USDA Rep's Animal ID Address
Leaves Many Questions Hanging
By David Bowser
KANSAS CITY, Mo. — More than 300 people filled the 28th floor meeting room of the downtown Radisson Hotel here last month with questions about the National Animal Identification System.
Most of them left with those questions still unanswered after a meeting with Dr. John Clifford, deputy administrator of the U.S. Department of Agriculture's Animal and Plant Health Inspection Service.
Clifford said the objective of the meeting was to share information. There was no intent, he added, for the private sector to come away as a formal group ready to develop a private database.
On Aug. 30, U.S. Secretary of Agriculture Mike Johanns announced that the information in the National Animal Identification System would be collected and stored in the private sector, rather than by the USDA.
"In our minds, this is the beginning of that initially," Clifford said.
The deputy administrator said the purpose of the meeting here was to discuss the processes, responsibilities and general guidelines for having the animal movement-tracking database established in the private sector.
"It's important that we acknowledge that overall animal ID plan as defined by the National Institute for Animal Agriculture's draft program standards, other than the animal movement database, remains unchanged," Clifford said.
The discussion was to be about the privatization of the animal movement-tracking component of the plan, he said.
"The focus of NAIS," Clifford said, "is animal health."
The long-term goal, he added, is to be able to identify all premises that had contact with a foreign animal disease or other confirmed disease within 48 hours of discovery.
"The 48-hour goal," Clifford said, "requires the capability for both trace back and trace forward of animals of interest."
Trace back refers to the tracking of an animal's location over its lifespan, he explained, and determining which animals may have been in contact with the diseased animal or shared contaminated feed.
Trace forward data, he said, provides locations of animals moved from a premises of concern that may have been exposed to the disease.
The first step in the plan, he said, is a premise identification system.
"To track animals, we must know where they were born and where they are moved," Clifford said.
The animal identification system is needed to identify and track animals as they move from premises to premises.
"Animals will be identified either individually with the unique animal identification number," he said, "or with a group lot identification number."
Finally, an animal-tracking component is necessary.
"As animals move from one premises to another, a few basic pieces of information must be collected," Clifford said. "Our ability to achieve a 48-hour trace back objective will be directly affected by the animal movement that we were able to record."
The system must be able to allow tracking of animals from point of origin to processing within 48 hours without unnecessary burden to producers and other stakeholders, according to Johanns.
The system's architecture must be developed without unduly increasing the size and role of government, and it must be flexible enough to use existing animal identification technologies and incorporate new identification technologies as they are developed.
The animal data will be maintained in a private system that can be readily accessed when necessary by state and federal animal health authorities.
"NAIS was initiated in May 2004, when the Animal and Plant Health Inspection Service obtained its initial $18 million in Commodity Credit Corporation funds," Clifford said.
He said APHIS has accomplished a number of achievements with the system so far.
"We have made great progress with NAIS," Clifford said. "The first priority has been the premise ID system.
Fifty states, two U.S. territories and five Native American tribes are operational on premises registration. There are over 126,880 premises registered across the U.S. today.
"I know that's a small fraction of all the premises that exist in the U.S., but it's a good start," Clifford said.
In November 2004, the interim rule established 15-digit numbers beginning with 840 as an official identification number for the individual animal identification number. The 840 number specifies an animal's country of origin through three digits within the 15-digit number, Clifford said. The 840 indicates the United States.
"The 840 number is being integrated in some of our existing animal disease programs, including those for scrapies, chronic wasting disease and bovine tuberculosis in Michigan," Clifford said.
The deputy administrator said USDA will be technology-neutral in the system.
"The government will not mandate a particular identification technology be used," Clifford said. "However, we know full well that uniformity and compatibility of the technology is critical to ensure collection of animal ID is practical and cost-effective throughout the preharvest production chain. Therefore, it is appropriate that minimal performance standards be established that will allow qualifying technology to be used."
Such standards, he said, will be recommended by the species working groups and the NAIS subcommittee and finalized by APHIS to allow the use of technology that meets the needs of industry while providing adequate information to allow tracking of animals within the desired timeframe.
"The NAIS subcommittee advises the secretary's advisory committee on foreign animal and poultry diseases, and APHIS reviews those recommendations that come out of the full committee," Clifford said. "In terms of what works best for the marketplace, the industry should decide on that rather than the government."
For each species that uses individual animal ID, such as the beef cattle industry, USDA will authorize the use of the 840 animal identification number, or AIN, with base ID technology through the process to ensure technology is driven by industry stakeholders and the performance standards they deem necessary, he said.
"Any new or additional technologies in the future will follow this same approval process," Clifford continued. "This approach, we believe, will ensure new technologies are integrated in timely and practical processing."
The cattle working group has established performance requirements for automated data collection systems and technology standards, specifically radio frequency identification, or RFID, systems meeting ISO 11784 and 11785 standards.
The RFID transponder would be encased in a tamper-proof eartag containing the animal identification number.
"The distribution of those tags for cattle will begin soon this fall," Clifford said. "As other species working groups finalize their reports and recommendations, USDA will move forward with approval of ID technologies for other species."
On May 6, APHIS published drafts of a strategic plan and program standard, which were the results of more than two years of collaborative efforts, and asked for public comments.
"We've since reviewed nearly 600 comments on these documents," Clifford said. "Most of the comments reflected overall support for NAIS and were related to the timelines involved with implementation, a mandatory versus a voluntary system, and a private animal tracking database. Overall, the response has indicated general support for NAIS."
While more people supported the system than opposed it, the support was still less than a majority of the respondents.
Forty-four percent of the respondents were supportive, Clifford said. Thirty-nine percent opposed.
Thirty-four percent thought the timeline was too aggressive. Thirty-four percent thought it was too lax and should be quicker. Thirty-two percent supported the timeline as presented.
Thirty-four percent supported a complete voluntary program. Twelve percent supported phasing in to a mandatory program. Fifty-four percent supported a mandatory system from the start.
"There was support for both a federal and a private animal tracking database option," Clifford said.
Of all respondents, 36 percent supported a private database while 48 percent supported a federal one, he said.
Of all producers, 54 percent supported a private database while 39 percent supported federal one.
Among cattle producers, 60 percent supported a private database and 33 percent opposed it.
"I'd like to reemphasize the need for support from USDA to have industry input into the system," Clifford said. "If USDA moves forward with the development and implementation of NAIS, stakeholder input will continue to be a vital component. The current stakeholder review and input structure will remain in place. Stakeholders through the species and issue-based working groups, the U.S. Animal Health Association, the National Institute for Animal Agriculture, and many other organizations make recommendations to the NAIS subcommittee, which then advises the secretary's committee on foreign animal and poultry diseases as well as USDA APHIS veterinary services."
The NAIS subcommittee provides overall program recommendations, reviews and acts on species working group reports, and reports to the secretary's advisory committee.
"This overall structure ensures that the stakeholder input is considered throughout development and implementation," Clifford said, "ensuring a practical national identification program."
As for transparency, he continued, the secretary's advisory committee meets publicly. The NAIS subcommittee, however, meets behind closed doors.
The subcommittee comprises both state animal health officials and industry representatives.
"The subcommittee represents USDA's commitment to a federal-state-industry partnership and development of NAIS," Clifford said. "It's important to understand the subcommittee will continue to provide overall program recommendations for the program."
The private database issue does not interfere with their overall responsibility, he said.
"Privatization of the animal movement tracking database is a significant issue," Clifford insisted. "One that the department takes very seriously."
He said USDA acknowledges that views regarding the privatization of the animal movement and tracking database vary.
"However, we do feel that privatization of this information will help us achieve our end result while strengthening our partnership with the industry," Clifford opined.
He said USDA will be at the table to participate in future discussions to the degree requested by the industry.
"Basically, we'll help you in any way we can from a standpoint of facilitation and collaboration," Clifford said.
He said that only the repository of the data has changed from earlier proposals.
"The overall program has not been altered," Clifford insisted. "I want to clarify that other than loosening the animal movement tracking database, the repository for the private sector, no change is being made to the NAIS plan as presented in the draft program standards of May 2005."
The private database, he said, is for animal movement records only. That includes movement in and out of different premises.
"Animal health events associated with disease programs, disease testing and program vaccinations, will continue to be maintained by the existing state-federal animal health monitoring system, including certificates of veterinary inspection for interstate movement," Clifford said.
To avoid conflict with federal advisory acts, USDA will develop a memorandum of understanding with a legal industry entity to provide the oversight and development of the animal movement repository, Clifford said.
"The industry will be responsible for formulating and organizing this legal entity," he said. "USDA and state animal health officials will serve in an ex-officio role as requested. State and federal governments will provide the NAIS specifications that must be achieved."
The data standards for the most part have already been established in the NAIS draft program standards, he said.
"USDA envisions a privately held animal tracking repository that state and federal animal health officials can access 24-7 by submitting queries necessary to perform their duties," Clifford said.
There are to be no access or user fees for state or federal agencies using the database.
The premise registration system and animal identification number management system will continue to be operated by APHIS.
Clifford said APHIS will have access to the states' databases.
"There are about 15 states that will track their own data within their states," Clifford said. "A number of those states have laws that will not allow them to provide that data to a private system."
Seven or eight such states have such laws on the books.
"The change in the NAIS information system is that animal health officials will access the animal tracking data repository operated in the private sector," Clifford said.
He said he sees multiple databases feeding the industry repository that states and USDA will have access to for animal health issues.
"While we acknowledge various database architectural solutions could prove successful for the private system, the industry-government partnership must ensure the ability to maintain animal health is not compromised," Clifford said. "We're going to have information flow for animal movement to state databases, those states that collect it, probably in the neighborhood of 15. You're also going to have information flow from all these sources into the privately held system that hopefully will feed into one private system."
He said the federal government wants to deal with only one private entity.
"It is critical that USDA access the privately maintained data from one portal," Clifford said. "While it is not feasible for USDA to access multiple independent and stand-alone systems, this does not preclude the industry from maintaining species and program databases."
The industry group will determine the configuration of the private system, including the relationship within the industry databases," he said.
"We will provide data standards and criteria for accepting the private system, including risk management factors, but the solution itself will be the responsibility of the industry," Clifford said.
USDA is committed to a timely implementation of this system, he said.
"It's imperative that progress continues," Clifford said. "For the reporting of animal movements, we must continue to work selectively to resolve the challenges of data collection infrastructure, including the capability of technology and the cost, how it will be paid for."
USDA is still not ready to issue individual animal identification numbers, but Clifford said the system needs to be implemented quickly.
"We believe the voluntary collection and reporting of animal movement records should be initiated in as timely a manner as possible, including the development of a private animal movement data repository," Clifford said. "Yes, we have challenging issues to resolve, and I'm sure there will be stimulating debates, but we must keep our focus and achieve the basic fundamentals to this critically important program."
Questions? Comments? Suggestions?
Email us at [email protected]
325-949-4611 | FAX 325-949-4614 | 800-284-5268
Copyright © 2003 Livestock Weekly
P.O. Box 3306; San Angelo, TX 76902
Leaves Many Questions Hanging
By David Bowser
KANSAS CITY, Mo. — More than 300 people filled the 28th floor meeting room of the downtown Radisson Hotel here last month with questions about the National Animal Identification System.
Most of them left with those questions still unanswered after a meeting with Dr. John Clifford, deputy administrator of the U.S. Department of Agriculture's Animal and Plant Health Inspection Service.
Clifford said the objective of the meeting was to share information. There was no intent, he added, for the private sector to come away as a formal group ready to develop a private database.
On Aug. 30, U.S. Secretary of Agriculture Mike Johanns announced that the information in the National Animal Identification System would be collected and stored in the private sector, rather than by the USDA.
"In our minds, this is the beginning of that initially," Clifford said.
The deputy administrator said the purpose of the meeting here was to discuss the processes, responsibilities and general guidelines for having the animal movement-tracking database established in the private sector.
"It's important that we acknowledge that overall animal ID plan as defined by the National Institute for Animal Agriculture's draft program standards, other than the animal movement database, remains unchanged," Clifford said.
The discussion was to be about the privatization of the animal movement-tracking component of the plan, he said.
"The focus of NAIS," Clifford said, "is animal health."
The long-term goal, he added, is to be able to identify all premises that had contact with a foreign animal disease or other confirmed disease within 48 hours of discovery.
"The 48-hour goal," Clifford said, "requires the capability for both trace back and trace forward of animals of interest."
Trace back refers to the tracking of an animal's location over its lifespan, he explained, and determining which animals may have been in contact with the diseased animal or shared contaminated feed.
Trace forward data, he said, provides locations of animals moved from a premises of concern that may have been exposed to the disease.
The first step in the plan, he said, is a premise identification system.
"To track animals, we must know where they were born and where they are moved," Clifford said.
The animal identification system is needed to identify and track animals as they move from premises to premises.
"Animals will be identified either individually with the unique animal identification number," he said, "or with a group lot identification number."
Finally, an animal-tracking component is necessary.
"As animals move from one premises to another, a few basic pieces of information must be collected," Clifford said. "Our ability to achieve a 48-hour trace back objective will be directly affected by the animal movement that we were able to record."
The system must be able to allow tracking of animals from point of origin to processing within 48 hours without unnecessary burden to producers and other stakeholders, according to Johanns.
The system's architecture must be developed without unduly increasing the size and role of government, and it must be flexible enough to use existing animal identification technologies and incorporate new identification technologies as they are developed.
The animal data will be maintained in a private system that can be readily accessed when necessary by state and federal animal health authorities.
"NAIS was initiated in May 2004, when the Animal and Plant Health Inspection Service obtained its initial $18 million in Commodity Credit Corporation funds," Clifford said.
He said APHIS has accomplished a number of achievements with the system so far.
"We have made great progress with NAIS," Clifford said. "The first priority has been the premise ID system.
Fifty states, two U.S. territories and five Native American tribes are operational on premises registration. There are over 126,880 premises registered across the U.S. today.
"I know that's a small fraction of all the premises that exist in the U.S., but it's a good start," Clifford said.
In November 2004, the interim rule established 15-digit numbers beginning with 840 as an official identification number for the individual animal identification number. The 840 number specifies an animal's country of origin through three digits within the 15-digit number, Clifford said. The 840 indicates the United States.
"The 840 number is being integrated in some of our existing animal disease programs, including those for scrapies, chronic wasting disease and bovine tuberculosis in Michigan," Clifford said.
The deputy administrator said USDA will be technology-neutral in the system.
"The government will not mandate a particular identification technology be used," Clifford said. "However, we know full well that uniformity and compatibility of the technology is critical to ensure collection of animal ID is practical and cost-effective throughout the preharvest production chain. Therefore, it is appropriate that minimal performance standards be established that will allow qualifying technology to be used."
Such standards, he said, will be recommended by the species working groups and the NAIS subcommittee and finalized by APHIS to allow the use of technology that meets the needs of industry while providing adequate information to allow tracking of animals within the desired timeframe.
"The NAIS subcommittee advises the secretary's advisory committee on foreign animal and poultry diseases, and APHIS reviews those recommendations that come out of the full committee," Clifford said. "In terms of what works best for the marketplace, the industry should decide on that rather than the government."
For each species that uses individual animal ID, such as the beef cattle industry, USDA will authorize the use of the 840 animal identification number, or AIN, with base ID technology through the process to ensure technology is driven by industry stakeholders and the performance standards they deem necessary, he said.
"Any new or additional technologies in the future will follow this same approval process," Clifford continued. "This approach, we believe, will ensure new technologies are integrated in timely and practical processing."
The cattle working group has established performance requirements for automated data collection systems and technology standards, specifically radio frequency identification, or RFID, systems meeting ISO 11784 and 11785 standards.
The RFID transponder would be encased in a tamper-proof eartag containing the animal identification number.
"The distribution of those tags for cattle will begin soon this fall," Clifford said. "As other species working groups finalize their reports and recommendations, USDA will move forward with approval of ID technologies for other species."
On May 6, APHIS published drafts of a strategic plan and program standard, which were the results of more than two years of collaborative efforts, and asked for public comments.
"We've since reviewed nearly 600 comments on these documents," Clifford said. "Most of the comments reflected overall support for NAIS and were related to the timelines involved with implementation, a mandatory versus a voluntary system, and a private animal tracking database. Overall, the response has indicated general support for NAIS."
While more people supported the system than opposed it, the support was still less than a majority of the respondents.
Forty-four percent of the respondents were supportive, Clifford said. Thirty-nine percent opposed.
Thirty-four percent thought the timeline was too aggressive. Thirty-four percent thought it was too lax and should be quicker. Thirty-two percent supported the timeline as presented.
Thirty-four percent supported a complete voluntary program. Twelve percent supported phasing in to a mandatory program. Fifty-four percent supported a mandatory system from the start.
"There was support for both a federal and a private animal tracking database option," Clifford said.
Of all respondents, 36 percent supported a private database while 48 percent supported a federal one, he said.
Of all producers, 54 percent supported a private database while 39 percent supported federal one.
Among cattle producers, 60 percent supported a private database and 33 percent opposed it.
"I'd like to reemphasize the need for support from USDA to have industry input into the system," Clifford said. "If USDA moves forward with the development and implementation of NAIS, stakeholder input will continue to be a vital component. The current stakeholder review and input structure will remain in place. Stakeholders through the species and issue-based working groups, the U.S. Animal Health Association, the National Institute for Animal Agriculture, and many other organizations make recommendations to the NAIS subcommittee, which then advises the secretary's committee on foreign animal and poultry diseases as well as USDA APHIS veterinary services."
The NAIS subcommittee provides overall program recommendations, reviews and acts on species working group reports, and reports to the secretary's advisory committee.
"This overall structure ensures that the stakeholder input is considered throughout development and implementation," Clifford said, "ensuring a practical national identification program."
As for transparency, he continued, the secretary's advisory committee meets publicly. The NAIS subcommittee, however, meets behind closed doors.
The subcommittee comprises both state animal health officials and industry representatives.
"The subcommittee represents USDA's commitment to a federal-state-industry partnership and development of NAIS," Clifford said. "It's important to understand the subcommittee will continue to provide overall program recommendations for the program."
The private database issue does not interfere with their overall responsibility, he said.
"Privatization of the animal movement tracking database is a significant issue," Clifford insisted. "One that the department takes very seriously."
He said USDA acknowledges that views regarding the privatization of the animal movement and tracking database vary.
"However, we do feel that privatization of this information will help us achieve our end result while strengthening our partnership with the industry," Clifford opined.
He said USDA will be at the table to participate in future discussions to the degree requested by the industry.
"Basically, we'll help you in any way we can from a standpoint of facilitation and collaboration," Clifford said.
He said that only the repository of the data has changed from earlier proposals.
"The overall program has not been altered," Clifford insisted. "I want to clarify that other than loosening the animal movement tracking database, the repository for the private sector, no change is being made to the NAIS plan as presented in the draft program standards of May 2005."
The private database, he said, is for animal movement records only. That includes movement in and out of different premises.
"Animal health events associated with disease programs, disease testing and program vaccinations, will continue to be maintained by the existing state-federal animal health monitoring system, including certificates of veterinary inspection for interstate movement," Clifford said.
To avoid conflict with federal advisory acts, USDA will develop a memorandum of understanding with a legal industry entity to provide the oversight and development of the animal movement repository, Clifford said.
"The industry will be responsible for formulating and organizing this legal entity," he said. "USDA and state animal health officials will serve in an ex-officio role as requested. State and federal governments will provide the NAIS specifications that must be achieved."
The data standards for the most part have already been established in the NAIS draft program standards, he said.
"USDA envisions a privately held animal tracking repository that state and federal animal health officials can access 24-7 by submitting queries necessary to perform their duties," Clifford said.
There are to be no access or user fees for state or federal agencies using the database.
The premise registration system and animal identification number management system will continue to be operated by APHIS.
Clifford said APHIS will have access to the states' databases.
"There are about 15 states that will track their own data within their states," Clifford said. "A number of those states have laws that will not allow them to provide that data to a private system."
Seven or eight such states have such laws on the books.
"The change in the NAIS information system is that animal health officials will access the animal tracking data repository operated in the private sector," Clifford said.
He said he sees multiple databases feeding the industry repository that states and USDA will have access to for animal health issues.
"While we acknowledge various database architectural solutions could prove successful for the private system, the industry-government partnership must ensure the ability to maintain animal health is not compromised," Clifford said. "We're going to have information flow for animal movement to state databases, those states that collect it, probably in the neighborhood of 15. You're also going to have information flow from all these sources into the privately held system that hopefully will feed into one private system."
He said the federal government wants to deal with only one private entity.
"It is critical that USDA access the privately maintained data from one portal," Clifford said. "While it is not feasible for USDA to access multiple independent and stand-alone systems, this does not preclude the industry from maintaining species and program databases."
The industry group will determine the configuration of the private system, including the relationship within the industry databases," he said.
"We will provide data standards and criteria for accepting the private system, including risk management factors, but the solution itself will be the responsibility of the industry," Clifford said.
USDA is committed to a timely implementation of this system, he said.
"It's imperative that progress continues," Clifford said. "For the reporting of animal movements, we must continue to work selectively to resolve the challenges of data collection infrastructure, including the capability of technology and the cost, how it will be paid for."
USDA is still not ready to issue individual animal identification numbers, but Clifford said the system needs to be implemented quickly.
"We believe the voluntary collection and reporting of animal movement records should be initiated in as timely a manner as possible, including the development of a private animal movement data repository," Clifford said. "Yes, we have challenging issues to resolve, and I'm sure there will be stimulating debates, but we must keep our focus and achieve the basic fundamentals to this critically important program."
Questions? Comments? Suggestions?
Email us at [email protected]
325-949-4611 | FAX 325-949-4614 | 800-284-5268
Copyright © 2003 Livestock Weekly
P.O. Box 3306; San Angelo, TX 76902
