Whether or not you happen to agree with how the National Animal Identification System (NAIS) is coming together, surely there is no disputing the need for an identification system that enables tracking any head of livestock back to all previous locations of residence within 48 hours for the sole purpose of livestock disease surveillance and animal health monitoring.
The first case of bovine spongiform encephalopthy (BSE) discovered in Washington a year ago, the most recent cases discovered in Canada—one born after the ban on feeding mammalian protein went into effect—and ongoing efforts to re-open trade with the rest of the world underscore the disadvantage faced by an industry without such a standardized national identification system.
Never mind the fact that the success of previous USDA disease eradication programs such as Brucellosis means fewer and fewer cattle in the U.S. can be tracked quickly.
That's why many in the industry are cheering the fact that USDA is finally making some headway with NAIS. In fact, producers can now begin tagging cattle in compliance with NAIS, even though official NAIS tags aren't expected to be available until mid-2005.
Specifically, the Animal Health and Plant Inspection Service (APHIS) published an interim rule in the Federal Register (effective Nov. 8), which amends regulations to recognize NAIS program's 15-character animal ID number, 13-character group/lot ID number and 7-character premises ID number. The rule also 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's code issued by the International Committee on Animal Recording—to do so and grand-father these numbers into NAIS.
USDA emphasizes the interim rule doesn't change requirements defining which animals must be officially identified. Nor does it require that producers use the new numbering systems. Instead, according to APHIS, the rule ensures the new NAIS numbering systems are recognized as official, allowing those who want to use such systems to do so. The system will apply to interstate commerce and cooperative disease control and eradication programs for animals.
APHIS also is amending regulations to prohibit the removal of official ID devices, including those recognized as official on livestock imported from other countries.
Premises Registration First
This interim rule is being introduced at a time when 43 states and tribes either already have or are in the process of implementing a premises registration system, the foundation and first step of NAIS. In fact, some states have already passed laws making it mandatory for livestock operators to register their premises.
If you're unfamiliar with it, premises registration is basically a process by which USDA issues premises identification numbers to state animal health departments, which in turn issue numbers to livestock producers. These numbers provide an address for all livestock at each stage of their production lives. Without this information, the individual animals numbers would have no relevance; you can't track an animal unless there is somewhere (premises) to track it to.
So far, NAIS is completely voluntary, excepting the states mentioned earlier that are making premises registration mandatory. The notion is that USDA will evaluate the program in a couple of years: if producer interest and/or market incentives have driven a high level of NAIS participation, then there is no reason for USDA to make the program mandatory. On the other hand, if participation is too low—and there are no objective estimates of this—then it's likely USDA will make the program mandatory.
In fact, even though there are a number of issues yet to be resolved in the program—including whether USDA, states or private companies will house the data submitted by producers (and attendant worries about confidentiality), and who must foot the bill—some in the industry already favor the mandatory approach.
For instance, in an opinion survey issued to members of the National Institute for Animal Agriculture only 9.9 percent favor the voluntary approach, while 79 percent believe the program should be made mandatory immediately or upon a pre-defined date in the future. Most survey respondents (53.8 percent) support a voluntary system during NAIS development, with a known date for making the system mandatory after development.
The voluntary-mandatory question was of less concern to these respondents than those regarding program funding, producer participation and maintaining confidentiality of information submitted by producers.
Other key findings in the survey by NIAA, whose members have been central to the development process resulting in NAIS, include:
*Database – 28 percent of respondents support a decentralized database operated by state animal health agencies; 27.3 percent support a centralized database operated by USDA; 15.9 percent would choose a decentralized database that is privatized; 13.6 percent are in favor of a centralized database that resides in private industry.
*Funding – 75 percent believe there needs to be more federal financial support than the $33 million allocated for the 2005 fiscal year.
*Awareness – 43 percent believe industry producers and stakeholders are not receiving necessary information and education about NAIS from USDA in a timely manner.
*Preparedness - Only six percent of respondents feel unprepared to participate in NAIS; 75 percent indicate they're somewhat or very prepared.
*Program input – 47 percent believe their concerns about NAIS have been heard and are being addressed; 25 percent believe otherwise.
*Progress – 33 percent believe the rate of NAIS progress is below average or poor; more than half believe progress is average or better.
You can find more detail about NAIS at www.usda.gov/nais
NAIS if For Health Only
Here's the rub, though. While NAIS is needed for its intended purpose, data collected for NAIS can only be used for the purposes of national animal disease surveillance and animal health monitoring. That means producers must still create a system that tracks cattle for other purposes, such as source verification and age verification currently required by some programs and expected to be required for making beef eligible for export to Japan.
Ironically, some of the entities clamoring loudest for the need of a system that enables such verification seem to think that NAIS will provide them this ability. That's not the case, though.
The good news is that premises and animal identity are common requirements of both NAIS and any system that verifies source and other market-driven demands. Consequently, some producer organizations are working to help members comply with NAIS and market-driven ID/verification demands in a single step.
The Southeastern Livestock Network (SLN) is an example of this. Modeled off of a program pioneered by the Kentucky Beef Network, users of this system can obtain NAIS-compliant tags, record animal and premises ID—manually or electronically—that complies with NAIS, while also funneling that and other information into a producer-owned data base so that information can be utilized, at the producer's discretion, for market needs. Users of this system can even obtain “verification certificates”.
Members of the SLN include state cattlemen's associations from: Alabama, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia. For more information about SLN: www.slnllc.com.
So, NAIS is a voluntary program at this point in time. And, while some buyers in the market are seeking source-verified and/or age-verified calves, that market is still narrow enough to make animal ID and tracking voluntary on a market basis, too. But how much longer?
As mentioned earlier, odds say that resuming beef exports to Japan—the largest international beef customer of the U.S. prior to December 2003 (on a value basis)—will ultimately require records to validate age. The Beef Export Verification program designed for this purpose already does. And, none of the major packers in this country can afford not to export beef to Japan when that market resumes.
Moreover, it's not a stretch to imagine that domestic consumers will become increasingly interested in knowing the source of their beef as BSE news continues to permeate the press.
The crux of this is that tagging cattle in compliance with what's known about NAIS thus far, and collecting data necessary for market verification purposes is not free. However, it will pay to consider the cost relative to lost opportunities as time goes on.