Even though USDA’s efforts toward the National Animal Identification System have been underway for more than a year, skeptics remain in terms of the program’s goals and pace.
Some of that should clear up with USDA’s draft NAIS Strategic Plan and draft NAIS Program Standards, published in the Federal Register last month. (Go to www.usda.gov/nais. Once there, click on the “Strategic Plan” or “Program Standards” to view each document.)
While this is not a rule-making process, it is a step in that direction. And, while these documents are not a final version, they also are a step in that direction.
“We can not do this (implement NAIS) without input from those involved — state and local officials, farmers, ranchers and everyone involved with animal production,” says USDA Secretary Mike Johanns. “The last thing we want to do is push people into a system that won’t work. This issue is too important for us to get it wrong.”
The documents outlining the program’s strategic plan and standards reflect industry and governmental efforts as well as comments gleaned from last year’s 19 public hearings. Additional ideas gathered from the current comment period (which ends June 6) will be used to fine-tune a final draft.
Among the significant points in the NAIS Strategic Plan is the goal to make animal identification mandatory nationwide by 2009. “We would have a voluntary system going to mandatory,” notes Johanns.
Key milestones in the proposed timeline are:
July 2005: All states able to register premises.
July 2005: Animal Identification Number (AIN) and Group/Lot Identification Number (GIN) systems operational. This includes test runs.
April 2007: Premises registration, animal and group/-lot identification “alerts” sent out. This means that USDA will notify all parties involved that NAIS will be moving toward a mandatory program.
January 2008: Premises registration, animal and group/lot identification required.
January 2009: Reporting of defined animal movements required, moving NAIS to a fully mandatory program. At this point, USDA could track all animals through the system.
“Collecting and recording animal movements is the greatest challenge ahead,” says Johanns.
As of mid-May, 47 states and five tribes had premises registration capabilities in place and nearly 70,000 premises had been registered. Certainly, by the time you read this there will be even more premises signed up.
To make the premises registration task easy for you, the National Pork Producers Council has established an interactive Premises Registration Map at http://www.nppc.org/hot_topics/premidstatesites2.html. It’s a simplified option that links you directly to your state’s Animal Identification and Premises Registration Web site.
“Registering premises is the first step towards developing a mandatory identification program,” says Joy Phillipi, NPPC president-elect. In March, NPPC producer delegates passed a resolution supporting the movement toward mandatory identification of “all relevant animal species.” The pork industry’s stance is that a mandatory approach is necessary in order to have a truly effective animal identification program nationwide. At USDA’s listening sessions, a 3:1 ratio of participants preferred a mandatory program to a voluntary one.
With a mandatory directive, however, comes even more questions about data confidentiality, which has been the driving concern among producers. After all, information collected in the NAIS program relates to your business and what businessperson wouldn’t raise a skeptical eyebrow?
Producers’ concerns fall into two areas:
Who will have access to the data and how will it be used? USDA states emphatically that the data collected is to be used only for animal-health tracing needs.
Public access to the data via the Freedom of Information Act presents the concern that someone could use the data to harm producers or their businesses.
Moving to a mandatory program does increase the Freedom of Information Act concern. However, USDA is investigating and addressing options. For example, the strategic plan reports that federal agency records must be disclosed, unless they fall within an exemption for confidential business information or privacy issues.
However, those aren’t ironclad exemptions. Therefore, USDA is pursuing legislation to establish a system that would allow an avenue to withhold information obtained through NAIS.
Right behind confidentiality concerns come liability concerns. But, Under Secretary of Marketing and Regulatory Programs Bill Hawks believes these two issues get unnecessarily muddied. “What we’re doing here shouldn’t create any additional liability,” says Hawks. “Liability that one might be exposed to exists if the individual is doing something wrong. If there’s nothing wrong, there shouldn’t be any significant liability.”
Finally, future costs and funding remain question marks. Among those: Who should bear the costs; how should the costs be allocated; and where should the funding originate?
So far, the government has allocated $18.8 million from the Commodity Credit Corporation emergency funds; another $33 million was committed in the Fiscal 2005 budget. The President’s budget for 2006 has another $33.3 million proposed. “It’s a pretty good commitment on our part,” says Hawks.
Even with public funding there will be costs to producers. “This is a federal, state and industry partnership. We expect all three entities to contribute,” says Keith Collins, USDA chef economist.
He spells out three cost categories for NAIS:
Infrastructure development. Building a repository for premises, animal and group/lot ID, as well as tracking. This involves building state systems, as they will be responsible for implementation and maintenance. Government funds focus on infrastructure development.
Individual animal identification. Some species will be identified via groups or lots, such as most hogs and poultry. However, many species will require individual identification, such as cattle, horses, as well as any animal removed from a group/lot. Individual identification can be costly.
The cost of reporting animal movements to the system and animal tracking “is the one we know the least about,” says Collins.
“As we bring the tracking system on line over the coming year, we will learn where efficiencies can be gained and we’ll be in a better position to figure out what the costs will be,” he adds.
It’s worth noting that the animal ID movement is not exclusive to the United States; it is spanning the globe. At an international food exhibition in Montreal this spring, Daniel Chaisemartin, representing the World Trade Organization for Animal Health (OIE), said there is much interest in developing standardized animal traceability systems globally. So, OIE has developed a working group to provide its 167 members with technical assistance toward that goal.
“Identification and traceability are considered key tools in the sphere of animal health, public health and trade,” he said.
All the more reason why it’s good to see USDA moving forward with the NAIS timeline.