Animal Identification: Overview and Issues

Animal Identification: Overview and Issues
Geoffrey S. Becker
Specialist in Agricultural Policy
Resources, Science, and Industry Division
Summary
Livestock industry groups, animal health officials, and the U.S. Department of
Agriculture (USDA) have been working to establish a nationwide identification (ID)
system capable of quickly tracking animals from birth to slaughter, to deal with animal
diseases and/or to satisfy foreign market specifications. Some consumer groups are
among those who believe ID also would be useful for food safety or retail labeling
purposes. Not all producers support a new program, fearing it will be costly and
intrusive. In the 110^th Congress, measures with animal ID and/or traceability provisions
include H.R. 1018, H.R. 1148/S. 654, H.R. 2301, H.R. 3485, H.R. 3624, and S. 1292.
What Is Animal ID and Why Is It Used?
Animal ID refers to keeping records on farm animals or groups (e.g., flocks; herds)
so that they can be more easily tracked from birth to slaughter. Use of animal ID dates
back at least to the 1800s, when hot iron brands were used throughout the U.S. West to
indicate ownership. ID methods today include ear, back, and tail tags; neck chains, freeze
(as opposed to hot iron) brands, and leg bands. Some producers use radio frequency ID
transponders with information that is read by scanners and fed into computer databases.
The reasons for identifying and tracking animals and their products also have evolved.
Animal Health. Animal ID can help to identify the source of dangerous and costly
animal diseases and to contain them. In the global marketplace, animal disease programs,
aided by traceability systems, are used both to reassure buyers about the health of U.S.
animals and to satisfy foreign veterinary and/or food safety requirements. USDA’s
Animal and Plant Health Inspection Service (APHIS) oversees animal health in
consultation with state veterinary authorities, and some of its disease eradication and
control efforts effectively require ID and tracking. For example, for brucellosis, a highly
contagious and costly disease mainly affecting cattle, bison, and swine (once common
here), uniquely numbered brucellosis ID tags were routinely attached to animals, which
noted that they had been vaccinated or tested. Because brucellosis has largely been
eradicated from U.S. commercial herds, ID is no longer widespread. Examples of other
official disease programs include pseudorabies in swine and scrapie in sheep, where swine
and sheep, respectively, must be officially identified before entering interstate commerce.

Often state laws or breed association rules require animals of these and other species, like
cattle and horses, to be identified to participate in shows or races.
Still, no universal system captures the locations and movements of all farm animals
across all states. U.S. limitations were noted after bovine spongiform encephalopathy
(BSE, or mad cow disease) was discovered in the United States (in a Canadian-born dairy
cow) in December 2003. A number of trading partners that had quickly closed their
borders to U.S. beef reportedly were reluctant to reopen them, due in part to U.S.
difficulties in tracing the whereabouts of other cattle that had entered the United States
with the BSE-infected cow; similar difficulties arose in determining the whereabouts
and/or herdmates of the two later U.S.-born BSE cases.¹
Commercial Production and Marketing. Many farmers and ranchers already
keep track of individual animals and how they are being raised, in order to identify and
exploit desirable production characteristics. Universal bar codes on processed food,
including many meats, are widely used by processors and retailers to manage inventories,
add value to products, and monitor consumer buying. When consumers seek meat, eggs,
or milk from animals raised according to specified organic, humane treatment, or
environmental standards, ID and traceability can help firms verify production methods.
Government-coordinated programs also have been established for these purposes.
For example, a process verification program operated by USDA’s Agricultural Marketing
Service (AMS) “provides livestock and meat producers an opportunity to assure
customers of their ability to provide consistent quality products by having their written
manufacturing processes confirmed through independent, third party audits,” according
to AMS. USDA “Process Verified” suppliers can have marketing claims such as breeds
and feeding practices, and so label them, under this voluntary, fee-for-service program.
After BSE appeared in North America in 2003, AMS developed an export
verification (EV) program for U.S. plants seeking to meet the differing beef import
specifications of various countries like Japan, once the number-one foreign market for
U.S. beef. AMS establishes the standards that U.S. suppliers must follow if they want to
ship beef to these countries, and certifies that the proper procedures are in place. While
EV is “voluntary,” it is also a prerequisite for access to the Japanese, Korean, and other
foreign markets. Other programs employing varying levels and types of traceability
include the domestic origin requirement for USDA-purchased commodities used in
domestic feeding programs; and the national organic certification program, which AMS
also oversees.²
Food Safety. Federal and state food safety agencies collaborate with APHIS to
protect the food supply from the introduction, through animals, of threats to human health,
such as tuberculosis; and foodborne illnesses from bacteria like Salmonella and E. coli

¹ See CRS Report RL32199, Bovine Spongiform Encephalopathy (BSE, or “Mad Cow Disease”):
Current and Proposed Safeguards, by Sarah A. Lister and Geoffrey S. Becker.
² For more information see the AMS website at [http://www.ams.usda.gov/]. Also, AMS released
on April 2, 2008, a draft business plan intended to integrate USDA’s current animal ID efforts
with these marketing programs. The plan was posted on the Internet at [http://animalid.
aphis.usda.gov/nais/naislibrary/documents /plans_reports/NAIS_ Business_Plan.pdf].

O157:H7. Generally, when local health officials can link an illness to a particular
product, firms and their regulators have been able to trace that product back to the
processor and/or slaughter facility. It is more difficult and costly to determine which
particular animals, herds, or flocks were involved. Some believe that a more rigorous
traceback and animal ID system would facilitate food recalls, possibly contain the spread
of a foodborne illness, and help authorities stem future incidents. Others, particularly
many within the food industry, strongly disagree, countering that such a system would not
be based on sound science, and would be technically unworkable and extremely costly.³
Development of a National Plan
Early Private-Public Efforts. Work toward a coordinated national animal ID
system began in earnest in the early 2000s and evolved into a joint industry-government-
professional effort whose principal goal was the ability to trace animals of interest within
48 hours of an animal disease problem. A draft “U.S. Animal Identification Plan
(USAIP)” published in December 2003 called for recording the movement of individual
animals or animal groups in a central database or in a “seamlessly linked” database
infrastructure. APHIS roles would be to allocate premises (e.g., farms, feedlots, auction
barns, processing plants) and animal numbers and to coordinate data collection. The work
plan envisioned by the USAIP had first called for all states to have an animal premises ID
system by July 2004, with farm animals of all major species identified by July 2006.
USDA Actions.⁴ As the draft USAIP was being published in December 2003, the
first U.S. BSE case emerged. Among the initiatives USDA quickly announced to shore
up confidence in the beef supply was accelerated implementation of animal ID. Since
early 2004, the Department has committed nearly $128 million to its development,
providing many of the funds to states and tribal organizations for research, database
systems, and startup of premises registration.
USDA first announced a “framework” for its National Animal Identification System
(NAIS) in April 2004 and has been periodically revising the outlines of the program since
then. It issued a “draft strategic plan” in May 2005, announced a new set of “guiding
principles” in August 2005, and unveiled a new plan in April 2006 that set a timeline for
full implementation by 2009. In November 2006, USDA distributed a draft “user guide”
as “the most current plan for the NAIS [which] replaces all previously published program
documents, including the 2005 Draft Strategic Plan and Draft Program Standards and the
2006 Implementation Strategies.” The user guide sought to assure producers that USDA
would not require them to participate in the program, and that it is bound by law to protect
individuals’ private and confidential business information. The draft user guide described
three successively greater steps toward full participation:
^!premises registration, done through one of the state (or tribal) animal
health authorities (by late 2006, the goal was to register all premises by

2009);

³ See also CRS Report RL32922, Meat and Poultry Inspection: Background and Selected Issues;
and CRS Report 97-508, Country-of-Origin Labeling for Foods, both by Geoffrey S. Becker.
⁴ This section is based primarily on current and archived materials found at APHIS’s animal ID
website at [http://animalid.aphis.usda.gov/nais/index.shtml].

^!animal ID, accomplished by obtaining USDA-recognized numbering tags
or devices from representatives of authorized manufacturers;
^!selection by the producer of one of the NAIS-compliant animal tracking
databases to which the producer can report animal movements.
On this last point, USDA continues to envision a universal system as a series of state
or privately held databases which the Department could tap only in the event of an animal
disease outbreak, with the goal of tracing animals from point of origin to processing
within 48 hours. Its user guide anticipated that the NAIS would cover the following
species: cattle and bison; poultry; swine; sheep and goats; cervids such as deer and elk;
horses and other equines; and camelids (e.g., llamas and alpacas). Household pets and
other animals not listed would be excluded from NAIS. Only animals that enter
commerce or that commingle with animals at other premises (like sales barns, state or
national fairs, or exhibits) would be identified. Also, animals that typically are moved in
groups — such as hogs and poultry — could be identified as part of their group rather
than individually.
The draft business plan released in April 2008 attempted to further clarify current
implementation strategies. One of seven key strategies would be to prioritize species, with
the primary commercial food animals in “Tier 1,” along with horses that need a health
certificate or test when moved. All other livestock and poultry would be in a lower-
priority Tier 2. One key objective would be to bring 70% of the cattle breeding herd into
NAIS by the end of 2009.⁵
Selected Issues
Supporters assert that an animal ID system is needed to maintain U.S.
competitiveness in the global marketplace, where other major meat-exporting countries
have been rapidly developing their own ID programs, in part to meet importing countries’
demands for such traceability. Some livestock producers say they are not convinced that
any new program, mandatory or voluntary, will improve animal health oversight, and they
fear that it will only impose costly and intrusive regulations on their operations without
adding any significant value to their animals. Some reportedly are working within
individual states to block mandatory and/or voluntary programs there.
Implementation Pace. Some animal ID program supporters, on the other hand,
have criticized USDA for moving too slowly and/or not setting a clearer path toward
universal ID. As of mid-July 2008, APHIS reported that less than 500,000 animal
premises had been registered in one of the available databases. This compares with an
estimated 1.4 million livestock and poultry farms in the United States (2002 Census of
Agriculture data). Registration rates vary widely among states.
A July 2007 report by the Government Accountability Office concluded that a
number of problems had hindered effective implementation of animal ID, such as no
prioritization among the nine animal species to be covered to focus on those of greatest
disease concern; no plan to integrate NAIS into existing USDA and state animal ID
requirements; and no requirement that some types of critical data be provided to the

⁵ See footnote 2.

databases, such as species or age.⁶ Others believe that USDA’s progress simply reflects
the wide differences among producers and other interests over many unresolved issues.
House and Senate appropriators also have questioned USDA’s progress and direction
in implementing a national system. Over several years through FY2007, about $117.8
million went into the program’s development. The enacted FY2008 appropriation (part
of the Consolidated Appropriations Act, 2008, P.L. 110-161) provided $9.8 million more
to continue implementation of NAIS, which is well below the Administration’s requested
appropriation of $33.2 million for NAIS for FY2008. The conference report cites
concerns about “the lack of information provided on full costs and concerns about the use
of funds to date,” including information on how APHIS would reach its 48-hour traceback
goal, and information on how the funds for the program have been used to date. The
report states the committees’ concern that more than 50% of the obligations to date in
NAIS have been for “cooperative agreements that, until very recently, did not require that
cooperators or grantees agree to specific performance goals.” The committees are also
concerned that 25% of the funding has gone for program management.
Administration officials, seeking $24 million for the program for FY2009, were
harshly criticized by the chair of the House Appropriations agriculture subcommittee at
a hearing on April 9, 2008. She indicated that she wanted more accountability regarding
the spending. The House Appropriations Committee had not marked up USDA’s FY2004
USDA appropriation as of mid-July 2008. However, the subcommittee’s draft bill
reportedly contains incentives to encourage wider adoption of animal ID, notably a
requirement that USDA purchase meats for the school lunch program starting in 2010
only from suppliers in the ID system.⁷
Mandatory or Voluntary? According to the Department’s latest thinking on the
NAIS (see above), “Participation in NAIS is voluntary at the Federal level.... The NAIS
does not need to be mandatory to be effective.” Others, including many state animal
health officials, reportedly disagree. At meetings in October 2006, the National Assembly
of State Animal Health Officials and the U.S. Animal Health Association’s livestock
committee each approved a recommendation that, as a step toward a national system,
USDA make animal ID mandatory for all U.S. breeding cattle. Consumer advocacy
groups also have pressed for a mandatory national system.
Costs and Who Pays. An animal ID system will impose a variety of costs, such
as for tags or other identifying devices and their application, and data systems to track
animals. Cost estimates of a national system have varied broadly — and are not directly
comparable, a reflection of estimators’ differing assumptions and of the varying designs
of proposed programs. As the extent of traceability increases, so do likely costs. A
related policy question is who should pay — the industry (and ultimately consumers),
government, or both? USDA’s current thinking calls for expenses to be shared (e.g.,
database costs funded by government and the identifying devices by producers).

⁶ National Animal Identification System: USDA Needs to Resolve Several Key Implementation
Issues to Achieve Rapid and Effective Disease Traceback, GAO-07-592.
⁷ See, for example, “Funding bill links NAIS, school sales,” Feedstuffs, June 23, 2008.

It has been argued that, as more tracing requirements are imposed, large retailers and
meat packers will exercise market power to shift compliance costs backward to farms and
ranches, making it even more difficult for the smaller, independent ones to remain in
business. Larger, more vertically integrated operations are more likely to have the
resources and scale economies to survive, some have argued. On the other hand, if
traceability costs forced big meat plants to reduce line speeds, “smaller plants with slower
fabrication speeds may be better equipped to implement traceability to the retail level and
may find niche market opportunities.”⁸
Liability and Confidentiality of Records. Some producers are concerned they
will be held liable for contamination or other problems over which they believe they have
little control after the animal leaves the farm. On the other hand, documentation of
management practices, including animal health programs, can help to protect against
liability because they can prove where animals came from and how they were raised.⁹
Also at issue is whether producers can and should be protected from public scrutiny of
their records. The federal Freedom of Information Act (FOIA) entitles members of the
public to obtain records held by federal agencies. Some producers are concerned, for
example, that animal rights extremists might misuse information gained through FOIA,
or that the data collection might reveal proprietary information. However, FOIA exempts
access to certain types of business information, such as trade secrets, commercial or¹⁰
financial information, or other confidential material that might harm the provider.
Conferees deleted a provision (Sec. 10305) in the Senate-passed version of H.R.
2419, the omnibus farm bill enacted as P.L. 110-246, that would have required USDA
regulations addressing “the protection of trade secrets and other proprietary and/or
confidential business information” disclosed due to participation in an animal ID system.
Other Bills in the 110^th Congress
USDA has claimed it has authority, under the Animal Health Protection Act (7
U.S.C. 8301 et seq.), to implement an animal ID program. Several other pending bills
aim to clarify USDA’s authority and/or spell out what type of program should be
established. They include H.R. 1018, prohibiting USDA from carrying out a mandatory
program and also seeking to protect the privacy of producer information under a voluntary
system; H.R. 2301, establishing an industry-led Livestock Identification Board to manage
a national ID system; and S. 1292, requiring USDA to implement a more comprehensive
farm-to-consumer animal ID and meat traceability program. H.R. 3485 would require
comprehensive new traceability systems for both USDA-regulated meat and poultry and
for other foods regulated by the U.S. Food and Drug Administration (FDA); several
broader food safety bills (e.g., H.R. 1148/S. 654; H.R. 3624) contain traceability
provisions that could affect animal agriculture.

⁸ “Meat Traceability: Its Effect on Trade,” Iowa Ag Review, Winter 2002.
⁹ Ibid.
¹⁰ For more discussion of the liability and confidentiality issues, see National Agricultural Law
Center, Animal Identification — An Overview, National AgLaw Center Reading Room, at
[http://www.nationalagl awcenter.org/ readingr ooms/animalid/].