Right – have at last got round to looking at the response from BPEX to my initial Q’s
Format below is
My original question
BPEX responseAdditional comments from me1. The guides do not cover what is needed for new users not just of the system, but also the concept, legal reqs and processes of e-aml. The present guides only show part of the screens, and do not list what data users need ahead of starting a transfer.
These are quick start guides only to get people set up initially. The system is designed to be intuitive and users are encouraged to phone the helpline to get a quick turnaround on their query. From experience not many people read lengthy ‘manuals’. 2. More critically a full guide to using the WHOLE e-aml system (not just screen shots) is needed covering both sender and receiver being on computer, sender on PC - receiver not, sender not on PC but receiver is, moves between E&W and Scotland (who still have paper at the mo), and import/export moves. For instance where is a user told if they are sending to a user who does not have a PC, they should hand two copies of the form to the haulier, one for him and one for the receiver - just one of 15 different process possibilities excluding sms !
Not really a satisfactory answer to Q's 1 & 2, although hopefully further guides will follow – i am chasing for more progress on this.4. The system all over the place says "slapmark" (for instance in a location search, at the start of a farm to farm move) which is only used for moves to slaughter (and then it is only one option), the correct term should be herdmark. Not being pedantic, many new pig keepers won't know what a slapmark is, or think they must slap a live to live move.
Thanks – we will get that amended where applicable.
5. If a user does a farm to farm e-aml, and knows the vehicle registration no. of the haulier, and completes this, they STILL have to input it again to confirm move, there needs to be a check to say if you have already done it, and not to require it being re-input. Systems should not require the same data twice.
we looked into this option in the outset but there was not a satisfying solution for various reasons – will re-visit again.6. How will force majeaure be dealt with for those without PC's - eg a holder arrives on land and it is flooded, need to move pigs urgently, but not PC user so have to give two days notice to BPEX and await a form before they can move?
Where are the 2 days notice from; animals should not be on unsuitable land in the first place; producer can call the helpline for instantaneous recording: producer to record the individual movement reference that is thereby created on a blank haulier summary template, which all producers are advised to have copies of. These can be obtained from the bureau service. “animals should not be on unsuitable land in the first place” – so no animals to be kept in the lake district or cuumbria presumably !! I Am querying this back on using pro-formas, if true then at least an instant mon-fri with hand written would be possible.7. Are BPEX sending out email forms to non-pc users first class?
yes if not by fax BPEX seem obsessed that farmers without PC’s all have fax machines !8. Why are pigs with temporary marks required to complete "holding of birth" - I can see nothing in the legislation that requires this, and users may not know this in any case, in which case what should they enter?
we are replicating what is on the current AML2 paper form; a query for Defra re legislation. Not an answer I am happy with, as BPEX is the data owner, they must know what data they are legally required to keep, and what is optional.9. Why is it required that the type of pigs being moved must be entered? This was only on the old form for convenience to let several pigs to be listed for ease of haulier and receiver, but since on e-aml you cannot have multiple lines - Just one type eg weaners or “mixed” or “both”. And what does “Both” mean as a choice? Is this part now redundant and I see nothing in law requiring the type of pigs being moved, so why is this data being gathered?
See above answer, but required for the FCI (Food Chain Information). Yes, this is from the initial phase when there weren’t as many different types to select. Already amended on website: Both is finished & cullI could argue this one further (eg FCI data is not specified in law, and farm to farm is not FCI) , but frankly theer are more important issues.10. Has Wales yet passed the legislation that e-aml requires - I cannot trace this legislation
The legislation is out for consultation, ending 1.11. as far as we are aware. Defra is liaising with the WelshGovernment on this. 11. Overall major question, why do those without computers now have to give at least two working days notice of a move, and await forms, when someone with a pc but not working printer, can use a pro-forma and handwrite the info that they have typed in. At least then those moving pigs at the weekend would only need to decide this on Friday at 4.45pm phone the details through and then do a hand pro-forma, not have to decide Wednesday or otherwise have to break the law. And PC users don’t tend to have fax either, which was a suggested answer.
They don’t - You have to get your movement details on eAML2 before making the move and need to allow enough time to get the haulier summary sheet either print it your self or have it posted/faxed/emailed to you. You can phone the move in and have the HS faxed back/emailed to you for printing. Haulier summary pro-forma are only valid with an individual movement reference, which is automatically created by the service once a move it set up. This can be obtained by either phoning the bureau or having set the movement up yourself.[oaklands is populating this as he types, so apologies that it is being added to !]
not quite what the law says, but if BPEX are happy that people following this route will be OK, then fine12. The movement archive is very “bitty”. To reconcile my movement book with the system for say the last 3 months, a user would need to look at both received and purchased, and within sent area do three additional areas (F/S, F/F, F/M), and within each of those arras a further 4 categories, making a total of 18 searches ! and this is before movements to shows, which presumably would add another 4 searches. A single list showing all moves on and off by date would be far more useful to the average user, who really has no interest in whether sent moves have been “completed” or indeed sent to the local authority, but merely for sent moves whether they are pending or sent, and for received whether they are pending or completed.
I was already looking into the options to re-structure the archive. Good news13. The received movement area doesn’t have “received movements” as a category - only “sent movements” - presume this is a typo?
no typo but the word might be misleading and I arranged already to get that changed14. The legislation requires a user to notify BPEX using the system or phone of an intended move. This would create a “pending” move in the system. There is another duty on the receiver to notify BPEX by system or phone etc. within 3 days. There is nothing in the legislation requiring the confirmation of sending which is part of the PC process, but it looks likely that a receiver cannot confirm receipt of a move until this confirmation has been sent. Since there are no email reminders of pending moves (seem to remember there are for F/S?), it is quite possible for the sender to forget to confirm, at which point the whole process is held up? Since the sender is not breaking any law by doing this, what happens? If the receiver cannot use the system to notify within 3 days does he need to phone to be legal? If on the other hand (and of course I have no way to seeing how the system does things without doing real moves, and the guides do not cover all this stuff – see item 2!) the receiver can confirm, does this negate the need for the sender to confirm? And since this all seems to hold up the movement being sent to AH, this doesn’t really help them keep on top of what is happening in their area. In other words the whole system could fall apart, but everyone be legal ! Knowing how this process all works would be very useful as would a full guide!
Not at all: the system will flag up any user that has outstanding feedback/confirmation and chase processes will kick in for the relevant user to confirm the relevant data, so that movements will be confirmed and uploaded to the government movement database.Need to go back on this, as a) I don't understand the process, and b) I haven't seem this happen to the move I tried!15. A user has to enter dates (loading and departing) and time. This is presumably to cover the very rare but possible situation where pigs are starting to be loaded before midnight and completed after. This means that the user has to type the same date in twice and in long hand dd/mm/yyyy. Changing the second box to be called “Departure date if different” would allow a single date entry. The form subsequently could simply use the first box data in the “departure date” unless a different date is entered.
This has to do with WATO regulations No it doesn't it has to do with decent computer coding, but don't expect it to change16. The ability to pick a date rather than enter date longhand from a calendar display would also aid accuracy of entry for loading (and departure dates), particularly where some farmers might be from say American origin and familiar with different orders.
Differing viewpoints – from feedback we used this form of data entry exactly to prevent mistakes 17. Where a user has not yet registered, and the sender is entering details for a new location, they have to enter certain details (holding No. address, postcode etc.)- one of these boxes is called “company name” – the vast majority of pig keepers will not be companies – a simple “name” here would be better.
We will put it like that: ‘(company) name’.18. The Defra pig keeping guide (
www.defra.gov.uk/publications/files/pb13647-pig-keepers-guide.pdf) says that “The eAML2 system is run on 2 servers so there is always a back up if one server goes down. In the unlikely event that both servers are down keepers should revert to paper and forward a copy of the HS/MD to the MLCSL paper bureau for keying (the address for the MLCSL bureau is in Annex 1). It is advised that keepers keep blank copies of the HS template to allow for any such occurrence. HS/MD template is available from markets and MLCSL. “ This advice should be repeated on the e-aml site(and in the guide)
yes the website text is to be updated and will include this guidance 19. The Defra guide ((
www.defra.gov.uk/publications/files/pb13647-pig-keepers-guide.pdf) says on page 16 that an imported pig must be entered on the system – how is this achieved, as there appears to be no area on the system to do this.
From beg of November20. I presume a/several further communicatiosn are planned before the April deadline setting out the new rules in detail. For instance a non-computer user has not been told that they must phone/fax etc. confirmation of move within 3 days, or indeed that they need to register.
We have indeed planned further communications through various channels prior to April 201221. Given that a receiver must confirm a move within 3 days [this is not working days in the legislation], can BPEX/Defra confirm that non-pc users, whilst guilty of an offence, will not be sanctioned for a move say over Easter, where it is not possible to do this due to help lines being closed.
Defra question not BPEX – I will take that up.24. There is no published fax no. for the service.
the fax has been added delayed due to internal clarificationEh??? Ok so someone forgot to order teh fax line it is my take!25. The movement detail in archive needs to show the CPH numbers, otherwise a user reconciling the system to their movement book has to open every HS/MD to get the CPH.
We will check on that26. When doing a farm to farm movement for pigs under a year pigs can move on a temporary mark and there is a question about moving on a temporary mark. However despite answering yes to this, the movement form still says that the pig ID is the slap mark which is the first question and cannot be left blank. This is not correct at worst it should say temporary mark, but better should specify the type of mark (see 27 below).
You have the option to enter free text for your temp mark in the question about the temp amrk and then in ‘enter reference’ this is also in the help text. This will then appear on the haulier summary sheet.I need to validate this, but in essence this is not what I saw happen - one to re-test27. The idea behind temporary marks is that in the now highly unlikely ( but still technically possible) event that multiple loads of pigs are being carried, the sets of pigs can be reconciled against the paperwork, with the temporary mark only being required under law to last the journey . For instance a haulier could carry 6 weaners with a blue spot on shoulder from holding a and 8 with red stripe down back from holding b, delivering say both to holding c. There would be two haulier documents, and since the whole idea of a temporary mark is to be able to reconcile pigs in a lorry against the paperwork, the temporary mark needs to be specified in the paperwork as a freeform text entry eg “blue spot on shoulder”. Otherwise temporary marks are entirely pointless.
This relates to movements from a collection centre and they have the option to enter several her marks and a temp mark as a free text option.Need to validate28. The Disease Control Order 2003 (under which the general movement licence is issued as stated at the top of the HS/MD) has article 15 which essentially specifies paper forms and retention periods of 6 months are required. Under primo 2007 the additional requirements did not contract this regulation, but under PRIMO 2011 there are contradictions between the two regulations. Can this be explained, or should amendment s to one or other regulation be made. Otherwise by complying with PRIMO 2011, I am breaking DCO 2003?
A regulation query for Defra29. Given that the vast majority of holdings will only have one slap mark, cannot a check for this against a holding be made, and if only one, pre-populate this field. Otherwise the majority of users will need to click a single choice every time.
there are a large number of holdings that have multiple herd marksBut that wouldn't stop a decent coder not giving users a choice of one wher only one choice existsSo overall some good progress, but i will need to push further to try and get better guides and clearer guidance.
Given that we are getting this whether we like it or not, anyone finding other annotances or errors, plesae let me know, and happy to push these whilst we have a chance before April.
