National Campaign for Sustainable Agriculture

ARCHIVE: RURAL DEVELOPMENT AND SUSTAINABLE LIVESTOCK

UPDATE -- March 27, 2006

National Animal Identification System

To date, no actions have been initiated by USDA to develop regulations to require participation in the National Animal Identification System (NAIS), according to USDA. However, states are moving ahead on their own to put the animal-tracking system in place. It has been reported that Minnesota and Wisconsin have approved measures that make stage one of the NAIS program (premise identification) mandatory, and Maine, North Carolina, Texas, Vermont, and Washington are considering similar legislation.

The National Campaign for Sustainable Agriculture does not have a position, as of yet, on NAIS. But we have received calls from a number of states expressing concern that the burden of the NAIS falls disproportionately on small farms and ranches that have to ID every animal, as opposed to large farms and ranches that ID animals by lot. In addition, there are concerns about confidentiality and potential mis-use of information by agri-business. I am passing along some relevant articles and websites. Please keep us informed on what is happening in your states. Thanks.

INCLUDED BELOW:
1) USDA NAIS Website
2) USDA Guidelines for Official ID Devices
3) R-CALF USA 2006 Position Paper on NAIS
4) WORC Comments on NAIS
5) Texas Organic Farmers & Gardeners Association Website
6) NAIS Backstops Agribusiness, Ben Grosscup, NOFA
7) Old Big Brother Had a Farm, Amanda Griscom Little, GRIST
8) Comments on NAIS Draft Standards and Plan, Mary Zanoni

1) USDA WEBSITES:
NAIS is a cooperative State-Federal-industry partnership to standardize and expand animal identification programs and practices to all livestock species and poultry. NAIS is being developed through the integration of three components-- 1) premises identification, 2) animal identification, and 3) animal tracking. ALTHOUGH THE DRAFT STRATEGIC PLAN REFERENCES MANDATORY REQUIREMENTS IN 2008 AND BEYOND, TO DATE NO ACTIONS HAVE BEEN INITIATED BY USDA TO DEVELOP REGULATIONS TO REQUIRE PARTICIPATION IN NAIS.
http://www.usda.gov/nais
http://animalid.aphis.usda.gov/nais/about/index.shtml

2) USDA GUIDELINES FOR OFFICIAL ID DEVICES:
USDA released Guidelines for the manufacture and distribution of official identification devices as the next phase of the voluntary National Animal Identification System (NAIS) on March 3, 2006:
http://www.aphis.usda.gov/publications/animal_health/content/printable_version/sa_vs_nais3-3-06.pdf

3) R-CALF USA 2006 POSITION PAPER ON NAIS:
The Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF USA) has serious concerns about how the NAIS is being implemented. R-CALF is not convinced that a mandatory program is needed, but if it is deemed necessary, it should be publicly funded and operated.
http://www.agmatters.net/Livestock/RCALF_NAIS_Position.pdf

4) WESTERN ORGANIZATION OF RESOURCE COUNCILS (WORC) COMMENTS:
WORC believes that the unstated purpose of the NAIS is to further integrate the U.S. cattle industry for the benefit of the meatpacking industry. Instead, National Animal Identification should build on existing animal health and ownership brand identification programs. There should be no privatization of the program-- privatizing would create unnecessary costs and foster profiteering off the program. Privatization could lead to misuse of data, ie, information on genetics, management, or other practices that could be used by meatpackers to discriminate against producers or dictate production practices, and to manipulate markets.
http://www.agmatters.net/Livestock/WORC_NAIS_Oct05.pdf

5) TEXAS ORGANIC FARMERS & GARDENERS ASSOCIATION:
Under pressure from angry Texans, the Texas Animal Health Commission canceled its March 23 meeting to implement premises registration, the first step of a program that would require mandatory livestock Tagging,Tracking and Taxing in Texas. Livestock owners have said that HB1361 must be repealed.
http://www.tofga.org/
http://www.tofga.org/?page=25&pp=1âŒ(c)=51

6) NATIONAL ANIMAL ID PROGRAM BACKSTOPS AGRIBUSINESS, WHILE SMALL-FARM SYSTEM OFFERS REAL DISEASE ANSWERS, Ben Grosscup, NOFA

If the USDA's Standards are any indication of what is to come, there will be a two-tiered implementation of NAIS that encourages massive-scale to the detriment of human-scale farming. Large industrial operations will more easily incorporate a tracking system by making just one ID tag for each group of animals kept together for all stages of the mechanized production process. By contrast, small farmers would be required to tag each individual animal, a financial burden the USDA says will befall the farmer. Furthermore, NAIS traces animals back to their farm of origin, not forward to the consumers. Thus, NAIS increases farmer liability risk and cost without providing consumer benefits or dealing with the main culprit of these new disease threats: factory farming.
http://www.nofamass.org/news/nais.php

7) OLD BIG BROTHER HAD A FARM
USDA ID-Tag Plan For Farm Animals Has Some Small-Scale Farmers Unhappy
By Amanda Griscom Little, Grist, 10 Mar 2006

The USDA's NAIS coordinator, Neil Hammerschmidt, said in a speech last month to the cattle-industry group R-Calf USA that USDA isn't sure whether it has the authority to impose a federally mandated program that requires producers to report to a private entity. In the meantime, states are moving on their own to put the animal-tracking system in place. USDA has allocated more than $60 million to help states implement the animal-ID program. Martha Noble of the Sustainable Agriculture Coalition acknowledges that some form of tracking system may be necessary for public-health reasons. "We are not opposed to a tracking program, per se," she says. "We understand the need for effective monitoring of animals and disease, but there's a lot of disagreement about how is it going to be implemented, who is in control, and how is it going to be paid for."
http://www.grist.org/news/muck/2006/03/10/griscom-little/

8) COMMENTS ON NAIS DRAFT PROGRAM STANDARDS AND STRATEGIC PLAN
By Mary Zanoni, Ph.D. (Cornell), J.D. (Yale) Feb 6, 2006,

Many aspects of the Standards and Plan appear to create insurmountable legal, fiscal, and logistical problems. Her comments address five categories of problems:
1. Constitutional infirmities of the proposed program;
2. An enormous economic cost to animal owners, the States, the Department, and, ultimately, to American taxpayers and consumers for a program likely to be ineffectual;
3. Weaknesses in the stated rationales for the program;
4. A lack of consideration of alternative, far cheaper and more easily administered measures which would more effectively protect animal health and food security; and
5. A lack of notice and an opportunity to be heard for medium-scale, small-scale, and home farmers, and for other citizens owning livestock solely for their own use or pleasure, in the Department's process thus far.
http://www.organicconsumers.org/ofgu/ID060202.cfm.