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There are only two
reasons to do anything in business: either you have to do
something to secure a market or comply with regulations, or you
need to do something to maintain or enhance business.
That’s why the
National Animal Identification System (NAIS) is deader than
desert road kill.
USDA—and the current administration—effectively and quietly
knocked it in the head last November by finally—and apparently
decisively—answering the industry’s question about the mandatory
or voluntary intent of the program.
According to the
unheralded release of the NAIS User Guide, “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.” The User Guide replaces all
previous NAIS plans and documents.
As such, timelines
for implementing the system let alone concrete steps toward
establishing it melted into the ether.
“We’re making it
crystal clear that NAIS is voluntary—no ifs, ands or buts,”
explained Bruce Knight, USDA Deputy Secretary for Marketing and
Regulatory Programs. “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.”
Sure makes you want
to sign up.
USDA took the
deeply rutted road of inaction, despite the fact that the U.S.
Animal Health Association had earlier passed a resolution
calling for mandatory animal ID for the purposes of animal
disease surveillance and animal health monitoring. This
organization includes folks such as state veterinarians and
other officials charged with protecting the health of livestock
at state and local levels. Why listen to them?
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.”
That’s possible, like winning the lottery.
What NAIS
Accomplished
Yes, approximately 390,000 premises have been registered. And,
yes, some folks who have a premises ID number have already found
it useful. As an example, it helped emergency responders know
who had cattle during last year’s severe Colorado blizzards. As
well, state animal health officials have used the information to
notify operations sooner about the outbreak of disease.
Some states such as
Michigan make NAIS components compulsory. Other states like
Arizona are pushing for laws that would make NAIS participation
illegal.
NAIS money also
funded 16 pilot projects aimed at getting a firmer grip on the
challenges associated with ID systems and technology. USDA
issued the NAIS Pilot Projects/Field Trials Summary in April
(see What NAIS Pilot Projects Found).
Beyond that,
though, the $84.8 million taxpayers ponied up to build parts of
the infrastructure doesn’t seem like it moved the nation any
closer toward a goal of being able to identify animal and
lifetime locations of residence within 48 hours—the original
intent of the program.
When USDA said in
effect, “Here’s a program, use it if you want,” they robbed NAIS
the opportunity to plug the gaping holes that exist in the
nation’s ability to quickly and accurately identify animals who
may have come in contact with any other animal that turns up
positive for one virulent disease or another.
The only real
incentive for animal ID remains to be the value individual
producers see in it for their own management or marketing
purposes.
Lingering Needs
Paradoxically, USDA bailed out on NAIS just as consumer and
business interest in tracking food and feed ingredients is
growing.
There was the
spinach fiasco with e-coli 0157:H7 last fall, followed by the
peanut butter debacle with salmonella. What really captured
America’s attention, though, was the pet food problem that
emerged this spring.
First, pet food
manufacturers investigating the sickness and death of cats and
dogs discovered that melamine—an ingredient prohibited in an
animal feed and human food—was the likely culprit. This was
traced back to wheat gluten—later discovered to be wheat flour
rather than gluten—that originated in China.
For the record,
Melamine is produced from Urea and is used in everything from
plastics to laminates; it’s also used in some countries as a
fertilizer, though it’s not approved for use as such in the U.S.
Speculation is that
the two Chinese companies linked to the scandal were spiking
wheat flour with melamine to increase its protein content so
that it would resemble the pricier wheat gluten it was labeled
as.
Those Chinese
companies have since gone out of business, according to FDA
officials. Popular press headlines have also pointed out the
government official who should have been overseeing such
activities has been sentenced to death.
Concern about the
contaminated pet food began to grow when it was discovered that
some of the pet food had subsequently been used to make feed for
pork, poultry and fish.
Ultimately, FDA and
USDA officials announced 30 broiler farms and eight breeder
poultry farms in Indiana had received and fed feed made with
this pet food. Kenneth Petersen, Assistant Administrator for
Field Operations with the Food Safety and Inspection Service
explained the feed was thought to have been fed to 2.5 million
to 3 million broilers, which had long since been harvested.
That’s on top of approximately 100,000 breeder chickens that
received the feed and were awaiting depopulation.
A week earlier, FDA
announced swine in eight states had been fed feed made with pet
food byproducts that had been manufactured with rice protein
from China, also found to be tainted with melamine and
melamine-related compounds. Apparently, most of the 6,000 hogs
that could have ingested the feed were still on-farm and had
been quarantined; approximately 300 presumably went to market
prior to quarantine. Eventually these hogs were cleared to enter
food commerce.
Some fish at commercial fish farms were also quarantined.
Most recently
melamine was linked to pelleted cattle feed. In that case,
though, the domestic manufacturer of a binding agent for pellets
was the culprit.
As for pet owners,
Michael Rogers, Director of Field Investigations for FDA’s
Office of Regulatory Affairs explained, “The agency has received
as many as 17,000 calls regarding this pet food incident,
alleging some association with animal illness or death
associated to recalled product. Of those, about 8,000 have been
entered into our official data system and have been evaluated;
roughly 50 percent of those allege an animal death.”
FDA, working with
U.S. Customers and Border Protection imposed a nationwide import
alert—still in effect—including detention without examination of
vegetable products imported from China, including: Wheat gluten,
rice gluten, rice protein, rice protein concentrate, corn
gluten, corn gluten meal, corn byproducts, soy protein, soy
gluten, and other proteins including mung beans.
FDA and USDA officials continue to stress there is no indication
that humans are in danger from consuming meat from animals that
received the feed. This conclusion revolves around the notion
that only a small percentage of wheat gluten (wheat flour
masquerading as wheat gluten in this case) or rice protein is
used in making pet food, only a small percentage of pet food
byproduct is used in making livestock feed, and that humans
generally eat a diet more diverse than pork and poultry.
Would NAIS have
prevented tainted feed supplies? Of course not, any more than
wearing an ID tag and being traceable within a standardized
national database would prevent an animal’s infection with
disease. What NAIS would have provided, though, is the necessary
connecting point between a feed problem and a potential food
problem.
Don’t be surprised
if this adds fuel to the debate surrounding such issues as
Country of Origin Labeling. Pet owners comprise lots of votes
and economic clout. According to the Pet Food Institute (PFI)
there are 63 million dogs and more than 81 million cats in the
United States (2005). Also according to PFI, dog and cat food
sales in 2005 reached a record $14.1 billion; it was $11.1
billion in 2000.
Who knows, maybe it
will reignite the zest for NAIS.
Influence
vs. Leadership
If you ever doubt that influence and leadership are as
different as profit and price, remember the industry’s
ability to force the status-quo in protecting itself from
animal disease introduced to the nation by accident or
intent.
The influence of
assorted cattle industry organizations and individual producers
was so strong that they could force USDA to abandon a timetable
for implementing the National Animal Identification System (NAIS).
That’s despite various polls consistently indicating producers
believed such a system was needed to protect the health and thus
the viability of the nation’s livestock industry. That’s despite
a couple of year’s worth of effort put forth by livestock
industry representatives drafting and achieving industry support
for the U.S. Animal Identification Plan—the foundation of NAIS.
That’s despite a promise former Agriculture Secretary Ann
Venneman made to the world in the wake of America’s first case
of BSE. That’s also despite the U.S. Animal Health
Association—heretofore, a kind of defacto advisory group to
USDA—passing a resolution that NAIS should be mandatory.
That’s influence.
Industry
leadership is another matter.
In the case of NAIS, leadership would have recognized the need
to establish the system, through regulation if necessary.
Leadership would have taken its lumps from the folks who believe
such a system somehow infringes on their business privacy more
than the numerous government programs they already ascribe to.
Leadership would have recognized not only the need for NAIS but
the opportunity and momentum that would be lost by allowing USDA
to backpedal on implementation time-tables. And, if leadership
believed NAIS unworthy of industry support, it would have
offered an alternative for a solution.
In the case of
USDA, the sad fact is the agency seems to have little influence
within the administration. Further, their flip-flopping back and
forth on the ID issue certainly raises question about the
leadership.
What The Nais Pilot Studies Found
In assessing the National Animal Identification System, what
might work and what might not, USDA funded 16 pilot projects.
Though most would regard the findings as something this side of
an epiphany, they do quantify some of the common technical and
logistical concerns. Among the findings:
The retention rate of RFID button-button tags is significantly
higher than anticipated.
In the Southwest
pilot project a producer with 6,000 tagged animals reported a
retention rate of nearly 100%, compared with a 96-98% rate for
visual tags. Other participating producers found similarly high
retention rates with properly-placed RFID tags.
The use of RFID at the auction market can reduce the need to
restrain animals when recording their individual ID numbers.
The Minnesota
project concluded that RFID technology in this environment can
actually improve animal and human safety.
Using the group/lot method of animal identification can
significantly reduce a major barrier for producers to
participate in NAIS.
In the Northwest
region, groups of animals are often moved and managed together
in situations where uniquely identifying them is virtually
impossible without causing a serious and often detrimental
change in the way business is conducted.
RFID technology is not a plug-and-play application and must be
customized to individual locations—the needs of which vary
tremendously.
In the Texas pilot
project, the sites chosen for testing were often ill suited for
immediate installation of equipment and required a time
intensive process of site surveys and collaboration with
facility owners to prevent any interference with the natural
flow of commerce.
Proper tag application and placement has a direct and
significant impact on the retention and readability of the tags.
The Kentucky pilot
project shows that RFID ear tag application and placement alone
can account for as much as 40 percent of the variation in read
rates and retention.
In certain environments, the automated recording of animals’
identification as they are loaded onto and off-loaded from
trucks is critical for successful animal tracing.
While RFID
technology is promising to achieve this goal, the Kansas pilot
project found that improvements and advancements in the
technology are still needed to make the “on-board” RFID systems
more rugged.
Animal identification number (AIN) radio frequency (RF) ear tags
used for NAIS can also support value-added opportunities.
Florida’s pilot
project demonstrated the market-driven benefits of electronic
animal identification and tracing. In one segment of the
project, 6,500 individually identified cattle qualified as
source-verified beef and yielded monetary premiums.
Workable options are available for producers who want to
identify their animals electronically without the added expense
of reader equipment.
Producers in the
Northwest pilot project found value in using “matched set pairs”
of ear tags. A group/lot visual tag was used for day-to-day
management purposes and then matched with an individual RFID tag
number—without the use of an RFID reader or software—when the
animal moved off the premises.
The level of training equipment operators receive directly
impacts data collection and, ultimately, the system’s success.
In the Oklahoma
project, employees at most locations were either unprepared or
unwilling to properly operate computer equipment, resulting in
poor data capture rates. However, the South Dakota project
reported that equipment performance improved with operator
training and experience. In fact, all facilities in this project
experienced improved read rates as employees became more
familiar with the equipment.
The use of electronic identification allows for more accurate
and efficient recordkeeping.
During the
Southwest pilot project, many producers who were exposed to RFID
technology for the first time reported a significant reduction
in data entry errors.
The summary is available on the web at
http://animalid.aphis.usda.gov/nais/index.shtml |
