A few years ago, when the USDA decided NAIS was a good idea, they put together a framework on how they thought it should look. It met with some pushback. The new Ag Secretary, a man who inherited the project from his Bush Administration predecessor, embarked on a multi-city ‘listening’ tour to see if the animal agricultural community and the USDA might find common grounds on the subject.

We all know how that turned out. Tom Vilsack got an earful, most of it adamantly against the idea in any way, shape or form. The little guys – those folks who owned just a few cattle or hogs – were in the forefront of the offensive. They didn’t like the cost, the reliance on high tech solutions, the uncertainty of that privacy promise…I’ll stop the list here. They didn’t like anything about it.

A chastened USDA took a long look at what they heard and decided that NAIS was, indeed, dead. Well, maybe not. They put the concept on life support, some would say it was tantamount to extraordinary measures prohibited by living wills or ‘do not resuscitate’ orders.

They’ve come back with a new, gentler incarnation; an animal disease traceability proposal that was wisely exposed to the public during a three city listening tour that just ended. APHIS folks asked stakeholders to talk about the concept and how it might work…or not work. When I attended the Kansas City meeting in early May, it seemed like the Feds had a pretty good idea about what they wanted to do but were hesitant to cast anything in stone until they had a chance to digest the feedback.

Wise decision on their part. There were a handful of those rabble-rousers in attendance who fought strenuously against NAIS last year.

The APHIS tour is now over and I had hoped to have ‘Five Minutes’ with one of their top guns to learn more about what they heard and how it would affect their plans. But a lot was said and they weren’t quite done with digesting it all. I’ll get back with them on that later. In the meantime, let’s spend a few minutes with excerpts from a Q and A about ADT that was posted on their web site in February. I’m sure most people haven’t read it and I know only a few hundred were able to attend the recent listening sessions so, if you’re a stakeholder, spend a little time reading. If you want to read the entire document, here is the link: http://www.aphis.usda.gov/publications/animal_health/content/printable_version/faq_traceability.pdf

Q. What kind of comments did you receive during the National Animal Identification System (NAIS) listening tour and submitted online?

A. The U.S. Department of Agriculture (USDA) received a wide variety of comments during the listening tour. Some people were in favor of NAIS, but the vast majority of participants were highly critical of the program. Some of the concerns and criticisms raised included confidentiality, liability, cost, privacy, and religion. There were also concerns about NAIS being the wrong priority for USDA, that the system benefits only large-scale producers, and that NAIS is unnecessary because existing animal identification systems are sufficient.

During the feedback process, USDA also received input from Tribal Nations and industry groups, as well as representatives for small and organic farmers. USDA seriously considered and reviewed all the comments and feedback we received before deciding how to address animal disease traceability.

Q. What has USDA decided to do about NAIS?

A. USDA announced on February 5, 2010, that it will revise the prior animal identification policy and offer a new approach to achieving animal disease traceability. We need an adaptable system that will help us find disease, quickly address it, and minimize harm to producers. USDA will move forward using a flexible yet coordinated approach that embraces the strengths and expertise of States, Tribal Nations, and producers.

Q. Why did you make this decision?

A. Preventing and controlling animal disease is the cornerstone of protecting American animal agriculture. The United States needs a flexible system that will allow us to find disease, quickly address it, and minimize harm to producers.

Under the previous Administration, USDA tried to implement NAIS. USDA spent more than $120 million, but only 36 percent of producers participated. It is no secret that there are concerns about and opposition to NAIS. While USDA appreciates the more than 500,000 producers who took part in our animal disease trace ability efforts, it’s time that we do more to make these efforts more workable, feasible, and common sense for all of America’s producers—especially small producers.

This new approach honors the very legitimate concerns of the American public and those in Rural America, as well as those who have supported our past animal disease traceability efforts. USDA is moving forward with an approach to animal disease traceability that is flexible and lets the States, Tribal Nations, and producers use their expertise to fi nd and use the animal disease traceability approaches that work best for them.

Q. Do we really need animal disease traceability?


A. Animal disease traceability, or knowing where diseased and at-risk animals are, where they’ve been, and when, is very important to make sure that there can be a rapid response when animal disease events take place. Animal disease traceability does not prevent disease. But knowing where diseased and at-risk animals are is indispensable during an emergency response and for ongoing disease programs. It helps to reduce the number of animal deaths and preserve animal health when outbreaks occur in certain parts of the country. It can also limit the number of animal owners impacted by an outbreak and reduce the economic strain on owners and affected communities.

Q. What exactly is the new animal disease traceability framework ?

A. The benefit of Secretary Vilsack’s decision to move forward with a new approach to animal disease traceability is that USDA will not be creating the framework alone. USDA will partner with States and Tribal Nations to create the framework for the new approach. USDA also plans to re-establish a Secretary’s Advisory Committee on Animal Health with representatives from States, Tribal Nations, industry groups, local farms, organic farmers, and underserved communities to assist us in evaluating commodity-based animal disease traceability approaches, along with State-by-State and Tribe-by-Tribe animal disease traceability efforts. This Committee will also advise USDA on other issues that need addressing, such as confidentiality and liability.

A few other aspects are clear. The intent of the new approach is to:

• Achieve basic, effective animal disease traceability and response to animal disease outbreaks without overly burdening producers;
• ONLY apply to animals moving interstate;
• Be owned, led, and administered by the States and Tribal Nations with Federal support focused entirely on animal disease traceability;
• Allow for maximum flexibility for States, Tribal Nations, and producers to work together to find identification solutions that meet their local needs;
• Encourage the use of lower-cost technology;
• Ensure that animal disease traceability data is owned and maintained at the discretion of the States and Tribal Nations;
• Be less Federally intrusive and support producers’ request to operate on principles of personal accountability; and
• Help overcome some of the mistrust caused by NAIS.

Q. How is this different from the old system?

A. This new approach will be focused entirely on animal disease traceability. It will be led and administered by the States and Tribal Nations. USDA’s role will be to provide support to the States and Tribal Nations, and to work cooperatively with them to ensure animal disease traceability standards are defined, measurable, and well documented. Once the standards are defined, States, Tribal Nations, and producers will determine what methods will work best for them to achieve animal disease traceability.

The new framework focuses only on animals that move interstate. So, small producers who raise animals and move them within a State, Tribal Nation, or to local markets, as well as to feed themselves, their families, and their neighbors are not a part of the framework’s scope and focus.

Q. Is the new framework mandatory for all owners of animals?


A. No. USDA will not mandate a one-size-fits-all approach to animal disease traceability. The system will not be mandatory in the sense that all producers are required to participate or that all States and Tribal Nations must implement one approach. What is certain is that animal disease traceability will be required for animals moving interstate. However, each State and Tribal Nation will be able to determine the specific approaches and solutions it wants to use to achieve the minimum animal disease traceability performance measures. Animals not moved out of State, as well as small producers who raise animals to feed themselves, their families, and their neighbors, are not a part of the framework’s scope and focus.

Q. Will the new system be less burdensome for producers?

A. The new framework will allow States, Tribal nations and producers maximum flexibility—and therefore reduce the burden on producers. They can work together to determine what identification methods meet their local needs, while still meeting the national standards and performance measures.

The new approach also places producers who do not move their animals in interstate commerce outside the scope of the Federal animal disease traceability system.

Finally, several species groups already have animal disease traceability methods in place, and the specific animal disease traceability needs of each species will be considered by the Secretary’s Advisory Committee.

Q. How will this new animal disease traceability approach support lower-cost technology?

A. States and Tribal Nations will have the flexibility to adopt the specific methods that best enable them to meet animal disease traceability performance measures. They will also have flexibility to determine what technology they choose to use to support their efforts. In some States or Tribal Nations, animal disease traceability goals could be achieved through branding; in other States or Tribal Nations, metal ear tags may be suitable. To ensure interstate compatibility and connectivity, APHIS will work with States and Tribal Nations in establishing standards and guidelines, where free or low-cost tags will be incorporated as options.

Q. How will having different systems in different States and Tribal Nations affect the interstate movement of animals


A. Under the new framework, USDA will work with States and Tribal Nations to develop systems that achieve basic animal disease traceability performance measures based on the needs of their local producers.

USDA will work cooperatively with the States, Tribal Nations, industry, and the public to set the minimum requirements for animal disease traceability that allow for the efficient movement of animals.

Q. Who will hold the information needed to conduct traces? How will USDA gain access to this information when a disease event occurs?

A.
Under the new framework, the States and Tribal Nations will hold animal disease traceability information. USDA will stand ready to assist States and Tribal Nations as requested. USDA will have access to necessary animal disease traceability information when an animal health event arises. In developing the details of the new animal disease traceability approach, USDA will work with States, Tribal Nations, and industry to provide options and support for information systems.

Q. Will my animals’ information or my information be entered into any government database?

A.
Under the new framework, animal disease traceability information will be held by the States and Tribal Nations, unless a State or Tribal Nation requests that USDA hold their information. USDA will have access to necessary animal disease traceability information only when an animal health event arises.

Q. Who’s going to pay for this?


A. While the total cost of the new framework is not known at this time as the details still need to be decided, it is USDA’s intent to be a cooperative partner in terms of both technical and financial assistance with States and Tribal Nations.

U.S. taxpayers have already made a significant investment in USDA’s past animal disease traceability efforts, and it is vitally important that funding for this initiative not go to waste. USDA will be fiscally responsible and use some elements from NAIS in the new approach. Elements, such as IT infrastructure and tags, will be changed or updated to work with the new approach—and made available to the States and Tribal Nations to use as they see fit for their producers.

Finally, the cost of the animal disease traceability framework will be less than the $228 million per year that the NAIS Benefi t-Cost Analysis outlined for a full animal disease traceability system. It will cost less for two reasons:

1. The framework covers only animals moving interstate and offers flexibility in the identification devices and tracing methods used.

2. The Benefit-Cost Analysis was based, among other things, on identifying and tracing livestock animals, as well as using electronic identification devices for cattle (the largest segment of the livestock population).

Q. Will the new approach be an unfunded mandate on States and Tribal Nations or expensive for producers?

A. No. It is USDA’s intent to provide funding to the States and Tribal Nations to develop animal disease traceability approaches for their producers. USDA also intends to work with States, Tribal Nations, and producers to facilitate access to tags and to help offset other costs, just as USDA does for other animal disease programs.

USDA funds previously allocated to NAIS will be used for the new animal disease traceability approach.

Q. What about States that legislated that they would not participate in NAIS?

A. It’s important to remember that the new animal disease traceability framework the USDA is announcing is not NAIS. This framework will set forth criteria that States and Tribal Nations must meet for their animals to be able to move interstate. States and Tribal Nations will have the flexibility to decide what methods they will use.

Q. What will USDA do to keep my information confidential?


A. USDA understands that the confidentiality of producer information is a foremost concern. USDA believes that producer information gathered through animal disease traceability efforts is exempt from provisions of the Freedom of Information Act. USDA also intends to continue to work with stakeholders and Congress to thoroughly consider this issue.

Q. One of the concerns raised during the listening sessions is the entry of foreign animals with diseases. How does the new framework help this situation? What steps is USDA taking to address it?

A. We know that the best defense against animal disease is to prevent it from reaching the United States. While USDA already has procedures and regulations in place to protect U.S. livestock from diseased animals entering the United States, we will take several steps to strengthen our first line of defense as part of the animal disease traceability announcement.

The steps include:
• taking actions to lessen the risk from disease introduction, such as developing a highly pathogenic avian influenza rule to prevent the introduction of this disease into the United States;
• initiating and updating analyses on how animal diseases travel into the country, including conducting a risk assessment on the introduction of new world screwworm into the United States, Mexico, and Central America from the Caribbean;
• improving response capabilities, and
• focusing on greater collaboration and analyses with States and industry on potential disease risk overall.

Q. Can certain aspects of animal disease traceability be used to ensure safe food and prevent food borne illnesses?

A. Animal disease traceability is focused on animal health. However, there are some aspects of disease traceability that can help promote a safe, healthy food supply:

1. When animals arrive at slaughter facilities, before they are slaughtered, FSIS conducts a wholesomeness evaluation. At this time, if FSIS sees any potential signs of disease, the animal is removed from the food chain and evaluated. If the animal is diseased, the animal disease traceability system would make the traceback of that animal much more effective and timely than if the animal did not have identification.

2. If animal disease is found, either at a pre-slaughter inspection or on the farm, animal disease traceability allows animal health officials to better determine what animals may have been exposed to the disease, as well as where they are located. This allows animal health officials to test potentially exposed animals for a disease, while leaving unexposed animals free to move in commerce.

3. Animal disease traceability will also ensure that the United States can manage zoonotic diseases, or those diseases that can be transmitted from animals to humans.

Q. What are the next steps?


A. USDA wants to be fully open and transparent in any actions taken in support of animal disease traceability and wants to engage and collaborate with those impacted by this new system as much as possible.

The first step is to reach out to the States, Tribal Nations, and industry, and other stakeholders to begin the process of working together to develop the animal disease traceability framework, minimum standards, and regulations. In March 2010, USDA will convene a meeting with States and Tribal Nations, who will work together with their producers to provide us with guidance and input on what they feel should be a part of the animal disease traceability framework and eventual regulations.

USDA will also issue a call for nominations for a re-established Secretary’s Advisory Committee on Animal Health that will provide feedback on the animal disease traceability regulations, as well as other issues like confidentially and liability. It is the goal for this subgroup to meet and begin work in summer of 2010.

Finally, USDA will convene a regulatory working group of Federal, State, and Tribal Nations animal health officials to assess options for the animal disease traceability framework, provide input to the agency, and review the feedback received from the public and other partners.

Q. If I have concerns about the new animal disease traceability system, how can I raise them? Who do I need to talk to/write?

A. Because establishing the new animal disease traceability framework will be a joint State/Tribal Nation/USDA effort, your input and feedback are welcome and very important. You can either contact your USDA area veterinarian in charge (AVIC), your State veterinarian, or Tribal animal health officials with comments.

To find contact information for your State veterinarian, please visit USDA’s animal disease traceability Web site at www.aphis.usda.gov/traceability. In the “Quick Links” menu, click on “State Veterinarian Directory.” (Editor’s note: Here is the direct link - http://www.usaha.org/StateAnimalHealthOfficials.pdf)

During the rulemaking process, a public comment period will also offer an opportunity for sharing your views.

Chuck Jolley is a free lance writer, based in Kansas City, who covers a wide range of ag industry topics for Cattlenetwork.com and Agnetwork.com.