If you could buy insurance that you thought you might need, but also doubted there would be enough participation from your peers to fund potential claims, would you buy it?
That's essentially the position USDA has placed producers in when it comes to the National Animal Identification System (NAIS).
On the one hand, USDA continues to maintain that a national, standardized system of animal identification is necessary for animal health surveillance and animal health monitoring. As you know by now, the need stems from the success of producers—and state and federal authorities—in practically eradicating diseases such as Brucellosis. Heretofore, these eradication programs served as a sort of defacto National ID program.
Last spring, USDA seemed to have finally drawn a line in the sand with the publication of its NAIS implementation plan. This document inferred that NAIS would become mandatory in early 2009 unless 100 percent of livestock premises—estimated at around two million by USDA—were registered, 100 percent of livestock born that year were registered, and unless movement data was recorded for at least 60% of the livestock in commerce that were less than one year of age.
By November, that document was replaced by USDA's NAIS User
Guide, and complete reliance on the voluntary implementation of NAIS.
“USDA is not requiring participation in the program. NAIS can help producers protect the health and marketability of their animals—but the choice to participate is theirs,” says the guide.
Absent from the User Guide are the suggested timelines and benchmarks for achieving an effective level of producer participation. Instead USDA emphasizes its belief that market demands will provide the necessary incentive for participation.
Chuck Conner, USDA Deputy Secretary and Bruce Knight, USDA Under Secretary for Marketing and Regulatory Programs paved the way for the agency's newfound voluntary approach at an outreach meeting in October.
“Since we've had some confusion on this, we need to be as clear as we can be. This is Voluntary with a capital V. Not a currently voluntary, then maybe a mandatory system. This is a permanently voluntary system at the federal level,” said Conner.
“We're making it crystal clear that NAIS is voluntary—no ifs, ands or buts,” explained Knight.
The guide goes on to explain, “Participation in NAIS is voluntary at the Federal level. Under our current authorities, USDA could make the NAIS mandatory, but we are choosing not to do so—again, participation in every component of NAIS is voluntary at the Federal level. The NAIS does not need to be mandatory to be effective; we believe the goals of the system can be achieved with a voluntary program. As producers become increasingly aware of the benefits of the NAIS and the level of voluntary participation grows, there will only be less need to make the program mandatory.”
Roping the Cart Ahead
The only benefit of NAIS is the system itself, and the 48-hour trace-back it would provide for the purposes of animal disease and health monitoring. That benefit can't be realized until the system is up and running with a level of voluntary or mandatory participation that logic says needs to approach 100 percent.
Yes, if cattle wear a unique ID in a standardized system, verification of such attributes as source, age and management protocols is possible, but that doesn't have anything to do with NAIS.
Yes, producers have already been using individual animal ID for management and marketing purposes, but that doesn't have anything to do with NAIS, either.
Maybe that's part of the problem; ID tends to get wrapped in the same package as management, marketing and NAIS.
For example, in the 2005 National Beef Quality Audit, personal interviews with representatives of eight trade organizations and six government agencies—including five USDA agencies—a lack of mandatory traceability, ID System and NAIS compliance was cited as the number one Quality Defects/Challenge. That was ahead of product inconsistency, food safety: Pathogens/Bacteria/EHEC/Salmonella/
Listeria monocytogenes; BSE; growing concern about humane handling, animal welfare/husbandry, and the environment; inadequate tenderness/ palatability, and too low quality grade; appropriate SRM Removal/Disposal and Lack of 4-D Animal Disposal; growing concern about chemical residues; carcass/cut weights too heavy and inconsistent; shelf-life; lack of age/source verified cattle; growing concern about antimicrobial resistance; poor meat color and pH variation in ground beef and beef trimmings, and; susceptibility to Foreign Animal Disease, agro terrorism and bioterrorism.
Carrots and Whatnot
Obviously, no one wants to be forced to do anything, especially when the thing in question has all of the confusion surrounding it that has defined NAIS. On the other hand, if you need and want to trace animals to all previous locations of residence within 48 hours—as NAIS was designed to do ultimately—it's tough to see how that can be accomplished when there is no incentive or disincentive to participate voluntarily.
A state veterinarian explained to me recently that Brucellosis eradication began as a voluntary system decades ago. However, it wasn't until regulatory components were attached to the program years after its inception that progress was made. The result today is a national herd virtually free of the disease.
This experience was surely one of the guiding lights that led the U.S. Animal Health Association (which includes lots of state and federal animal health officials) to pass a resolution for mandatory animal ID last fall.
As reported previously in this column, by and large, cattle producers continue to support the need for a national ID system, for the purposes of animal health surveillance and livestock health monitoring. In a BEEF Magazine poll 18 months ago 76 percent of respondents said a national ID system was necessary, for the stated purposes of NAIS; 63 percent said such a system should be mandatory. BEEF conducted a similar survey of readers a few months later: 69 percent said a national system was necessary; 55 percent thought it should be mandatory.
In an informal poll conducted by the National Institute of Animal Agriculture (NIAA) at the recent ID Info/Expo 78 percent of respondents said a national system should be mandatory, implying that a system is also needed; only three percent said there was no need for a national ID program. However, 81 percent of those responding also felt that NAIS progress was lagging expectations and 73 percent believed NAIS implementation would fall short of the timeline goals outlined in last spring's implementation plan.
Yet, Knight remarked in October, “Farmers can choose to register their premises. They can choose to participate in individual animal or group identification. And they can opt to be part of tracking. Or not.
“Choosing not to participate (in NAIS) may limit marketing opportunities in the future. As NAIS matures, I believe the marketplace will respond. To the extent that more information is available, they will demand it. That's because more information means greater security—and a premium for poultry and livestock whose history is readily available.”
Never minding that NAIS has nothing to do with marketing, the above is possible, though it hasn't been the case thus far. It's hard to imagine, too, the need commerce will see for a system cohesive and coordinated enough to provide the industry-wide 48-hour trace-back NAIS was designed to provide.
As well, producers continue to rightfully question why they should foot the bill for something that benefits the public overall.
Consequently, the only real incentive for animal ID remains to be the value individual producers see in it for their own management and marketing purposes.
You can find the complete NAIS User Guide at http://animalid.aphis.usda.gov/nais/naislibrary/documents/instructions_guidelines/NAIS-UserGuide. pdf.