LMA presents update on ID plan
Anticipating that the National Animal Identification System (NAIS) was dead in late 2009, the Livestock Marketing Association (LMA) began an internal conversation about what to do do develop an animal identification and traceability plan that would work.
“As we talked, we realized it couldn’t be just LMA’s plan, but a plan we thought would work for our markets and our consignors. Then we realized what we needed was everyone – every sector of the industry. We were extremely successful in our efforts, and almost all of the national cattle and farm organizations came together, cooperated, and worked toward at least developing some basic principles upon which we thought a workable identification or animal disease traceability (ADT) plan could be developed,” notes Robinson of LMA.
The result of those efforts is a three-step plan that will only apply to animals moving in interstate commerce, and that will be administered by the states and tribes. It will also encourage the use of lower-cost technology and full transparency throughout the implementation process.
Of step one, known as the “foundation,” Robinson says, “Upon the effective date of the rule, all sexually intact cattle and bison, 18 months of age and older, as well as all dairy, rodeo and show cattle of all ages, will be required to be officially identified with an official ID device when moving interstate. This plan only affects interstate commerce because USDA doesn’t have any authority over intrastate commerce.”
“What’s different from NAIS in this plan, particularly regarding the foundation, is the fact that it’s no longer required that you must use an RFID electronic tag when moving livestock within interstate commerce,” she adds.
Official ID devices include eartags imprinted with an official animal ID number and the U.S. shield. Tags currently approved include brucellosis tags, National Uniform Eartags and the Animal ID Number (AIN) 840 U.S. visual or RFID tags that can be imprinted with additional information for other programs.
“One thing I want to mention, since you’re a brand state, is that the USDA, in the proposed rule, will delist brands as an official ID device. I mention this because as this gets out it will probably be very concerning to producers in brand states who don’t understand exactly why the USDA is doing this. It gives the appearance that they are trying to do away with brands, and they are not. Any two or more agreeing brand states can allow a brand to be used for interstate ID. But, this allows states that don’t have brands to not accept brands for ID purposes.
“As part of the federal rule, the official ID devices will say to states, you cannot prohibit any official devices from being used in interstate commerce. You must accept all official ID devices because of preemptive authority. But, you can have tougher standards in the states if you choose. You just can’t have less than the federal rule lists to move cattle into interstate commerce,” notes Robinson.
“The required ID could be as simple as a metal clip, which is done a lot in the markets already. Even those states that don’t still have a brucellosis program are familiar with the metal clips, and it’s not terribly outside what they’ve known for the 50, or more, years of the brucellosis program,” says Robinson of setting brucellosis tags as the basic required form of ID.
Another aspect of the program that differs from NAIS is the official ID numbers on tags will be kept in a database in-state.
“Not at the federal level, but only in your state,” reiterates Robinson.
“They’re trying to create a bookend ID system. They’re going to know what farm that animal came from because the official ID number is attached to an address. Just like now, if you took your animal to a market and they had to put a metal a clip in that animal for health traceability reasons, your address is connected to the tag,” says Robinson.
It was added that those producers who don’t wish to have their physical address associated with their official ID number could obtain a post office box.
“Under a bookend system they don’t have the cost and complexity of a movement-by-movement system. But, they’re able to ID the farm of origin and start working from those records forward as well as from the point the disease was detected, and where that animal was at that point in time, backward. Moving forward and backward from those two points is called bookending,” says Robinson.
She adds the USDA anticipates having a proposed rule that would possibly implement the first step by June 2012.
Step two in the system is to be an assessment process for step one.
“The assessment process is triggered by reaching 70 percent of adult cattle being identified under step one, and will be done to show that they have successfully implemented the first part of the program. Without that, we are unwilling to ever see it go on to feeder cattle. Because, as you can imagine, if you’re injecting hundreds of thousands more animals into an ID system that already doesn’t work, it would be a disaster,” explains Robinson.
She adds that in addition to simply reaching 70 percent of all adult cattle being identified, a number of other “performance indicators” will be looked at regarding step one and prior to moving forward.
“I think we’ll continue to have a lot of influence, and we’ll make very sure this thing is working and making sense,” notes Robinson of step two.
Step three is full implementation, and would require traceability of all cattle moving interstate, with few exceptions.
“USDA’s timeline says five years before we even begin the identification of feeder cattle. I think, given the current state and federal resource situation, that it could be much longer than that.
“Dr. Clifford, who is the head vet with USDA APHIS, has said that if it states and the federal government don’t provide the necessary resources to do this, it won’t be done, and that’s right. They can start implementing, but how successful they’ll be will depend on the resources they have,” notes Robinson.
“You will have to keep watch over your own state officials. They could come up with a rule that says if you’re selling to your neighbor, they’ll require this kind of tag. Some states may try to influence usage of higher technology, such as RFID tags, versus a metal clip,” says Robinson.
“USDA is very much on track to publish a proposed rule with the guts of the program I’ve just described to you in April of this year, so you need to be on the watch for that,” she concludes.