Several different livestock groups offered mixed reviews regarding the U.S. Department of Agriculture’s (USDA) proposal to transition to Radio Frequency Identification (RFID) as the official eartag for use in interstate movement of cattle that are required to be identified by the traceability regulations.
The National Cattlemen’s Beef Assn. (NCBA) said in its comments that it “has long been supportive of traceability for animal health purposes and believes that the goal of any identification program should be to enable the cattle industry, state, and federal animal health officials to respond rapidly and effectively to animal health emergencies.”
NCBA’s comments noted from 2018 to 2020, the U.S. beef industry worked to explore the use of RFID through three state pilot projects in Kansas, Florida, and Texas. The state of Michigan has required RFID for all cattle prior to movement from any premise in Michigan since 2007.
In Kansas, the CattleTrace pilot project used ultrahigh frequency (UHF) identification tags with the goal to collect the minimum necessary data (official animal identification number, GPS location of the readers, time, and date of recording) for disease traceability with a system that can operate at the speed of commerce and utilizes a private third-party data collection system. The pilot project in Florida aimed to demonstrate the feasibility of an economically justifiable traceability model with protected proprietary data, using low frequency (LF) RFID tags. The Texas pilot project utilized both UHF and LF tags to achieve the goal of disease traceability and the exchange of value-added information up and down the processing chain.
The results from the three pilot projects, concluding in 2020, will provide important data for enhancing the current animal identification system using RFID ear tags, NCBA said in its comments.
NCBA policy regarding any animal disease traceability program advocates for the following overarching principles:
- Utilize low cost electronic official tagging devices paid for by federal or state funds, when possible.
- Require that cattle identification information for disease traceability be kept confidential and strongly protected from inappropriate disclosure. Data collected should be only that data necessary to achieve the goal of ADT.
- Operate at the speed of commerce.
- Honor cattle movement between adjoining states in pasture-to-pasture permits, at the discretion of the involved states.
- Protect producers from liability for acts of others after the cattle have left the producer’s control.
- Does not replace or impede existing state brand inspection activities.
- Compatible with private sector animal identification and verification programs backed by USDA.
- Built using infrastructure that supports other potential uses of identification.
Meanwhile, the U.S. Cattlemen’s Assn., at its 2019 Annual Meeting, USCA members approved policy related to animal health and ID priorities. Their statement includes: “There is concern across the countryside that a move toward electronic identification will open the door for private tag and data companies, and other allied industries, to profit from the effort, leaving the producers’ information in the hands of a third-party provider…the main reason for official identification is for disease traceability, and it is with the above concerns in mind that USCA suggests that any official USDA identification remain focused on disease traceability.”
In comments signed by Dr. Brooke Miller, M.D., president of USCA, Miller stated, “With the growth of a global marketplace, our trading partners will begin to expect a more comprehensive and transparent national animal identification system.”
USCA’s comments said that all official tag information should be held in state animal health databases and shared with federal animal health officials as needed. “Producer information should only be used for disease tracking by state and federal animal health officials and for no other purposes. There should be absolutely no private control of data, or access to the data, without the prior approval of the owner at the time of application,” the comments state. “The confidential nature of the information stored within an ADT system would present a clear conflict of interest for private organizations to own and manage.”
USCA commended USDA for currently providing RFID tags free of charge to states and accredited veterinarians. “However, more certainty is needed that producers will not be held responsible for future costs related to the physical tag, tag application, data collection, and data management,” USCA added.
USCA added the USDA must remain technology neutral as they begin to transition to RFID identification devices. Both ultra-high frequency (UHF) and low frequency (LF) technology “should be included in any national program, giving U.S. cattle producers the opportunity to choose which system is best for their operation,” USCA said in its comments.
USCA said official identification should only be required on breeding cattle and only as they move into interstate commerce, or as determined by each state’s importation requirements. In addition, the group also commented that premises identification numbers (PINs) should not be required to acquire and apply EID tags. The same information can be gathered on health certificates and test charts and other animal health documents.
USCA also said the use of USDA metal NEUS tags and electronic tags should be allowed to continue simultaneously within this transition. “The industry requires more time to adapt and transfer to an all-electronic system; time will determine whether multiple systems can be used,” USCA said.
The dairy industry also advocated for official mandatory animal identification to aid disease traceability. The National Milk Producers Federation also submitted comments that detailed the dairy industry’s support and suggestions.
In 2005, a coalition of six dairy organizations that serve many thousands of dairy farmers – the American Jersey Cattle Association, Holstein Association USA, Inc., National Association of Animal Breeders, National Dairy Herd Information Association, National Milk Producers Federation and Dairy Calf and Heifer Association – formed a group called IDairy™ to collectively advance official mandatory animal identification to aid disease traceability. In 2007, IDairy™ was a recipient of a USDA-APHIS cooperative agreement on premise registration and animal ID education which propelled the use of RFID tags in the U.S. dairy industry.
APHIS has proposed to require the use of official 840-RFID tags for all dairy cattle involved in interstate commerce starting Jan. 1, 2023.
“We commend USDA-APHIS for taking this next step in moving animal identification forward, with the use of RFID tags for official animal identification for dairy cattle,” said Jim Mulhern, president and chief executive officer of the NMPF. “A national animal identification system can provide immediate access to relevant information in an animal disease or food safety crisis that could endanger the entire dairy chain, while protecting farmers' privacy.”
NMPF supports the USDA-APHIS proposed timeline for implementation for dairy cattle of:
- Beginning January 1, 2022, USDA would no longer approve vendors to use the official USDA shield in production of metal ear tags or other ear tags that do not have RFID components.
- On January 1, 2023, RFID tags would become the only identification devices approved as an official eartag for dairy cattle pursuant to § 86.4(a)(1)(i).
- For dairy cattle that have official USDA metal clip tags in place before January 1, 2023, APHIS would recognize the metal tag as an official identification device for the life of the animal.