Friday, September 01, 2006

National Animal Identification System - Is there anything to Moo about yet?

RFID Law Journal
Newsletter No. 2
September 1, 2006

The USDA is in the midst of launching its National Animal Identification System (“NAIS”), which consists of three components – (1) premises identification, (2) animal identification and (3) animal tracking. NAIS is not at the mandate stage, and it does not dictate the technology choices enabling compliance. Early pilots support the view that RFID will play some role, especially with tracking cattle, because one of RFID’s primary advantages is that its tags offer the opportunity to automate the process of assigning individual animal identification numbers.

The NAIS initiative is a national program sponsored with industry and state cooperation. Its primary purpose is protecting U.S. livestock from foreign and domestic disease threats. The NAIS aims to identify all agriculture animals (i.e., not domestic animals like cats and dogs), and it enables tracking of livestock as they intermix with animals other than herdmates. It is expected that during disease investigations, automated, national animal identification will enable faster tracking of animal movements, resulting in faster detection of the location of outbreaks and quicker containment measures.

The USDA is promoting a fast timeline for this initiative – 25% premises identification by January 1, 2007, 70% by January 1, 2008 and 100% by January 1, 2009. However, premises identification is being implemented at the state level. Without the teeth of a mandate, query whether the USDA will hit its targets. For example, according to Texas officials administering NAIS, the average Texas herd consists of 35 animals. That suggests a situation not unlike the challenge of incenting the tens of thousands of small business manufacturers doing business with the DoD to comply with DFAR 252.211-7006 “voluntarily.” Few DoD suppliers, other than the likes of Lockheed Martin, “volunteered” to ship in accordance with the DoD’s passive RFID tagging requirements prior to the effective date of the RFID mandate. (On the commercial side, SMBs haven’t exactly been lining up to adopt Wal-Mart’s RFID tagging requirements.) Is it realistic to assume that participants in a highly fragmented industry will voluntarily opt into the NAIS program, especially in view of the few small business early adopters elsewhere? And without a mandate, will SMBs invest in automated technology, given that they may be required to replace or upgrade technologies as best practices, standards and regulations change as the initiative moves from the pilot phase to the proof-of-concept stage?

Beyond these policy questions, the USDA policy makers will be struggling with a number of other hurdles relating to the management of the data itself. One of the primary concerns is ensuring the privacy of the database, including, for example, taking steps so that the information doesn’t inadvertently become subject to FOIA requests.

RFID Law Journal will be following key developments as the USDA pushes forward with its NAIS initiative. In the interim, there are a number of original sources worth reviewing in greater detail if you are interested in learning more about the NAIS requirements.

“National Animal Identification Costs and Regulations,” Robert Fourdraine, Ph.D, Wisconsin Livestock Identification Consortium.


“Strategies for the Implementation of NAIS” (April 2006):

“Implementation of Animal Identification”

Premises Identification:

Animal Identification:

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