Recent articles in several publications devoted to small-scale farming and homesteading have strongly criticized the USDA’s proposed National Animal Identification System. Consequently many people have contacted MOFGA over the past year asking what effects the system might have on their operations and how they should respond to any attempts by the Maine Department of Agriculture to implement components of the plan. The MOFGA board recently approved an official position regarding the USDA’s April 2006 NAIS proposal and directed MOFGA’s public policy committee to coordinate an extra teach-in at the Common Ground Country Fair to educate fairgoers on this controversial issue. Approximately 30 people attended the event to hear and question panelists Don Hoenig (state veterinarian), Diane Schivera (MOFGA’s organic livestock specialist) and Christine Alexander (owner of Udder View goat farm in Columbia, Maine). Russell Libby, MOFGA’s executive director, moderated the event.
Hoenig spoke from the position that “we need a better system of animal identification in this country.” He gave as an example the incident in March 2006 in which a native-born cow in Alabama was diagnosed with bovine spongiform encephalopathy (mad cow disease), and government officials were unable to discover where the animal was born. He admitted that the Maine Department of Agriculture was thinking of worst-case scenarios, but claimed that in the event of a foreign animal disease epidemic, “the public and the farming community will demand that we get things back to normal as soon as possible.” The department’s current tools for doing so, he said, are its staff, good animal health laws, and good farmers – but the state lacks a system to quickly contact all animal owners who might be concerned during a disease outbreak or to track potential disease vectors.
Hoenig rejected metal ear tags (currently, along with tattoos, the prevalent method of identifying animals) as ineffective, “50-year-old technology,” because they tend to get lost or become unreadable. Radio frequency identification (RFID) tags stay in better and are easier for a veterinarian to read. He emphasized that RFID tags are a passive technology – that is, they can be read only by a special reader at close range, like an Interstate EZ Pass; they cannot be tracked at any time by a satellite, as some farmers feared.
The language of the April 2006 proposal indicated that livestock owners would need to report all off-property movements of their animals. The far reach of this requirement was particularly worrisome to many farmers and homesteaders. The USDA has since released material clarifying that in many situations this requirement would not apply – including homesteaders’ animals going to custom slaughter, escaped animals returned to the farm property, participation in local fairs such as the Common Ground, and trail rides. No exceptions have been made yet for homesteaders’ animals that are transferred between farms for breeding. Hoenig also noted that while many animal movements would have to be recorded by livestock owners, the movements would not have to be reported “under ordinary circumstances.”
Currently Maine’s only participation in the NAIS is the “IDME” program – a voluntary premises registration that does not involve individual animal identification or tracking. The USDA is relying on participation in such voluntary programs to demonstrate public support for an expanded animal identification system.
Christine Alexander acknowledged that disease outbreaks are a concern, but questioned how much NAIS would actually help. She feared the program was really about assuaging consumers’ doubts as to the safety of food produced in large, anonymous plants and noted that the proposal had not been approved or given funding by Congress. The USDA’s alternate assurances that the program would be strict and comprehensive yet pose little burden to small farmers make Maine farmers suspicious of Maine Department of Agriculture initiatives such as IDME. “No one wants to sign up for a “voluntary” program when we don’t know where it’s headed.” The USDA claims that its proposal is “market-driven,” she said, but the small, local markets that are the livelihood of most MOFGA farmers are not asking for any such program.
Alexander questioned the constitutionality of a program that threatens the ability of many people, especially those (such as the Amish) who may hold religious or other objections to RFID technology, to hold a whole class of property (livestock). “Johanns wants a voluntary program with 100% participation – that’s not possible,” she said. “If you can’t buy, sell or trade without it, it’s hardly voluntary.” She proposed that the government address risks to animal health by strengthening state veterinary resources and giving technical support to agricultural organizations such as MOFGA.
Diana Schivera said that MOFGA had four major problems with the proposed program. First, the complicated requirements might cause small growers to “opt out of the system” and stop producing their own livestock products. This could reduce the self-sufficiency of homesteaders and close a revenue option for small-scale of part-time commercial farmers. Second, the new technology would impose an unnecessary financial and administrative burden on farmers, who are usually already overextended. Third, the program exhibited a morbid focus on animal disease instead of focusing on proactive steps toward animal health (e.g., biosecurity education for livestock farmers). Fourth, implementing any kind of identification system at the federal level would inevitably be more cumbersome and expensive than any kind of state program.
Schivera pointed out that many farmers – such as certified organic farmers and participants in the scrapies program – already use excellent identification systems for their livestock. “Record-keeping is very helpful and appropriate,” she said, “but large-scale fancy identification only makes sense for large growers with large markets.”
Libby interjected that the MOFGA board had committed to helping livestock farmers see how record-keeping supports animal health by providing sample record sheets for various types of operation.
Hoenig added that as of June or July 2006, the USDA was discussing only a voluntary system that would be “market-driven” in the sense that certain large markets (such as McDonalds) might require their sources to use this type of identification program.
One audience member asked whether rabbits and poultry were included in the program (poultry are, but rabbits are not) and whether her regular visits with her horse to another horse farm for group trail rides would have to be reported. Hoenig responded that horse shows and farm visits “should not be of concern unless there is a disease outbreak immediately threatened, in which case movements may be restricted.”
One person repeated Schivera’s point that certified farmers have an identification system in place and said that “the Feds should let us do things the way we are already doing it.” Hoenig replied that it was quite possible that MOFGA databases could be accepted as a substitute for participating in the federal database.
Someone wondered what was wrong with using “50-year-old technology” if it worked. Hoenig said that RFID tags were simply more convenient for the person reading the tag and that the cattle industry was strongly supporting their use. The USDA, however, would probably permit the use of old-fashioned tags or tattoos instead. A second person had heard that multiple incompatible models of readers and chips are on the market, making a truly universal identification system impracticable. Hoenig answered that a universal reader had recently been developed.
Another person asked if the FDA were to require markets to have NAIS-style traceability, whether that would override the USDA’s “voluntary” program. Schivera thought that this would be unlikely to affect small-scale producers who relied on intrastate markets.
One audience member asked what systems of animal identification were being used in Europe. Hoenig replied that most European countries use RFID-style identification, but that the U.K. also used paper “passports,” which could be very helpful. Libby added that for organic certification, a paper trail is very important.
A final questioner said that no mention of NAIS had been made at Clark’s Auction and pointed out that auctions already maintain a paper trail. Hoenig said that the state had begun discussions with auction holders and that their current methods were insufficient, because they recycled tag numbers, so an identification number was not unique to an animal.
Summing up, Alexander said that she would like to see the state encouraging farmer participation in developing a program that was guaranteed to remain voluntary, and added that farmers should be more proactive about effective identification methods for their own sakes. Schivera said that the problems with NAIS were mostly issues of scale and marketing – what was appropriate for large-scale producers versus what was appropriate for small-scale, direct marketers or homesteaders. Hoenig invited audience members to attend any of seven public meetings the Department of Agriculture was holding in the fall to gather input from interested parties.