 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% of livestock premises—estimated at around 2 million
by USDA—were registered, 100% 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...What
benefits?
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%.
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% of respondents said a national ID system
was necessary, for the stated purposes of NAIS; 63% said such a
system should be mandatory. BEEF conducted a similar survey of
readers a few months later: 69% said a national system was
necessary; 55% 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% of
respondents said a national system should be mandatory, implying
that a system is also needed; only 3% said there was no need for
a national ID program. However, 81% of those responding also
felt that NAIS progress was lagging expectations and 73%
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 by
clicking here. |
