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HUNTIN' DAYLIGHT -- VOLUNTARY - MANDATORY ANIMAL ID

by: Wes Ishmael

It wasn't until the last hour of the Animal ID Expo May 19-20 in Chicago that participants got a straightforward perspective on how the paradox of having a voluntary animal ID system that becomes mandatory without a government directive might be fulfilled.

Someone in the crowd posed the bottom line question to the U.S. Animal Identification Plan (USAIP) steering committee, asking when producers should be prepared to have their livestock individually identified. Clarence Siroky, the state veterinarian for Idaho explained, “I think in about four years this will go from about zero percent participation today to about 85 percent. At that point it would become mandatory.” He's not the one making the decisions on national ID, but to his credit, he bellied up to the plate and offered a vision that makes more sense than any Texas two-step answers USDA has offered so far.

For clarification, USAIP was developed by a group of industry representatives spanning the livestock industry. The USAIP plan was submitted to the U.S. Animal Health Association (USAHA) last October and was adopted by that group as a work in progress. At that time, USAHA called for the USAIP Development Team to form species-specific working groups to detail how USAIP could be implemented in each species. So far, USDA has adopted the data standards of USAIP for its recently announced National Animal Identification System (NAIS).

The stepping stones to Siroky's four-year estimate are these: He figures it will take at least a year to get the NAIS premises identification system in place (more later), a couple of years to inform producers what NAIS is all about and begin identifying their stock individually, and finally for the industry itself to turn to USDA and say, “Hey, we can't afford to have this relative handful of non-complying animals running around, make it a mandatory system.” Conversely, Siroky pointed out there is no way USDA could make the system mandatory at the outset, if it even wanted to, because there is no way for the industry to quickly comply with such a demand.

Until Siroky's comments, arguably even after, there was plenty of disappointment among the participants who had hoped that the much-anticipated reports from USAIP Working Groups would begin to clarify the nebulous NAIS announcement made by USDA April 27.

In that announcement, Bill Hawks, USDA Undersecretary for Marketing and Regulatory Programs explained it would use the $18.8 million recently procured from the Commodity Credit Corporation to move forward with establishing premises identification in 2004. In fact Hawks said, “We hope to be issuing premises IDs later this year. And, hopefully, or shortly thereafter, we will be able to issue individual animal identifications.”

Specifically, USDA outlined the initial implementation plan for NAIS as follows:

Phase I -- Evaluate current federally-funded animal identification systems and determine which system(s) should be used for NAIS; continue dialogue with producers and stakeholders about what is needed; identify staffing needs; develop any regulatory and legislative proposals needed for implementing the system.

Current federally funded animal ID programs include databases and networks used by states for livestock disease eradication, as well as ongoing ID pilot projects funded by USDA, such as the Farm Animal Identification Records project in Wisconsin.

Phase II -- Implementation of the selected animal identification system(s) at regional levels for one or more selected species; continue industry dialogue and education; address regulatory needs and work with Congress on any required legislation.

Bill Hawks, USDA Undersecretary for Marketing and Regulatory Programs points out USDA has the authority under the Animal Health Protection Act to mandate national ID if it deems necessary (more later).

Phase III -- Scale up the selected animal identification system(s) to a national level.

Timetable for the Unknown

Premises ID is the foundation of a national ID system, by which each unique location where livestock exist will be identified by a unique and official premises identification number. The logic is that since USDA is interested in national animal ID for the purposes of tracing livestock infected with a Foreign Animal Disease back to any premises previously occupied by them, within 48 hours, premises ID must exist in tandem with individual animal ID.

A lion's share of the initial funding will reportedly go toward evaluating current federally-funded animal identification systems and determine which system(s) should be used for NAIS. For perspective, current federally funded animal ID programs include databases and networks used by states for livestock disease eradication, as well as ongoing ID pilot projects funded by USDA, such as the Farm Animal Identification Records project in Wisconsin.

In terms of cost, also be aware when considering the funding mentioned above that the USAIP estimates the second-year cost of a national program at $70.8 million, $98.3 million the next year and so on. So the money allocated so far falls far short.

Hawks wasn't any more forthcoming at the Chicago meeting. When asked directly if he could offer even a general timeframe when USDA might issue a general timeframe for specific implementation of an ID Plan, he simply repeated the notion that Phase I included evaluating ID systems that USDA already had in place and had been funding. When asked for clarification on whether the system would in fact be voluntary of mandatory, he said that USDA wanted to get the highest participation in the program that was possible in whatever fashion was necessary. Yes, it is for good reason that politicians have a reputation for riding the fence.

It's still unclear what other aspects, if any, of the USAIP that USDA will adopt as part of the national system. They have adopted USAIP data standards (you can find these in the USAIP working document at www.USAIP.info), but they have remained coy about indicating whether or not they will adopt other parts of USAIP or merely borrow elements of it.

Consequently, Siroky's common sense appraisal provided the kind of hope that comes when you think at least one of your guides knows not only where the mountain is, but understands in realistic terms what it will take to scale it.

Beef Specifics

Up front, there's no way of knowing how much attention USDA will pay to the reports issued by the species-specific groups. However, as with USAIP overall, the agency continues to indicate they will look to these documents for guidance as they flesh out NAIS.

If USDA adopts recommendations from the Beef Working group, among other things: official NAIS tags will be ISO-compliant RFID ear tags; cattle will have to be identified with these tags the first time they move from one premises to another where commingling can occur, regardless of ownership. In other words, moving cows from one pasture to another would not require tagging them, even if the new pasture represents a completely different premises, as long as ownership is maintained and the cattle won't be commingled with cattle coming from another premises.

“It's our opinion all producers must participate,” explains Gary Wilson, chairman of the USAIP Beef Working Group. That statement says plenty when you realize not so long ago producers as a whole were adamantly opposed to any sort of mandatory program. Ironically, now as more producers are encouraging USDA to work more quickly toward adoption of mandatory requirements, USDA has been moving too cautiously for some.

Furthermore, the Beef Group believes that producers should not have to bear the full cost of ID. “We started as a partnership and it needs to continue as a partnership,” explains Wilson. His point is that USDA encouraged the industry to coordinate the USAIP process, and participated in the process itself. Consequently, the feeling is that if USDA wanted to be a partner then, it should also be a partner now that it requires money.

These are only some of the highlight recommendations. At press time, the full report was not yet made public.

The Tough Issues

Whatever USDA does ultimately, there are basically three issues they and the USAIP working groups continue to wrestle with. In no particular order: Cost, Confidentiality and Oversight.

As for cost, Hawks made USDA's position clear during the April 27 announcement, saying, “It is our expectation that this (NAIS) will be a cooperative project that the U.S. government is not and should not pay for every bit of.”

Likewise, cattle producers and their representative groups, including the USAIP Beef Working Group and the National Cattlemen's Beef Association have continued to emphasize that producers are willing to share the cost, but should not have to bear the full burden since USDA is supposedly implementing national animal ID for the public good, both in terms of animal safety and as an additional protection for agriculture, which is one of the nation's critical infrastructures. Until, USDA offers more detail on NAIS, though, figuring out who may pay what portion of the cost is impossible.

The issue of confidentiality—in this case keeping necessary NAIS data submitted by producers (such as premise and animal ID numbers and movement information) from the eyes of a prying public—is no less sticky than the cost issue, but USDA has already indicated they have no plans to begin collecting information until they can assure producers complete confidentiality. In fact, that's one of the reasons served up regarding reluctance to make the program mandatory. In essence, the common wisdom says that any database USDA or any other government agency controls is subject to the Freedom of Information Act (FOIA). Moreover, USDA officials reported in Chicago that once USDA accesses private databases this information might also be subject to FOIA. Consequently, Hawks and others say they will pursue legislation that protects NAIS information before expecting producers to submit the data.

Finally, while USDA will obviously be involved in administering NAIS, how do the prospective livestock industries continue to have oversight of and input into the program? Early on, the USAIP process and the working groups have provided this vehicle. Once the USAIP Development team and working groups complete their efforts, which are close at hand, there must be a way to still provide input. One possibility raised recently is that the USAIP Steering Committee may become a formalized advisory committee to the Secretary of Agriculture.

When Siroky offered his common sense perspective, he began by equating the process of implementing a national ID program to gathering cows from the top of a horse. Before doing so, the horse has to be trained. Before the horse can be trained, it must be born and raised. Before it can be born, a mare must be bred. By that barometer, it appears the industry has at least chosen the mating.

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