By: Doreen Hannes
Doreen Hannes is the Director of Research for the National
On May 11th, the USDA held the first of three public meetings on their “New
NAIS” program “Animal Disease Traceability”. The meeting began
at 8am with three power point presentations. California State Veterinarian,
Dr. Richard Breitmeyer gave the first presentation. This was the same presentation
he gave at the mid-March NIAA (National Institute of Animal Agriculture) meeting,
also held in Kansas City.
A little history is in order to understand the progression of this idea
for animal traceability. In the US, the first notable plan for identifying
animals was the NFAIP, along with FAIR, those being the National Farm Animal
Identification Program and Farm Animal Identification and Records. Then under
the Bush Administration there was the United States Animal Identification
Plan, with the NAIS, National Animal Identification System hot on it’s heels.
Now, they have “killed” NAIS, but are moving forward with the Animal
Disease Traceability plan, the ADT. The main difference here is that the USDA
is going to make a rule on the ADT to prescribe the “performance standards” for
traceability that the states MUST meet to engage in interstate commerce with
Breitmeyer’s presentation focused on the difficulties around tracing the
contacts of tubercular (and suspect) cattle in the state of California and
other states without the aid of an interoperable database covering all animals
and all movements. According to his presentation, the state of California
has approximately 57,500 known live cattle imports from Mexico per year. This
is significant in that more than 75% of all tuberculosis in cattle is of Mexican
origin. Breitmeyer lamented that when he began as a vet 25 years ago, the
US had nearly eliminated TB except for in small areas of northern Michigan
and northern Minnesota where the soil make up continues to keep TB in the
wildlife and therefore occasionally in cattle. Breitmeyer’s presentation was
actually quite a good illustration of many of the failed policies of the USDA
in disease control, the lack of quarantine at the borders chief among them.
Of course, he is a proponent of a NAIS style system because having all that
data available would make his job easier…At least on paper.
The second presentation was given by a very soft-spoken APHIS/VS (Veternary
Services) representative, Dr. TJ Mayer. He stressed that the “theme” for
the development of the “new” program is “collaboration”.
Those to be affected must be involved in the process of developing the solution
for the lack of traceability that now exists— particularly in cattle. Cattle
are the primary focus for this new plan, and the methodology for bringing
cattle to 95% traceability back to the point of identification in 2 business
days is dependent on “collaboration” in developing the processes
in our states. (Sounds familiar, doesn’t it?) Mayer also illustrated that
the desired traceability would be implemented gradually through partnerships
of stakeholders and building upon the requirements outlined in the rule that
is to be developed for criteria that states must meet for interstate commerce.
The third presentation was by Becky Brewer (Oklahoma State Vet) and the
apparent lead member of the newly established “Regulatory Working Group”.
Dr. Brewer related the thinking of the Regulatory Working Group on the measurable
outcomes of the ‘traceability’ standards to arrive at 95% of “all” animals
traced back to the ‘traceability unit’ within 2 business days. Sounds just
like the NAIS Business Plan, doesn’t it? Brewer stated, “In government
speak, “all” doesn’t mean all.” This may explain why the USDA
kept insisting that when opponents of NAIS cited documents verbatim, we were “spreading
misinformation”. Evidently the English language is a linguistic and statistical
anomaly in the hands and mouths of bureaucrats.
There were no question and answer sessions after the presentations. Instead
every table was given a USDA facilitator and three segments of questions to
answer regarding how we might achieve the desired outcome of getting animals
id’d back to the ‘traceability unit’ within their timeframes. The tables were
marked with species placards and there were at least five cattle tables, three
swine, two poultry, one sheep and goat, and one “other species”.
When I entered the room I noticed that Kenny Fox of R CALF USA was at a
cattle table and I failed to notice the “other species” table so
I sat at the sheep and goat table. There were no people at the poultry tables.
The cattle tables were quite full, and all of the reporters were sitting at
the ‘other species’ table, so I thought I would just sit at the empty sheep
and goat table.
When the facilitating began, I was blessed with three USDA representatives
at my table, where all the other tables only had one. I shared the table with
one sheep broker from New Mexico. He deals in 20 to 30,000 head of sheep annually
mostly exported to Mexico and was quite content with the Scrapie program.
This program identifies breeding animals back to the flock of origin with
a number assigned to the flock manager and not the land the animals are held
on. It also allows for tattoos as an alternate form of official id for interstate
commerce, and does not use RFID tags, although it could in the future.
The USDA representatives at my table were not particularly interested in
hearing about how the failed agricultural policies have created a problem
that the USDA would now like all of us to ‘partner’ with them to solve. They
did take copious notes, and were quite proficient in ‘mirroring’ my statements
while slightly adjusting them to fit their desired outcome more handily.
At the end of each of the three segments, a representative from each table
stood and gave the ‘report’ from the table on that segment. The consensus
of the cattle groups were that only breeders should be identified, RFID tags
should be avoided, back tags should continue to be used for feeders and slaughter
cows, and a NAIS styled system would not work at all.
The USDA is currently promoting the use of ‘bright’ tags for cattle. These
are very similar to brucellosis tags in numbering and appearance. However,
when the only question and answer segment of the day took place and Neil Hammerschmidt
(one of the main authors of NAIS) gave most of the answers, he made it clear
that the USDA still wants to ‘aggressively’ pursue the use of 840 tags.
The bottom line about the entire meeting is that the USDA will try to have
a draft rule ready in June from the “Regulatory Working Group”.
This rule will define the “performance standards” that are to be
met by the states to engage in interstate commerce. The USDA plans to publish
this proposed rule in November or December of 2010, allow a 90-day comment
period, and finalize the rule (make it law) from 8-10 months after the comment
period is complete. There may be different requirements under these performance
standards by species, and some potentially exempted sectors or movements.
There is admitted concern from the USDA and their friends that incentives
and disincentives for states must be expressed clearly and not be too “heavy
handed”. In other words, if a state meets compliance levels in hogs and
not cattle, the hogs should not be refused access to interstate commerce.
It appears to me that we must proactively engage our state legislators
to statutorily define requirements for interstate livestock movement and not
allow the Departments of Agriculture the leeway to cooperate with the USDA
to achieve the goals of the USDA as those goals are still NAIS oriented. The
USDA will not dismantle the National Premises Repository although Hammerschmidt
stated that if a state were to want to withdraw all of their participants,
they could do so. Also, according to Hammerschmidt, they still want to move
‘aggressively’ to 840 tags as official identification along with electronic
Certificates of Veterinary Inspection.
The onus of implementing the graduated Animal Disease Traceability program
rests squarely on the individual states. Either the states will define those
standards statutorily or the USDA will bring about their final desires incrementally
through the regulatory process.