contact AUS-MEAT on telephone 07 3361 9200, fax 07 3361 9222 or email email@example.com
The requirements for access to Alternate Feedstuff are a part of the LPA program Rules. LPA accredited producers are required to adhere to the LPA Program Rules and Standards, including access to Alternate Feedstuff.
Cotton trash is classified as an Alternate Feedstuff under the LPA program Rules and its use will be enforced as a part of the LPA program requirements. Producers acquiring cotton trash will also need to demonstrate how they are adhering to these requirements when selected for random or targeted LPA audits.
The protocol has been developed based on a risk assessment undertaken by the government in consultation with the industry. The protocol requires authorised gins to have regular samples of cotton trash tested by the National Residue Survey and only those gins that are meeting the requirements of the protocol will be able to supply cotton trash to producers. On-going monitoring of livestock being consigned for slaughter from properties that have accessed cotton trash will be conducted to ensure that any potential residue risks are being effectively mitigated through the protocol.
A Declaration must be completed for every order of cotton trash.
Yes, all LPA accredited producers are subject to random audits. Completion of 60 days on clean feed period and provision of a signed ‘Clean Feed Verification Form’ to LPA Administration does not negate this. Some Approved Auditors may conduct a full LPA audit while they are conducting the Clean Feed Verification audit. This is a voluntary audit at no additional cost, and would exclude you from the LPA Random Audit Pool for three years. It would not exclude you from the LPA Targeted Audit program.
Yes, whether livestock have access to cotton trash or not all animals will be considered to have accessed cotton trash as an alternate feedstuff. All animals are required to complete a 60 day clean feed period before going to slaughter or export. This must be verified by an approved auditor once the property is clear of Cotton Trash. If livestock are moved to a clean property a 60 day clean feed period will still apply.
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