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’ status being applied to both the property and the livestock on the National Livestock Identification System (NLIS).

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 Property Identification Code (PIC) and individual devices are automatically assigned a Cotton Trash status on the NLIS database.
7. Producer files the Commodity Vendor Declaration and Alternate Feedstuff Declaration as per LPA record keeping requirements

Removal of cotton trash status on NLIS

Livestock destined for slaughter that have had access to cotton trash, must have been grazing on clean feed for a minimum of 60 days prior to slaughter. Following verification by an Approved Auditor that livestock no longer have access to cotton trash and are grazing on clean feed, producers must submit a ‘Clean Feed Verification Form’, signed by an Approved Auditor, to LPA Administration to initiate the clean feed period. 

The clean feed period will commence on the date recorded on the ‘Clean Feed Verification Form’ and will be automatically removed after 60 days. The 60 day clean feed period will apply to the livestock referenced on the signed ‘Clean Feed Verification Form’, which may be all livestock on the PIC (if cotton trash is no longer being accessed by the producer), or a specific group of animals. 

For example:

  • 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
  • 01/02/2019 - Animals are suitable to slaughter

The cotton trash PIC status will remain attached to a PIC indefinitely, or until the producer provides the LPA Administrator with a copy of a signed ‘Clean Feed Verification Form’ from an Approved Auditor confirming that cotton trash is no longer available on the PIC. Upon receipt of a signed ‘Clean Feed Verification Form’, the LPA Administrator will remove the cotton trash status from the PIC, and all devices registered to the PIC will have their individual cotton trash device statuses removed after 60 days. This reflects the 60 day clean feed period requirement.

Where animals move off a property with a cotton trash PIC status to a property that does not have a cotton trash status, the cotton trash device status will remain attached to those animals for 60 days after the movement date recorded on the NLIS database.

Resources

  1. Alternate Feedstuff Declaration (Cotton trash)
  2. Alternate Feedstuff Factsheet
  3. Approved cotton gins

FAQS

1. Why has this protocol been introduced?

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.

2. How do I access cotton trash to feed my cattle?

Cotton trash must be sourced from an authorised supplying cotton gin.

3. What are the risks associated with feeding my livestock cotton trash?

Producers should consider management of livestock expected to go direct to slaughter 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.

4. How long will cotton trash be able to be accessed?

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.

5. Can I feed my sheep cotton trash?

Sheep can be fed cotton trash under the same provisions as cattle.

6. How long will the status be assigned to my PIC?

The cotton trash 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.

7. How long will the status be assigned to the device (individual animal)?

The cotton trash 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 a 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 cotton trash status move to a property that does not have a cotton trash 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.

8. What do the statuses mean?

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.

9. How will these statuses be removed?

The cotton trash 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 a cotton trash 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.

Individual device 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.

10. How long is the clean feed period?

Livestock must be verified by an Approved Auditor that they do not have access to cotton trash and are grazing on clean feed, in order for the clean feed period to commence. A clean feed period of 60 days will commence once a signed ‘Clean Feed Verification Form’ is received by LPA Administration.  The 60 day clean feed period will be applied to individual animals on the NLIS database that have been verified as grazing on clean feed by an Approved Auditor.

11. Who audits the clean feed period?

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 ausmeat@ausmeat.com.au

The producer will be required to lodge the verification received following the audit with LPA Administration (operations@integritysystems.com.au) within two days of the verification being provided.

12. When should I contact the auditor?

The Approved Auditor needs to be contracted before the livestock clean feed period is activated. It is recommended that you book in your audit two to three weeks ahead of when it will be required.

13. How much will it cost me to be audited?

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 ausmeat@ausmeat.com.au

14. How will this be enforced? 

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.

15. Could the 1995 Helix contamination repeat itself as a result of this decision?

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.

16. How often do I need to complete a Alternate Feedstuff Declaration (Cotton Trash)?

A Declaration must be completed for every order of cotton trash.

17. If I complete the grazing on clean feed audit can I still be audited under the LPA program?

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.

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