National Animal Identification System:

USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback

GAO-07-592: Published: Jul 6, 2007. Publicly Released: Aug 2, 2007.

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Livestock production contributed nearly $123 billion to the U.S. economy in 2006. In response to concerns about animal disease outbreaks, the U.S. Department of Agriculture (USDA) announced in December 2003 that it would implement a nationwide program--later named the National Animal Identification System (NAIS)--to help producers and animal health officials respond quickly and effectively to animal disease events in the United States. In this context, GAO determined (1) how effectively USDA is implementing NAIS and, specifically, the key issues identified by livestock industry groups, market operators, state officials, and others; (2) how USDA has distributed cooperative agreement funds to help states and industry prepare for NAIS and evaluated the agreements' results; and (3) what USDA and others estimate are the costs for USDA, states, and industry to implement NAIS. In conducting its work, GAO reviewed USDA documents; interviewed agency, industry, and state officials; and consulted 32 animal identification (ID) experts.

In implementing the NAIS program, USDA has taken some steps to address issues identified by livestock industry groups, market operators, state animal health officials, and others. Nonetheless, the agency has not effectively addressed several issues that, if left unresolved, could undermine the program's ability to achieve the goal of rapid and effective animal disease traceback. Specifically, USDA's decision to implement NAIS as a voluntary program may affect the agency's ability to attract the necessary levels of participation. However, some industry groups believe that NAIS could succeed as a voluntary program, or that USDA needs to first resolve several issues before making participation mandatory. Agency officials are analyzing what participation levels are necessary to meet the program's goal and may introduce benchmarks to measure progress. In addition, several key problems hinder USDA's ability to implement NAIS effectively. USDA has not prioritized the implementation of NAIS by species or other criteria. Instead, the agency is implementing NAIS for numerous species simultaneously, causing federal, state, and industry resources to be allocated widely, rather than being focused on the species of greatest concern. USDA has not developed a plan to integrate NAIS with preexisting USDA and state animal ID requirements. As a result, producers are generally discouraged from investing in new ID devices for NAIS. USDA has not established a robust process for selecting, standardizing, and testing animal ID and tracking technologies. USDA does not clearly define the time frame for rapid traceback, possibly slowing response and causing greater economic losses. USDA does not require potentially critical information to be recorded, such as species or age, in the NAIS databases. USDA has awarded $35 million in NAIS cooperative agreements from fiscal years 2004 through 2006 to 49 states, 29 tribes, and 2 territories to help identify effective approaches to register premises and identify and track animals. However, USDA has not consistently monitored or formally evaluated the results of cooperative agreements or consistently shared the results with states, industry groups, and other stakeholders. As a result, USDA cannot be assured that the agreements' intended outcomes have been achieved and, furthermore, that lessons learned and best practices are used to inform the program's progress. No comprehensive cost estimate or cost-benefit analysis for the implementation and maintenance of NAIS currently exists. As a result, it is not known how much is required in federal, state, and industry resources to achieve rapid and effective traceback, or whether the potential benefits of the program outweigh the costs. Industry groups and state officials say the cost of implementing NAIS is one of their biggest concerns. USDA plans to hire a contractor to conduct a cost-benefit analysis, in part to more precisely forecast the economic effects of NAIS.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: In May 2007 USDA issued the results of the cooperative agreements it entered with States in 2004 under NAIS. That report, entitled "The Pilot Projects/Field Trials Summary", contained the final results of 20 initial pilot projects funded in 2004 and descriptions of 7 ongoing pilot projects funded in 2005 through 2007. This was USDA's only report on the cooperative agreements. The ongoing projects were awarded from 2005 funds; no subsequent funding was provided. We made this recommendation because USDA was not carefully monitoring and evaluating the cooperative agreements. While it published the results of the 2004-funded projects, the report does not demonstrate that USDA monitored and evaluated those results in a timely fashion. Since USDA did not publish the results of the 2005-07 agreements nor demonstrate that it monitored and evaluated their results, it has not implemented this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to increase the monitoring of NAIS cooperative agreements, and evaluate and publish the results of cooperative agreements on a timely basis.

    Agency Affected: Department of Agriculture

  2. Status: Closed - Implemented

    Comments: USDA determined that States and Tribes will primarily maintain disease traceability data under the new framework, to address some of the privacy concerns that industry raised with NAIS. Under the framework and the August 2011 rule, States or Tribes must keep the data from the ear tags or leg bands for 5 years and make it available to APHIS during a disease event or an audit. While these data will provide disease traceability for most species, USDA is phasing in the requirements to address traceability for cattle. Through regulation, all livestock moved interstate will have to be officially identified and accompanied by an interstate certificate of veterinary inspection (ICVI) or other official documentation. Livestock facilities will have to keep a copy of the ICVI or alternate documentation for 5 years. USDA?s framework identifies the authorized methods of official identification for each species that must be accepted by all States and Tribes, thereby ensuring national uniformity. Identification and documentation requirements will be phased in for some classes of cattle to allow adequate time to ramp up compliance and enforcement efforts. Because the federally-required information includes, at a minimum, species and approximate age or date of birth, and it requires States, Tribes, and livestock facilities to maintain data for 5 years, the new framework achieves the intent of this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to evaluate what information is critical for efficient traceback, such as species, approximate age or date of birth, and require that participants record that information in the NAIS animal ID and tracking databases.

    Agency Affected: Department of Agriculture

  3. Status: Closed - Implemented

    Comments: NAIS had a 48-hour traceback goal for all species and diseases. Under the new framework, timeframes for traceback are species-specific, but not disease-specific. According to the framework and the August 2011 proposal, baselines and performance standards/goals were developed in consultation with stakeholders and in consideration of views of States, Tribes, industry groups, and representatives of small and organic farmers, obtained through extensive outreach. The framework and August 2011 rule propose using information required under several other livestock regulations that were already in place for disease monitoring or identification for captive cervids, equine, poultry, sheep and goats, and swine. To help ensure current data on animal movement for disease traceability, USDA is helping States and Tribes electronically maintain these data or it will keep the data, if the State/Tribe requests it. Because of the significant void in traceability for cattle, the identification and documentation of cattle moving interstate are being phased in. The new framework provides approximate timelines for establishing benchmarks and baselines for cattle. The August 2011 rule states that species-specific traceability performance standards will be established in future rulemaking, after States and Tribes have had experience with the framework. USDA expects to reach a 48-hour timeframe for cattle traceback by 2015. We believe USDA's actions largely achieve the intent of this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to identify--in consultation with the NAIS species working groups, state animal health officials, and others--current baselines for animal disease traceback, and develop time-sensitive, cost-effective goals for traceback under NAIS, which may include separate time frames for specific diseases.

    Agency Affected: Department of Agriculture

  4. Status: Closed - Implemented

    Comments: The terminated NAIS program required animals to be identified using radio frequency identification devices (RFID), which were viewed by cattle producers as expensive and having readability issues. Under the new framework, RFIDs are not required. USDA has designated the following official devices: for poultry, a group or lot identification number (GIN) or a sealed and numbered leg band, which are consistent with the National Poultry Improvement Plan (NPIP) regulations, and will not require a change for most producers; for sheep and goats, any approved device/method under the scrapie regulations, such as electronic implant, official eartag, USDA backtag, official registry tattoo, or premises identification eartag; for swine, any device or method approved under the existing requirements for interstate movement of swine, such as official eartag, USDA backtag, official swine tattoo and other tattoos, or ear notching; for equines, any device or method currently used to identify horses and other equines, such as detailed description, an electronic International Organization for Standardizations (ISO)-approved device, or digital photograph; for captive cervids, primarily eartag, with some exceptions; for cattle and bison, an eartag, which USDA will provide, although other devices, including branding, may be used if both states agree. The August 2011 rule lists tracking devices traditionally used for the covered species, and USDA and industry have experience with their performance, which achieves the intent of this recommendation. Electronic devices, such as transponders with microchips, must be ISO compliant. USDA and industry have experience with the performance of the animal ID tracking devices allowed under the new framework, which achieves the intent of this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to establish a robust process to select, standardize, and independently test and evaluate the performance of animal ID and tracking devices to ensure they meet minimum standards.

    Agency Affected: Department of Agriculture

  5. Status: Closed - Implemented

    Comments: Unlike NAIS (now terminated), the new traceability framework and August 2011 rule are designed specifically to integrate existing USDA and State animal disease eradication programs, such as scrapie for sheep and goats and chronic wasting disease for cervids. Under the new framework, USDA removed brands as an official form of identification, but left States the discretion to use brands, if both the shipping and receiving States agree. Currently, 14 States accept brands on livestock movements within their own State. The new framework is intended to integrate with USDA's and States' animal disease tracking programs and it allows brands to be used as identification between States that have agreed to branding; thus, it accomplishes the intent of this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to determine how NAIS will integrate with existing USDA and state animal disease eradication programs and branding systems.

    Agency Affected: Department of Agriculture

  6. Status: Closed - Implemented

    Comments: USDA has set priorities for implementing animal identification/traceability in the new framework document and the August 2011 rule. Currently, the highest priority species is cattle--specifically, traceability will be required initially for beef and dairy cattle 18 months of age or older, with benchmarks for covering cattle under 18 months old by 2015. Aquatic animals are the lowest priority. USDA includes aquatic animals in its definition of livestock and their inclusion in the traceability regulation will be considered as the National Aquatic Animal Health Plan in implemented. For most other species (e.g., sheep, goats, swine, and poultry) will move forward as States and Tribes proceed because the new framework and rule build on requirements in existing disease eradication and identification programs for those species, many of which provide traceability components. The rule sets implementation steps specific to each of the covered species. We believe that USDA's actions in setting priorities under the new framework achieve the intent of this recommendation. Since NAIS has been terminated, the NAIS species working groups were not involved; for the new framework, USDA consulted industry, State officials, and other stakeholders through numerous meetings and listening sessions across the country.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to set priorities, in consultation with the NAIS species working groups, state animal health officials, and others, for implementing NAIS incrementally by species or other criteria.

    Agency Affected: Department of Agriculture

  7. Status: Closed - Implemented

    Comments: In September 2010, USDA presented a new framework for tracking the interstate movement of farm-raised livestock and poultry to replace the voluntary National Animal Identification System (NAIS) and, in an August 2011, USDA issued a proposed rule for mandatory animal disease traceability. In the proposed rule, which applies to cattle and bison, sheep and goats, swine, horses and other equines, captive cervids (e.g., deer and elk), and poultry, USDA noted that NAIS had become a barrier to achieving meaningful animal disease traceability; although there was some support for NAIS, the comments USDA received were highly critical of the program and of having data maintained by the government. The new framework and proposal give States and Tribes primary responsibility for tracking and maintaining data on animal movement; States may also register premises, but premises registration is not required. For most species, according to the proposal, tracking builds on the traceability-related requirements in existing disease eradication and documentation requirements. For example, USDA notes that in the National Scrapie Eradication Program (NSEP), 92 percent of the cull breeding sheep are officially identified at slaughter, primarily using flock identification eartags. Most new requirements relate to cattle, where USDA believes that disease tracing capabilities are inadequate. The proposed rule presents a phased-in approach working with States and Tribes and starting with cattle 18 months of age or older, with benchmarks for covering all cattle by 2015. Because there are only a few regulations in place for horses and other equines, the proposal also contains new requirements for equines; it also addresses the traceability gap regarding moving poultry to live bird markets. Because participation will be mandatory, we believe USDA's actions achieve the intent of this recommendation.

    Recommendation: To achieve the program's goal of rapid and effective animal disease traceback, the Secretary of Agriculture should direct the Administrator of the Animal and Plant Health Inspection Service (APHIS) to reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory or creating incentives to achieve those levels of participation.

    Agency Affected: Department of Agriculture

  8. Status: Closed - Implemented

    Comments: USDA conducted the recommended cost assessment for NAIS, which estimated the cost of full implementation at $200-300 million per year between industry and government. That was a critical reason why USDA terminated NAIS and developed the new disease traceability framework. USDA has prepared a cost-benefit analysis and an initial regulatory flexibility analysis for the August 2011 rule. USDA implemented this recommendation.

    Recommendation: To implement NAIS more effectively and efficiently and achieve the program's goal of rapid and effective traceback, the Secretary of Agriculture should direct the Administrator of APHIS to conduct the planned analysis of the costs and benefits of NAIS following criteria established in Office of Management and Budget guidance for conducting cost-benefit analyses for federal programs and publish the results for comment.

    Agency Affected: Department of Agriculture

 

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