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The purpose of the program, which began in 2004, was to give producers not already part of a livestock health program an opportunity to participate in national efforts to safeguard the health of food animals.
What originally spurred NAIS was when the first case of bovine spongiform encephalopathy (BSE) was discovered in the U.S. on Dec. 23, 2003. But other food-animal diseases, such as foot-and-mouth disease, also put pressure on to set up a viable means of tracing food animals back to their sources, or identifying the premises where the animals come from, especially when disease occurs.
Last summer, USDA’s Animal and Plant Inspection Service (APHIS), which is responsible for food-animal health in the U.S., and which has implemented the animal-health program since 2004, held “listening hearings” on NAIS looking for advice about the best way to implement and improve the program. The program had been criticized by farmers, ranchers, the state departments of agriculture represented by the National Association of State Departments of Agriculture (NASDA), Native American tribes, the meat industry and others.
Major debate
Between last summer and now, there was a great deal of debate over whether the program was being run well or not. Central to concerns expressed about the program was debate over whether it should remain voluntary, or become mandatory. The success of NAIS was described by various groups as mixed. In fact, less than one-third of farmers and ranchers were willing to participate in the old APHIS NAIS animal health traceability program, despite the fact that under the Bush administration USDA spent more than $120 million on the program. It is no secret there are concerns about and opposition to NAIS, largely due to the control of the program by the federal government, rather than states, as well as some of the program’s mandatory aspects and its high costs.
On Feb. 5, Agriculture Secretary Tom Vilsack made an appearance at NASDA’s Mid-Year meeting in Washington, D.C., and announced USDA, through APHIS, would develop a new, flexible framework for animal-disease traceability in the U.S., as well as undertaking several other actions to further strengthen its USDA’s disease prevention and response capabilities. Amy Mann, director of legislative and regulatory affairs for NASDA, says when the announcement was made representatives of the state departments of agriculture were quite happy, realizing they would be playing a major role in developing and operating a new national animal-identification system to trace diseases in food animals across the U.S.
Since then, a lot has been happening to redesign and change the program, says Lyndsay Cole, an APHIS spokeswoman. There have been many public meetings for discussion about the program, with meetings being held all over the U.S. during the months of March, April and May. More meetings were scheduled for June and July.
“APHIS has conveyed a regulatory working group of federal, state and Tribal Nations animal-health officials to assess options for the animal disease traceability framework, provide input to our agency and review the feedback received from the public and other partners,” Cole says. According to Benjamin Richey, executive director of the United States Animal Health Association, a group that includes state veterinarians are playing a major role in re-writing the program. One of those is Dr. Becky Brewer, state veterinarian for Oklahoma. Three other state veterinarians are members of the 20-member working group.
Filling the NAIS void
“The United States is the only one of the five-biggest beef-producing countries in the world without a national animal identification system for health purposes,” Brewer says. “So that is going to change. It is going to be a very simple system, as simple as producers and others want it, using ear tags to identify the animals.” Electronic identification will also be possible, she says.
Brewer says the new system will be focused entirely on animal-disease traceability and will be led and administered by the states and tribal nations, not the federal government. “The rulemaking will come from APHIS, but the performance standards, how it will be carried out, will come from us,” she says. “The new framework focuses only on animals that move interstate. But animal-disease traceability health certificates will be required for animals moving interstate, just as it always has been. USDA will not mandate a one-fits-all approach. But each state and tribal nation will be able to determine the specific approaches and solutions it wants to use to achieve the minimum animal disease traceability performance measures. States will actually be able to require higher standards than the federal government. The federal rule will be the minimum.”
Brewer points out the main changes in the new system, compared to the old one begun six years ago, are changes in dynamics. “Under the current NAIS, benchmarks are set consisting mainly of numbers: how many identification tags, how many animals to be covered – in other words, a series of benchmarks to be met.
“In the system we are developing, animal-disease traceability is much more concerned about how fast our actions are going to be in tracing cattle, swine or poultry,” Brewer says. “Where was it born? Where was it tagged? How long will it take to find out? That’s going to be the top priority under this new system. Other factors will include how to notify a state or tribe where a shipment of animals originated; notifying the state where the animal was officially identified; how long should the action take, how many work hours are needed? How can we establish a baseline for traceability, where are we right now? And what if a state can’t meet the performance standards?”
Brewer emphasized that standards should focus on tracing animals, not diseases. During the past few months, the meetings focused on how to give states and tribes more responsibility for their animal disease traceability programs; how to direct interstate livestock movement through compliance with performance standards; what kinds of performance standards should be set; how to evaluate the capability of tracing animals; what kind of consequences there should be for noncompliance with the new rule; and what incentives could be offered for compliance.
APHIS’ Cole says after the failures of the current program, USDA and the states decided it was time to take action to make animal-disease traceability and identification efforts more workable, feasible and carried out in a common-sense way. The new approach responds to a number of concerns raised by producers that the approach is too bureaucratic and too expensive. She says the goal of the new system is to impose the least burden on producers as possible, while still making sure that we have effective animal disease traceability in the U.S.
Cole says by this fall, it is the goal of APHIS, supported by the state veterinarian and tribal groups, to develop new proposed rulemaking for the animal disease traceability program. “By next winter, we hope to publish performance standards in a proposed rule for animal-disease traceability in straightforward, understandable language. And we will offer a comment period of 90 days to allow ample time for comments and feedback from all interested parties,” she says.
According to Bethany Shively, a spokeswoman for the National Cattlemen’s Beef Association, the new APHIS program applies only to interstate movement of cattle, not movement of cattle within the states. States will be able to determine the performance standards within their individual borders. The performance standards will be meant for states to utilize to meet interstate requirements, she says.
Animals are currently traced for disease to the state where it was officially identified, where it was shipped from, to the herd of origin, to all the herds the animal has been in and movements in and out of affected herds. The thinking on the part of the working group is three factors would make up a basis for interstate traceability performance standards: Tracing animals to the state or tribe where they were officially identified; tracing animals to the state they were shipped from; and notifying the state of origin.
Better baselines needed
“Right now, the current system is criticized because current tracing capabilities are inadequate, there is not a good baseline for the time it takes to trace the animals, and that a good baseline must be established to document tracing capability,” Brewer says.
As APHIS and the states, cattle, swine and poultry producers, the meat and poultry industry and others continue their efforts to develop a new animal disease traceability system, their work sessions continue. Two more public meetings will be held in July in Salt Lake City, Utah, and in Fort Worth, Texas.
USAHA’s Richey says USDA is also planning to take additional steps to strengthen protections against the entry and spread of disease. These steps include accelerating actions to lessen disease risks – posed by imported animals, beginning and updating analyses on how animal diseases travel into the country, improving response capabilities and focusing on greater collaboration with states and industry on potential disease risk. •
Bernard Shire is M&P’s Washington correspondent, contributing editor and feature writer based in Lancaster, Pa. With a background in editing and writing for daily news publications, he also works as a food safety consultant and writer for Shire & Associates LLC.
