The pace is still slower than some would like, and the road toward a fully realized National Animal Identification System (NAIS) is strewn with question marks. But, producers can now register their premises in a number of states, and soon will be able to tag individual animals to comply with the program.
In fact, Neil Hammerschmidt, NAIS coordinator, says, “We've made tremendous progress with the foundation of the system.”
Specifically, Hammerschmidt is referring to the Standardized Premises Registration System adopted by USDA in August that is part of the framework for NAIS implementation. So far, he says 15 states are up and running with the system, with another 17 in various stages of becoming operational with it. He adds, three tribes and 11 other states have requested use of one of the nine other premises registration systems currently being reviewed by USDA.
So, 43 states are either registering premises for NAIS or preparing to do so.
By way of review, premises registration — allocating a unique ID number to each unique location where livestock reside — is the first step in implementing NAIS.
For the purposes of NAIS, a premises is defined as any geographically unique location associated with animal agriculture that would allow for the commingling or movement of animals or poultry involved in commerce. So, farms, ranches, livestock exhibitions, sale barns and feedyards are all example premises. It will be left to states and their producers to cut frog's hair over what they define as premises within those terms.
When fully implemented, NAIS is supposed to enable state and federal animal health officials to track any head of livestock discovered to have a foreign animal disease (FAD), or what are termed “diseases of domestic concern,” back to all previous premises (locations) of residence within 48 hours. Thus, premises registration, with unique NAIS premises ID numbers issued by state animal health departments, will ultimately allow tracking and matching individual animals to specific locations.
“Producers need to be figuring out their premises registration and getting them registered,” says Gary Wilson, an Ohio producer, co-chair of the NAIS Cattle Working Group and a member of the NAIS subcommittee to the Secretary of Agriculture's Advisory Committee on Foreign Animal Disease and Poultry Disease.
In the case of producers with multiple operations, Wilson says that means first deciding whether to request a single premises ID number that encompasses all operations, or requesting premises ID numbers for each distinctly separate operation.
For example, your operation includes two distinctly different and geographically separate enterprises — a cow-calf herd and a stocker operation — that you register as a single premises. If an animal with a FAD were traced back to the stocker enterprise, chances are state animal officials would have no choice but quarantine both the cow herd and the stocker operation.
On the other hand, if each one had a separate premises ID (both operations being distinctly different with no cattle commingled between the two), presumably officials might be able to quarantine only the stocker operation, leaving the cow-calf business open for commerce.
To see if your state is registering premises or when it will be, contact your state veterinarian's office. As well, by Dec. 1, USDA plans to have a new NAIS Web site operational (www.usda.gov/nais), which will include state contact information.
Let the tagging begin
With the premises registration system coming on line, Hammerschmidt explains USDA issued an interim rule on Nov. 8 that enables cattle producers to begin tagging individual animals in compliance with NAIS requirements. These requirements will be fully explained in the Uniform Methods and Rules (UMR) — expected to be released by early 2005. UMRs provide program standards for federal, state and industry participants as animal health programs are implemented. The NAIS UMR will be based on the results of various federal, state and industry collaborative efforts from the past few years.
The interim rule sets the standards for official NAIS animal identification numbers (AIN) — 15 digit numbers, with the first three being the country code (840 for the U.S.). AIN distributors should be able to start obtaining AINs from USDA by mid 2005. Operations using these numbers should also obtain a premises registration number. When AIN numbers are available they will only be issued to operations that have registered their premises. In the meantime, the rule allows producers who are already using tags with certain versions of the Animal Numbering System — specifically those that begin with USA or with a manufacturer code issued by the International Committee on Animal Recording — to do so, as they are being grandfathered into NAIS.
For perspective, producers ready to begin NAIS — and those already tagging cattle as a course of business but wanting to ensure their tags will comply with NAIS — had become increasingly frustrated that USDA couldn't tell them which tags they could use or when official tags will be available.
In that same vein, cattle producers have been wondering how the NAIS Cattle Working Group, which has specified that radio-frequency ID (RFID) technology be used for cattle in the NAIS program, would resolve that recommended requirement with USDA's stance that NAIS be technologically neutral.
“The opinion of the Cattle Working Group is that RFID is the technology that works best for our industry and that only one technology should be used in our industry,” Wilson says. “We don't believe the concept of technological neutrality has any application at the producer level.”
As for USDA, Hammerschmidt explains, “We're not recommending the use of multiple technologies, but rather leaving it to the industries to decide. Every beef or dairy animal must have a tamper-evident (single use) tag with an official AIN. Whether that tag happens to have an electronic chip in it, or if the AIN is associated with a retinal image, that decision will be driven by the industry.”
According to Wilson, the RFID recommendation will be made by the Cattle Working Group committee for consideration and inclusion in USDA's UMR draft.
NAIS in the real world
Besides ongoing questions about cost and who will ultimately foot the NAIS bill, Wilson says the most contentious issue to be resolved concerns the database or databases that will house required NAIS information collected from producers. This information will include premises ID number, animal AIN and animal movement information, but no production data. Just who will control this information?
“We feel it's essential for USDA to have the responsibility for a centralized database,” Hammerschmidt says.
He explains USDA needs unencumbered access to the data necessary for 48-hour traceback. He points out a centralized database of this sort can also be integrated with other disease monitoring databases at the federal level, such as those for the emergency response system and the national animal health monitoring laboratory. Such integration, he says, would also mean that all producers, sale barns and packers would only have one database to which to report animal movements.
“Even the private data companies recognize that state veterinarians need a central point to go for retrieving information for tracking,” Wilson says. “And, sale barn managers aren't going to know what animal's information is maintained by which private data company, so they need a central point for depositing animal movement information from all of the livestock moving through their facilities.”
Still, some in the industry favor the private approach.
Apparently, part of this has to do with confusion over what USDA intends a centralized database to be and ongoing squeamishness about USDA housing any producer information for fears that it might be accessed for non-NAIS reasons via the Freedom of Information Act (FOIA).
Speaking to the confusion, Hammerschmidt explains the only data USDA wants to maintain in a central repository is what is necessary for them to initiate immediate traceback. This information is premises number, AIN, date and event code (indicating such things as animal movement or tag retirement).
So, rather than USDA seeking to pull necessary data from individual databases in each state, Hammerschmidt says each state will use a data collection system provided by USDA, or a compliant one chosen by the state, then will forward the four essential NAIS data elements to USDA.
As for the worries of information confidentiality, USDA has already forwarded a draft bill to the House Agriculture Committee which amends the Animal Health Protection Act by adding a new section that protects from disclosure certain information contained in the NAIS database. It also specifically precludes state and local authorities from releasing USDA's NAIS information under their respective laws. Whether the bill finds a sponsor and then ultimate Congressional approval is anybody's guess.
Moreover, even with such a law, some worry that information could remain FOIA accessable at the state level if states don't have laws protecting it. According to Hammerschmidt, some states are currently reviewing the need for such legislation, just as some states have already passed laws requiring all livestock premises be registered.
Hammerschmidt also points out a centralized database only receiving the minimal required data from states means that states must maintain additional animal information such as age, sex and breed that will allow for the next steps in traceback. States might build upon the system USDA will make available, craft their own individually or as part of regional alliances, or they might contract private data management companies to provide these services.
Potentially, some of the cooperative agreements USDA funded last summer may help demonstrate the merits of one database design compared to another. At least one of the projects will compare the efficiency of a centralized database to a decentralized one.
All told, USDA awarded $11.6 million for cooperative agreements to 29 states and tribes last August. In October, the agency awarded another $1.5 million to the 13 states that had unsuccessfully requested funding earlier. In addition to funding existing and new field trials demonstrating the effectiveness of different technologies and systems for use in NAIS, the money will support premises registration.
Of course, being awarded money and receiving it are two different things. Through October, some of the recipient states had yet to receive the awarded dollars. Hammerschmidt says the time lag has to do with official processes and the fact most of the recipients were requested to make revisions to their original applications. He expected dollars to begin changing hands in November.
Wilson also speaks for many others when he says, “I really don't care what database system is decided on as long as it's accurate, secure and easy to use.”
Next steps coming soon
The database discussion may seem like mundane minutiae to those not intimately involved in the process. But, it's central to USDA and the livestock industries being able to move forward with the UMR mentioned earlier, which will provide producers more detailed NAIS standards and requirements.
So far, those who have studied the USAIP that preceded NAIS should not be disappointed.
“The work done through the national animal ID group at the National Institute of Animal Agriculture, then through the National Animal ID Team (which developed USAIP), all of the basic standards are being carried through quite well into the NAIS program,” says Scott Stuart, a committee-mate of Wilson's.
“Look for individual animal ID and animal movement reporting systems to come online next year and in 2006,” Wilson says. “Our (NAIS) plan is to be able to evaluate the system in 2007 and identify the level of participation in it. This will continue to operate as a voluntary system at the federal level at least through 2007.”
Presumably, at that point, if participation is too low — the definition of which is everything but objective — all bets are off on the mandatory nature of the program.
A series of NAIS fact sheets, produced by the Western Extension Marketing Committee, the Livestock Marketing Information Center and the Western Center for Risk Management Education, are available online at: http://ag.arizona.edu/arec/wemc/wemc.html.