HUNTIN' DAYLIGHT -- NATIONAL LIVESTOCK I.D. RIDES AGAIN

You might remember the National Animal Identification System (NAIS). USDA spent years and millions of dollars trying to get it off the ground. The reasons for its ultimate failure are well chronicled, everything from industry partisanship, to a lack of sustained, clear communication from USDA.

Of course, there was the black helicopter crowd, too, those eternal keepers of paranoia and all things irrational who sense conspiracy at every turn. NAIS had them swinging from the rafters. Some equated individual animal identification to the mark of the beast mentioned in Revelations. At one listening session for the program, one opponent loudly, and apparently sincerely, tried to hex proponents with some sort of voo-doo. I'm not making that up.

What seemed to be lost in the cacophony of confusion and ineptitude surrounding NAIS was the reason so many folks had spent so many volunteer hours trying to get it off the ground to begin with.

Find ‘em if you Can

For years livestock disease eradication programs, like the Brucellosis and Tuberculosis eradication programs for cattle, served as the nation's de facto animal identification and trace-back programs. The Scrapie eradication program still serves that role admirably for sheep and goat producers. Dairy and pork producers have long identified their stock every way from Sunday in the course of day-to-day management; for the most part, they can already trace individual animals from any trouble spot back to the source of origin, and quickly.

In the absence of any other standardized system, though, the success of the aforementioned cattle disease eradication program means that fewer cattle are being identified in a standardized way that would enable state and federal animal health officials to quickly and accurately trace cattle in the event of some virulent animal disease outbreak, such as Foot and Mouth.

That's one reason that USDA, thankfully, never abandoned efforts to develop an ID and trace-back system, despite claims by many that national ID was dead in the water.

Fact is, NAIS died ignominiously last February when Agriculture Secretary Tom Vilsack said a new, flexible framework for animal disease traceability was needed. You can find current details at http://www.aphis.usda. gov/traceability/. But, as implied by that same announcement, there remained a need for ID and traceability, if not via NAIS, then by means of something else.

Keep in mind the focus of USDA is squarely on beef cattle because of the level of risk—cattle hither, thither and yon across the U.S.—and the current lack of standardized ID.

Welcome to ADT

In broad strokes, the Animal Disease Traceability (ADT) program being hashed out by USDA would ultimately require all cattle moving between states to carry an official USDA ID tag. Though certain electronic tags would be compliant, the baseline consideration is official USDA Brite tags (think here of those metal clip tags long used to identify calfhood vaccinates). The paperwork involved would be Interstate Certificates of Veterinary Inspection. Information would be maintained in state databases by state animal health officials. States would be the ones in charge of compliance.

All of this is being considered on a phased-in approach, addressing sexually intact adult cattle first, feeder cattle last.

The bottom line initial goal considered with ADT is the ability to trace 95 percent of the cattle within seven business days. That's a far cry from the NAIS goal of tracking all cattle within 48 hours. But, it's a place to start.

At least that seemed to be the consensus of those attending the open joint strategy forum in August hosted by the U.S. Animal Health Association (USAHA) and the National Institute for Animal Agriculture (NIAA). Participants included USDA officials and animal health officials from virtually all states. All told, 43 states, four tribes, 33 state animal health agencies, 38 industry organizations, 8 universities, and 34 producers and supply companies were represented at the Forum. Representatives from Canada, Mexico, and Japan also attended.

The focus of the Forum was discussion of program details being recommended to USDA by the Traceability Regulation Working Group (TRWG). Loosely, the TRWG is the body through which state and tribal animal health officials have been developing the basic tenants of the new traceability framework.

Consensus points reached at the Forum were:

• There is a significant need for more efficient and effective Animal Disease Traceability in the United States.

• Feeder cattle identification should be required as soon as adequate benchmarks and baselines established indicate that identification of adult animals has been achieved.

• Inexpensive metal Brite tags are acceptable as a form of official identification as a baseline; but the option to use electronic identification shall continue to be allowed.

• Brands (hot iron or freeze) should be allowed as official identification; provided the two states (origin and destination) have agreement regarding movement and that the brand information provides the original point of origin.

• Animal Disease Traceability implementation should include separate considerations across species regarding official identification devices and methods.

• Interstate Certificates of Veterinary Inspection (ICVIs) should be standardized across all states to improve uniformity of data collected. In addition, enforcement of ICVI requirements and the ability to update ICVI information both need to be enhanced so that minimum data collected and final destination information is accurate.

• Back tags for cattle moving directly to slaughter should continue to be considered official identification until a better method to identify such cattle is developed. The framework was designed to build on existing systems that are workable; there was general agreement that the back tag system is a workable, efficient system that is widely utilized in commerce.

• Official ear tags with the “840” country code should continue to be used only for animals born in the U.S.

• Concise and accurate outreach and education for animal producers, handlers, marketers and processors regarding the new requirements under the Animal Disease Traceability framework must be a top priority.

• Terminology regarding a state's progress in implementing animal disease traceability should be defined to better convey the progress towards complete implementation, rather than its “status.”

• Identification of fed cattle moving directly to slaughter should be delayed until two years after all feeder cattle are required to be identified.

• Successful Animal Disease Traceability must include strong and ongoing collaboration among producers, commercial interests and regulatory agencies at both the state and federal level.

There's a sea of detail surrounding these consensus points. You can find the dialogue, the TRWG documents that were considered, as well as the White Paper resulting from the USAHA-NIAA forum at www. AnimalDiseaseTraceability.com.

Keep in mind, though representing a broad and deep cross section of the industry—and the main representation of state animal health officials—USDA is considering comments from all individual and groups as it drafts the proposed ADT rule. USDA says it plans to publish the proposed rule in April. Following 60-90 days of public comment and any adjustments, that would put the final rule in place by mid-summer next year.

Key Points to Monitor

Cost to producers was a major sticking point with NAIS; it could be with ADT, too. One reason USDA is considering Brite tags as the baseline is that USDA currently plans to pay for the tags and give them to producers. Even so, depending on the final requirements surrounding the Interstate Certificates of Veterinary Inspection, getting that paperwork signed by an accredited veterinarian could add cost, besides the time and labor of tagging cattle.

Next, timing is everything. Folks at the USAHA-NIAA program made it clear that reaching compliance with sexually intact adult cattle moving interstate is one thing. Logistically, it will take much longer to reach compliance with the millions of feeder cattle moving between states each year.

Ongoing consideration of the need for quicker, more accurate cattle traceability of cattle should be the essential point to consider as ADT details are fleshed out.

The need grows daily as fewer cattle are identified via disease eradication programs, while people and product traffic into and out of the United States continues to grow exponentially. Unfortunately, the need also grows with every terrorist hatching a plot.

All of that is before considering the potential of restricted access to some of this nation's most valuable beef export markets if the U.S. can't more effectively trace its own cowherd.







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