USDA Going for RFID Again…And Again…Ad Nauseum, Ad Infinitum

From my friend Darol:


Memo: THE USDA BEATS THIS DEAD MULE OVER AND OVER. They just won’t quit! All government programs are about expanding government and increasing tax-trampling of the citizens. This proposal has been soundly trounced by cattle producers every few years since the early 2000s. It is glossed-over and repackaged at NAIS, ADT, and new names of this old dastardly enforcement.

Unnecessary: The USA has the most cautious livestock producers, with less disease than any country on earth. No livestock producer is asking the government for help in identifying their own cattle. They already know how to ID their cattle. Not needed at all.

Cost: The added cost to large livestock producers is from $6 to $15 per animal. The cost to small producers for pins, applicators, computer entry, etc., will be $25 to $75 per calf. In an industry fighting for their lives, $15 more cost per critter is asinine. Multiply the uselessness considering all cattle are identified by their owners already — no extra cost is wanted or needed.

Follow The Money: Large ear pin/tag companies are “buying” USDA. If USDA makes electronic pins the law, billions will be made by the major companies. It is not about disease — not about identification — it is not that livestock owners want it — it is about the government jobs and ear tag companie’s profits.

Who Wants What: In every comment or listening process USDA and APHIS has conducted (every 2 years) the huge majority of livestock producers soundly reject the increased cost involved, with no value return. Livestock producers are getting so tired of USDA shoving this down our throats over and over…. tired…. tired…….tired.

Call to Action: One more time, tell USDA in their public comments, on line, that no cattle people want this. We don’t need this again, and again. DD

The Dastardly Banner of the Evil USDA

The U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) is seeking public comment on a proposal where APHIS would only approve Radio Frequency Identification (RFID) as the official eartag for use in interstate movement of cattle that are required to be identified by the traceability regulations.

An official eartag is defined as an identification tag approved by APHIS that bears an official identification number for individual animals. Regulations allow APHIS to approve tags that can be used as official identification, and both metal and RFID tags are current options.

A transition to RFID tags would support APHIS’ ongoing efforts to increase animal disease traceability by more accurately and rapidly allowing animal health officials to know where affected and at-risk animals are located. While this would not prevent disease outbreaks, it would allow animal health officials to more quickly contain outbreaks early before they can do substantial damage to the U.S. cattle industry.

APHIS is also seeking comment on a proposed timeline for implementation, which the agency would use if this transition occurs. The timeline would make RFID tags the only option for use in cattle and bison requiring official identification on January 1, 2023. APHIS would “grandfather in” animals that have metal tags already in place on that date – their metal tags would serve as official identification for the remainder of their lifespan.

This transition timeline would not alter the existing regulations. The cattle and bison that must be identified will not change, nor will the option for animal health officials in shipping and receiving states to agree to accept alternate forms of identification, including brands and tattoos, in lieu of official identification.

Public comments will be accepted through October 5, 2020 at the following site: After reviewing all comments, APHIS will publish a follow up Federal Register notice. This notice will respond to any such comments, announce our decision whether to only approve RFID tags as the only official identification devices for cattle, and, if so, provide the timeline for such a transition.


I tried to tell everyone….NAIS Never Went Away-it simply had a name change

The NIAA and the infamous Neil Hammerschmidt are at it again. Having an expensive meeting to figure out how to subject livestock growers to “enforcement” measures for RFID tagging of livestock. They are after the cattle, as they always have been.

Maybe they should remember the nooses on the livestock trailer with their agency name on them the last time they tried this in Colorado. If you are interested, here is the release from the fascist group, NIAA:

Exceptional Agenda Set for Strategy Forum on Livestock Traceability

The National Institute for Animal Agriculture (NIAA) announces an impressive agenda for the upcoming day and a half Strategy Forum on Livestock Traceability which they will co–host with the US Animal Health Association (USAHA) in Denver, CO in September.

The Strategy Forum will kick off with an introduction from Dr. Tony Forshey, Board Chair, National Institute for Animal Agriculture and Dr. Boyd Parr, United States Animal Health Association.

Mr. Matt Deppe, Executive Director, Iowa Cattlemen’s Association (Invited) is scheduled to moderate the Strategy Forum as first day continues with updates on the USDA Animal Disease Traceability (ADT) program and feedback on public meetings from USDA APHIS Veterinary Services Cattle Health Staff/Animal Disease Traceability Veterinarian Dr. Sunny Geiser–Novotny and Dr. Aaron Scott.

Mr. Neil Hammerschmidt, Animal Disease Traceability, Program Manager, will discuss “ADT Next Step Considerations.” After a networking lunch, a panel discussion with State Veterinarians from around the US, will examine “Enforcement Rules –Successes and Opportunities.” Dr. Nevil Speer and Dr. Justin Smith will moderate more panel discussions on “Implications for Livestock Markets ” and “Making Standards and Technology Work.”

Mr. Paul Laronde, Tag & Technology Manager, Canadian Cattle Identification Agency , will open the second day of the Strategy Forum with a review of the Canadian Traceability Forum. Mr. Randy Munger, Mobile Information & Animal Disease Traceability Veterinarian, USDA / APHIS / STAS will speak about “Using RFID to Advance Traceability.”

The final panel discussion will consider “Implications for Livestock Used for Rodeo, Fairs & Exhibitions.”

The Strategy Forum on Livestock Traceability will be held September 26 –27, 2017 at the DoubleTree by Hilton, Denver–Stapleton North, Denver, Colorado. View the entire AGENDA HERE. Register HERE.

NAIS Is NOT Dead. Never was.

From my good friend Darol Dickinson:

NAIS – ADT enforcements still stink. Dr. Michael W. Radebaugh, state veterinarian for Maryland has been and continues to be a strong promoter of NAIS and ADT. Although there is less large animal disease in the USA than any time in history, certain paranoid state vets continue to increase ADT and costly enforcements onto livestock producers. The new Maryland enforcements stated below are a continuation of the NAIS plan of 10 years ago where the USDA paid special grants to states and tribes to enforce fees and laws that would increase government jobs and encumber livestock commerce, shows and reduce general profitability to producers. It is still not about animal disease.The ADT and NAIS enforcements were soundly rejected by livestock producers under the reign of Ag Sec Thomas James Vilsack (2008 – 2017) to the extent, he announced all such efforts on a national level would be permanently discontinued. The listening sessions and comment periods revealed that over 90% of livestock producers opposed this intrusion of property and unnecessary production costs. DD

There is a new requirement for RFID tags for all cattle at all Maryland shows
Annapolis, MD- The Maryland Department of Agriculture, Animal Health Program has issued a policy that all cattle and swine shown at Maryland exhibitions must have an official USDA approved Radio Frequency Identification (RFID) ear tag for 2017 and beyond.
Who needs RFID tags for 2017? All exhibitors of cattle and swine in Maryland including both open class and 4H exhibitors.
How do I get official RFID Tags? After obtaining a Premise Identification Number (PIN), a list of available official USDA approved RFID tags manufacturers can be obtained from this USDA website:
How do I get a premise identification number (PIN)? You may request a Premises Identification Number (PIN) with our Premises Registration Form. Your premises identification number will arrive on a card in the mail 7-10 days after we receive the Premises Registration Form. Call 410-841-5810 with any questions.
How do exhibitors get official RFID ear tags? Two ways: 1. Veterinarians can tag animals when they perform the required health inspection prior to exhibition. 2. Exhibitors wishing to obtain their own premises tags may do so by obtaining a Premises Identification Number (PIN) and then purchasing RFID tags from an approved USDA distributer.
Can producers give out their own tags to other producers? No… Because of animal disease traceability purposes, any official USDA RFID ear tags assigned to a specific PIN cannot be given to other producers. Producers are responsible to insert in their cattle and swine only the RFID ear tags designated for their PIN alone and no other.
Who should tag exhibition livestock? It is best that livestock be tagged at the farm of origin. Having an official RFID tag in place before exhibition is the exhibitor’s responsibility. A veterinarian may apply official tags to cattle and swine while performing a health inspection or the exhibitor may purchase official RFID tags and apply them. Be sure to keep records of tags applied.
What if an animal already has an official tag but not a RFID official tag? It is unlawful to remove an official identification tag. If an animal does not have an RFID ear tag, the animal can be “double” tagged with a RFID ear tag. This is an allowable upgrade.
What if tags fall out or get lost? If it becomes necessary to retag an animal with a new official RFID ear tag (assigned to that premise), every effort should be made to correlate the new official RFID number with the previous official number. A record of this change should be kept on file by the exhibitor. Also, the official RFID ear tag number must correlate to the official identification listed on the Certificate of Veterinary Inspection (CVI) as recorded by a veterinarian.
Will animals without RFID tags be rejected? The 2017 Maryland Fairs and Shows Policy require RFID ear tags for cattle and swine at Maryland exhibitions. 2017 will be a transitional year. Leniency may be afforded at the discretion of each of the exhibition. It is strongly recommended to avoid any inconvenience by having proper ID and paperwork. No exceptions will be made beyond the 2017 season.
From the UMD Extension service.

Bacon Prices Rising….

As I have been saying, food prices are going to skyrocket. We don’t even eat pork here, but this is going to affect a lot of households, and it isn’t factored into the inflation index. Please, please, please get all the food you can and store it properly and well and plant whatever you can as a hedge against food chaos. No more living “high on the hog” for many.

You might recall that “traceability” is supposed to stop this kind of thing from happening. As those of us who opposed NAIS and ADTF have said, no tracking, tracing, RFID tag or premises number will halt disease! Commercial hogs are pretty close to 100% traceable…Sometimes it sucks being right.

US bacon prices rise after virus kills baby pigs



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Scientists think porcine epidemic diarrhea, which does not infect humans or other animals, came from China, but they don’t know how it got into the country or spread to 27 states since last May. The federal government is looking into how such viruses might spread, while the pork industry, wary of future outbreaks, has committed $1.7 million to research the disease.

The U.S. is both a top producer and exporter of pork, but production could decline about 7 percent this year compared to last — the biggest drop in more than 30 years, according to a recent report from Rabobank, which focuses on the food, beverage and agribusiness industries.

Already, prices have shot up: A pound of bacon averaged $5.46 in February, 13 percent more than a year ago, according to the U.S. Bureau of Labor Statistics. Ham and chops have gone up too, although not as much.

Farmer and longtime veterinarian Craig Rowles did all he could to prevent PED from spreading to his farm in Iowa, the nation’s top pork producer and the state hardest hit by the disease. He trained workers to spot symptoms, had them shower and change clothing before entering barns and limited deliveries and visitors.

Despite his best efforts, the deadly diarrhea attacked in November, killing 13,000 animals in a matter of weeks, most of them less than 2 weeks old. The farm produces about 150,000 pigs each year.

Estimates of how many pigs have died in the past year vary, ranging from at least 2.7 million to more than 6 million. The U.S. Department of Agriculture says the die-off has had a hand in shrinking the nation’s pig herd by 3 percent to about 63 million pigs.

Diarrhea affects pigs like people: Symptoms that are uncomfortable in adults become life-threatening in newborns that dehydrate quickly. The best chance at saving young pigs is to wean them and then pump them with clear fluids that hydrate them without taxing their intestines. But nothing could be done for the youngest ones except euthanasia.

“It’s very difficult for the people who are working the barns at that point,” Rowles said. “… No one wants to go to work today and think about making the decision of baby pigs that need to be humanely euthanized because they can’t get up anymore. Those are very hard days.”

PED thrives in cold weather, so the death toll in the U.S. has soared since December.

The first reports came from the Midwest, and the states most affected are those with the largest share of the nation’s pigs: Iowa, Minnesota, North Carolina and Illinois. The disease also has spread to Canada and Mexico.

Some states now require a veterinarian to certify that pigs coming in are virus-free, while China, which has seen repeated outbreaks since the 1980s, has asked the U.S. Department of Agriculture to similarly vouch for animals shipped overseas.

Companies are racing to develop a vaccine, but the federal government has yet to approve one. While the mass deaths have been a blow for farmers, the financial impact to them may be limited because pork prices are rising to make up for the loss of animals.

It takes about six months for a hog to reach market weight so the supply will be short for a while. Smithfield Foods, one of the nation’s largest pork processors, has cut some plant shifts to four days per week in North Carolina, and those in the Midwest are likely to do so later this spring, said Steve Meyer, an Iowa-based economist and pork industry consultant.

Smithfield Foods declined to comment.

In the end, consumers will be most affected, Meyer said, with pork prices likely to be 10 percent higher overall this summer than a year ago.

“We’re all used to: ‘We’ve got plenty of food, it’s cheap. We’ll eat what we want to,'” Meyer said. “We Americans are very spoiled by that, but this is one of those times that we’re going to find out that when one of these things hits, it costs us a lot of money.”


NAIS Operates Under Aliases

Former state vet touts traceability system

Retired Washington State Department of Agriculture Veterinarian Leonard Eldridge says some gaps in credible, accurate information still need to be filled to develop animal traceability. The department is building its new Animal Tracks searchable database. Eldridge stressed the need for the system to be electronic, which would be easily and quickly searchable. SPOKANE — The Washington Department of Agriculture is developing an animal traceability system to easily search cattle records in the event of a disease outbreak.

Retired state veterinarian Leonard Eldridge stressed the need to fill information gaps during the Spokane Ag Expo and Pacific Northwest Farm Forum.

He sees high risks in feeder and slaughter cattle practices outside the state and cattle trading from one producer to another without notifying the department or third-party verification.

Eldridge said the state realized it needed a better traceability system after bovine spongiform encephalitis was discovered in a cow in December 2003. That cow was found to have been exposed in Canada, he said, but his department could not find all cows that ate the same feed there.

“There are exemptions for female dairy cattle to be traded in the state without telling the Department of Agriculture, and I think that was a big issue,” Eldridge said. “It’s still a gap today we need to fix. We need to go to the whole industry and say, ‘Tell us how to do this.’”

WSDA animal disease traceability program manager David Hecimovich said Washington agriculture director Bud Hover is removing the exemption. The department will announce the rule change in February or March, which could be official by mid-summer, Hecimovich said.

The department has established three animal health investigators.

Eldridge estimates establishing the state’s new “Animal Tracks” program costs $440,000 each year for two years. State legislators approved $881,000 for the department to begin building the system last year.

The traceability system would include information on documents showing animal movement, change of ownership, brand information and disease and test records.

“You could search for any one of these pieces and the rest of the information comes up,” Eldridge said. “That’s what we said we needed.”

The department provides monthly updates on the status of implementing the system.

The future cost of maintaining the program is uncertain. Eldridge stressed the need for communication with the entire industry about the best methods to protect the industry and keep costs low. Committee feedback called for a stable source of funding each year, with costs shared by taxpayers and all aspects of the industry, he said.

Eldridge believes the system needs to be electronic. Paper records are time-consuming and difficult to search through quickly, he said. One-time data entry is faster, eliminates a lot of work and reduce the possibility of error.

State departments are likely to lead the development of electronic databases, Eldridge said, and USDA will likely eventually follow suit.


ADT-NAIS….Alive and Well Masquerading As Different Programs

From Darol Dickinson of Ohio….just as received:

EYE WITNESS REPORT  October 29, Sugar Creek, Ohio
 ANIMAL DISEASE TRACEABILITY final USDA rules for livestock moving interstate.

The Ohio State Veterinarian, Tony M. Forshey, officiated an ADT rule — cattle requirements overview meeting with producers on Oct 29.  This was one of about a dozen in Ohio and similar to a few hundred held in most states.

My appreciation of Dr. Forshey was increased as I watched him carefully articulate the maze of complicated and difficult federal rules for state veterinarians and animal producers.  The tight rope he had to walk being forced to enforce federal rules and yet having “state rights” to tweak certain parts of the rule making process — his assistant called it “ability to relax” federal ADT rules.

If the Affordable Care Act is confusing, the facial expressions of Ohio farmers attending told the story. One major veal producer, RC Farms, said “I am not going to do it!” No reply was offered by Dr. Forshey as to the enforcements, fines or penalties for future non-compliance. (I sensed he did not want to go there in this crowd.)

New ADT changes and procedures defined include:

~ There are federal rules of ADT that are enforced federally and there are ways a state veterinarian can increase enforcements or “relax” these rules. Although the feds have a solid rule process, states can and may or may not relax or add to these rules. The state veterinarian has that authority.
~ The federal written rule leaves a clever option –“Other movements as approved.” Of which the layman will find out what these “other movements” are in years to come.
~ More clamp-down enforcements affect cattle than all other animal species.
~ The new acronym for vet certificate or health certificate is ICVI, Interstate Certificate of Veterinary Inspection.  No other term will be used in the future.
~ At first blush approved animal ID methods seem broader than ever before which includes official back tags, NUES (free silver ear clips), USDA shield yellow plastic AIN, 840 pens, tattoos, brand inspections, normal ICVI, breed registration certificates and the new OSS (Owner-Shipper Statement federal form) which, believe it or not allows the owner-shipper to fill out the basic info of a ICVI, except does not require any health evaluation by a veterinarian. (attached)
~ The approval of a breed registration certificate is new. Most breed association certificates contain more information than the ICVI or any other USDA method of ID. The Texas Longhorn registration  certificate (attached) requires a color photo, OCV on females, a permanent hot iron herd holding brand and individual ID number brand, which is far more documentation than any USDA requirement.
~ A federal category called “commuter herds” is created to accommodate transient herds that cross tribes or herds in joining or different states.
~ New ADT rules recommend to USDA tag day old calves in the USA the same as required in Europe.
~ All auction facilities will be politically forced to become a USDA approved official “tag site.”
~ The 840 pen is required to attach to a premises ID site number.
~ The NUES clip does not require a premises ID.

With careful reading, the above do not include all the intricate demands of the new ADT. The same master minds of NAIS (most hated USDA program in history) are still Neil Hammerschmidt and John Wiemers controlling and expanding federal rule books.

To add layers of confusion to ADT consider Obama’s “57 states” all have state veterinarians who can apply their own personal “tweaking” to add and remove rules. Take the dozens of different federal flavors of rules, add the state veterinarian’s tweak factors, the tribes and the commuter compromise rules and you have a recipe to equal or excel the enforcement confusion of Obamacare.

The NAIS was about identification — that didn’t sell.  The new ADT includes the word disease, which all animal owners have a healthy respect for — disease prevention is important. However, with the new OSS federal form it takes the veterinarian out of the picture who was licensed to do a “health inspection.” Now, disease has proven to not be the central issue.

Australia was 6 years ahead of the USA with their National Livestock Identification Scheme (NLIS), which has become the night mare of all night mares for ranchers there. They are recording a 32% lost tag record.

Many thought NAIS and ADT was totally about adding government jobs, because all rules, regulations, paper piles, and enforcements cause the feds to hire more staff. They require more veterinarian inspections and fees — then when it appeared to make sense, here comes the OSS form that eliminated the veterinarian’s job.

Have no fear of simplicity or minimal paper/computer work. On the APHIS factsheet it says, “Additional traceability requirements for this group (cattle & bison) will be addressed in separate rulemaking in the future, allowing more time for APHIS to work closely with industry to ensure the requirements are effective and can be implemented.”

Hammerschmidt and Wiemers still have a paying job ever creating “additional requirements.”  Is there just a chance of, perhaps — “less requirements” in the future, to allow the American cattle producer to spend more time just simply making a living?

Caption DZ 0660: Tony M. Forshey, DVM, Ohio State Veterinarian, labors to explain the federal ADT rules as two of his support associates assist with the power point presentation.  Sugar Creek, Ohio Livestock Auction Barn, Oct 29, 2013.

Caption DZ 0663: Listeners at the ADT power point presentation, Sugar Creek Auction Arena, Sugar Creek, Ohio. RC Farms owner, Roy Yoder, Apple Creek, Ohio, on the left. Veterinarians, state staff and ranchers were in attendance.

Darol Dickinson, Eye Witness

What We Have to Look Forward to with ADT, formerly NAIS

Recently the requirements for initial tagging under APHIS’ final rule on Animal ID began to be implemented in Missouri. It caused a kerfuffle at many auction barns throughout the State as the owners weren’t prepared for the requirement. Australia is further along than we are in following the edicts of free trade under the WTO regulator’s guidelines. They have a program called NLIS. Here is an update from down under:


Penny Finally Drops For NSW FMRS ASSOC with RFID NLIS.

ABA Chair Brad Bellinger said that a sense of relief was felt through the NSW Sheep Industry when they read NSW Farmers Assoc Fiona Simpson announce that they will not be supporting sheep RFID.
New leadership within the organisation has obviously led to better policy setting where the financial welfare of their members is now at the forefront instead of Government as it had in the past.
While NSW FMRS correctly points to the enormous financial cost to producers as their reason for not backing the scheme,the fact is that it does not provide adequate trace back.
A trial commissioned by the ABA on the efficacy of RFID NLIS Cattle conducted over 14 property identification codes in all mainland states involving the movements of over 50 000 head of cattle showed 34% had lost their whole of life traceability.
A year by year description on the data showed that the accuracy level continued to drop as time progressed.These findings are consistent with the Price Waterhouse Coopers report commissioned by the Federal Government ,that admitted that the number of cattle that had lost Whole Of Life Traceability was considerable and that the problem would snowball over time.
With now over 130 million tags on the cattle database the direct costs to producers in tags and reading charges alone is close to 3/4 of a billion dollars,we have definitely been sold a very expensive lemon.
Mr Bellinger would remind the NSW Farmers Assoc that their support of Cattle RFID was conditional.Stipulating that the system must work.The ABA has all the evidence to prove that it doesn’t.
We congratulate NSW FMRS on their sheep RFID policy but we ask for the penny to drop and abandon their support for Cattle RFID.

For more information contact Brad Bellinger on: 02 67254282
Or David Byard on: 0409 426 710.

First They Came for the Cows—On Kindle!

My good friend Sharon Zecchinelli wrote this book as part of National Novel Writing Month, NanoWriMo, which I did once, and still haven’t finished the novel I began! Anyway, the release of this Kindle version of “First They Came for the Cows” contains an epilogue written by yours truly.

On Kindle with Epilogue by Doreen Hannes

There is some serious serendipity here. Unbeknownst to either Sharon or me, the USDA is releasing their final “general” rule on the ADT, which is NAIS by a different name, on the same day this Kindle release becomes available! Very interesting, no?

To be sure, there was no collusion between the USDA and Sharon Zecchinelli….I just don’t ascribe to “coincidence” as a general rule. Seems like more of a divine paradox to me.

At any rate, you can look forward to my dissection of the rule in the very near future, and in the interim, get your NAIS not NAIS refresher course by reading “First They Came for the Cows” on Kindle!


Name Games with the USDA (again)

©Doreen Hannes

On May 11th, the USDA held the first of three public meetings on their “New NAIS” program “Animal Disease Traceability”. The meeting began at 8am with three power point presentations. California State Veterinarian, Dr. Richard Breitmeyer gave the first presentation. This was the same presentation he gave at the mid-March NIAA (National Institute of Animal Agriculture) meeting, also held in Kansas City.

A little history is in order to understand the progression of this idea for animal traceability. In the US, the first notable plan for identifying animals was the NFAIP, along with FAIR, those being the National Farm Animal Identification Program and Farm Animal Identification and Records. Then under the Bush Administration there was the United States Animal Identification Plan, with the NAIS, National Animal Identification System hot on it’s heels. Now, they have “killed” NAIS, but are moving forward with the Animal Disease Traceability plan, the ADT. The main difference here is that the USDA is going to make a rule on the ADT to prescribe the “performance standards” for traceability that the states MUST meet to engage in interstate commerce with the ADT.

Breitmeyer’s presentation focused on the difficulties around tracing the contacts of tubercular (and suspect) cattle in the state of California and other states without the aid of an interoperable database covering all animals and all movements. According to his presentation, the state of California has approximately 57,500 known live cattle imports from Mexico per year. This is significant in that more than 75% of all tuberculosis in cattle is of Mexican origin. Breitmeyer lamented that when he began as a vet 25 years ago, the US had nearly eliminated TB except for in small areas of northern Michigan and northern Minnesota where the soil make up continues to keep TB in the wildlife and therefore occasionally in cattle. Breitmeyer’s presentation was actually quite a good illustration of many of the failed policies of the USDA in disease control, the lack of quarantine at the borders chief among them. Of course, he is a proponent of a NAIS style system because having all that data available would make his job easier…At least on paper.

The second presentation was given by a very soft-spoken APHIS/VS (Veternary Services) representative, Dr. TJ Mayer. He stressed that the “theme” for the development of the “new” program is “collaboration”. Those to be affected must be involved in the process of developing the solution for the lack of traceability that now exists— particularly in cattle. Cattle are the primary focus for this new plan, and the methodology for bringing cattle to 95% traceability back to the point of identification in 2 business days is dependent on “collaboration” in developing the processes in our states. (Sounds familiar, doesn’t it?) Mayer also illustrated that the desired traceability would be implemented gradually through partnerships of stakeholders and building upon the requirements outlined in the rule that is to be developed for criteria that states must meet for interstate commerce.

The third presentation was by Becky Brewer (Oklahoma State Vet) and the apparent lead member of the newly established “Regulatory Working Group”. Dr. Brewer related the thinking of the Regulatory Working Group on the measurable outcomes of the ‘traceability’ standards to arrive at 95% of “all” animals traced back to the ‘traceability unit’ within 2 business days. Sounds just like the NAIS Business Plan, doesn’t it? Brewer stated, “In government speak, “all” doesn’t mean all.” This may explain why the USDA kept insisting that when opponents of NAIS cited documents verbatim, we were “spreading misinformation”. Evidently the English language is a linguistic and statistical anomaly in the hands and mouths of bureaucrats.

There were no question and answer sessions after the presentations. Instead every table was given a USDA facilitator and three segments of questions to answer regarding how we might achieve the desired outcome of getting animals id’d back to the ‘traceability unit’ within their timeframes. The tables were marked with species placards and there were at least five cattle tables, three swine, two poultry, one sheep and goat, and one “other species”.

When I entered the room I noticed that Kenny Fox of R CALF USA was at a cattle table and I failed to notice the “other species” table so I sat at the sheep and goat table. There were no people at the poultry tables. The cattle tables were quite full, and all of the reporters were sitting at the ‘other species’ table, so I thought I would just sit at the empty sheep and goat table.

When the facilitating began, I was blessed with three USDA representatives at my table, where all the other tables only had one. I shared the table with one sheep broker from New Mexico. He deals in 20 to 30,000 head of sheep annually mostly exported to Mexico and was quite content with the Scrapie program. This program identifies breeding animals back to the flock of origin with a number assigned to the flock manager and not the land the animals are held on. It also allows for tattoos as an alternate form of official id for interstate commerce, and does not use RFID tags, although it could in the future.

The USDA representatives at my table were not particularly interested in hearing about how the failed agricultural policies have created a problem that the USDA would now like all of us to ‘partner’ with them to solve. They did take copious notes, and were quite proficient in ‘mirroring’ my statements while slightly adjusting them to fit their desired outcome more handily.

At the end of each of the three segments, a representative from each table stood and gave the ‘report’ from the table on that segment. The consensus of the cattle groups were that only breeders should be identified, RFID tags should be avoided, back tags should continue to be used for feeders and slaughter cows, and a NAIS styled system would not work at all.

The USDA is currently promoting the use of ‘bright’ tags for cattle. These are very similar to brucellosis tags in numbering and appearance. However, when the only question and answer segment of the day took place and Neil Hammerschmidt (one of the main authors of NAIS) gave most of the answers, he made it clear that the USDA still wants to ‘aggressively’ pursue the use of 840 tags.

The bottom line about the entire meeting is that the USDA will try to have a draft rule ready in June from the “Regulatory Working Group”. This rule will define the “performance standards” that are to be met by the states to engage in interstate commerce. The USDA plans to publish this proposed rule in November or December of 2010, allow a 90-day comment period, and finalize the rule (make it law) from 8-10 months after the comment period is complete. There may be different requirements under these performance standards by species, and some potentially exempted sectors or movements. There is admitted concern from the USDA and their friends that incentives and disincentives for states must be expressed clearly and not be too “heavy handed”. In other words, if a state meets compliance levels in hogs and not cattle, the hogs should not be refused access to interstate commerce.

It appears to me that we must proactively engage our state legislators to statutorily define requirements for interstate livestock movement and not allow the Departments of Agriculture the leeway to cooperate with the USDA to achieve the goals of the USDA as those goals are still NAIS oriented. The USDA will not dismantle the National Premises Repository although Hammerschmidt stated that if a state were to want to withdraw all of their participants, they could do so. Also, according to Hammerschmidt, they still want to move ‘aggressively’ to 840 tags as official identification along with electronic Certificates of Veterinary Inspection.

The onus of implementing the graduated Animal Disease Traceability program rests squarely on the individual states. Either the states will define those standards statutorily or the USDA will bring about their final desires incrementally through the regulatory process.==========