“Mad Cow” Policy: The National Animal Identification System
21 July, 2005
category: Biometrics, Library, RFID
David C. Wyld is the Mayfield Professor of Management and the Director of the Strategic e-Commerce Initiative at Southeastern Louisiana University in Hammond, Louisiana.
The word from the plains of Texas is not good. Earlier this month, investigators confirmed that the U.S. has suffered its second case in three years of “Mad Cow” disease (also known as Bovine Spongiform Encephalopathy – BSE).
When the U.S. experienced its first case of the so-called “mad cow disease” in December 2003, billions of dollars were lost as both Americans at their dinner tables and buyers for restaurants and grocery stores, both at home and abroad, decided that U.S. beef would not be “what’s for dinner.” While Mad Cow inspires fear in the hearts of every non-vegan, it is especially worrisome for the American beef industry, which employs 1.5 million people and generates $68 billion a year in sales from the approximately 100 million head of cattle in the United States.
Mad Cow is just one of a host of what are known as FADs – foreign animal diseases, any one of which can wreak havoc on species of animal(s) in our food supply chain. These include such maladies as not just BSE, but Foot-and-mouth Disease, Esicular Stomatitus, Equine Infectious Anemia, and even the West Nile Virus. What’s worse, there’s now the prospect of “agroterror,” where Al Qaida or other terrorists could seek vengeance on America through our food supply. Think that’s just the Homeland Security officials elevating the terror level for no reason? Consider the fact that over ninety percent of American cattle pass through only five feed lots on their way to the display case at Wal-Mart or Whole Foods Market or to your plate at Ruth’s Chris or the Sizzler. Such “cattle hubs” mean that FADs – whether introduced intentionally or accidentally – could rapidly spread throughout the animal population and into the food supply.
Thus, both the federal government and the agricultural industry have determined that it is vital to have an animal identification system in place for species that are integral to our food supply. Under the auspices of the U.S. Department of Agriculture (USDA) and in consultation with agribusiness, the government has recently announced the creation of the National Animal Identification System (NAIS).
The goal of the NAIS is to be able to identify all animals with and that have been exposed to a disease of concern within 48 hours after the discovery of the occurrence. This “rapid traceback” capability is vital in order to contain and eradicate the FAD by limiting the scope of any outbreak, minimizing the damage to the affected animals, the agricultural interests involved, and the American economy – and population – as a whole. The NAIS will enable animal health officials to trace a sick animal – or group of animals – back to the herd or premise that is the most likely source of infection. This is especially important in the case of Mad Cow disease, given the fact that we presently test only 1 in 10,000 cows for the condition, far less than the 1 in 4 cows tested in the European Union and Japan, where every cow gets tested.
The NAIS will cover:
- Camelids (llamas and alpacas)
- Cattle and bison
- Cervids (deer and elk)
- Equines
- Goats
- Poultry
- Sheep
- Swine.
In order to track the animal population, the NAIS will register both animals and the locations where they are. In doing so, the USDA can – for the first time – create a database that will give animal health officials the ability to “track and trace” an identified subpopulation of animals that may need to be targeted in a disease outbreak.
For animals, the NAIS will represent a national “one number – one animal” identification system for all animals in species covered by the plan that may commingle with animals from other sources in their lifetime. In time, this single number – the AIN, or Animal Identification Number – will replace the multiple identifiers animals such as cattle and hogs have had for differing purposes. In simple terms, the 15-digit AIN will become the animal equivalent of the VIN (Vehicle Identification Number).
The NAIS also seeks to register all locations where animals are managed, held, or passed through. These are known as “premises,” and they encompass any location where animals can commingle. Thus, for the purposes of the NAIS, all of the following locations are examples of premises:
- Farms
- Ranches
- Grazing areas
- Veterinary Clinics
- Animal Exhibition Centers
- Livestock Markets and Auctions
- Slaughter and Processing Establishments.
Each of these premises will be identified with a seven character identifier – a Premises Identification Number (PIN). Since beginning to accept premises registrations last August, according to the USDA 47 states and 5 Indian tribes have established premises registration programs, registering over 79,000 premises as of June 2005.
Once the premises registration and animal identification elements are in place, and the goal is to have both completed by June 2008, animal health officials will be able to track an individual animal’s movements over its lifetime, as animals move from premises to premises. In the case of animals commonly housed in groups (such as chickens and pigs), the movements of the group/lot can be tracked in the same manner, but without the automation and granularity possible with the “one animal – one number” system. The prescribed protocol, according to the program standards for the NAIS, will have the receiver of the animal (or group/lot) reporting their receipt of the animal to the National Animal Records Repository and/or the appropriate state/tribal agency. In the case of abattoirs, or processing plant operators, they would be required to report both the receipt of the animal and the slaughter of the animal.
And the technology at the heart of this program? It will certainly be RFID in most instances. While other high-tech methods, such as retinal scanning or even DNA testing, could be used, so too could “old fashioned” technology, such as tattooing and branding. The USDA’s position is to remain technology neutral and concentrate on designing the overall identification data system. In its official statements, the agency believes that the market will dictate what ID method will be appropriate for specific species, stating that “there is no ‘one-size-fits-all’ identification technology.” Indeed, while RFID-equipped ear tags or implanted devices may be the obvious choice for larger animal species, such as cattle, bison, camelids and cervids, for other smaller animals, such as goats, the size of their ears may preclude such tagging methods. Research clearly demonstrates that at least for the cattle industry, RFID ear tags will be the most cost effective way to track individual cows and herds as they move from location to location. Indeed, Dale Blasi, an industry expert at Kansas State University, says RFID will eventually be used to track every domesticated animal in the United States.
The National Animal Identification System is to be a voluntary program – for now. While the Secretary of Agriculture, under the powers granted to the office by the Animal Health Protection Act (AHPA), could institute such a system unilaterally, the USDA is committed to both public and industry input into the NAIS plan and to allow for a phased-in implementation of the program. This is being done both to garner support for the program and to allow for any “kinks’ to be worked-out as the program is being implemented. Yet, the paradoxical situation is that for the national identification system to be effective, there needs to be complete visibility across all premises and in all affected species. Thus, it is inevitable that the program be made mandatory in the U.S. Such a voluntary, then mandatory approach has been taken in other countries, such as Australia, Brazil, and Canada, where national animal ID frameworks are presently in place.
The projected costs of the NAIS are substantial. It has been estimated that the cost to create the system by 2009 will exceed half a billion dollars, with recurring expenses for RFID tags and software/hardware upgrades to be in a range $70-$122 million annually.
To date, the federal government has not shown a willingness to bear a significant share of the overall cost of the program. In fact, it has spent just over $50 million on the development and implementation of the NAIS to date. The USDA believes that because of the benefits in protecting the animal population from disease, and protecting the agricultural markets from the shock that can occur when such outbreaks take place, the costs of the program should be borne by the industry. However, consumers could well end-up bearing the costs of enhanced animal identification in the form of higher prices for meat, poultry, and other animal products. Yet, if events happen that would raise the fear that animal disease outbreaks could be intentionally started as acts of “agroterrorism,” then it is likely that the federal government would step in to substantially fund the NAIS as a way of enhancing Homeland Security.
Today, it appears that the National Animal Identification System is well on its way to becoming an integral part of American agriculture. For the beef industry and for other parts of the animal supply chain, animal ID appears to be a matter of “when” and not “if,” although it remains to be seen if the program will be made mandatory throughout all animal species presently covered by the plan. However, the stakes for American agriculture are such that it would appear that it is very much in the interests of all stakeholders – government, industry, and the public at large – that such a system be put in place as soon as possible. As we have seen with past animal disease outbreaks, the costs – both in terms of animal and human lives and in the impact on agricultural interests – are too great to not have such a rapid traceback capability to be in place. As Congressman Michael Rogers (R-Alabama), a member of the House Agriculture Committee’s Livestock and Horticulture Subcommittee, commented: “If we have a foot-and-mouth outbreak, everyone will be clamoring to figure out what went wrong. We’ll all be sitting around saying ‘I wish we would have done this.'”
NOTE: If you would like to learn more about the National Animal Identification System, information is available at http://www.usda.gov/nais/. The USDA will also take your comments on the NAIS at this site until the close of the public comment period on July 6, 2005.