National Animal Identifi-cation System coordinator, USDA-APHIS.
president and chief executive officer, National Institute for Animal Agriculture, which spearheaded the industry/government process that led to the foundation of NAIS. (www.animalagriculture.org).
animal ID coordinator for the National Cattlemen's Beef Association (NCBA). NCBA opposes a mandatory ID system, and argues for an industry-based, rather than government-based, program. (see NCBA's ID “System,” page 23).
A survey of BEEF readers in May found 69.1% in favor of a national system of livestock ID and traceback. And, the general outlines of a National Animal Identification System (NAIS) to bolster current animal health programs and mitigate a catastrophic foreign animal disease (FAD) event in the future were sketched last month by USDA (www.usda.gov./nais).
But disagreement remains between government and some producer groups when it comes to critical NAIS issues, such as how the program will be funded and how the necessary producer data will be protected. We asked principal players Neil Hammerschmidt, Glenn Slack and Allen Bright (see sidebar on right) to offer their organization's perspectives:
BEEF: How does USDA's Draft Strategic Plan for NAIS answer ongoing producer concerns? What concerns remain unanswered?
Hammerschmidt: I think the documents are of tremendous value in clarifying the timelines USDA is considering. That's the primary intent of the Strategic Plan, whereas the draft standards are more the nuts and bolts and how the system could work. In combination, the documents underscore the issues that still need to be addressed such as funding and data confidentiality.
Slack: The strategic plan is the most comprehensive look at the industry/government effort toward the establishment of a national animal ID system. The plan gives producers a good overview of USDA's thought process, as we begin to see a silhouette of what NAIS really will look like.
The plan acknowledges four of the major concerns: financial, confidentiality, flexibility and liability. Currently, these issues are being addressed. In time, they will be resolved through the same cooperative process that has brought us to this point.
Bright: The Strategic Plan is fairly straightforward. Left unanswered is how we pay for this? Where does the money come from? Specifically, what other USDA programs will they take money from, or will it be an unfunded mandate? Will USDA and the industry work together on a solution?
Another concern is the timeline: On one hand, how can deadlines suggested in the strategic plan be achieved? And, from a disease standpoint, is the timeline fast enough? We don't think it is. Obviously, the issue of funding will help determine the possibility of the timeline.
BEEF: NCBA believes a private-industry database should be used for NAIS? How does that or any other private industry proposal fit the intent of NAIS?
Hammerschmidt: As outlined today, NAIS is an animal disease management system administered by state and federal animal health officials. However, we feel very strongly that USDA can't achieve NAIS without integrating private industry systems. We need information flow from privatized systems.
There's opportunity for private industry systems to participate in NAIS as third-party system providers that feed required producer data to the NAIS database. This way, producers who choose to use a third-party data provider for reasons other than NAIS compliance can be assured they comply with NAIS and use a single system.
Anything beyond NAIS data is not a USDA issue, it's an issue for the industry to decide. This division of regulatory data from marketing data keeps from muddying the waters about who shares what information with whom.
As well, collection of animal movement data is critical to achieving the NAIS long-term goal of 48-hour traceback. From a technology standpoint, design of the database for premises and individual animal data is simple by comparison. Yet, I believe much of the industry's focus has been on these databases rather than on addressing the challenges of collecting and managing animal movement data.
Slack: Both industry and government have put a lot of effort into NAIS, all the way back to development of the U.S. Animal Identification Program (USAIP) that preceded NAIS. We hope new proposals don't become counterproductive to establishing a national system.
There will be endless opportunities for private enterprises to plug into NAIS. It's imperative, however, that a national animal tracking system provides our state and federal animal health officials the capability for 48-hour traceback for disease purposes. The system has to be accessible for current program diseases such as tuberculosis and brucellosis, as well as any potential FAD.
Bright: From our perspective, it's very clear to us we don't want USDA-APHIS to hold all the data. It needs to be held within an industry consortium. State veterinarians can query a private database for the information they need, so we see it as being a very natural fit with NAIS.
BEEF: What are the key producer and industry misunderstandings about NAIS?
Hammerschmidt: I think most producers understand NAIS is focused on animal disease management issues, but too often there is misunderstanding on what information is needed to track animals. We need to continue to clarify that we are looking at minimal information to record animal movement. It's also important that producers know what NAIS means for them today. I hope the Strategic Plan clarifies we're still in the voluntary phase of NAIS, and when we may look at making the program mandatory (January 2008 for premises and individual; January 2009 for animal movement).
Slack: The biggest misunderstanding is about confidentiality. Information technology developed in the later part of the 20th century and utilized today by all of us in ATM and online banking transactions, provides a similar scenario to the information that would be collected, stored and accessed through a national animal ID system.
When someone gets cash from a generic ATM machine using a debit card, it allows that banking institution to immediately access that individual's bank account. Are we concerned about that kind of information access in 2005? For the most part, no.
While confidentially issues exist relative to NAIS, they're not insurmountable. A combination of legislation and regulation can and will resolve these issues.
Bright: I'm asked the most about confidentiality and, along with that, liability. The key misperceptions when it comes to NAIS aren't among producers, but those who argue a need for a national ID system without understanding the complexities.
This must be a cooperative effort between APHIS, state and federal veterinarians and industry. State and federal veterinarians work for the producer, not the other way around. True cooperation doesn't mean I as a producer simply listen and do what USDA tells me I need to do.
BEEF: What should everyone understand about NAIS?
Hammerschmidt: Overall, the focus for NAIS is to strengthen our animal health surveillance program, and the fact that there are differences between species. That's why the various species working groups have had tremendous input about how the system will work for their species. A good example is the cattle working group, which recommends RFID tags using ISO standards as the standard for official NAIS ID in that industry.
The other issue is NAIS is specific to animal health issues. Other opportunities producers have to use the documentation and information for marketing purposes is outside our scope. Certainly the NAIS infrastructure can be used by the industry for other programs, but such resulting information and opportunities are maintained and administered through industry initiatives and programs.
Slack: The U.S. animal agriculture industry operates under risk of introduction and spread of a FAD. NAIS will provide a fast, effective method to mitigate this risk, and help advance eradication of domestic diseases.
Producers should understand the industry has been driving this program as far back as 1988. Producers also should understand the Strategic Plan evolved from the USAIP (U.S. Animal Identification Plan) produced by the cooperation of industry and government. Many concerns we're hearing today have been discussed for years. These aren't new to many industry leaders, including producers, veterinarians, livestock markets, and state and federal officials.
Bright: Whatever we do must help producer profitability without limiting a producer's ability or choice in the market. As animal ID is initiated, it must be understood that protecting the national herd does help protect producer profitability. This shouldn't be confused with market demands placed on this and other data that producers should be paid for.
BEEF: What's your perspective on potential NAIS funding options or preferences?
Hammerschmidt: As we get consensus on the timelines, more specifics on overall cost to get us through 2009 will be documented and discussed, along with who will cover which cost. Our next priority is to clarify that in greater detail.
We continue to look at cost sharing. I believe the understanding in the cattle industry is the cost of ID devices and their application is a cost that can be absorbed by the producer.
USDA is providing much of the infrastructure to support the state and federal system. We'll continue to evaluate which costs are absorbed and how, especially in the marketing channel, specifically at livestock markets and packers. We realize there are additional costs in the marketing channel that need to seriously and fairly be evaluated. We're not planning to dump lots of added expense on the markets.
Slack: NIAA hopes adequate federal funding is available for developing the NAIS infrastructure, including premises registration and data collection capabilities required for NAIS to be successful. Industry will bear some cost, as will the states. But it's become a necessity to spend some money to mitigate the risk that could adversely affect every producer in the country. Consider foot-and-mouth disease in the UK as an example of that.
Bright: Disease animal surveillance has to be considered a cost of doing business, but producers must also be concerned about how to recover that cost. If the question of funding isn't resolved, other than the $33 million already allocated by USDA for premises registration, then chances are other costs will come solely out of producers' pockets. That's unacceptable.
APHIS must continue to develop and implement the NAIS premises registration system. That's a necessary first step and a good use of the available funds for NAIS. We have to look for ways producers can benefit beyond just protecting the national cowherd in order to recover the cost.
We need to ask ourselves, “Has a disease surveillance system been requested that costs the producer more than it can return to them?” Can we take that disease surveillance data and use it for other benefits? The answer is yes.
BEEF: What's your perspective on potential NAIS confidentiality options or preferences?
Hammerschmidt: USDA plans to transmit draft language to Congress this year. We support congressional action to exempt this data from the Freedom of Information (FOI) Act. We believe it's the most solid assurance of confidentiality at this time. Our state partners are also working on this issue locally.
Slack: Draft legislation has been sent to Congress by the Bush Administration to begin the process of addressing confidentiality. Other options have been suggested, but it's doubtful that privately managed systems independent of USDA actually provide a resolution to confidentiality issues. That's because, once information is provided to the government, the original FOI concerns are back in play.
Bright: Confidentiality is key, and the only way it can be assured is if the data is held outside APHIS and the government where current laws protecting private business information already exist in all 50 states.