Twelve years ago, American farmers started to hear about a federal program called the National Animal Identification System (NAIS). The U.S. Department of Agriculture (USDA) documents called for every person who owned even one livestock or poultry animal to register his or her property, individually identify each animal (in most cases with electronic ID like microchips or radio-frequency identification [RFID] tags), and report their movements to a database. At first, many people didn’t pay much attention, some because the program was labeled as “voluntary at the federal level” and others because it seemed too absurd to be taken seriously.
And then we took a closer look. The paper trail revealed a decade of planning by agribusiness groups. They had developed the plan for an international system of tracking animals in order to grease the wheels for exports and imports. The goal was to throw open the border so that when there was a disease outbreak in a country they could claim that they could safely continue exports because they could supposedly guarantee that the exported animals or meat had not had any contact with sick animals. The huge market for RFID tags and database management meant that technology companies eagerly joined the push for this massive program.
The agribusiness interests that had developed the program had included provisions for group ID for animals that were owned by the same entity, and not commingled with others, from birth to death. The way it was written, the vertically integrated meat packers—companies like Tyson and Cargill who control every stage of production in poultry and swine operations —would face minimal costs. And the vast differences between the costs of individual ID for independent producers and group ID for such operations would inevitably drive many small farmers and independent ranchers out of business, leading to the consolidation of the beef industry and the loss of the burgeoning sustainable livestock movement.
For consumers in general, this would have meant a significant loss of options. For WAPF consumers, who emphasize nutrient-dense animal foods, it would have been a disaster.
When small farmers and their consumer allies became aware of this plan in 2006, we were already far behind the curve. Despite claims that the program would be “voluntary at the federal level,” USDA’s documents laid out the method for making the program mandatory on every livestock owner in the country by January 2009, and the momentum was all on the side of agribusiness.
But as activists spread the word, USDA faced a firestorm of protests from organic farmers, independent ranchers, horse owners, property rights advocates and others. Thanks to the organized grassroots outcry, then-Secretary Vilsack withdrew the plans for NAIS in 2010. At the same time, he announced plans for a replacement program, to be called the Animal Disease Traceability (ADT) program. We spent the next two years fighting to ensure that USDA kept its commitment to make ADT a reasonable, cost-effective plan.
In 2012, USDA issued the ADT rule. It covered inter-state movements only, requiring that cattle and poultry that crossed state lines be identified. Traditional, low-tech forms of ID were expressly allowed, and several exemptions that we had fought for were included.
Among other things, the final ADT rule dropped the proposed requirements for “feeder cattle”—beef cattle younger than eighteen months of age. The USDA explicitly stated that it would revisit the issue of feeder cattle in the future, allowing a focused discussion on the specific problems posed by identifying younger animals in a separate discussion.
So when USDA posted a notice for a series of meetings to discuss ADT this spring, it was not a major surprise—we had known that sooner or later there would be a discussion about feeder cattle.
Then, a week before the first meeting, USDA posted the supporting documents. The meeting handout hinted that the underlying agenda is to begin pushing intra-state requirements and electronic forms of identification again—in other words, a NAIS-type system. See aphis.usda.gov/aphis/ourfocus/animalhealth/traceability/adt-meeting-information (see pages 9 and 10 of the handout).
Reports coming from the first meeting in Oklahoma City confirmed these fears. Reading the attendees’ accounts was like a flashback to the NAIS debates—all the same arguments about the export market, agency failures in tracing animals, and scare tactics about disease (but with no explanation as to how electronic ID solves disease problems). And, yet again, the proponents of animal ID dismissed the concerns of small-scale producers, going so far as to say that if they couldn’t comply with such a system, they should get out of the business.
WAPF and other groups have quickly gone to work to oppose this attempt to revive NAIS. Even USDA officials acknowledge that the feedback it has received so far at the meetings has been strongly against any expansion of the ADT program.
Why are we so concerned? The idea of a comprehensive animal ID program may sound good. But consider the following:
• It’s too expensive. The profit margins for most livestock producers are tiny. A NAIS-type program means not only buying RFID tags (which are more expensive than the traditional metal or plastic ones), but having the infrastructure to place the tags properly, read them and manage the data.
• The program doesn’t address animal disease. Traceability is part of the program to control and limit the spread of disease—but it does nothing that actually addresses disease. The real focus needs to be on prevention. If the government and industry spent even a fraction of the time that they have spent on NAIS addressing overcrowding in feedlots, poor nutrition and the overuse of drugs, and preventing imports from countries with outbreaks, we would have far healthier animals and less risk of disease in this country. But those things cost the industry money and limit their international markets, so they’d rather focus on tagging and tracking animals.
• It’s about money. The real reason the industry players want electronic ID and tracking is to boost their own profits. The first time around, it was about exports to South Korea and Japan—because with a 100 percent traceability program exporters have greater leverage to claim that countries must open their borders to our products. This time, they’re talking about exporting to China. Not to mention the profits to be had from selling tens of millions of electronic tags, or from managing the massive databases that would be part of the system. Multiple companies and trade organizations stand to make a lot of money from the program—at the expense of the vast majority of farmers and ranchers.
We don’t need every animal to have an electronic tag in its ear and its information entered in a database. What we need are programs that support independent producers, a vibrant competitive market and healthy animal management to prevent disease. Unfortunately, it appears that we will have to fight this battle all over again. Fortunately, this time we have been tracking this issue vigilantly and are on top of it from the beginning.
In addition to the public meetings, USDA is accepting written comments. You can submit them online at
https://www.regulations.gov/comment?D=APHIS-2017-0016-0001 until July 31 at midnight.
SAMPLE COMMENT FOR CONSUMERS: Extensive new animal ID requirements could have significant impacts on our agricultural and food system.
I buy my food from small farmers who would be particularly hard-hit by the cost and burdens associated with electronic ID. I do not want to see the farmers who provide food for my family and me burdened by requirements for the benefit of those who are exporting to other countries. A local food system is vital to our health, economy and food security, and I urge USDA to prioritize the needs of small farmers.
SAMPLE COMMENT FOR PRODUCERS: Any action by USDA should be limited to the question of whether young cattle should be required to be identified when crossing state lines. That is the issue that USDA committed to reviewing when it adopted ADT just a few years ago.
(Add any comments or experience you have with animal ID requirements. Have you shipped cattle or poultry across state lines? Have you been involved with a traceback? What would be the impact on you if young cattle [under 18 months] had to have individual identification? What would be the impact if electronic ID were required? If you live in Michigan, which already requires electronic ID, what have been the impacts?)
UPDATE ON THE NEW ADMINISTRATION
President Trump’s nominee to lead the FDA, Scott Gottlieb, was confirmed by the Senate in May. While Dr. Gottlieb was a clinical assistant professor at New York University School of Medicine and has several years of prior experience at FDA, his main work has been with pharmaceutical companies and in the venture capital world. He is a venture partner at New Enterprise Associates, a director at Tolero Pharmaceuticals, and a member of GlaxoSmithKline’s product investment board. Gottlieb’s financial disclosure letter during the nominations process disclosed financial relationships with over twenty-five entities, many of them giants in the biotech and pharmaceutical industries.
As predicted based on the Presidents’ list of likely candidates to lead the FDA, Gottlieb is a supporter of measures to allow companies to bring drugs to market much faster. This might open the door for more innovative alternative therapies—but only if the costs of FDA approval are drastically reduced in the process.
On the food side, we know very little about Gottlieb’s views, just what came out during the confirmation process. In response to questions from the Senate committee, Gottlieb stated: “The Food Safety Modernization Act (FSMA) provides FDA with important tools and authorities to support its responsibility to ensure the safety of our nation’s food supply. If confirmed, I will work to ensure the agency has the appropriate policies, processes, and resources in place to implement FSMA, as intended by Congress. FDA should implement FSMA in a way that protects and promotes public health by enhancing food safety, while also collaborating with the U.S. Department of Agriculture, state officials, and other government agencies to conduct regulatory activities in a manner that takes into account the unique challenges faced by small farmers and small businesses.”
One of the Big Food industry’s top priorities is to delay until 2021 new nutrition labeling requirements that were due to take effect this year. The excuse is that the USDA will be requiring GMO labeling in 2021 (although it will likely be of little use to consumers, since the DARK Act included so many loopholes). Big Food claims that changing labels twice in four years would be too confusing for consumers. Gottlieb has indicated that he is open to the idea, and the agency already temporarily delayed the rules during his confirmation process.
This article appeared in Wise Traditions in Food, Farming and the Healing Arts, the quarterly magazine of the Weston A. Price Foundation, Summer 2017.