Animal disease traceability became a fact of life for U.S. beef in March 2013, but for now, federal officials are focused on education rather than enforcing compliance.
A key feature of the Animal Disease Traceability (ADT) rule is the USDA has turned implementation and management over to individual states and tribes, meaning that within the rule’s guidelines states can choose their requirements for cattle coming in and can negotiate agreements with other states on types of documentation they will accept. That feature allows considerable flexibility for state animal- health officials to craft a system that works for their producers, but it also creates potential confusion or compliance challenges for producers, veterinarians and market personnel.
Last month’s Joint Strategy Forum on Animal Disease Traceability focused largely on harmonizing the compliance process across states and tribes, to facilitate market efficiency while achieving the program’s goals of traceability for timely and effective intervention in case of a disease event.
The forum, hosted by the National Institute for Animal Agriculture (NIAA) and the U.S. Animal Health Association (USAHA), brought together state veterinarians, USDA officials and industry representatives to discuss the current status of ADT and ongoing work to streamline the process.
The ADT rule requires identification for certain classes of cattle destined for interstate shipment. All sexually intact cattle 18 months of age or older fall under the rule, as do dairybreed cattle of any age or sex, and all cattle transported to shows, exhibits or rodeos. Beef calves and feeder cattle less than 18 months of age are not covered by the rule. USDA’s Animal and Plant Health Inspection Service (APHIS) has stated its intention to address those classes of cattle in a separate, future rulemaking process.
Covered classes of cattle moving across state lines need official identification and documentation. The default or “gold-standard” documentation is the Interstate Certificate of Veterinary Inspection (ICVI). Some other documents such as brandinspection certificates can work in place of the ICVI if the shipping and receiving states have agreed upon the documents. Likewise, in addition to official ear tags, brands or breed-registry tattoos can meet program requirements if the shipping and receiving states have such an agreement.
Variation in state systems
To unravel some of the variability in the ways individual states are administering the ADT system, USDA, in cooperation with NIAA, USAHA and the Livestock Marketing Association, recently conducted a survey of state animal-health regulatory offices. Ohio State Veterinarian Tony Forshey summarized the results, based on responses from 41 of 50 states.
• Thirty-four states distribute National Uniform Eartagging System tags, also known as metal or “brite” tags, to producers. • Thirty-nine states have electronicICVIs available.
• Twenty-five states have commuter herd agreements with other states, 23 have alternative ID agreements and 20 have agreements for movementdocuments other than ICVI and owner/shipper statements.
• Nineteen states accept brands as official identification; five accept them in all cases and 14 in limited cases.
• Thirty-one states accept breed registries as official identification, 15 in all cases and 16 in limited cases.
• All the responding states indicated “yes” or “yes unless exempt” when asked whether they require official identification for classes of cattle specified in the ADT rule entering their states.
• Some indicated they require official identification for cattle not covered by the rule. For example, nine states indicated they require official identification on steers and spayed heifers below 18 months of age entering their states, and 16 indicated the same for sexually intact beef animals less than 18 months of age.
• Twenty-three of the responding states indicated they have official identification requirements for cattle moving within their states.
Chuck Adami, president and CEO of Equity Livestock Sales Association, which operates 11 livestock markets in Wisconsin, participated in the forum. He expresses some concern over variation in state requirements regarding the ICVI. He’d like to see more uniformity but says forum participants generally agreed the ICVI is necessary.
Adami acknowledges that markets face additional expense in employing veterinarians to inspect cattle and file ICVIs, but he also believes the process is beneficial. “I’m interested in one thing,” he says. “That’s moving animals that I know are healthy.” The Equity auctions, he adds, work to minimize costs by contracting with veterinary technicians to collect the necessary information on cattle, then bringing a veterinarian in for a short time to inspect cattle and sign the ICVI documents before the cattleship out.
Throughout the forum, it became clear that regional differences in the ways cattle are marketed, and the role of market facilities, influence the ways states administer ADT and cooperatewith neighboring states.
Cows in large Western herds, for example, might only move through a market once in their lives but might ship to that market in relatively large numbers when managers cull herds. In the Southeast, cows could walk the auction ring multiple times and typically go to market in small lots.
Many of the smaller auction facilities, particularly in the East and Southeast, do not have a veterinarian on hand throughout the sale, or in some cases, ever. Instead, they rely on state or federally accredited technicians to monitorthe health of cattle arriving at the facility. Several state veterinarians from Southeastern states noted they have reached cooperative agreements with neighboring states to allow movement of cattle with alternative official documents instead of the ICVI.
Several Western brand states have indicated they have reached agreements with neighboring states to use brands, along with the ICVI, for interstate movement.
These discussions led to a general consensus among participants that regional harmonization of ADT policies might be more realistic than national harmonization, with groups of neighboring states developing agreementsthat fit for their producers and markets.
Glenn Fischer, senior vice president with Allflex USA, says he is encouraged by movement toward a workable regional model and overall progress toward a national ADT system. Fischer, who also serves as vice-chair of NIAA,says it has been a long road to an official traceability system, which will continue to evolve.
As a global supplier of a variety of visual and electronic ID devices, Allflex has participated in the evolution of traceability systems in countries such as Australia and Canada, where systems have been in place for years. As an ID supplier, he says his company does not make the rules but works to develop solutions that allow producers to comply while ideally providing additional management and marketing benefits.
In any case, he says, commerce will go on, and the system has to work with commerce rather than limiting the ability of markets to function efficiently. The U.S. system, he says, is headed in the right direction.
Education, then enforcement
Another point of consensus was that outreach and education will be critical in the coming months and years, as many producers and veterinarians remain unclear on the details and requirements of ADT. Some of that outreach will come from the federal level, but much of it will need to occur at the state level, due to accountability for each state’s import and export policies.
During the forum, John Clifford, DVM, who serves as deputy administrator and chief veterinary officer in Veterinary Services at APHIS, said USDA’s current focus is on outreach and education to aid implementation at the state level, rather than enforcement. Eventually though, USDA will lead the enforcement effort for the mandatory program.
Auction markets will serve as key resources for implementation of ADT across the country. Many serve as official tagging stations, stockyard veterinarians issue and manage ICVI documents, and sale managers are becoming well versed in ADT requirements and the specific requirements of states to which sale cattle might be shipped.
Several state veterinarians and other participants pointed out that ADT requirements are not that much different from management and marketing practices that have been in use for decades, such as official identification for disease-control programs, sale facilities collecting information on buyers, sellers and livestock, and veterinarians inspecting animals and issuing health certificates. With time, effort and perhaps a little patience, we should be able to make ADT work.
Sidebar: Potential voluntary solution for feeder cattle
During the Cattle Industry Summer Conference in Denver last month, participants heard of a potential voluntary, incentive-based program for tracing calves and feeder cattle. Jim Collins, director of industry relations with the Southeastern Livestock Network, presented a report from the Cattle Industry Animal Traceability (ATS ) Working Group to the NCBA ’s Cattle Health and Well Being Committee.
Collins says the working group has focused on developing a framework for a voluntary traceability system to support beef exports and domestic demand.
USDA this year launched its Animal Disease Traceability (ADT) system, but it covers limited classes of cattle, focusing mostly on mature breeding cattle. USDA plans to address traceability of calves and feeder cattle in a later rulemaking process, after the ADT system is up and running. Calves and feeder cattle account for the majority of cattle shipped across state lines.
The working group has spent the past 18 months developing a concept that would support the ADT system. The proposed voluntary ATS system would work as a public-private partnership with private, non-profit oversight to assure confidentiality of data in the system. It would essentially create linkages with existing private systems that currently provide age-, source- and process-verification services for producers involved in value-added marketing.
Animal-health officials would be able to query the database under approved circumstances to trace cattle, such as in the case of a disease outbreak.
The ATS system would use radio-frequency ID to maintain the speed of commerce. Collins says the system would provide financial incentives, allowing producers to receive premiums for cattle thatqualify for export or other value-added markets. It also would facilitate voluntary transfer of information from feedyards to cow-calf producers. Collins says their proposal would provide traceability for animal- health purposes while leveraging the strengths of existing technology and protecting the viability of existing process-verification programs.