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.==========