WESTON A. PRICE FOUNDATION
June 9, 2006
On June, 2006, the USDA released a new guidance for small-scale and non-commercial farmers and ranchers (http://animalid.aphis.usda.gov/nais/downloads/print/Guide_Smal_NonCommercial_6_2_06.pdf).
For the first time, the USDA officially states that the focus of the National Animal Identification System (NAIS) is animal health, primarily within the commercial animal production sector in which animals move from their birthplace to a subsequent location(s) over the animal’s life cycle. USDA claims that its NAIS efforts will therefore largely focus on commercial operations and animals at such locations because of their higher risk of spreading diseases among multiple locations and for greater distances, not small-scale farmers and non-commercial producers. But this provides limited reassurance because the USDA’s definition of “non commercial” is incredibly narrow, as discussed below.
The NAIS participation guidelines for small, non-commercial producers is based on how you manage (move, market, etc.) animals and the associated risk of disease exposure and spread. Again, the NAIS covers only cattle and bison, cervids (e.g., deer and elk); goats; horses; camelids (e.g., llamas and alpacas); poultry; sheep; and hogs.
Definition of Non-Commercial Producer for NAIS:
- Individuals whose animals are not moved to auction barns or from their location to those of commercial producers; and/or
- Individuals whose animal movements are limited to those moved directly to custom slaughter; movement within a single producer’s premises; local fairs and local 4-H events.
Although the USDA includes this description of non-commercial producers as being people who do not take their animals to auction barns, they do not create an actual exemption for anything other than born on property and never leaves the property except for slaughter. Even if everything they say in this document is true, people who buy a calf from their neighbors or a few baby chicks from the local feed store would have to identify and track them.
Guidance for Non-Commercial Producers Premises Registration: USDA encourages, but does not require, all livestock and poultry owners to register their premises with the animal health authority in their State, regardless of the size of their operations or the number of animals present at the facility. Voluntary registration of premises does not obligate producers to identify their animals or to report the premises-to-premises movement of their animals.
The USDA’s repeated admonition in this document that premises registration is voluntary is not consistent with its other documents nor with what is actually happening. The USDA’s prior documents – which it has not disclaimed – state that it expects 100% participation by January 2009, or it will consider regulations. In other words, USDA’s program is only voluntary temporarily. And, even now, USDA is providing grants to several states to implement NAIS. Some states, such as Wisconsin and Indiana, are already mandating premises registrations., while others have proposed doing so. USDA’s avoidance of “mandatory” regulations does not mean that NAIS is voluntary as that word is commonly understood.
Animal Identification and Reporting Animal Movements:
Scenarios that would not call for animals to be identified and/or movements reported in the NAIS include:
- animals that never leave the farm/location of birth;
- animals moved from their birth premises directly to custom slaughter for personal use of the animal’s owner;
- livestock moved from pasture-to-pasture within one’s operation;
- participation in local fairs and parade,
- the local trading of birds among private individuals; and
- animals that “get out” and cross over into the neighbor’s land.
Animals used for recreational purposes do not need to be identified if they are permanently cared for at their birth premises. Taking your animal on a trail ride with a neighbor would not be a reportable movement.
Also, household pets (e.g., parakeets, cats and dogs) are not reportable to the NAIS.
These “scenarios” are an interesting mix. Moving animals from pasture-to-pasture on one’s own property was clearly not a reportable event under the Draft Plan, since it did not involve leaving the “premises.” The same logic applies to animals that never leave the premises on which they were born. But what do these two scenarios really mean? How many people have animals that are born on their property, never leave their property, and die on their property? Even the exclusion for custom slaughter is, in practice, almost meaningless. How many people have their own breeding herds or flocks, but raise animals only for their own personal consumption? Almost anyone who has enough land and resources to support breeding animals also sells at least some of their offspring for one reason or another.
The USDA even contradicts itself in its attempts to discuss these reassuring scenarios. In this document, USDA states, “Reportable movements are those that involve a high risk of spreading disease, such as moving livestock from a farm to an event where a large numbers of animals are brought together from many sources.” Anyone who has ever been to a local fair or parade knows that they fall within this description. And the USDA’s current Q&A on their website includes the following:
“Q. If a Person Only Shows Animals or Only Takes Them to Trail Rides, Do They Need to be Identified?
A. When people show or commingle their animals with animals from multiple premises, the possibility of spreading disease becomes a factor. Those animals will need to be identified.”
So participation in local fairs and parades will have to be reported.
Will NAIS require that all livestock animals be microchipped? USDA’s official answer is “No.” The notion that USDA will require all animals – ranging from livestock to chicks – to have microchips is false, according to this document. With regard to the question of how an animal could be identified (i.e., ear tag, tattoo, microchip, leg-banding), USDA declares its neutrality. The USDA claims that such questions should not be answered for producers; instead, such questions would best be resolved by producers themselves.
While it is accurate that USDA has not proposed microchipping birds, USDA’s claim to neutrality is nonsense. They have already included, in the Draft Program Standards, that RFIDs are the preferred/default ID for cattle. The Michigan Department of Agriculture, using funding from USDA, has just announced that all cattle will have to have RFID tags by March 2007 – no other form of ID will be acceptable in the TB zones. And the Equine Species Working Group has also specified RFID chips. NAIS is not technology neutral.
Will NAIS require that all animals to be tagged individually? No. USDA states that tagging each and every animal individually would be unrealistic and impractical. Group/lot ID is an option for both large- and small-scale producers, depending on the circumstances, such as animals that move as a group through the production chain (e.g., groups of pigs or chickens). If a producer chooses to participate in the animal identification system for a group of animals and utilizes the group/lot identification method and later removes an animal from the group, that animal should then be identified individually. However, this would be the case with animals from any size farming operation, large or small.
In this section, USDA has again made a technically correct statement that does not tell the whole story. The definition of group ID makes it useful only for confinement operations. USDA’s Draft Program standards stated that group identification can only be used where groups of animals are managed together from birth to death and not commingled with other animals”. Few small farms manage their animals in completely isolated, single-age groups.
What about individuals’ religious freedoms? The USDA claims to be sensitive to individuals’ religious beliefs. We are respectful of these beliefs and are committed to ensuring that workable options are available to religious communities.
Send Your Comments Regarding USDA’s NAIS Program. Comprehensive recommendations for identifying animals and reporting movements are in development in cooperation with the species-specific working groups and State-Federal animal health authorities. We encourage you to make suggestions about NAIS by contacting the working group(s) for the species of animal(s) you raise. The working group information is on the left side of the NAIS Web page (http://animalid.aphis.usda.gov/nais/index.shtml); under “Browse by Audience” click the “Select a Working Group” dropdown button. Stakeholders can also submit comments to a particular working group via e-mail at animalidcomments (at) aphis.usda.gov. Please include the species name and the term “working group” in the subject line of your e-mail.
Although USDA is trying to direct comments to the working groups, it is important that you also let your elected representatives know what you think about NAIS. We encourage you to copy your representative and senators on all correspondence that you send to the agency and working groups. To find the names, mailing address, e-mail address or fax of your Senators and Representative, please link to http://www.contactingthecongress.org/