The public comment period for the new Dairy Code of Practice has closed as of January 2, 2022. The committee will be reviewing the document and making changes before its publication in early 2023. We have had a few opportunities for sessions about the new Code of Practice, and there are many documents available to give much detail about the research and reasoning behind the changes. There has been a lot of chatter among our clients about the new Code and so this is a good opportunity to clarify some of the important points that seem most heavily contested.
Timeline for Changes
It is important to keep in mind that many of these changes have specific dates on them for implementation, many of which are 5-11 years away – especially the high impact changes. Lots of these bigger updates will be phased in slowly over many years. The other important part to consider is that the actual enforcement of these changes will be done by ProAction – which usually runs about 2-3 years behind the change to the Code of Practice before they become a required part of your ProAction validation. This means that some of the bigger changes (for example; paired housing of calves) would not be incorporated into ProAction until approximately 2035.
Tie-stall Housing and Daily Activity
The biggest myth floating around is that tie-stall housing will be completely banned. This isn’t completely true. There are differences for existing tie-stalls vs. new builds.
Existing tie-stalls must include one of four of the following options:
house lactating cows in loose housing or at pasture;
house dry cows in loose housing or at pasture;
provide regular access to exercise yards and/or pasture for dry cows year-round (e.g., covered exercise area for winter, shaded area in the summer);
provide regular access to exercise yards and/or pasture for lactating and dry cows year-round, weather and conditions permitting;
Many of our tie-stall barns already meet this criteria, most commonly with loose dry cow housing.
New Builds must provide daily exercise – also known as, providing just loose housing for dry cows or just seasonal pasture access will not be enough. There must be an opportunity for exercise 365 days of the year. This effectively makes building a new tie-stall very difficult to meet this criteria, and so in a roundabout way, new tie stalls will likely become a thing of the past. The requirement for new builds come into effect in early 2023, when the Code gets published.
Several of the other big changes - like changing away from calving in tie-stalls and paired housing for calves and prolonged weaning - are laid out in a fairly straightforward manner. Look for further newsletters on suggestions from the veterinary side for implementing these changes.
So what, practically, does this look like for you, the farmer, and we as your veterinary service providers and ProAction advisors? Other than the possible need for construction or changes to barn design, this will bring more paperwork (everyone’s favourite, I know) - the changes to ProAction could bring 8+ new SOPs, with one being a super SOP (health/disease protocols). Currently ProAction has 15 in total.
The process of incorporation into your farm’s validation is a lengthy one. Every requirement equals:
Finding a home for it in ProAction, either within a current requirement or creating a new one (what are farmers required to do?);
Developing the rationale for every change;
Developing guidance on how to meet every change;
Developing a validation protocol for every change (how do we verify farmers are meeting the requirement?);
Implementing change management with farmers, vets, provincial staff, validators, assessors, stakeholders, etc.
We know that much of the discussion has been about the burden these changes place on our dairy farmers – for a seemingly non-existent payout for your efforts. Many vets and farmers have submitted commentary during the public forum, and so we hope that suggestions are considered fairly throughout this ongoing process. Vets have been used as the point of liaison between ProAction and dairy farmers, so as the changes come along we will be heavily involved in helping you in the process. Whether this is providing education opportunities like our classroom presentations, newsletters with condensed information to save you the time of combing through documents, discussions on-farm, meeting with you one-on-one at the clinic to assist with paperwork, or developing pre-made SOPs that can be utilized, we will try our best to help!