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Letter of appeal to BCMS
for refusing a calf passport
Dr James Irvine
Teviot Scientific, Cultybraggan Farm, Comrie,
Perthshire
Filed 21 Oct 04
©www.land-care.org.uk
Appeals Section, BCMS
Curwen Road
Workington
Cumbria CA14 2DD
20 October 2004
Dear Sir/Madam
Appeal re Refusal by BCMS to issue a passport
for calf UK542058/300462
BCMS has refused to issue a passport for the
above animal on the grounds that the application for a passport
was received too late (beyond 27 days). While recognising the need
for an efficient and timely passport system, I would like to appeal
against the decision taken by BCMS with regard to this particular
beast for the following reasons.
In common with many other farms, for sometime
now all those working on the farm are either on contract or are
self employed. A system was therefore established so that when a
calf is born the two tags for it are placed in an A5 strong envelope
at the farm office, the envelop labelled with the eartag number
and the envelop is than given to the farmworker to tag the calf.
When he has done so he writes on the envelope the eartag number
of the dam, the sex of the calf and its colour. The envelope is
then placed in the farm mail box to be picked up by the following
day and taken to the farm office for the information to be processed
and an application for a passport made to BCMS by recorded delivery
within the permitted time.
In this particular instance, the calf was born
on the hill on 12th April 2004. It was tagged with the appropriate
tags the next day. Because the farmworker could not reliably identify
the dam the data could not be completed for entry on the envelope.
Consequently the envelope was not put in the letter box and did
not reach the office. Nevertheless, the calf was appropriately tagged
at the appropriate time as can be seen by its number in the orderly
sequence of tagging.
At a later date it was possible to confidently
establish who the dam of the calf was by referring to pregnancy
scanning records, bulling records and by exclusion of other cows
in the group that had produced calves. By then the passport application
was time expired and was refused. Consequently, not only was the
calf appropriately tagged but its traceability is perfect.
The fact that this calf did not have a passport
was picked up at the SEERAD inspection (1).
The herd at Cultybraggan Farm consists of 50%
pure pedigree animals (Aberdeen Angus and Limousin) and 50% commercial
crosses between these two breeds. It has been closed for over 4
years, meaning that no bovines have been brought into the herd for
that number of years. The reason why it has been closed is to raise
animal health standards and to make traceability very apparent.
Thus, not only was this calf appropriately tagged
and has perfect traceability, it also has a particularly high health
status.
Running a closed herd incurs greatly increased
costs on account of the increased labour and management that is
involved. It is disheartening to say the least when, in a genuine
effort to achieve accuracy in recording, the farm is seriously penalised.
I and others are all too aware that BCMS itself
is quite capable of making mistakes that are not necessarily confined
to the occasional, and that communication between BCMS and SEERAD
leaves something to be desired (2). The
fact that the Public Accounts Committee severely criticised BCMS
(3) for the way in which it conducts itself
does not in my view justify BCMS inflicting such draconian penalties
on others.
The calf in question is a first rate calf with
high health status and traceability. In the circumstances described
above, it appears to be a needless waste of a perfectly good animal
due to an overly officious attitude by BCMS.
As Magnus Linklater (4),
author and columnist, has put it in relation to a different context
“Good laws badly administered are a form of tyranny”
Yours faithfully
Dr James Irvine
Director, Teviot Scientific at Cultybraggan Farm
References
1. Irvine, James (2004).
SEERAD cattle inspection at Cultybraggan.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 27 Aug 04,
www.land-care.org.uk Click
Here to View
2. Irvine, James (2004).
Public Accounts Committee: identifying and tracking livestock in
England. Comments.
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 09 Jul 04,
www.land-care.org.uk Click
Here to View
3. Irvine, James (2004).
Alleged failures in cattle cross-checking. Letter of complaint to
SEERAD
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 31 May 04,
www.land-care.org.uk Click
Here to View
4. Linklater, Magnus (2004).
Me 1, mindless bureaucracy 0.
Scotland on Sunday 5th September: reproduced with permission
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 14 Sep 04,
www.land-care.org.uk Click
Here to View
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