Environment, Food and Rural Affairs CommitteeWritten evidence submitted by ZooTrack Systems

Introduction

1. ZooTrack Systems comprises of a number of experienced and committed individuals focused on creating a universal online network that embraces the domestic, recreational, commercial and sporting horse communities. Our group is drawn from inside and outside of the equine community. It contains specialists from industry, IT, and the public and private sectors.

2. Horse Passport legislation was created to prevent equines contaminated with toxic veterinary drugs entering the human food chain. Since its inception the passport system has broadly failed to achieve its objective. This is a widely recognised fact that is borne out by the recent horsemeat scandal. Our evidence is to aid the Committee’s thinking as to how to deal with this problem.

3. There is an amount of commercially sensitive and confidential information lying behind ZooTrack’s plans and developments. Some matters cannot be divulged at this point. We are pleased to share the following overview, our solution, and our knowledge of the current status quo.

4. ZooTrack has developed a system to address the extant horse passport and animal welfare arrangements in conjunction with a “social network” for owners and industry stakeholders. The system we envisage will enable horse owners to communicate and share data. It will also enable NGOs, trade organisations and Government agencies to target keepers, owners and breeders with information on a range of practical animal care topics and welfare issues.

5. In 2012 the “static” National Equine Database (“NED”) was scrapped. Since then ZooTrack has focused its attention on developing a solution that can track and trace all “live” equines from birth to death and monitor each equine’s suitability to enter the human food chain. This new system would form the UK component of the EU-wide solution currently being planned. By combining the creation of a secure horse identification system with a secure equine database that can be accessed remotely and in real-time, it is possible to achieve an all-encompassing self-funded system in a single developmental step. This single step can fulfil all governmental objectives for stopping unfit horses from entering the food chain and also overhaul the discredited equine passport system that serves little current purpose for owners or UK food safety.

Horse Passports Verified by a Single Equine Database

6. All equines in the UK and throughout the EU are required to have a horse passport and a unique identity microchip. This horse passport is currently a paper document. Since the NED was scrapped, no horse or passport needs to be registered on a centrally-held database. There are many passport issuing organisations (“PIOs”) licensed to issue horse passports in the UK. There are most definitely too many PIOs, and the Government and equine industry is considering ways to reduce these.

7. A horse passport is somewhat of a misnomer. Unlike a human passport, it is not merely a travel or ID document. Its regulatory function is to record and monitor the horse’s veterinary history, particularly if it is destined to enter the human food chain. The flaws in a paper passport system are obvious and numerous, but a live central database containing up-to-date independently verified information will eliminate almost all of them.

8. These paper “passports” are required by law to include information relating to veterinary procedures and inoculations, specifically whether an animal has received phenylbutazone (or “bute”), a substance that has been identified as a risk to human health. There are other potentially harmful veterinary substances administered to horses that are also known to be hazardous to human health, and these are legally required to be logged in passports when administered.

9. The NED was costly to administer and limited in its utility. What is required is a real-time central database that can be accessed remotely and which securely holds ID, ownership and veterinary information, most especially detailed veterinary information, for any horse that might enter the food chain or, more specifically, is not barred from the food chain by its previous veterinary treatment(s).

10. The plethora of paper-based PIOs need to be phased-out, or radically reduced in number. There is, anyway, a pressing need for a central database that holds all the key data online for real-time inspection. All paper-based systems, not backed by IT or real-time, remote checking, are unreliable and easily open to fraud. It seems likely that this weakness is being exploited by criminal gangs.

11. We envisage a new e-passport system that is quick and inexpensive to implement. It simplifies the whole system of paper equine passports, making it more secure and valuable for all users, dramatically increasing human food safety and animal welfare within the confines of the existing Zoo-Technical, EU and UK Horse Passport and Borders (animal import) legislation. It provides Government Agencies with a robust platform to monitor and prosecute fraud and criminality.

12. Our system would provide law enforcement agencies with a rigorous, secure and dependable identification system that can be accessed remotely in real-time—enabling them to stop and prosecute non-compliance with the new horse passport/ID system on the spot. It can also alert the officials to possible theft, smuggling, unlawful-movement, passing-off, cruelty, fraud and potential food-chain contamination all without the need for expensive new equipment and all within a few seconds. This will save significant agency time and money whilst increasing performance effectiveness.

13. The parties that will have secure and verifiable access to this new database will include owners, vets and welfare agencies, law enforcement and border agencies, food standards officers, DEFRA, abattoirs, dealers, trading standards officers and the police. It will reform the way horses are tracked, treated, traded and transported. Existing hand-held devices, backed by bespoke software solutions, will enable secure, auditable look-up, data validation and information updates in real-time by scanning the horse’s implanted microchips.

Current Passport Issuing Organisations

14. There are many licensed PIOs but they can be split into three main types: stud books (such as Weatherbys and the Welsh Pony & Cob Society), equine organisations (eg BHS and BEF) and commercial PIOs, including Pet ID Equine and The Horse Passport Agency.

15. The ZooTrack solution enables security and service to be maintained alongside previously-issued paper passports from multiple agencies. The confusion, the opportunity for fraud and other untrustworthy information will be reduced. The old paper “passports” can eventually be phased-out over a practical and commercially political timetable, as and when the existing Zoo-Technical and EU passport legislation allows.

16. There are strong arguments for treating racehorses differently and fully accommodating the role of the recognised stud books and key equine agencies in their zoo-technical capacity. It might also be possible to allow approved commercial PIOs to work with the new system for a period of grace.

17. Stud books and particularly Weatherbys will continue to play their vital role. Stud books can continue to issue paper IDs and sign-up breed-owners and thoroughbreds as they do already. They can retain their important role as verifiers and keepers of the various breed stud books. We know from our conversations with stud book organisations that this would relieve a lot of administrative pressure on them in their role of updating and issuing paper passports. Most racing horses are unsuitable for human consumption and do not often enter the food chain as meat.

18. Whilst foals born in the future will not be required to have a paper passport “in addition” to their online registration, many stud books and horse organisations will have their own horse registration schemes for competitions, stud book records, and other recreational and horse welfare purposes.

Veterinary & Food Chain Safety Issues for UK Horses

19. Each and every equine in the UK will be required to be part of the new online database system.

Under EU law if a national central database exists, there is a requirement for all equines to be on it.

Owners will be required to register online. PIOs will be required to upload their data onto the secure centralised database (“SCD”).

20. All existing horses with paper passports will be required to register on the SCD for a nominal annual fee. Online annual renewal will be mandatory but inexpensive. The renewal requirement helps check the online record, rather like a company annual return or MOT certificate for vehicles. It verifies ownership records, the current status of the horse, changes in particulars and its veterinary treatments. Currently very few owners register a death. This leaves an opportunity for criminals to clone identities and pass-off unfit horses as healthy ones—making it relatively easy to insert “Bute” contaminated horses into the food chain under the guise of “clean” horses. DEFRA attempted to address this by assuming that all horses on the NED died on their 25th birthday. This in turn led to “ghost” horses that were still alive, and dead horses being unlawfully resurrected for slaughter.

21. The information on the SCD can be printed and retrieved at will by authorised individuals. The database will include the following information: horse name and date of birth, markings, microchip number, owner information and a unique online ID number. Importantly there will be a clear indication as to whether certified as fit or unfit for human consumption, based on its veterinary history. Once deemed unfit by a vet, or the owner elects to give the horse unfit status, this classification is irreversible—thereafter the horse cannot be lawfully slaughtered for human consumption by any UK abattoir. All this information can be accessed remotely in real-time.

22. Horses ruled out of the human food chain, either by owner election or veterinary record, can keep their online vet records updated, as an option. Horses that remain fit for the food chain will have a different registration fee and status. Vets treating these horses will be required to update online records every time they administer drugs, as is the case with all paper passports. Any doubts over online vet records will require an independent test, at the owner’s expense.

23. Most thoroughbreds will likely remain out of the food chain. The majority of UK-owned horses will also remain out of the food chain but still be tracked. A relatively small number of horse owners will wish to keep open the option of selling for meat. The system will focus on these horses and these owners. Vets will be required to record drugs administered to horses that are marked as potential “food chain” or if the owner requests that the vet do so for a full “online history” of the horse. Such veterinary histories will be valuable at re-sale or transfer of ownership, in the same way that cars carry full service records and history.

Meat Trade Equines & Overseas Horse Owners & Importers

24. For any horse, new-born or elderly, to be declared “fit for the food chain” at online registration, it must have: a clean passport, a unique chip, a vet to verify that the animal has not been treated with banned drugs and substances. This horse will then be “monitored” closely, utilising the SCD, at every stage.

25. At time of slaughter the horses’ online records, rather than any paper document, is key to the food chain safety and public reassurance that the horse is bona fide and fit for human consumption.

26. ZooTrack’s system has built-in significant, but easily implemented plans and procedures to deal with equines entering the UK from abroad whether temporarily and short term (ie for competing, breeding, training, acclimatising etc); or permanently and long term (as in the case of purchases and polo horses etc); or for slaughter. There are even provisions to track transiting equines. These procedures have been developed with the status quo as a starting point but to take into account future developments with France and Ireland under the tripartite agreement and developments for equine data to be shared across the EU. Ireland is already working on their national database.

Implementation of the ZooTrack system would see an immediate reduction in the opportunities for organised crime to import fraudulent and/or unfit horses into the UK’s human food chain. It would also enable law enforcement agencies to catch criminals in the act. As with all aspects of the ZooTrack system this is self funding.

27. Importers of horses for meat will register on the SCD at or prior to reaching UK borders as part of the existing UK Border veterinary checks. To be declared “fit for the food chain” the horse must have a clean and verifiable non-UK passport, a unique chip, a vet to verify it and a negative test for banned drugs and substances—this test would be funded by the owner.

28. In the first instance ZooTrack would focus on securing the UK’s borders within and for equines entering. Until credible systems like ours are adopted nationally across Europe, we would treat all animals entering the UK for slaughter into the human food chain with suspicion and test accordingly at the owners’ expense. Our aim is to arrest the problem of contaminated equines being passed off and entering the food chain. ZooTrack’s system would see the UK being able to secure its borders and its human food chain quickly and effectively, no matter how many years that it takes the EU and/or tripartite system to be created and established.

Finance & Development Costs & Future Revenue Implications

29. Every aspect of our solution is fully recoupable and need not be seen as a tax on the law-abiding horse owner, as some believe it to be now. We are encouraged by feedback received that our solution will be seen as a real force for good. It provides a range of useful services, it deals with security for the food chain, and it raises welfare standards and increases horse value for the private owner.

30. DEFRA estimates there are approximately 1.75 million equines in the UK. It is easy to see how capital funding of the infrastructure can be recouped. We envisage a commercial fundraising model and with the right annual registration tariff, the database cost will also be revenue neutral.

31. Capital recoupment time will depend on the route or choices the Government is minded to take.

For example, how long PIO amnesties shall last, the scale of the PR and publicity campaign, and the transition period between wholly paper passports to wholly online passports. The choices made will impact on the time it takes to implement. Another example: the option of one single PIO, versus multiple PIOs, is equally possible—remembering the implementation of the SCD is always essential.

32. Aside from the design of the infrastructure, the critical stage is the launch and adoption process.

This will essentially dictate the success and take-up time of the new system. We have identified a number of promotional and marketing activities to propagate the information, support the owners and smooth the integration of the e-passport system.

33. Our proposal combines a single inexpensive registration fee with a rolling annual fee. The rolling annual fee enables owners to make as many updates as they want. The information alerts will provide value on a range of topics including crime, disease outbreak and vet alerts. Agencies like DEFRA, FSA, BEVA, the Police, Trading Standards etc can dramatically increase their effectiveness whilst simultaneously reducing their costs.

34. The public awareness “launch” and publicity can begin as soon as the decision to build is made.

The operational revenues will cover the core IT infrastructure running costs. These will reduce considerably over time, as fewer existing horse owners join the new infrastructure and use the helplines, and as the “transitional” arrangements and teething problems fall away. The commercial capital is required to cover the build and launch before the revenues from e-passports come on stream. The expenditure and income “dials” can all be adjusted to suit a politically acceptable timeframe for adoption as well as considerations of perceived public value for the new proposals.

35. Our solution is self-funding and deliverable without the need for Government money or the adoption of new, expensive or complicated technology. A social enterprise approach to the “Horse Facebook” and optional horse owner add-ons will allow investment of some future profits into the grass roots: horse welfare and improving the services offered to the horse owners. The industry itself will be invited to determine the shape of the underlying social network as well as how the investable surpluses are distributed to charities and community activities of the horse-owning public.

May 2013