NIAA: PR versus Reality—Animal ID and Tracking
by Judith McGeary

Many people focus on the animal identification and tracking portions of NAIS because of the amount of time and money that will undoubtedly be required. So these facets are also where the government and industry have focused their reassuring PR. Let’s look at some of the issues.

Food you raise for yourself. The government and industry officials repeatedly imply that people raising food for themselves will not have to identify or track their animals, but a closer look shows a quite different reality.

The exemption in the USDA’s Guide for Small Producers does not cover most people raising their own food. Rather, it creates an exemption for animals that are born on the property, never leave the property, and are taken off only for custom slaughter for personal consumption. In practical terms, this exception is meaningless. The vast majority of individuals who raise food for themselves buy young animals, such as baby chicks or weaned calves, from other sources. Maintaining a breeding herd or flock is expensive and time-consuming, and not feasible for most individuals to do just for personal consumption. Almost every small farmer or homesteader buys a few animals, whether at a sales barn or from a neighbor, and sells a few. This exemption is relevant only for government bureaucrats who have never raised their own food.

The working group presentations at the ID Expo reinforced just how narrow this exemption is. The speaker for the Cattle Working Group stated that cattle will have to be electronically identified and tracked whenever an animal is sold, even by private treaty. Cattle will also have to be electronically identified and tracked when multiple owners commingle their animals, including in commercial transport, joint grazing agreements, rodeos, and fairs. The Working Group also noted that animals born on your property, never leaving your property, and dying on your property may still need to be “officially identified as a condition of acceptance” at a rendering plant. So don’t forget to put that electronic tag on your cow’s ear and file the paperwork before you call the renderer.

Group Identification. To further reassure animal owners, government and industry statements have repeatedly mentioned that animals may be identified with “group or lot” identification under certain circumstances. So what are those circumstances?

The USDA’s 2005 Draft Program Standards state that group ID is available when animals are managed together from birth to death and not commingled with animals from outside their production chain. At the ID Expo, the Swine Working Group shed light on this definition.

Federal regulations define a swine production enterprise as being “by ownership or contractual relationships, between which swine move while remaining under the control of a single owner or a group of contractually connected owners.” In other words, if you are a contract farmer for a large company that effectively controls the animals from birth to death, you are within the production chain. If not, you will have to individually identify your animals.

The Poultry Working Group’s presentation at the ID Expo was even clearer, admitting explicitly that group identification for poultry was “mainly for commercial poultry.” So the backyard flock, the pastured poultry operations, the heritage breeding operations, all will be faced with individually identifying each bird.

Horses. The Equine Species Working Group (ESWG) released a glossy brochure in April 2006 reassuring horse owners we would not have to report trail rides and local shows. But in both 2004 and 2005 the ESWG submitted recommendations to the USDA that provided for tracking every time a horse is taken off the premises: “When horses are transported interstate, intrastate when commingled with other horses or livestock, or to premises or events where a Certificate of Veterinary Inspection (CVI) or other equine health papers such as Coggins are required, the movement must be reported to the appropriate USDA NAIS database(s).” When the ESWG released its brochure, filled with lovely color photos, the ESWG’s PR directly contradicted its own official recommendations.

Months after releasing the brochure, the ESWG revised its recommendations, which now propose that equine movements not be reported to databases. But it continues to recommend that horses be subject to the first two stages of NAIS: premises registration and animal identification. It also continues to recommend that horse owners be required to use a specific type of microchip for that identification [Horses and NAIS].

At the Animal ID Expo, the co-chair of the ESWG stated that the latest recommendations for no reporting are not consistent with NAIS. She also stated that the states could impose additional requirements, simply by increasing the number of places where health certificates or other documents are required. Interestingly, the Cattle Working Group listed exhibitions and rodeos as being reportable events for cattle. Does anyone believe cattle owners will have to report every rodeo, but horse owners will avoid this burdensome and expensive requirement, especially when they are subject to the first two stages of NAIS?

For years, the ESWG stood by its recommendations that required reporting of every show, trail ride, trip to the vet or breeding facility, or essentially any other movement of a horse off your property. Now that they have decided to change their position, what guarantee do we have that they will not simply flip back to their original plan as soon as the public outcry subsides?

Indeed, when I asked about the reason for the change in the recommendations, Ms. Mann said the ESWG had realized what a negative effect reporting would have on the equine industry. It took them two years to realize horse owners might object to having to report every show, vet visit, and trail ride?

Costs. At the ID Expo many people repeatedly asked about whether a cost analysis has been done. Some officials avoided the question entirely; others said an analysis had not been done because the plans aren’t complete enough. In other words, the 22-page Draft Plan and 34-page Program Standards published in 2005, as the result of three years of intensive work building on a decade of industry planning, are sufficient to justify spending tens of millions of tax dollars, but not enough for a basic cost analysis. Is this how the government ends up spending $20,000 for a hammer?

One industry claim is that radio frequency ID tags will be sold for $2.75, which includes “lifetime reporting.” This claim is confusing, especially when you consider that the total cost for the program in other countries has been reported as ranging from $37 per head to $69 per head.

A conversation with one of the board members of the United States Animal Identification Organization (USAIO) cleared up the confusion. USAIO was created in 2006 by Farm Bureau, National Cattlemens Association, and others to manage the “industry-led animal movement database.” USAIO’s plan is to develop contracts with slaughterhouses and sales barns to fund part of the cost of the databases. So, instead of paying for reports when you file, you will indirectly pay for them whenever you take an animal for processing or sale. Whatever shortfall is not covered by the levies on the tags and services will presumably be made up in our tax dollars.

In discussing costs, let’s not overlook the fact that the need for individual tracking of every movement means one form of identification is not enough. After all, what happens if you have 50 cows and five of them lose their tags? How would you know which was which, to report the new tag numbers? The Cattle Working Group’s answer is that producers should use a second visible tag as a cross-reference. How much will buying both tags and keeping both sets of records cost you?

• What You Can Do

Judith McGeary is an attorney in Austin, Texas, and the executive director of the Farm and Ranch Freedom Alliance, an organization representing independent farmers, ranchers, livestock owners, and homesteaders. This article appeared in the Holiday 2006 issue of Rural Heritage.