So much for the quandary over the proverbial chicken and egg. USDA's decision to privatize a key component of the sluggish National Animal Identification System (NAIS) has left the industry without a perch or a nest. Far as that goes, no one is even sure who has access to the henhouse.
Until the end of September, USDA steadfastly maintained that government would build and maintain the animal-movement database for NAIS. This database will be the core of the program, essential to achieving the NAIS goal of tracing livestock back to all previous locations of residence within 48 hours, then tracing forward to locate peers that resided with a particular animal at each stage along the way.
One reason USDA proffered for maintaining control of this database, since NAIS officially began in April of 2004, was so that state and federal animal health officials would be ensured access to the data for the purposes of disease surveillance and animal health monitoring. USDA also maintained that as part of a public system, creating and maintaining the database—along with premises registration and official NAIS number allocation and documentation (other key NAIS components)—is how they intended to share NAIS cost with producers.
All of the livestock species working groups, except beef (more later), which make NAIS implementation recommendations to the Agriculture Secretary, via a complex committee system, were operating under this principle. When USDA switched gears, these folks reined in their progress. So far, the beef-working group is the only one that has submitted recommendations. These recommendations, now approved, include the choice of RFID ear tags for the official NAIS ear tag.
Some in the cattle business—chiefly the National Cattlemen's Beef Association (NCBA)—had argued since the inception of NAIS that the database in question should be built and maintained by the private industry. A common argument was that data maintained by the government would be subject to the Freedom of Information Act (FOIA). The implication sometimes stated and sometimes not, was that data maintained by the private sector then made available to government would be protected from FOIA. Common, collective opinion from the livestock industry and from government officials suggests that NAIS data will be subject to FOIA, whether government or private industry maintains it. That is, unless a legislative remedy is developed. Both USDA and industry are trying to fabricate such a band-aid.
When USDA switched gears and reversed direction so quickly and completely that Barry Sanders would have been proud, it washed its hands of building and maintaining the database, instructing the industry to do it instead.
Running Counter to Majority Opinion
Though it can be rightly argued that USDA did precisely what industry demanded—or at least a vocal part of that industry—USDA's decision places the financial responsibility for building and maintaining the database entirely on the shoulders of industry.
According to a couple of recent polls, this is not what the majority of the livestock industry had in mind.
In a recent survey conducted by the National Institute for Animal Agriculture (NIAA), for instance, 57 percent of respondents believe the federal government should bear the brunt of the total NAIS cost; 16 percent believe consumers should and 14 percent believe producers should be responsible.
Of course, 56 percent in this same poll disagree with USDA's decision to make the NAIS animal movement-reporting database private rather than public. One reason is that the majority isn't convinced a public database is any more risky than a private one when it comes to confidentiality. All told, 22 percent cite funding as their primary concern about NAIS, while only three percent say confidentiality of NAIS data is their most pressing concern.
Keep in mind, the NIAA poll—described as an unscientific one by the organization—represents a 22 percent response rate (198 responses). Those polled include the NIAA membership as well as participants at the ID Info Expo hosted by the organization in September. For perspective, 31 percent of the respondents cited beef cattle as their primary species of interest. Overall, 19 percent of survey respondents described themselves as producers or as executives of producer organizations. Another 30 percent are veterinarians and/or state or federal animal health officials. You can find complete survey results at www.animalagriculture.org.
Incidentally, even with all of the confusion surrounding NAIS, respondents to this poll not only want NAIS, they want it as a mandatory program. In fact, 90 percent of respondents favor a mandatory program. Of these, 61 percent want the program to be voluntary during the development stages, then mandatory either “as quickly as possible” or by USDA's NAIS Draft Plan deadline of January 2009. Only seven percent of the respondents are in favor of a voluntary program.
These results mirror those of a survey BEEF magazine conducted in July (700 responses). In that poll, 63 percent stated a preference for a mandatory program. Overall, 76 percent in the BEEF survey believe a national animal identification and trace-back system is needed for animal health monitoring.
So, Who's In Charge?
Bottom line, USDA's reversal in the public/private database debate has transformed an already chaotic process into a rudderless one. Specifically, USDA has instructed the industry to develop a legal entity, representing all livestock species and sectors impacted by NAIS to decide how to get the job done. That's a whole lot like asking Sitting Bull to invite Custer for a cup of tea.
“If I wanted to call someone who was in charge of putting this group together, who would I call?” wondered one of the participants at a USDA listening session in Kansas City October 12. No answer was offered because there isn't one. No organization represents all of the species for animal ID, nor is there a process for developing one. It's a whole lot like that old cartoon where two team ropers are watching a steer grow smaller in the distance. Neither one has even swung their loop. Both look at each other and say at the same time, “I thought you were heading.”
The closest the industry has come to an industry ID collaboration in recent times is the U.S. Animal Identification Plan (USAIP) Development Team that crafted the document and garnered the industry consensus for what has become NAIS. This process began with work initiated by NIAA, which is a multi-species organization. The same kind of approach seems like a logical step now, but so far no one has picked up the gauntlet.
NAIS Progress to Date
Premises registration—now operational in all states—is the foundation of NAIS, since achieving the 48-hour trace-back goal of the program demands tying specific animals to specific locations.
All 50 states, two U.S. territories and two Indian tribes now have NAIS premises registration systems in place. These are administered through state animal health departments and officials. Livestock producers have registered approximately 126,800 premises so far. USDA estimates that's about six percent of approximately 2.2 million premises nationwide. So, there's a long ways to go.
Another primary component of NAIS is identifying livestock individually (as in the case of cattle) or by group (as with poultry and swine), using official NAIS numbers. The numbering system for NAIS has been adopted. According to USDA these numbers will be made available to tag manufacturers later this year, but last spring they had promised to have them available by now, so go figure. In the meantime, any cattle producers using electronic ID tags that conform to ISO standards can grandfather those numbers into NAIS.
In its Draft Strategic Plan and Draft Standards published in May, USDA calls for making premises registration and identification of animals within commerce mandatory by January 1, 2008. This plan calls for the mandatory reporting of animal movement in commerce by January 1, 2009.
But, these days USDA says it's still trying to figure out what parts of NAIS to make mandatory and when. The Draft
Strategic Plan and Draft Standards USDA issued for NAIS are just that, drafts. There is still are still no definitive rules. Consequently, there has been little incentive for producers to worry about doing anything when it comes to NAIS.
Should You Care?
Since there are still no concrete NAIS rules, nor any mandate from the government or the marketplace to implement the program, it makes prefect business sense for producers to play the waiting game.
For those wondering about getting their feet wet, though, or for those exceptions to the rule who actually have buyers offering money up front for NAIS-based compliance, there are a couple of no-cost steps you can take at this stage.
First, there's every reason to believe that NAIS premises registration will become mandatory. It doesn't cost anything to register your premises, and it could prove useful to state animal health officials to more quickly determine whether a particular site is involved in the outbreak of one disease or another. So, there appears to be potential upside to registering your premises and no downside.
Next, if you work your way through the logic of what USDA envisions with a private animal movement database, it's worth getting to know what data service providers are currently available, and what services they provide.
With a private database, it appears producers will either submit required NAIS data for each tag—date applied, retired, etc., and premises ID—themselves or will be able to do so through a data service provider who will then funnel necessary data to the NAIS database. So, either way there is a cost to consider. The advantage of a data service provider may be that they offer other services that would enable a producer to recoup the cost. This might be in the form of certifying particular attributes of the cattle (preconditioning, age, source, etc.) and or herd management opportunities that increase net returns.
You can find a comprehensive directory of such companies and their services at www.beefstockerusa.org.
Finally, continue to make your thoughts about NAIS known to your government and producer organization representatives. Given the lack of the progress so far, they need all of your help that they can get.
For more information about NAIS, http://animalid.aphis.usda. gov/nais/index.shtml