National Animal Identification System
USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback Gao ID: GAO-07-592 July 6, 2007Livestock 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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-592, National Animal Identification System: USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback
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Report to the Chairman, Committee on Agriculture, Nutrition, and
Forestry, U.S. Senate:
United States Government Accountability Office:
GAO:
July 2007:
National Animal Identification System:
USDA Needs to Resolve Several Key Implementation Issues to Achieve
Rapid and Effective Disease Traceback:
GAO-07-592:
GAO Highlights:
Highlights of GAO-07-592, a report to the Chairman, Committee on
Agriculture, Nutrition, and Forestry, U.S. Senate
Why GAO Did This Study:
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.
What GAO Found:
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.
What GAO Recommends:
GAO made several recommendations to help USDA achieve the program‘s
goal of rapid and effective animal disease traceback. In commenting on
a draft of this report, USDA generally agreed with the recommendations.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-592].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Lisa Shames at (202) 512-
3841 or ShamesL@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Key NAIS Implementation Issues Are Unresolved and Could Undermine the
Program's Goal of Rapid and Effective Traceback:
USDA Has Awarded NAIS Cooperative Agreements to Identify Effective
Implementation Approaches but Has Not Formally Evaluated Agreements'
Results:
Total NAIS Program Costs Have Not Been Determined, but USDA Recently
Announced Plans to Develop a Cost-benefit Analysis:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Select Domestic and Foreign Animal Diseases of Concern
Identified by USDA:
Appendix III: Members of GAO's Expert Panel on NAIS:
Expert Panel Members:
Appendix IV: GAO Expert Panel Questions and Responses on NAIS:
Expert Panel: USDA's Implementation of the National Animal
Identification System:
Appendix V: Select International Animal Identification and Tracking
Programs:
Appendix VI: Information on NAIS Cooperative Agreements:
Appendix VII: Comments from the U.S. Department of Agriculture:
GAO Comments:
Appendix VIII: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: USDA NAIS Budget Data, Fiscal Years 2004 (CCC Funds) through
2006:
Table 2: USDA Funding for NAIS Cooperative Agreements to States,
Territories, and Tribes, Fiscal Years 2004 through 2006:
Table 3: Species Covered by USDA NAIS Cooperative Agreement Field
Trials, Fiscal Years 2004 and 2005:
Table 4: NAIS Premises Registration Statistics, by State, as of June 4,
2007:
Table 5: USDA's Criteria for Distributing NAIS Cooperative Agreement
Funding in Fiscal Year 2007:
Figures:
Figure 1: A Calf Identified with Both a Visual and an Electronic Tag:
Figure 2: Number of NAIS Premises Registered, 2005 to Present:
Abbreviations:
APHIS: Animal and Plant Health Inspection Service:
BSE: bovine spongiform encephalopathy:
CCC: Commodity Credit Corporation:
EU: European Union:
FMD: foot-and-mouth disease:
ID: identification:
NAIS: National Animal Identification System:
OMB: Office of Management and Budget:
RFID: radio frequency identification:
TB: tuberculosis:
USDA: U.S. Department of Agriculture:
United States Government Accountability Office:
Washington, DC 20548:
July 6, 2007:
The Honorable Tom Harkin:
Chairman:
Committee on Agriculture, Nutrition, and Forestry:
United States Senate:
Dear Mr. Chairman:
U.S. agriculture provides an abundant supply of food and other products
for Americans and others around the world, annually generating more
than $1 trillion in economic activity, including more than $68 billion
in exports in 2006. Because of the economic importance of the
agriculture sector and the risks to public health as well as the
economy, we have designated the federal oversight of food safety as a
high-risk area.[Footnote 1] Within the broader sector, livestock
production contributed nearly $123 billion to the U.S. economy in 2006,
including $13.4 billion in livestock, poultry, and dairy
exports.[Footnote 2] One way to protect the health of livestock
animals--which are critically important to the integrity and safety of
the nation's food supply, the well-being of Americans, and the U.S.
economy--is through a national animal identification (ID) system to
trace back and contain diseases that spread rapidly. Our recent work
has described animal diseases and their economic and, in some cases,
human health consequences. For example, a highly pathogenic strain of
avian influenza has spread to nearly 60 countries over the past few
years, resulting in the death and destruction of millions of wild and
domestic birds and infecting almost 300 humans, more than one-half of
whom have died--creating serious concerns that the virus could reach
North America at any time.[Footnote 3] In addition, the first known
U.S. case discovered in December 2003 of one cow infected with bovine
spongiform encephalopathy (BSE) caused the U.S. beef industry to lose
more than 80 percent of its export trade, or an estimated $2 billion,
between January and September 2004.[Footnote 4] Commonly known as mad
cow disease, BSE has been linked by scientists to a fatal neurological
disease in humans known as variant Creutzfeldt-Jacob disease. Another
disease of particular concern is foot-and-mouth disease (FMD), a highly
contagious livestock disease that does not typically affect humans and
last occurred in the United States in 1929. According to several
estimates, the direct costs of controlling and eradicating a U.S.
outbreak of FMD could range up to $27 billion in current
dollars.[Footnote 5]
In response to concerns about such outbreaks occurring in the United
States and in recognition that speed and accuracy are critical factors
in controlling a disease, the U.S. Department of Agriculture (USDA)
announced in December 2003 that it would lead the design and
implementation of a nationwide program--later named the National Animal
Identification System (NAIS)--to enable USDA, states, and industry to
quickly and efficiently locate all infected and potentially exposed
animals and premises that have had contact with a foreign or domestic
disease of concern. USDA recognized that a fully functional animal
tracking system will keep the United States competitive in
international markets, can help reassure foreign consumers about the
health of U.S. livestock, and may satisfy other countries' import
requirements. Internationally, some of the United States' major trading
partners--such as the European Union (EU), Japan, and Canada--already
have mandatory national animal ID programs in place for certain
species. The Animal Health Protection Act authorizes the Secretary of
Agriculture to carry out operations and measures to detect, control, or
eradicate livestock pests and diseases,[Footnote 6] and USDA has
delegated this responsibility to its Animal and Plant Health Inspection
Service's (APHIS) Veterinary Services. USDA cites this broad authority
for implementing NAIS as either a voluntary or mandatory program.
NAIS is currently being implemented for nine livestock species groups:
bison; camelids (llamas and alpacas); cattle (beef and dairy); cervids
(deer and elk); equine (horses, mules, donkeys, and burros); goats;
poultry; sheep; and swine. Since 2004, USDA has received input on the
design and implementation of the program from various stakeholders,
including industry groups, individual producers, livestock markets,
slaughter facilities (processors), and state animal health officials.
USDA says that because NAIS is a state-federal-industry partnership,
the agency has used stakeholder input to adjust the program as NAIS has
evolved, and it encourages continued stakeholder input.
NAIS consists of three components: (1) registering all "premises" that
manage or handle livestock, such as farms, feedlots, veterinary
clinics, and livestock markets; (2) identifying livestock animals; and
(3) tracking animal movements throughout the production process, from
their premises of origin to their slaughter or death. Initially, USDA
stated that NAIS would start as a voluntary program and later become
mandatory, but, in late 2006, the agency decided that NAIS would remain
voluntary. The agency also provided a timeline for implementation and
set participation benchmarks that called for gradually increasing the
percentages of premises registered, animals identified, and animals
tracked. By August 2005, all states had the capability of registering
premises, and, as of late May 2007, USDA reported that more than
390,000 premises, or 27.5 percent of the national estimate, were
registered in NAIS.
Of the total $85.0 million funding made available for NAIS from fiscal
years 2004 through 2006, USDA has awarded $35.0 million in cooperative
agreements to states, territories, and tribes to help identify
effective approaches to register premises and to identify and track
animals. In fiscal year 2007, Congress appropriated another $33.0
million to develop and implement NAIS, and the President's Budget in
fiscal year 2008 requested an additional $33.1 million for the program.
Premises registration is currently funded by USDA, states, territories,
and tribes and, therefore, is free to the producer. The costs of animal
ID and tracking are to be borne by the livestock industry and will
vary, depending on the choices made by individual producers.
In this context, we determined (1) how effectively USDA is implementing
NAIS and, specifically, the key implementation issues identified by
livestock industry groups, market operators, state animal health
officials, and others; (2) how USDA has distributed cooperative
agreement funding 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 the livestock industry to
implement and maintain NAIS.
To address all three objectives, we reviewed USDA documents,
interviewed agency officials responsible for implementing NAIS, and
conducted site visits to selected livestock markets and cooperative
agreement field trials. We also conducted structured interviews in
person or via telephone with animal health officials in seven states.
These states were selected on the basis of their geographic dispersion;
the range in the number of premises located in each state; and, in some
cases, their high levels of livestock production. We also conducted
structured interviews in person or via telephone with, and reviewed
documents from, representatives from numerous stakeholder
organizations, including several NAIS industry working groups. In
addition, for the first and third objectives, we convened a Web-based
panel of 32 experts to learn their beliefs and opinions on various
aspects of USDA's implementation of NAIS. We selected experts who were
actively involved in the development or implementation of NAIS and were
knowledgeable of its details; who had conducted research on animal ID,
or had published in peer-reviewed journals on animal ID; or who were
recognized by their peers as an expert on NAIS. For the second
objective, we also reviewed USDA documentation related to cooperative
agreements signed between USDA and states, territories, tribes, and
industry groups from fiscal years 2004 through 2007. For the third
objective, we asked USDA and others for any NAIS cost estimates they
had developed, and we reviewed federal guidance for developing cost-
benefit analyses. A more detailed description of our scope and
methodology is presented in appendix I. We conducted our work from June
2006 to May 2007 in accordance with generally accepted government
auditing standards.
Results in Brief:
USDA has steadily increased the number of livestock premises registered
in the nation and taken some steps to address stakeholder concerns in
implementing NAIS. However, the agency has not effectively addressed
several key issues identified by livestock industry groups, market
operators, state animal health officials, and others that, if left
unresolved, could undermine the program's goal of rapid and effective
traceback and thus hinder its success. Foremost among these issues is
USDA's decision in late 2006 to continue implementing NAIS as a
voluntary program and to drop participation benchmarks that were
intended to gauge progress. Many industry groups, state animal health
officials, and experts say this approach may affect the agency's
ability to attract the necessary levels of participation to quickly and
efficiently locate all animals that are potentially exposed to a
disease. However, some industry groups oppose the program being
mandatory because they believe that NAIS could succeed as a voluntary
program or that USDA first needs to resolve several implementation
issues. USDA officials told us that the agency is analyzing what
participation levels are necessary to meet the program's goal, and that
it may introduce new, risk-based benchmarks, accordingly. In addition,
several other key problems hinder the agency's ability to implement
NAIS effectively, as follows:
* USDA has not prioritized the implementation of NAIS by species or
other criteria. Instead, the agency is implementing NAIS for numerous
species simultaneously, regardless of the species' economic value,
their risk of diseases of concern, the potential human health impact of
these diseases, or other criteria. Consequently, federal, state, and
industry resources for NAIS have been allocated widely, rather than
being focused first on the species of greatest concern and allowing
other species to be included later, on the basis of lessons learned.
Twenty-one of the 32 expert panel members said USDA should definitely
or probably implement NAIS incrementally by species and suggested
criteria to prioritize the order of implementation. USDA officials told
us that prioritizing implementation may be appropriate, such as
focusing on specific diseases of concern or commercial operations, and
that the states should determine their own priorities for
implementation.
* Although USDA aims to minimize the financial and practical impact on
producers and others in implementing NAIS, the agency has not developed
a plan to integrate NAIS with preexisting animal ID requirements, such
as scrapie ear tags and brands, for other USDA and state animal health
programs. As a result, producers have generally been discouraged from
investing in new ID devices for NAIS, according to industry groups we
interviewed.
* USDA has not established a robust process for selecting,
standardizing, and testing ID and tracking technologies. While
international programs have generally used specific animal ID devices
for their national animal ID programs, USDA has taken a "technology-
neutral" position to allow market forces to determine what devices are
most effective and practical. In addition, industry groups, experts,
and others told us that electronic ID technologies do not always
perform well in production environments, such as livestock markets, and
that the agency has not independently tested any ID or tracking
devices. Consequently, producers, livestock markets, and others are
reluctant to invest in new ID or tracking devices for NAIS, according
to industry groups and the experts.
* USDA does not clearly define the time frame for rapid animal disease
traceback. The definition of "rapid traceback" may vary by disease
because some diseases spread more quickly than others, but by not
clearly defining a rapid response for a given disease, there could be a
slower response and greater economic losses. A senior USDA official
told us the agency first needs to identify current baselines for
traceback before the agency can determine time-sensitive traceback
goals for NAIS.
* USDA does not require potentially critical information--such as the
species, date of birth, or approximate age of animals--to be recorded
in NAIS animal ID and tracking databases. This information can be
critical for efficient traceback because it helps limit the scope of an
investigation, thus saving time and potentially minimizing the economic
impact. USDA officials told us that although animal-specific data can
be valuable, the agency is collecting the minimum amount of information
needed due to some producers' concerns about protection of their
proprietary information in NAIS databases.
USDA awarded 169 NAIS cooperative agreements totaling $35 million to 49
states, 29 tribes, and 2 territories from fiscal years 2004 through
2006 to help identify effective approaches to register premises and
identify and track animals. To date, USDA has not consistently
monitored cooperative agreements, and, as a result, the agency cannot
be assured that the agreements' intended outcomes have been achieved.
In addition, USDA has not formally evaluated or consistently shared the
results of cooperative agreements with state departments of
agriculture, industry groups, and other NAIS stakeholders, which would
enable lessons learned and best practices to inform the program's
progress. USDA officials told us the quality of reports submitted to
the agency varies, and USDA has had insufficient resources to conduct
additional oversight. In fiscal year 2007, USDA plans to increase
oversight of all cooperative agreements awarded that year by assessing
progress midyear. Furthermore, USDA plans to give those states with
greater numbers of premises registered some flexibility in using
cooperative agreement funds to subsidize the purchase of animal
tracking equipment for livestock markets. For the first time, in fiscal
year 2007, USDA also plans to award $6 million in cooperative
agreements to nonprofit industry and other groups to increase premises
registration efforts.
Although USDA began to implement NAIS in 2004, 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. Twenty-nine of the 32 expert panel members
said that USDA should definitely or probably publish a cost-benefit
analysis for NAIS. The NAIS working groups, other livestock industry
representatives, and state animal health officials we interviewed also
said that the cost of implementing NAIS remained one of their biggest
concerns. USDA officials plan to hire a contractor to conduct a cost-
benefit analysis, in part, to more precisely forecast the program's
economic effects. Moreover, the Senate Committee on Appropriations and
the House of Representatives have raised concerns over how USDA has
spent funds to develop and implement NAIS. Finally, the experts had
mixed views on the impact that NAIS would have on the livestock
industry, such as whether NAIS may lead to changes in market structure
or affect prices.
To ensure that USDA continues to take steps to address unresolved
issues, we are making several recommendations aimed at improving USDA's
efforts to implement NAIS more effectively and efficiently. For
example, we are recommending that USDA 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. In addition, we are recommending that USDA 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. We are also recommending that USDA
increase the monitoring of NAIS cooperative agreements, evaluate and
publish the results of cooperative agreements on a timely basis, and
publish the planned analysis of the costs and benefits of NAIS
following criteria established in Office of Management and Budget (OMB)
guidance.
In commenting on a draft of this report, USDA stated that it
appreciated our comprehensive evaluation of NAIS and generally agreed
with our recommendations. However, regarding our recommendation that
USDA 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, USDA believed
that these standards must be defined through a consensus of affected
stakeholders and that working with stakeholders to resolve this issue
is imperative before selecting specific technologies for NAIS. We
recognize the need for USDA to work with stakeholders before
determining which ID and tracking devices are most appropriate for
NAIS. However, we emphasize that the sooner USDA selects specific
technologies, the sooner the animal ID and tracking components of the
program will be implemented effectively and efficiently. See the
"Agency Comments and Our Evaluation" section and appendix VII for a
reprint of USDA's comment letter and our responses to these comments.
Background:
The concept of animal ID is not new, in the United States or abroad.
For decades, American producers have kept records on, and used ID
methods for, livestock animals for both commercial and regulatory
purposes. Specifically, several USDA and state animal disease
eradication programs--such as programs for tuberculosis (TB) in cattle,
pseudorabies in swine, and scrapie in sheep and goats--include animal
ID requirements. Certain species and classes of animals require
officially recognized ID devices for interstate commerce, and all live
animals imported into, or exported from, the United States require
official ID. Thus, many livestock animals are already identified in the
United States by ear tags, branding, tattoos, or other devices.
However, the use of ID devices varies by breed, species, and state,
and, until NAIS, no attempt had been made to create a uniform animal ID
system of national scope and across multiple species using a universal
numbering system and central data repository.
Due to serious concerns about the United States' ability to safeguard
its livestock from the harmful effects of disease, in 2002, the
National Institute of Animal Agriculture--an organization of producers,
veterinarians, scientists, government representatives, and allied
industries--initiated a state-USDA-industry task force of approximately
70 representatives to create a national animal ID system. In 2003, USDA
expanded upon this work and established a development team consisting
of more than 70 industry associations, organizations, and government
agencies. That team ultimately produced the United States Animal
Identification Plan in December 2003, which provided the foundation for
NAIS. Although early versions of the plan focused on food animals only,
other livestock species were later incorporated. The plan was being
finalized when the nation's first case of BSE was confirmed on December
25, 2003. Five days later, the Secretary of Agriculture announced
measures to guard against BSE and indicated that USDA would expedite
the implementation of a national animal ID system.
Since 2004, USDA has solicited public comments on draft NAIS policy
documents, held public listening sessions, and met with industry groups
and others in its efforts to design and implement NAIS. In addition,
USDA has received input from 10 working groups comprising producers,
academics, and others representing the various livestock species and
industry sectors currently included in NAIS. These working groups make
recommendations to the NAIS Subcommittee, a group of state and industry
stakeholders established by USDA in September 2004 to provide regular,
formal input to the USDA Secretary's Advisory Committee on Foreign
Animal and Poultry Diseases (full committee) about how NAIS should
progress. The NAIS Subcommittee is also responsible for receiving input
from the National Institute of Animal Agriculture; the United States
Animal Health Association, an organization representing state
veterinarians and allied industry groups; and other organizations and
individuals. The full committee is a federal advisory group of state,
academic, and industry experts selected by the Secretary, which meets
once a year or as deemed necessary by the Secretary. While the NAIS
Subcommittee meets periodically, the full committee has met only twice-
-in September 2004 and September 2006--since the creation of NAIS. USDA
is not obligated to take action on the NAIS Subcommittee's, full
committee's, or others' recommendations.
For the premises registration component of NAIS, states and tribes are
responsible for submitting premises information--given to them by
producers and others--to a central, Web-based USDA premises database.
In turn, USDA allocates a unique, 7-digit, alphanumeric, premises ID
number (e.g., A123B45). The premises then receives confirmation online
or by mail from the relevant state or tribe with its unique premises ID
number.
For the animal ID component, USDA published an interim rule, effective
in November 2004, recognizing the Animal Identification Number as a
new, official numbering system for individual animals in interstate
commerce.[Footnote 7] Producers and other NAIS participants can order
ID devices from USDA-approved managers that are imprinted with a
unique, 15-digit Animal Identification Number for use on animals that
move through the production process as individuals, as is typical in
the cattle, sheep, and goat industries. Figure 1 shows a calf that is
identified with tags in both ears, with the calf's left ear bearing an
electronic tag and its right ear bearing a visual tag. Both tags have
the Animal Identification Number for official ID purposes, and the
visual tag also has a number used for the producer's herd management
purposes. For animals of the same species that typically move through
the production chain as a group, such as commercial poultry and swine,
producers can instead identify the animals with a group/lot ID number.
Group/Lot ID numbers are self-generated by the premises (not assigned
by USDA) and are maintained at the premises in management records.
Figure 1: A Calf Identified with Both a Visual and an Electronic Tag:
[See PDF for image]
Source: USDA.
[End of figure]
Lastly, for the animal tracking component, USDA has developed the
Animal Trace Processing System to allow state and federal animal health
officials to request information, in the event of an animal health
investigation, from multiple private and state animal tracking
databases containing animal location and movement records. Producers
and others are responsible for reporting certain animal movements, such
as when a change of ownership occurs or when animals commingle with
other herds or flocks. Events that would enable state and federal
animal health officials to request information from this network of
databases include an indication or a confirmed positive test of a
foreign animal disease, an animal disease emergency as determined by
the Secretary of Agriculture or state departments of agriculture, or a
need to conduct a trace to determine the origin of infection for a
domestic disease of concern. (See app. II for a list of domestic and
foreign animal diseases of concern identified by USDA.)
Key NAIS Implementation Issues Are Unresolved and Could Undermine the
Program's Goal of Rapid and Effective Traceback:
USDA has steadily increased the number of livestock premises registered
in the nation and has taken some steps to address stakeholder concerns
in implementing NAIS. However, the agency has not effectively addressed
a number of key issues identified by livestock industry groups, market
operators, state animal health officials, and others that, if not
ultimately resolved, could undermine the program's goal of rapid and
effective traceback, thus hindering its success. USDA's decision to
implement NAIS as a voluntary program without benchmarks to measure
progress may affect the agency's ability to attract the necessary
levels of participation to quickly and efficiently locate all animals
potentially exposed to a disease. In addition, USDA has not prioritized
the implementation of NAIS by species or other criteria. Furthermore,
USDA has not developed a plan for integrating NAIS with other USDA and
state animal ID requirements, nor has it established a robust process
for selecting, standardizing, and testing ID and tracking technologies.
The agency also does not clearly define the time frame for rapid
traceback. Finally, USDA does not require potentially critical
information for efficient traceback to be recorded in NAIS databases.
USDA Is Implementing NAIS as a Voluntary Program without Participation
Benchmarks:
During the first 2 years of the program's implementation, USDA stated
several times that participation in NAIS would initially be voluntary
but would eventually become mandatory to achieve full participation
and, thus, the goal of rapid and effective traceback. One of USDA's
first major NAIS policy documents, the Draft Strategic Plan 2005-2009,
released in April 2005, stated that during initial implementation,
participation would be voluntary so that stakeholders could have the
opportunity to obtain experience with the program and provide feedback
as successful and practical solutions evolved. The plan also provided a
timeline for implementation, with premises registration and animal ID
to be required by January 2008 and the reporting of defined animal
movements to be required by January 2009, under what would become an
entirely mandatory program. The plan stated that this phased-in
approach was "to support the transition from voluntary to mandatory as
full implementation is achieved." In addition, the plan also stated
that, "While market forces may eventually create more inclusiveness,
the clear stakeholder support for transitioning to a mandatory program
and the urgency of achieving the goal, suggest that setting a date for
that transition would benefit the program."
Later, the April 2006 Strategies for the Implementation of NAIS set
benchmarks that were intended to gauge progress in attaining full
participation. These benchmarks called for gradually increasing the
percentages of premises registered, animals identified, and animals
tracked from January 2007 through January 2009. Specifically, for
premises registration, USDA aimed for 25 percent participation by
January 2007, 70 percent by January 2008, and 100 percent by January
2009. In addition, the implementation plan called for 40 percent of
animals being identified by January 2008, 100 percent of "new" animals
less than 1 year of age being identified by January 2009, and 60
percent of new animals having complete tracking data by January 2009.
USDA stated that it would evaluate whether participation levels were
increasing at rates that would achieve full participation by 2009, and
that, if this were not the case, USDA would develop federal regulations
to require industry to identify their premises and animals.
In May 2006, in an announcement for NAIS cooperative agreements, USDA
stated that it anticipated promulgating regulations by early 2008 to
require participation in all three components of the program.
Furthermore, in a document supporting its fiscal year 2007 budget
submission to OMB, USDA stated that the intrinsic value of its
investment in NAIS was based on the assumption that there would be
sufficient animal ID and movement data available to support the
program's traceback goal. USDA also said that if participation fell
below expectations, traceback would periodically fail because of the
lack of animal tracking information from nonparticipants.
However, in August 2006, reporting that 20 percent of the nation's
premises had been registered, USDA decided that NAIS would permanently
remain a voluntary program. USDA officials told us that due to
opposition from some industry groups, it is imperative that industry
advance the program, rather than government regulations, to encourage
participation. Some industry groups believe that NAIS could succeed as
a voluntary program or that USDA first needs to resolve several key
implementation issues before making participation mandatory. For
example, officials from the National Cattlemen's Beef Association told
us they believe that NAIS could be successful as a voluntary program,
such as the beef industry's 20-year-old Beef Quality Assurance program,
which covers about 95 percent of cattle in feedlots and aims to reduce
drug residues and pathogen contamination. The association officials
also told us that if NAIS became mandatory, producers who have
voluntarily participated would lose the market advantage they currently
enjoy through higher prices paid at market or slaughter for animals
they identify for marketing or management purposes. Another industry
group, the American Farm Bureau Federation, which in 2006 supported
NAIS being a mandatory program, expressed its support in January 2007
for NAIS to be voluntary, while cautioning that USDA should not make
the program mandatory until the agency has published a full cost
analysis for the program. The Livestock Marketing Association--a
national trade association representing over 700 livestock auction
markets, dealers, and other livestock marketing businesses--also wrote
in comments to USDA in 2005 that NAIS should remain voluntary until
USDA addresses several implementation issues, including the
effectiveness and availability of animal ID technology.
In November 2006, USDA also dropped its participation benchmarks from
the most recent policy document for the program, the draft NAIS User
Guide.[Footnote 8] Despite a steady increase in the number of premises
registered since USDA began reporting premises registration information
in January 2005 and reaching the 25 percent target (nearly 360,000
premises) in early February 2007 (see fig. 2), USDA officials told us
they dropped the participation benchmarks because meeting future
benchmarks for all components of NAIS was no longer realistic. Instead,
the officials said the agency is analyzing what participation levels
for all components of NAIS would achieve the "critical mass" necessary
to have an efficient and effective program. The officials added that
the agency does not expect that equal levels of involvement across all
species will be necessary, and that new, risk-based participation
benchmarks for premises registration, animal ID, and animal tracking
may be developed accordingly, which could vary by species. However,
USDA has not determined what action it may take if participation levels
do not meet those new benchmarks.
Figure 2: Number of NAIS Premises Registered, 2005 to Present:
[See PDF for image]
Source: GAO summary of USDA data.
Note: On the basis of 2002 U.S. Census of Agriculture data, USDA's
National Agriculture Statistics Service estimates there are
approximately 1.4 million distinct livestock premises nationwide (with
more than $1,000 in annual income), which may contain one or more
species.
[End of figure]
Although it may be too soon to determine whether USDA's current
approach will be successful, many industry groups, state animal health
officials, and the experts we surveyed say the program will likely need
to become mandatory to achieve the levels of participation that are
necessary to rapidly and effectively locate all potentially exposed
animals in a disease traceback. In the Draft Strategic Plan, for
instance, USDA reported that most individuals who spoke about this
subject at the agency's 2004 listening sessions preferred, by a ratio
of 3:1, a mandatory program to a purely voluntary program. USDA also
reported at that time that a survey of National Institute of Animal
Agriculture members showed even stronger support, by a ratio of 8:1,
for a program that is or will become mandatory. In addition, state and
industry officials we interviewed said that as a voluntary program
without benchmarks, NAIS has lost momentum, deterred participation, and
faces an uncertain future. For example, officials from one major
agricultural state told us that USDA's changed direction on whether the
program would become mandatory has challenged the state's premises
registration efforts, because many producers are motivated by
compliance with federal requirements, not necessarily by NAIS's
traceback goal alone. These officials also said that the lack of
participation benchmarks had compromised the state's credibility with
producers and its ability to make progress in implementation. As of
early June 2007, this state had less than 16 percent of its premises
registered, and the officials believed there is little incentive for
producers to participate in NAIS. Moreover, three states where premises
registration is mandatory by state law--Indiana, Michigan,[Footnote 9]
and Wisconsin--accounted for about 26 percent of USDA's total premises
registered nationally as of that time.
Furthermore, a majority of the 32 expert panel members said that 81
percent to 100 percent of producers, livestock markets, and slaughter
facilities would need to register their premises to achieve the
program's goal of rapid and effective traceback (see apps. III and IV
for more details about these experts and their responses to our
questions). By contrast, under a voluntary program, only 1 expert
believed that producers would achieve at least 81 percent participation
in premises registration, while 11 experts believed that level would be
achieved by livestock markets, and 20 experts believed that level would
be achieved by slaughter facilities. For the animal ID and tracking
components, experts had similar views. For example, a majority believed
that 76 percent to 100 percent of producers, markets, and slaughter
facilities would need to participate in animal tracking to make the
program effective, while a minority believed that level would be
achieved in any of those sections under a voluntary program. Overall,
27 of the 32 experts said participation in NAIS should definitely or
probably be mandatory.
Several other countries, including the United States' major
agricultural trading partners and competitors, have instituted
mandatory animal ID programs for cattle and, in some cases, a few other
species. For example, the EU has mandatory programs in which all cattle
born or moved across EU state lines as of 2000 must be identified with
two individual ear tags and an animal passport, and member states must
maintain computerized databases that record births, movements, and
deaths. Since several cases of BSE were discovered in 2001, Japan has
made a series of changes to its food safety legislation, resulting in a
mandatory system where all beef and dairy cattle must be identified
using an ear tag. Information is maintained on an animal's ID number,
breed, gender, and production history from the farm of origin through
distribution to consumers. Similarly, in 2001, Canada started a
compulsory animal ID program that applies to all bovine and bison and
now requires that animals receive a radio frequency identification
(RFID) tag when leaving their herd of origin,[Footnote 10] which is
collected at slaughter or export. Canada later expanded its program to
sheep in 2004, requiring the use of visual ear tags. Brazil, the
world's largest beef exporter, gradually phased in its mandatory ID
program for cattle and bison starting in January 2002; the entire herd
is expected to be identified by the end of 2007. Australia, the world's
second-largest beef exporter, has developed a mandatory system that
uses RFID to identify and trace cattle from farm of origin to
slaughter. Australia has been moving toward a fully integrated program
linking electronic ID devices, product bar coding, and a central
electronic database. Appendix V provides more detailed information on
select international animal ID and tracking programs.[Footnote 11]
To increase participation in NAIS, several industry groups, state
animal health officials, and the experts we surveyed have also
suggested that USDA provide incentives, such as financial assistance,
to industry to implement the animal ID and tracking components. For
instance, the NAIS Cattle Working Group recommended in 2004 that USDA
assume primary financial responsibility for funding the initial
development of the basic infrastructure required for animal ID and
tracking--including equipping concentration points, such as livestock
markets and slaughter facilities, with RFID readers and software to
capture the data electronically. Livestock market operators and others
also say such financial support would be an attractive incentive
because RFID technology, if effective, would allow animal movements to
be recorded as quickly as the current "speed of commerce" and,
therefore, would not slow down business operations. The NAIS
Subcommittee also recommended, in 2005, a cost-sharing arrangement
between USDA and industry to fund the program's implementation. The
Secretary's Advisory Committee on Foreign Animal and Poultry Diseases
adopted these recommendations as well as the other NAIS working group
and Subcommittee recommendations presented at its September 2006
meeting. One state that has already created a cost-sharing incentive is
Wisconsin, where the state contributes 50 percent, or up to $1, of the
cost of an RFID ear tag on a first-come, first-served basis under its
voluntary animal ID program. Wisconsin officials say the cost-sharing
arrangement is designed to make the program more attractive to the
state's producers, and, as of early March 2007, the state had approved
reimbursing producers for a total of 30,000 tags for cattle, which was
up from 20,000 tags the previous month.
However, USDA officials told us that the power of producers to protect
themselves and their animals is a tremendous incentive for
participation in NAIS, and, as the program continues to be implemented
and developed, additional incentives will be realized by USDA,
producers, and state and industry partners. Nonetheless, whether NAIS
is mandatory or voluntary, the lack of participation benchmarks
prevents USDA from measuring progress in attaining the necessary
participation levels for an effective program.
Several Other Key Issues Hinder USDA's Ability to Implement NAIS
Effectively:
Industry groups, market operators, state animal health officials, and
others have identified several other key problems that, if left
unresolved, could undermine the program's goal, further hindering
USDA's ability to implement the NAIS program effectively.
USDA Has Not Prioritized the Implementation of NAIS by Species or Other
Criteria:
USDA has not prioritized the implementation of NAIS by species or other
criteria. Instead, the agency is currently implementing NAIS
simultaneously for numerous species, regardless of their economic
value, their risk of diseases of concern, the potential human health
impact of these diseases, or other criteria. Consequently, federal,
state, and industry resources for NAIS have been allocated widely,
rather than being focused first on the species of greatest concern and
allowing other species to be included later, on the basis of lessons
learned. In contrast, international animal ID programs have generally
started implementation with one species (cattle) and, in some cases,
later expanded to include a few other species, such as sheep, bison,
and goats, on the basis of disease risk, economic importance, or
potential human health impact. In addition, 21 of the 32 expert panel
members said USDA should definitely or probably implement NAIS
incrementally by species, while 8 experts said USDA should definitely
or probably continue with its current approach to implement the program
for numerous species simultaneously.[Footnote 12] Many of the 32
experts suggested criteria that USDA could use to determine the
priorities given to each species in implementing NAIS, including
whether it is a food animal; its likelihood of capturing diseases of
concern; the risk that the animal will spread a disease harmful to
human health; the relative ease of implementation for a particular
industry; and the industry's impact on the U.S. economy, including
export value.
Prioritizing implementation for certain species before trying to apply
the program to numerous species would likely result in more efficient
and cost-effective implementation, on the basis of lessons learned and
best practices being identified. In addition, the industries currently
covered by NAIS appear to be at various stages of readiness to
implement NAIS. For example, the Bison, Camelid, Cattle, Equine, Swine,
Sheep, and Goat Working Groups have submitted reports to USDA with
implementation recommendations for their industries, but the Cervid and
Poultry Working Groups have not. Furthermore, according to industry
representatives, some industries, such as commercial swine and poultry
operations, already have widespread ID and tracking systems in place
that would allow traceback to occur within 48 hours, while other
industries may not.
USDA officials pointed out that an animal ID program to support the
animal health needs of all livestock species would be unique in the
world and would place the United States in a position to set a new
standard for animal ID. Some industry groups have expressed their
support for NAIS being implemented for all species, since many
transmissible diseases are not species-specific. For example, the
National Livestock Producers Association, which represents about
200,000 producers across the country, wrote USDA in 2005 that the true
value of NAIS rests in its potential ability to track all livestock
animals, regardless of species, due to the extent of their commingling
and potential to spread disease. The association added that NAIS would
not be very effective or equitable if all species were not included as
soon as possible. Furthermore, 21 of the 32 experts we surveyed said
USDA should definitely or probably continue with its current approach
to include all species, rather than limit NAIS to one or a few species.
USDA officials also told us that establishing NAIS across all species
is critical, because many operations handle more than one species, and
that focusing entirely on cattle, as some other countries have done, is
a critical flaw since some animal diseases cross species lines.
Nonetheless, USDA officials told us they recognize that prioritizing
program implementation may be appropriate, such as by focusing on
specific diseases of concern or large commercial operations, and that
the states should determine their own priorities for implementation.
These officials also said future NAIS plans will more clearly identify
higher-risk areas or sectors within the species. In commenting on a
draft of this report, USDA told us it plans to develop, in
collaboration with the species working groups, a NAIS Short-Term and
Long-Term Implementation Strategies document that will contain actions
for the remainder of 2007 through 2011. Specifically, the agency stated
that the short-term strategy, targeted for publication in August 2007,
will target species or industry sectors that have the greatest need for
advancing premises registration, animal ID, and tracking. The long-term
strategy will be distributed in early 2008 and will call for an
evaluation of participation through 2009 to determine what actions,
such as incentives, may be needed to accelerate participation in the
voluntary program.
USDA Has Not Developed a Plan for Integrating NAIS with Other USDA and
State Animal ID Requirements:
Although USDA aims to minimize the financial and practical impact on
producers and others in implementing NAIS, the agency has not developed
a plan to integrate NAIS with preexisting programs and systems. Many
producers are already required to participate in preexisting USDA and
state animal disease eradication programs that use specific ID devices
with different numbering systems or that require branding. For example,
the National Scrapie Eradication Program for sheep and goats requires
visual ear tags, and other USDA-state programs require ear tags for
brucellosis and TB in cattle and ear notches in swine. In addition,
several western states recognize branding as an official ID for disease
control purposes. As a result, producers have generally been
discouraged from investing in new ID devices for NAIS, according to
industry groups we interviewed, thereby inhibiting implementation of
the program's animal ID and tracking components.
Importantly, while USDA published an interim rule effective in November
2004 recognizing the Animal Identification Number as a new, official
numbering system for individual animals in interstate commerce, this
new system does not replace other, USDA-recognized, official numbering
systems. The rule established that the Animal Identification Number may
be used for official ID in other disease eradication programs.
Nonetheless, USDA officials told us that they are evaluating how NAIS
and other official ID systems can be standardized and moved to a single
numbering system, to the extent practical, and that eventually, the
agency expects Animal Identification Numbers to become the standard
national numbering system used for certain species, individual ID
methods, or both. USDA told us that as of early March 2007, 1.3 million
Animal Identification Number RFID ear tags had been distributed,
including some that are being used for state disease eradication
programs. For example, USDA reported that about 500,000 tags had been
distributed to Michigan producers, where the state's bovine TB
eradication program requires all cattle to have RFID ear tags prior to
movement from their premises.
For NAIS not to impose undue costs on producers by requiring additional
ID devices, stakeholders say the program must be integrated with
preexisting programs and systems. However, USDA faces challenges in
integrating NAIS with other animal ID requirements. For example, Sheep
Working Group members told us that because the scrapie program already
assigns a flock ID number to each premises--plus a unique, individual
ID number to each animal--sheep producers do not see the need to
participate in NAIS, which involves different premises and individual
animal ID numbering systems. Another challenge is that brands identify
all animals raised by a specific producer as a group, not as
individuals, and the same brands are often used in different states or
even in different counties within the same state. USDA's NAIS User
Guide states that registered brands are not considered to be an
official, individual animal ID as called for by NAIS because cattle
typically move through the production process as individuals. In
addition, NAIS animal tracking requirements may differ operationally
from state brand laws and practices. For example, New Mexico requires
state authorities to inspect all livestock moving across brand district
lines, which contrasts with NAIS, where the responsibility of reporting
animal movement lies with the premises receiving animals. New Mexico
officials told us that if they were to implement NAIS as envisioned,
the time required for state inspections would at least double if
inspectors were required to read and report ID tags. The Cattle Working
Group recommended, in 2004, that USDA develop protocols for integrating
existing brand laws with NAIS individual animal ID requirements and for
the reporting of animals' movements from brand law states to nonbrand
law states.
USDA officials told us that the need to have a single numbering system
across all species is less important than getting animals individually
identified and tracked using any official ID system recognized by USDA.
Furthermore, these officials said that while standardizing to a single
numbering system for animal ID may eventually be appropriate, USDA
recognizes there are differences among species and that cost,
technology capability, and practicality must be considered before
phasing out existing ID devices that have proven to be workable for
producers. For example, the 15-digit Animal Identification Number may
not be the most practical numbering system when used on visual ear tags
for smaller animals since the size of the tag does not lend itself to a
15-digit number. Nonetheless, USDA officials are starting to address
some integration issues. For example, USDA officials told us in April
2007 that the agency has decided to allow the official ID devices and
numbering systems used by other disease eradication programs for the
purposes of NAIS as well, although the agency has not yet communicated
this development to industry. In addition, in late 2006, a NAIS Brand
State Working Group was formed, in part to identify what brand concepts
could integrate with NAIS. In commenting on a draft of this report,
USDA informed us that it will update the NAIS User Guide in October
2007 to more clearly reflect the use of other official ID numbers
within NAIS.
USDA Has Not Established a Robust Process for Selecting, Standardizing,
and Testing ID and Tracking Technologies:
International programs have generally used specific animal ID devices
for their national animal ID programs, and some NAIS working groups
have recommended specific ID devices for their species, such as RFID
ear tags for cattle and RFID microchip implants for horses. However,
USDA has taken a "technology-neutral" position to allow market forces
to determine what devices are most effective and practical and to
accommodate future technologies. In a NAIS policy document on ID
devices released in February 2006,[Footnote 13] USDA stated that
individual, visual ID devices are a starting point to ensure greater
participation among producers and asserted that a neutral approach
allows RFID; biometrics, such as DNA and retinal imaging devices; and
other potential technologies to be used as supplemental identification.
Nonetheless, that document also stated that uniformity and
compatibility of technology are critical to ensure that the collection
of animal ID data is practical and cost-effective throughout
production. Furthermore, USDA recognized the need to have ID
technologies that are compatible with Canada and Mexico. USDA also
stated that as NAIS is phased in, ongoing efforts to harmonize animal
ID with other countries will facilitate safe trade.
While not all species can use the same devices due to industry
preferences or physical limitations, such as small ears, USDA's
technology-neutral approach means, for example in the cattle industry,
that a producer can choose to use visual ear tags; low-or high-
frequency RFID ear tags; or other advanced technologies, such as
retinal imaging. There are costs and benefits associated with any
device. For example, visual ID devices are less expensive but require
manual recording, which may cause errors and slow down the "speed of
commerce" at livestock markets and slaughter facilities. RFID systems,
on the other hand, allow data to be captured automatically into
databases, but these systems are also not consistently accurate and are
more expensive--in terms of both the ID device and the associated
infrastructure (reader, installation, and computer use). With such a
wide range of options in animal ID and tracking devices, industry
groups and expert panel members told us that producers and market
operators fear that their choices may be inconsistent with others in
the marketplace, or that USDA will adopt specific devices in the
future, and they may find themselves having made the wrong investment
decision. For instance, a producer may find that the closest livestock
market uses electronic readers and cannot easily accommodate visual ear
tags; alternatively, the market may not have installed RFID reader
equipment, and the producer would not get the anticipated return on his
or her investment. From another perspective, a multispecies livestock
market, based on its customers, may face a dilemma of investing in
equipment to read and record visual tags, RFID tags, RFID implants, and
other devices--or risk being unable to capture all information quickly
and efficiently and losing some customers. Consequently, producers,
livestock markets, and slaughter facilities have generally been
discouraged from investing in ID or tracking devices, thus inhibiting
implementation of the animal ID and tracking phases.
Asked whether USDA's technology-neutral position encourages or
discourages producers' investment in animal ID technology, 23 of the 32
expert panel members said this position definitely or probably
discourages investment, and 6 said it definitely or probably encourages
investment.[Footnote 14] In their written responses elaborating on this
question, several experts said USDA's technology-neutral approach
limits the interoperability (compatibility) of different systems in
place, thus reducing the viability of a consistent, national traceback
program. In addition, they wrote that it has caused confusion,
uncertainty, and a "wait-and-see" attitude in the marketplace, and that
it will take time to sort out efficient from inefficient technologies.
Conversely, other experts replied that USDA's technology-neutral
approach allows marketplace competition to advance new or improved
technologies and drive fair prices. Similarly, for animal tracking,
more experts replied that USDA's approach definitely or probably
discourages investment by producers, livestock markets, and slaughter
facilities more than it encourages investment. For example, 22 experts
said USDA's approach discourages investment by livestock markets,
compared with 2 who said it encourages such investment; 17 experts said
it discourages investment by slaughter facilities, whereas 4 said it
encourages that industry sector to invest.
While USDA has not selected specific animal ID devices, the agency has
published minimum standards for the various ID devices recommended to
date by the species working groups and the NAIS Subcommittee.
Specifically, USDA has established printing and performance standards
for visual and RFID ear tags that address characteristics such as
durability (expected tag life); tag loss; visual readability of the 15-
digit Animal Identification Number; and, in the case of RFID,
electronic read rates and ranges. USDA has published similar
performance standards for RFID implants, with additional
characteristics addressing the migration or breakage of the device and
its being harmless to an animal. However, USDA has not published
standards for RFID readers and does not expect to do so unless the
agency purchases readers for use by animal health officials, in which
case it says it will define performance standards for those specific
environments. In addition, USDA has not established a robust process to
independently test and evaluate the performance of animal ID and
tracking devices.
Industry groups, expert panel members, and others told us that RFID
devices do not always perform well in production environments, such as
livestock markets, particularly with RFID readers being made by
different companies. For example, one NAIS pilot project found that in
loading cattle onto commercial trucks, RFID readers read only 70
percent of the RFID ear tags, with variations among tag manufacturers
ranging from 47 percent to 96 percent.[Footnote 15] As a result,
stakeholders are lacking reliable, independent information on the
effectiveness of animal ID and tracking devices, and without such
information, they are reluctant to invest in these devices.
It is common U.S. practice to select one technology for systems that
need to be widely implemented in different environments to ensure
consistency and interoperability across multiple users. We have
previously reported that a robust process for selecting technologies,
setting and revising performance standards, and testing and evaluating
technologies against those standards leads to the most effective and
efficient use of technology.[Footnote 16] For example, we have reported
on the necessity of the federal government's selection and
standardization of RFID cards and readers for federal employees so that
the ID cards can be read at any federal agency across the
nation.[Footnote 17]
Several expert panel members suggested that USDA provide funding for
independent, third-party evaluations of technologies and make results
of such work readily available; appoint a standards committee to
evaluate and make recommendations on the basis of sound science; or
require independent evidence that devices meet standards before
approving them. The NAIS Subcommittee also recommended, in 2006, that
USDA establish an objective process to (1) test the performance of ID
devices to ensure they meet NAIS standards in various production
environments and over extended periods and (2) evaluate new
technologies as they emerge. Typically, federal agencies rely on
independent laboratories that are certified by a government agency,
such as the National Institute of Standards and Technology, for such
testing and evaluation.
USDA officials told us they are working with industry to determine
better ways to define performance criteria and establish a more
thorough process to test and evaluate ID devices, but they did not
specify a time frame for these developments. Toward this end, the
agency held preliminary discussions in mid-April 2007 with the American
Society for Testing and Materials' Committee on Livestock, Meat and
Poultry Evaluation Systems to form a task force to fine-tune ID
performance standards for NAIS and help USDA put testing protocols in
place. In the February 2006 NAIS policy document on ID devices, USDA
stated that when NAIS becomes fully operational, the agency will
develop an approval process for official ID devices and more complete
testing and evaluation procedures. Manufacturers of Animal
Identification Number devices, regardless of any prior permission from
USDA, will have to submit new or appended applications to be considered
for "USDA Approved" status. Evaluations may include laboratory or field
studies to verify compliance with criteria and specification standards,
either before or following issuance of "USDA Approval Pending" or "USDA
Approved" status for ID devices.
USDA Does Not Clearly Define the Time Frame for Rapid Traceback:
When USDA announced NAIS in 2004, the program's traceability goal was
to locate all potentially exposed animals within 48 hours of a
disease's discovery, and both USDA and states conveyed that message in
their outreach to producers and others. However, USDA's most recent
NAIS policy document, the draft NAIS User Guide issued in November
2006, is silent on this time frame and instead says NAIS will allow
producers and animal health officials to respond as "quickly,
efficiently, and effectively as possible." By definition, traceback
goals need to be time-sensitive and cost-effective to efficiently
target and evaluate the program's success in eliminating a disease
outbreak. If rapid traceback goals are not clearly defined, there could
be a slower response to an animal disease outbreak and, therefore,
greater economic losses.
Of the 32 expert panel members, 25 defined rapid traceback in an animal
disease event as occurring within 48 hours, with 10 of the experts
defining it as 24 hours or less and 15 defining it as 25 to 48 hours.
State animal health and industry officials told us it is important that
USDA communicate a specific time frame to encourage participation,
reinforce the necessity of rapid traceback, and have a measure by which
to evaluate results. However, a senior USDA official told us that the
definition of "rapid traceback" may vary by disease, because some
diseases spread more quickly than others and some diseases are limited
in how they can be transmitted. For example, traceback for FMD might
ideally occur within 12 hours because the disease spreads so rapidly.
By contrast, because BSE is transmitted only through animal feed
containing certain contaminated animal products, and scrapie is
transmitted during the breeding season, a longer traceback would be
appropriate. In addition, the senior official told us that until USDA
collects baseline information on tracebacks for specific diseases, the
agency cannot determine time-sensitive, cost-effective traceback goals
for NAIS.
USDA Does Not Require Potentially Critical Information for Efficient
Traceback to Be Recorded in NAIS Databases:
When producers and other participants register their premises, they are
required by USDA to record only their name and contact information,
with species information being optional. In addition, when USDA-
approved managers distribute ID devices to a producer, they must record
the devices' unique animal ID numbers, the premises ID number where the
devices were sent, and the date of distribution. However, USDA does not
require additional information, such as the species, date of birth, or
approximate age of the animals, to be recorded in NAIS animal ID or
tracking databases.
Information that may be critical for narrowing the scope of a
traceback--thus saving time and resources and potentially minimizing
the economic impact--includes the species, date of birth, or
approximate age of an animal. Many diseases, such as bovine TB, affect
only specific species or generally affect animals of a certain age,
such as in the case of Johne's disease, which is usually contracted at
a young age. Consequently, if a new case of these diseases arose in the
United States, tracing other species or animals of a different age may
unnecessarily use federal, state, and industry resources in locating
animals and premises that may not be affected--thus impeding the goal
of rapid and effective traceback. Similarly, most equine diseases of
concern affect only equine species, and exotic Newcastle disease
affects only poultry, so tracing other species would be an inefficient
use of time and resources. Other state and federal animal disease
eradication programs require the recording or reporting of this type of
information. For example, the Bovine Tuberculosis Eradication Program
requires, for all TB-tested bison and cattle, the reporting of the
animal's unique, official ID device; approximate age; gender; and
breed. In addition, the National Scrapie Eradication Program requires
goat flock owners to maintain a management and monitoring plan that
must record an animal's gender, year of birth, and breed following the
discovery of scrapie within the flock.
The Cattle Working Group recommends that producers identify calves at
birth or at the earliest date possible to support animal disease issues
when the age of an animal is needed, noting that when the precise date
of birth is not known, the approximate birth date within 2 to 3 months
should be recorded. USDA officials acknowledged that although animal-
specific data can be valuable, the agency is collecting the minimum
amount of information needed for traceback to (1) respond to some
producers' concerns about protection of their proprietary information
in NAIS databases and (2) encourage participation. In addition,
participants have the option to record such information in ID and
tracking databases, and USDA encourages them to do so. Nonetheless,
without this information being consistently recorded in NAIS databases,
USDA and state officials may not be able to efficiently trace only
those animals potentially affected by a disease.
USDA Has Awarded NAIS Cooperative Agreements to Identify Effective
Implementation Approaches but Has Not Formally Evaluated Agreements'
Results:
USDA has awarded $35.0 million in NAIS cooperative agreements to
states, tribes, and territories to help register premises and identify
and track animals. However, USDA has not consistently monitored or
formally evaluated the results of these cooperative agreements. In
addition, USDA has not consistently shared cooperative agreement
results with NAIS stakeholders. USDA plans to increase its oversight
and give states with greater participation in NAIS some flexibility in
using their cooperative agreement funds.
USDA Awarded 169 Cooperative Agreements between Fiscal Years 2004 and
2006:
To help identify effective approaches to register premises and identify
and track animals between fiscal years 2004 and 2006, USDA awarded 169
cooperative agreements, totaling $35.0 million, to 49 states, 29
tribes, and 2 territories. NAIS cooperative agreement awards ranged in
size from $7,381 to $1.2 million, and the average award was about
$207,000. In fiscal years 2004 and 2005, USDA did not require
recipients to contribute to, or share, costs (cost-share); however, in
fiscal years 2006 and 2007, USDA required certain recipients to
demonstrate 20 percent in matching funds, through cash or in-kind
(noncash) contributions. For more information about NAIS cooperative
agreements' funding by fiscal year, see appendix VI, table 2.
Cooperative agreements are typically funded for a 12-month funding
period, with recipients required to submit both quarterly
accomplishment and financial status reports.
USDA required all NAIS cooperative agreement recipients to submit
information to USDA in an initial work plan containing proposed project
objectives, species and industry sector focus, as well as milestones
for measuring progress. Although some premises registration cooperative
agreements proposed activities that would span across most species and
industry sectors covered by NAIS, other projects proposed focusing
premises registration activities on one, or a few, species and sectors
of the livestock industry. Of field trial cooperative agreement funding
to test animal ID and tracking solutions, all but two field trials
intended to focus on beef or dairy cattle; several proposed work on
sheep; a few included swine, cervids, goats, bison, and equine; and
only one project intended to focus some work on camelids. While no NAIS
field trials proposed work on the poultry industry, USDA has previously
funded work, through funds other than NAIS cooperative agreements, that
examined the tagging and record-keeping requirements that would
facilitate tracking of birds in the live bird marketing system. For
information on species covered under NAIS field trials, see appendix
VI, table 3.
Field trial funding recipients also varied in the number of industry
sectors they intended to involve in cooperative agreement activities.
Overall, more than one-half of recipients intended to work with
producers, livestock markets, slaughter facilities, and feedlots. USDA
did not require field trials covering multiple species or industry
sectors to include in initial work plans information regarding how
funding was to be spent on each species or sector. USDA officials told
us that they have not requested such details because of the
interconnectivity of the activities associated with cooperative
agreements.
Most of the cooperative agreement awards were focused on premises
registration. Specifically, of the $35.0 million awarded in fiscal
years 2004 through 2006, USDA awarded 146 cooperative agreements
totaling $23.4 million for premises registration efforts to 49 states,
29 tribes, and 2 territories. These premises registration awards
provided funding for activities such as hiring personnel to register
premises, developing educational materials, and providing outreach to
producers and nonproducer participants on the goals of NAIS. For
example, 1 cooperative agreement awarded to the Navajo Nation was for
the development of communications in the Navajo language for outreach
on premises registration and animal ID. In addition, some of these
cooperative agreements funded limited animal ID and tracking
activities, along with premises registration.
In fiscal years 2004 and 2005, USDA also awarded field trial
cooperative agreements. Specifically, in fiscal year 2004, USDA awarded
16 cooperative agreements totaling $9.7 million to 15 states and 1
tribe. USDA estimates that $1.8 million of the $9.7 million awarded was
used to support premises registration activities. The remainder was
used for field trials to develop, test, and offer solutions for
applying animal ID devices and collecting animal tracking information.
For example, 1 cooperative agreement with the Wyoming Livestock Board
tested whether existing brand inspection personnel and infrastructure
could be used to track livestock changing ownership and livestock
entering into interstate commerce through Wyoming livestock markets. In
fiscal year 2005, USDA awarded 7 cooperative agreements totaling $1.9
million to 6 states and 1 tribe for field trials to support research,
including the assessment of existing and novel ID technologies.
USDA anticipates awarding an additional $20.5 million in cooperative
agreements in fiscal year 2007. Of this, USDA anticipates awarding
$14.5 million for continued support of premises registration,
education, and outreach activities under approximately 80 cooperative
agreements to 50 states, 28 tribes, and 2 territories. As of March
2007, USDA had awarded 31 of the anticipated 80 cooperative agreements,
totaling $6.7 million. The remaining $6.0 million in fiscal year 2007
funding for cooperative agreements will be provided for the first time
to nonprofit organizations for premises registration activities. In
January 2007, USDA entered into a cooperative agreement with the
National Pork Board to begin work with pork producers to encourage
premises registration. Subsequently, in February 2007, USDA announced
that other nonprofit industry organizations, historically black
colleges, tribal land-grant colleges, and tribal organizations were
also eligible for these awards, which are intended to support the
continued registration of premises.
USDA Has Not Consistently Monitored or Formally Evaluated NAIS
Cooperative Agreements or Consistently Shared Their Results:
To date, USDA has not consistently monitored or formally evaluated NAIS
cooperative agreements and has not consistently shared their results
with state, industry, and other stakeholders. USDA officials told us
that NAIS program staff provided some oversight for field trial
cooperative agreements as well as for tribal premises registration
cooperative agreements. However, NAIS program staff do not directly
monitor most NAIS cooperative agreements; instead, USDA delegates
administrative oversight activities for each cooperative agreement to
designated representatives, mostly Area Veterinarians in Charge whose
overall responsibility is to supervise and perform the official animal
health activities of APHIS in the state concerned. These individuals
are responsible for direct administration of the individual state
premises registration and field trial cooperative agreements, including
the monitoring and assessment of agreements. According to USDA, it is
appropriate for these designated representatives to monitor cooperative
agreements because they are familiar with the circumstances associated
with implementing projects in a particular state. We have previously
reported with other government audit organizations that monitoring the
performance of federal awards helps to ensure that goals are reached
and required deliverables are completed.[Footnote 18] According to USDA
officials, the designated representatives responsible for monitoring
cooperative agreements have a multitude of competing responsibilities
and thus may not have sufficient time or resources to oversee
cooperative agreements.
In addition, NAIS program staff did not conduct any formal evaluation
of NAIS cooperative agreements. Evaluating results against cooperative
agreement goals can help to identify ways to improve program
performance. USDA officials said that the quality of quarterly and
final accomplishment reports provided to designated representatives by
cooperative agreement recipients varied. They said that many times,
these reports identified what was being done, rather than what was
being accomplished. For example, one state premises registration
project set milestones for educating 60 percent of livestock producers
and registering 40 percent of premises; however, the reported results
included the purchase of computers, number of presentations given to
producer organizations, and number of premises registration forms that
were printed for distribution. Furthermore, our analysis of available
reports indicated that results were not reported or were of limited
value because initial project goals and milestones presented in
recipients' work plans were vague or unclear.[Footnote 19] In addition,
several states indicated to us that they had difficulty completing the
work outlined in their cooperative agreements within given time frames.
For instance, one state told us that it was difficult for it to hire an
ID coordinator in its first year of cooperative agreement funding,
which meant the state was unable to use all of the funds it was
allocated. Thus, while USDA has awarded the majority of cooperative
agreement funds to support premises registration, the agency has not
been able to determine effective or ineffective approaches for
increasing premises registration, animal ID, or tracking.
USDA has formally shared few results of cooperative agreements with
NAIS stakeholders, hindering them from identifying approaches that have
worked to achieve NAIS program objectives, such as increasing outreach,
as well as ineffective approaches, such as the interoperability of RFID
devices and readers. To date, USDA has provided information regarding
NAIS field trial cooperative agreements on three occasions. In April
2005, USDA released a document containing summary information on the
goals of the initial 16 field trials, including the types of technology
tested and industry focus. In June 2006, USDA released a preliminary
progress report for these first 16 field trials but stated in the
report that due to the timing of work plan submissions and the
subsequent need for approved time extensions to complete proposed
projects, 10 of these 16 projects awarded in fiscal year 2004 had not
yet submitted final reports. In addition, USDA stated in this report
that to fully understand the projects' results, interested parties
should contact cooperative agreement project administrators to learn
more about the projects' specific activities. However, the report did
not include contact information. In May 2007, USDA released a third and
final report on the results of the fiscal year 2004 field trials and
descriptions of the fiscal year 2005 field trials for distribution to
state, industry, and other stakeholders.[Footnote 20]
USDA started sharing the results of premises registration and outreach
cooperative agreements by publishing weekly premises registration
statistics, by state, beginning in December 2006 (for state premises
registration statistics, see app. VI, table 4). However, USDA has not
formally shared any information about the strategies used by the
individual state projects, nor has the agency communicated to
stakeholders successful or unsuccessful approaches to registering
premises.
While USDA states that some results of cooperative agreements have been
shared publicly at numerous stakeholder meetings, animal health
officials and industry representatives told us that not enough
information exists about the results of NAIS cooperative agreements,
and that more sharing of results, best practices, and lessons learned
is needed. For example, a researcher applying for fiscal year 2005
field trial funding told us it was difficult to determine whether
previous NAIS cooperative agreements had included work similar to what
the applicant was proposing. In addition, industry groups, state animal
health officials, and experts told us that livestock markets would
benefit from more information concerning the retrofitting of animal
tracking equipment.
USDA Plans to Improve Oversight and Give States with Greater
Participation in NAIS Some Flexibility in Using Cooperative Agreement
Funds:
As we have previously reported, increasing oversight, linking funding
to performance milestones, and altering flexibility are accountability
mechanisms that can be used by agencies to encourage improved
performance during an award period.[Footnote 21] In fiscal year 2007,
USDA plans to increase oversight activities for some state cooperative
agreements, on the basis of state premises registration levels at the
time of the November 2006 announcement. For example, the 27 states that
had 25 percent or less of their premises registered at the time of the
cooperative agreement announcement and were eligible for more than
$82,000 in awards would receive only 90 percent of reserved funding
until a midyear review period. According to USDA, designated
representatives will determine the success of cooperative agreements
during this midyear review, largely on the basis of the goals stated in
the cooperative agreements' approved work plans. The 23 states with
greater than 25 percent of premises registered, or eligible for awards
of less than $82,000, are eligible to receive 100 percent of
cooperative agreement funding without a midyear review (see app. VI,
table 5). In addition, all nonprofit industry organizations that
receive cooperative agreement funding in fiscal year 2007 will be
eligible for 50 percent of approved funds, with an additional 25
percent of funds released following each successful third-and fourth-
quarter review of interim reports required by USDA.
Moreover, USDA has linked funding to participation levels by providing
for increased spending flexibility for some state recipients of fiscal
year 2007 premises registration cooperative agreements. USDA believes
that cooperative agreement funding may be more appropriately used by
states with greater numbers of premises registered to support the
animal ID and tracking components of NAIS. For example, the 14 states
that have achieved greater than 25 percent of premises registered may
spend up to 40 percent of funds on animal tracking infrastructure, such
as to support NAIS's integration with preexisting disease eradication
programs or to share in the cost of data collection equipment for
livestock markets and dealers. The 18 states that have registered
between 11 percent and 25 percent of premises may spend up to 30
percent of their funding on animal tracking infrastructure, while the 8
states that have registered between 6 percent and 10 percent of
premises may spend up to 20 percent of funding on animal tracking
infrastructure. Finally, those states that have registered less than 6
percent of premises are required to spend 100 percent of funds on
outreach and premises registration.
Total NAIS Program Costs Have Not Been Determined, but USDA Recently
Announced Plans to Develop a Cost-benefit Analysis:
USDA has not determined the program costs for NAIS but recently
announced plans to hire a contractor to conduct a cost-benefit analysis
for NAIS, in part to more precisely forecast the economic effects of
the program. The Senate Appropriations Committee and the House of
Representatives have raised concerns in recent years about how USDA has
spent funds to develop and implement NAIS. Finally, the views of our
expert panel members are mixed concerning NAIS's potential impact on
the livestock industry.
NAIS Costs and Benefits Are Not Known:
Although implementation of NAIS began in 2004, USDA has not developed a
comprehensive cost estimate or cost-benefit analysis for the program.
In addition, to our knowledge, no industry group, academic institution,
or state animal health agency has published a cost estimate for
implementing and maintaining NAIS. Without a comprehensive cost-benefit
analysis for NAIS, 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. In
2004, and again in 2006, the NAIS Subcommittee recommended that USDA
prepare an in-depth, cost-benefit analysis for NAIS as part of the
strategic planning process. In addition, 29 of the 32 expert panel
members said that USDA should definitely or probably publish a cost-
benefit analysis that contains detailed NAIS cost and benefit
information for the different sectors of the livestock industry,
states, and USDA. The NAIS working groups, other livestock industry
representatives, and state animal health officials we interviewed said
that the cost of implementing NAIS remained one of their biggest
concerns. For example, in comments to USDA in 2005, the Livestock
Marketing Association wrote that it is "highly critical of the fact
that too little has been known" about the potential costs of
establishing a national animal ID system and about who will bear those
costs. Furthermore, the association wrote that a cost-benefit analysis
is "long overdue" and that without better information, NAIS appears to
be prohibitively expensive for the livestock industry to implement. As
a result, without a reliable cost-benefit analysis that is consistent
with federal guidance, stakeholders are unlikely to participate in NAIS
due to their uncertainty that NAIS program benefits outweigh program
costs.
USDA announced plans in March 2007 to conduct a cost-benefit analysis
for NAIS. USDA officials told us that the cost-benefit analysis will be
used for program planning and resource allocation, producer and
industry education, and public relations and outreach and to more
precisely forecast the economic effects of NAIS. USDA officials
anticipate that the cost-benefit analysis will be available in 2008.
As we have previously reported, measuring the economic performance of
federal programs, such as the extent to which program benefits exceed
costs (net benefits) or are achieved at least cost (cost-
effectiveness), could be a useful way to assess, in conjunction with
other measures, the extent to which federal programs are meeting the
nation's priorities.[Footnote 22] In addition, OMB has established
general guidance on conducting cost-benefit analyses of federal
programs to promote efficient resource allocation through well-informed
decision making.[Footnote 23] OMB suggests that agencies follow this
guidance in conducting analyses used to support government decisions to
initiate, renew, or expand programs or projects that would result in a
series of measurable benefits or costs extending 3 or more years into
the future. The USDA announcement suggests that the planned NAIS cost-
benefit analysis follow this and other available federal guidance.
Concerns Exist over How USDA Has Spent Funds to Develop and Implement
NAIS:
In fiscal year 2004, the Secretary of Agriculture transferred $18.8
million from the Commodity Credit Corporation (CCC) to develop and
implement NAIS, as shown in table 1. Although approximately $85.0
million had been made available for NAIS implementation by the end of
fiscal year 2006, USDA had obligated only about $61.1 million as of
late March 2007;[Footnote 24] thus, the agency has carried over about
$23.9 million in unobligated NAIS funds into fiscal year 2007.[Footnote
25] Because NAIS funding has been designated by Congress to be
available until expended, USDA can carry funds that it did not expend
in prior years forward into the current year. In addition to these
carryover funds, Congress appropriated an additional $33.0 million for
the NAIS program for fiscal year 2007. The President's Budget requested
$33.1 million for NAIS in fiscal year 2008.
Table 1: USDA NAIS Budget Data, Fiscal Years 2004 (CCC Funds) through
2006:
Dollars in thousands.
Funding availability;
Fiscal year: 2004: $18,793;
Fiscal year: 2005: $33,197;
Fiscal year: 2006: $33,007;
Total: $84,997.
Planned obligations:
Information technology development, maintenance, and operations;
Fiscal year: 2004: $2,009;
Fiscal year: 2005: $6,858;
Fiscal year: 2006: $7,733;
Total: $16,600.
Cooperative agreements;
Fiscal year: 2004: 14,357;
Fiscal year: 2005: 17,050;
Fiscal year: 2006: 13,882;
Total: 45,288.
Communications and outreach;
Fiscal year: 2004: 2,137;
Fiscal year: 2005: 3,474;
Fiscal year: 2006: 1,940;
Total: 7,551.
Headquarters and field staff and materials;
Fiscal year: 2004: 290;
Fiscal year: 2005: 3,125;
Fiscal year: 2006: 5,285;
Total: 8,700.
Uncommitted/Unassigned funding;
Fiscal year: 2004: 0;
Fiscal year: 2005: 2,690;
Fiscal year: 2006: 4,167;
Total: 6,857.
Total;
Fiscal year: 2004: $18,793;
Fiscal year: 2005: $33,197;
Fiscal year: 2006: $33,007;
Total: $84,997.
Actual obligations:
Information technology development, maintenance, and operations;
Fiscal year: 2004: $1,829;
Fiscal year: 2005: $5,276;
Fiscal year: 2006: $2,466;
Total: $9,571.
Cooperative agreements;
Fiscal year: 2004: 13,944;
Fiscal year: 2005: 15,031;
Fiscal year: 2006: 6,026;
Total: 35,000.
Communications and outreach;
Fiscal year: 2004: 2,137;
Fiscal year: 2005: 2,719;
Fiscal year: 2006: 1,640;
Total: 6,495.
Headquarters and field staff and materials;
Fiscal year: 2004: 379;
Fiscal year: 2005: 3,213;
Fiscal year: 2006: 6,428;
Total: 10,019.
Total;
Fiscal year: 2004: $18,288;
Fiscal year: 2005: $26,238;
Fiscal year: 2006: $16,559;
Total: $61,086.
Unobligated funds;
Fiscal year: 2004: $505;
Fiscal year: 2005: $6,959;
Fiscal year: 2006: $16,448;
Total: $23,911.
Actual expenditures:
Information technology development, maintenance, and operations;
Fiscal year: 2004: $1,813;
Fiscal year: 2005: $3,946;
Fiscal year: 2006: $908;
Total: $6,668.
Cooperative agreements;
Fiscal year: 2004: 11,831;
Fiscal year: 2005: 9,799;
Fiscal year: 2006: 2,219;
Total: 23,849.
Communications and outreach;
Fiscal year: 2004: 2,103;
Fiscal year: 2005: 1,598;
Fiscal year: 2006: 216;
Total: 3,918.
Headquarters and field staff and materials;
Fiscal year: 2004: 379;
Fiscal year: 2005: 3,174;
Fiscal year: 2006: 6,427;
Total: 9,979.
Total;
Fiscal year: 2004: $16,127;
Fiscal year: 2005: $18,518;
Fiscal year: 2006: $9,770;
Total: $44,414.
Source: USDA data as of March 27, 2007.
Note: All figures have been rounded to the nearest thousand.
[End of table]
The Senate Appropriations Committee and the House of Representatives
have raised concerns in recent years about how USDA has spent funds to
develop and implement NAIS. For example, in the 109th Congress, the
House passed a fiscal year 2007 appropriations bill for agriculture
(H.R. 5384) that included a provision prohibiting funds from being
obligated on NAIS until the House Appropriations Committee received a
detailed plan for NAIS "including, but not limited to, proposed
legislative changes, cost estimates, and means of program evaluation,"
and that the plan be published in the Federal Register for public
comment. Although the bill, with the provision limiting obligations,
passed in the House, it did not become law. USDA officials told us they
have plans to obligate all carryover funds in fiscal year 2007. These
plans include awarding additional cooperative agreements to states and
industry organizations to register premises; additional investments in
information technology development, maintenance, and operations; and
communications and outreach.
Expert Views Concerning Changes to the Livestock Industry Are Mixed:
Questions have been raised about whether NAIS could lead to greater
contracting, vertical integration, or horizontal consolidation in the
livestock industry market structure,[Footnote 26] and whether NAIS
could affect prices at both the retail and producer levels. Expert
panel members provided the following views relating to changes in
market structure as well as to changes in costs and prices for various
market participants due to the implementation of NAIS.
* The 32 experts were evenly split on whether contracting or horizontal
consolidation would increase as a result of NAIS--16 said those effects
would definitely or probably be more likely to occur, and 16 said those
effects would not occur or are probably less likely to occur.
* Twenty experts said vertical integration would not occur or is
probably less likely to occur, while 12 said vertical integration is
definitely or probably more likely to occur.
* Regarding price effects at the retail level of meat and/or animal
products, 12 experts thought prices would be higher; 15 thought there
would be no effect; and 5 believed they would be lower.
* When asked what would be the effect on prices paid to producers for
livestock if NAIS led to increased costs in livestock markets and/or
slaughter facilities, 21 experts believed that prices would probably or
definitely decrease; 8 thought there would be no effect; and 2 thought
that there would probably be an increase.
* Similarly, when asked what would be the effect on prices paid to
producers for livestock if NAIS led to decreased costs in livestock
markets and/or slaughter facilities, 16 experts replied that prices
paid to producers would probably or definitely increase; 13 replied
that there would be no effect; and 1 respondent thought there would be
a decrease.
Conclusions:
NAIS provides USDA, states, and the livestock industry with a historic
opportunity for the United States to develop a comprehensive, coherent
program to identify the nation's livestock animals and premises and
achieve the goal of rapid and effective disease traceback. In addition,
a successful program in sync with our international trading partners
and competitors could boost consumer confidence in U.S. animal products
and help maintain and expand market access. However, for NAIS to be
fully effective and efficient in responding to an animal disease
emergency, adequate levels of participation need to be achieved in all
three NAIS components--premises registration, animal ID, and tracking.
If insufficient numbers of animals are identified and tracked, the
system will have gaps, despite millions of dollars being invested in
the program's development. Conversely, high levels of participation
would better position the United States to handle future animal health
emergencies and minimize economic, trade, and possibly human health
consequences. USDA's changes in direction over the past 3 years have
caused considerable confusion and frustration among many NAIS
stakeholders, and the program's implementation may be in danger of
losing momentum. Most critically, whether NAIS is voluntary or
mandatory, the lack of participation benchmarks makes it more difficult
to gauge progress in attaining the necessary levels of participation
for an effective animal ID program and, if there is insufficient
participation, to develop strategies to achieve it. Without meaningful
progress, USDA's expenditures on NAIS will continue to be questioned.
In addition, if USDA does not resolve several key implementation
issues, the program will continue to face opposition by some industry
stakeholders, and participation in all three NAIS components could be
limited. Collectively, these unresolved issues will likely lead to
ineffective and inefficient implementation and prevent NAIS from
achieving the goal of rapid and effective traceback. First,
prioritizing how NAIS is implemented, such as by species, would allow
USDA and stakeholders to better allocate their resources and improve
the program over time. Second, the integration of NAIS with other USDA
and state animal disease eradication programs and branding systems
would remove another hurdle preventing participation in NAIS's animal
ID and tracking components. Third, creating a robust process for
selecting, setting standards for, and independently testing and
evaluating animal ID and tracking devices in meeting NAIS standards is
important to ensure effectiveness and interoperability across the
national program and, therefore, would encourage investment. Fourth,
identifying time-sensitive and cost-effective goals for traceback,
which may vary by disease, would allow stakeholders to have common
goals in responding to an event, potentially speeding up response and,
therefore, minimizing economic losses. Fifth, requiring the recording
of information in NAIS databases that may be critical for efficient
traceback, such as species, approximate age, or date of birth, would
enable animal health authorities to more quickly locate only those
premises and animals that are relevant in an investigation, thus
minimizing time and resources and hastening response.
Finally, we believe that if USDA were to provide industry, state, and
other stakeholders with key information on the results of cooperative
agreements, it would help identify the most effective and efficient
means to implement the program and likely increase participation and
enable producers, livestock markets, states, and other stakeholders to
make informed decisions about where to allocate scarce resources.
Moreover, for planning purposes in allocating federal, state, and
industry resources, it is important for stakeholders, Congress, and the
public to know how much it will cost to implement and maintain NAIS,
compared with its benefits. Without a reliable cost-benefit analysis,
stakeholders are unlikely to participate in NAIS due to their
uncertainty about whether program benefits outweigh the costs.
Recommendations for Executive Action:
To achieve the program's goal of rapid and effective animal disease
traceback, we recommend that the Secretary of Agriculture direct the
Administrator of 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.
In addition, we recommend that the Secretary direct the Administrator
of APHIS to take the following seven actions to implement NAIS more
effectively and efficiently and achieve the program's goal of rapid and
effective traceback:
* 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;
* determine how NAIS will integrate with existing USDA and state animal
disease eradication programs and branding systems;
* 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;
* 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;
* 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;
* increase the monitoring of NAIS cooperative agreements, and evaluate
and publish the results of cooperative agreements on a timely basis;
and:
* conduct the planned analysis of the costs and benefits of NAIS
following criteria established in OMB guidance for conducting cost-
benefit analyses for federal programs and publish the results for
comment.
Agency Comments and Our Evaluation:
We provided a draft of this report to USDA for review and comment. In
written comments on our draft report, USDA stated that it appreciated
our comprehensive evaluation of NAIS and generally agreed with our
recommendations. However, regarding our recommendation that USDA
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, USDA agreed with the need to
establish a more robust process for having ID devices tested to meet
minimum performance standards, but believed that these standards must
be defined through a consensus of affected stakeholders. USDA stated
that as performance standards are established, the selection of such
devices will then be warranted. USDA also stated that as part of the
evaluation process, it will specify the testing standards and then
review the manufacturer's documentation of laboratory testing and field
trials. In addition, USDA stated that testing of such devices should be
at the expense of the device manufacturer.
We recognize the need for USDA to work with stakeholders before
determining which ID and tracking devices are most appropriate for
NAIS. However, the sooner USDA selects specific technologies, the
sooner producers, livestock markets, slaughter facilities, and others
will likely participate in the animal ID and tracking components of
NAIS. As a starting point, some NAIS working groups have recommended
specific ID devices for their species. It is common U.S. practice to
select one technology for systems that need to be widely implemented in
different environments, and we have previously reported that a robust
process for selecting, standardizing, and testing and evaluating
technologies leads to the most effective and efficient systems. During
the course of our work, we found that USDA's technology-neutral
position has caused producers, market operators, and slaughter
facilities to be generally discouraged from investing in new animal ID
or tracking devices for NAIS due to fear that their choices might be
inconsistent with others in the marketplace, or that USDA might adopt
specific devices in the future. The selection of specific ID and
tracking devices, therefore, would ensure consistency and
interoperability across the program's many potential users, leading to
more efficient implementation. Furthermore, as stated in this report,
USDA has recognized the need for animal ID technologies that are
compatible with Canada and Mexico, and it also has stated that
harmonizing the United States' program with other countries will
facilitate safe trade. Selecting technologies for NAIS that are in sync
with our trading partners and competitors could have positive trade
implications for the United States. Lastly, the selection of specific
devices would inform the cost-benefit analysis that USDA is currently
conducting, which, in turn, could affect participation levels. These
reasons underscore the need for USDA to select specific ID and tracking
devices, on the basis of independent, reliable information regarding
their performance in meeting minimum standards and of consultations
with stakeholders.
In its written comments, USDA also provided points of clarification and
provided details about current and future actions that the agency plans
to take to address our recommendations, which we incorporated
throughout the report, as appropriate. USDA's written comments and our
specific responses appear in appendix VII. In addition, USDA provided
technical comments that we incorporated throughout the report, as
appropriate.
As we agreed with your office, unless you publicly announce the
contents of this report earlier, we plan no further distribution of it
until 30 days from the date of this report. At that time, we will send
copies of this report to the interested congressional committees, the
Secretary of Agriculture, and other interested parties. We will also
make copies available to others upon request. In addition, this report
will be available at no charge on the GAO Web site at
http://www.gao.gov.
If your or your staff have any questions about this report, please
contact me at (202) 512-3841 or ShamesL@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to
this report are listed in appendix VIII.
Sincerely yours,
Signed by:
Lisa Shames:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of our review were to determine (1) how effectively the
U.S. Department of Agriculture (USDA) is implementing the National
Animal Identification System (NAIS) and, specifically, the key
implementation issues identified by livestock industry groups, market
operators, state animal health officials, and others; (2) how USDA has
distributed cooperative agreement funding 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 the
livestock industry to implement and maintain NAIS.
To address these objectives, we interviewed USDA officials responsible
for implementing NAIS and conducted site visits to selected livestock
markets and cooperative agreement field trials. We conducted structured
interviews in person or via telephone with animal health officials in
seven states: California, Iowa, Michigan, New Mexico, Texas, Vermont,
and Wisconsin. These states were selected on the basis of their
geographic dispersion; the range in the number of premises located in
each state; and, in some cases, their high levels of livestock
production. We also conducted interviews in person or via telephone and
reviewed documents from the NAIS Subcommittee and the 10 NAIS working
groups that report to the NAIS Subcommittee: Beef and Dairy Cattle
Working Group, Bison Working Group, Camelid Working Group, Cervid
Working Group, Equine Working Group, Goat Working Group, Market/
Processor Working Group, Poultry Working Group, Sheep Working Group,
and Swine Working Group. We also conducted structured interviews in
person or via telephone and reviewed documents from four industry
organizations: American Farm Bureau Federation, Livestock Marketing
Association, National Cattlemen's Beef Association, and National
Livestock Producers Association. In addition, we reviewed documents
from the United States Animal Health Association Livestock ID
Committee; the Ranchers-Cattlemen Action Legal Fund --United
Stockgrowers of America; three NAIS opposition groups--NoNAIS.org,
Liberty Ark Coalition, and the Farm and Ranch Freedom Alliance; and
other organizations that testified before Congress on NAIS in recent
years or spoke at USDA's listening sessions in 2004. We attended the
NAIS Subcommittee meeting and a USDA meeting with state departments of
agriculture on NAIS held in August 2006 in Kansas City, Missouri, and
the Secretary's Advisory Committee on Foreign Animal and Poultry
Diseases meeting in September 2006 in Riverdale, Maryland. We
identified and reviewed applicable laws, USDA policies, guidance, and
technical standards regarding NAIS. We also reviewed relevant GAO
reports and a Congressional Research Service report to Congress on
animal identification (ID) and traceability.
To determine how USDA has distributed cooperative agreement funding to
help states and industry prepare for NAIS, we reviewed USDA
documentation related to cooperative agreements signed between USDA and
states, territories, tribes, and industry groups from fiscal years 2004
through 2007. To determine which livestock species were the focus of
cooperative agreement field trials, we reviewed and systematically
recorded this information from cooperative agreement recipients' work
plans; however, we did not independently assess whether the proposed
work with these species and industry sectors took place. To determine
how USDA has evaluated the results of cooperative agreements, we
interviewed NAIS program staff, reviewed guidance provided to
recipients, and reviewed quarterly and final reports submitted to USDA
by cooperative agreement recipients. Because some cooperative
agreements were ongoing and because other recipients did not report to
USDA in a timely manner, we could not examine a complete set of
quarterly and final reports for all recipients. We conducted a
reliability assessment of the data that USDA provided to us on the NAIS
cooperative agreements and found these data to be reliable for our
reporting purposes.
For the third objective, to determine estimates of the costs to
implement and maintain NAIS, we asked representatives from USDA,
industry groups, academic institutions, and state animal health
agencies for any NAIS cost estimates they had developed. We identified
and reviewed federal guidance for developing cost estimates and cost-
benefit analyses and sound economic and cost accounting principles. We
also reviewed NAIS budget data from USDA for fiscal years 2004 through
2007, and conducted a reliability assessment of these data and found
them to be reliable for our reporting purposes.
To help answer the first and third objectives, we convened a Web-based
panel of 32 experts on several aspects of NAIS. The process we followed
is based on GAO guidance for identifying experts for panels or other
work requiring expertise in a specific area. We identified potential
panel members by conducting a literature search to obtain the names of
individuals who had published on animal ID in academic journals and in
other relevant venues. We also asked for recommendations from
individuals we interviewed for other aspects of the job. We then
selected individuals who were actively involved in the development or
implementation of NAIS and were knowledgeable of its details; who had
conducted research, or were published in peer-reviewed journals on
animal ID; or who were recognized by their peers as an expert on NAIS.
Panel members were asked to fill out a Web-based questionnaire, which
asked for their beliefs and opinions on future participation in NAIS,
effective traceback, implementation of NAIS, the costs and benefits of
NAIS, the impact of NAIS on the livestock industry and consumers, ID
technology, and databases for tracking animals. Panel members had
approximately 3 weeks to fill out their questionnaires in December 2006
and January 2007. All panel members completed their questionnaires,
giving us a 100 percent response rate. The questions and aggregated
responses are presented in appendix IV. While we display only the
quantitative, closed-ended responses, we also relied on the responses
to the qualitative, open-ended questions to inform our findings in this
report. The views expressed by the panel members do not necessarily
represent the views of GAO.
We conducted our work from June 2006 to May 2007 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Select Domestic and Foreign Animal Diseases of Concern
Identified by USDA:
Table:
Domestic:
Animal disease: Avian influenza (low pathogenic);
Livestock animals affected: Poultry;
Can affect humans?: No.
Animal disease: Bovine spongiform encephalopathy;
Livestock animals affected: Cattle;
Can affect humans?: Yes.
Animal disease: Bovine brucellosis and Swine brucellosis;
Livestock animals affected: Cattle, bison, goats, swine, and cervids;
Can affect humans?: Yes.
Animal disease: Chronic wasting disease;
Livestock animals affected: Cervids;
Can affect humans?: Unknown.
Animal disease: Equine infectious anemia;
Livestock animals affected: Horses, donkeys, mules, ponies, and zebra;
Can affect humans?: No.
Animal disease: Johne's disease;
Livestock animals affected: Cattle, sheep, goats, and cervids;
Can affect humans?: Unknown.
Animal disease: Pseudorabies;
Livestock animals affected: Swine, cattle, sheep, and goats;
Can affect humans?: No.
Animal disease: Scrapie;
Livestock animals affected: Sheep and goats;
Can affect humans?: Unknown.
Animal disease: Texas (splenetic) fever;
Livestock animals affected: Cattle;
Can affect humans?: No.
Animal disease: Tuberculosis;
Livestock animals affected: Cattle, bison, and captive cervids;
Can affect humans?: Yes.
Foreign:
Animal disease: Avian influenza (highly pathogenic);
Livestock animals affected: Poultry;
Can affect humans?: Yes.
Animal disease: Dourine;
Livestock animals affected: Horses and donkeys;
Can affect humans?: No.
Animal disease: Exotic Newcastle disease;
Livestock animals affected: Poultry;
Can affect humans?: Yes.
Animal disease: African swine fever;
Livestock animals affected: Swine;
Can affect humans?: No.
Animal disease: Classical swine fever;
Livestock animals affected: Swine;
Can affect humans?: No.
Animal disease: Contagious bovine pleuropneumonia;
Livestock animals affected: Cattle and bison;
Can affect humans?: No.
Animal disease: Foot-and-mouth disease;
Livestock animals affected: Cattle, sheep, goats, and swine;
Can affect humans?: Yes, but rarely infects humans.
Animal disease: Glanders;
Livestock animals affected: Horses, donkeys, mules, and goats;
Can affect humans?: Yes.
Source: USDA.
Note: Pursuant to the Public Health Security and Bioterrorism
Preparedness and Response Act of 2002 (the "Bioterrorism Act of 2002"),
USDA identifies animal diseases that have the potential to pose a
severe threat to livestock and human health, including bacillus
anthracis, brucella abortusm, brucella melitensis, brucella suis,
burkholderia mallei, burkholderia pseudomallei, clostridium botulinum,
coccidioides immitis, francisella tularensis, botulinum neurotoxins,
clostridium perfringens epsilon toxin, shigatoxin, staphylococcal
enterotoxins, T-2 toxin, African horsesickness, peste des petits
ruminants, swine vesicular disease virus, lumpyskin disease virus,
sheep pox, and goat pox.
USDA identifies other domestic animal diseases of concern in federal
regulations, including acute swine erysipelas (affects swine), anthrax
(all domestic species), bluetongue (all domestic species), chlamydiosis
(poultry), Eastern equine encephalomyelistis (horses), mycoplasma
gallisepticum (poultry), mycoplasma meleagridis (poultry), mycoplasma
synoviae (poultry), salmonella enteritidis (poultry), salmonella
gallinarum (poultry), salmonella pullorum (poultry), scabies (cattle),
infectious salmon anemia, and spring viremia of carp. Additional
foreign animal diseases of concern identified by USDA include equine
viral arteritis (horses, donkeys, mules, ponies, and zebra); hendra
(horses); nipah (swine and horses); Rift Valley fever (cattle, sheep,
and goats); rinderpest (cattle, sheep, and goats); Venezuelan equine
encephalomyelitis (all equine species); and vesicular stomatitis
(swine, cattle, sheep, and goats).
[End of table]
[End of section]
Appendix III: Members of GAO's Expert Panel on NAIS:
This appendix provides the names and affiliations of 32 academic,
government, and other experts who, as members of our expert panel on
NAIS, completed a Web-based questionnaire from December 2006 to January
2007 regarding USDA's implementation of NAIS. We also spoke with a
select number of these experts regarding animal ID and tracking
technology, among other issues.
Expert Panel Members:
* Dr. David P. Anderson, Associate Professor and Extension Economist -
Livestock and Food Products Marketing, Department of Agricultural
Economics, Texas A&M University:
* Dr. DeeVon Bailey, Interim Department Head and Professor, Department
of Economics, Utah State University:
* Dr. Joseph Balagtas, Assistant Professor, Department of Agricultural
Economics, Purdue University:
* Dr. Dale A. Blasi, Professor & Extension Beef Specialist, Department
of Animal Sciences & Industry, Kansas State University:
* Dr. D. Scott Brown, Research Assistant Professor and Program Director
of Livestock and Dairy, Food and Agricultural Policy Research
Institute, University of Missouri:
* Dr. Daniel D. Buskirk, Associate Professor and Beef Extension
Specialist, Department of Animal Science, Michigan State University:
* Dr. Julie A. Caswell, Professor and Department Chair, Department of
Resource Economics, College of Natural Resources and the Environment,
University of Massachusetts:
* Dr. David A. Daley, Professor, College of Agriculture, California
State University, Chico:
* Dr. Kevin Dhuyvetter, Agricultural Economist, Department of
Agricultural Economics, Kansas State University:
* Dr. Basil Eastwood, National Program Leader, Plant and Animal
Systems, Cooperative State Research, Education, and Extension Service,
USDA:
* Dr. Scott Greiner, Associate Professor and Extension Animal
Scientist, Beef and Sheep, Department of Animal & Poultry Sciences,
College of Agriculture and Life Sciences, Virginia Polytechnic
Institute and State University:
* Dr. Ron A. Gustafson, Senior Economist, Beef Analysis, Economic
Research Service, USDA:
* Dr. James C. Heird, Director of Equine Sciences Department, Equine
Teaching and Research Center, Colorado State University:
* Dr. Julie Jarvinen, Associate Professor, Department of Veterinary
Pathology, Iowa State University:
* Dr. Cleon V. Kimberling (retired), Clinical Sciences Department,
Colorado State University:
* Dr. John D. Lawrence, Professor and Extension Livestock Economist,
Agricultural Economics, Department of Economics, Iowa State University:
* Dr. Darrell R. Mark, Assistant Professor and Livestock Extentionist,
Department of Agricultural Economics, University of Nebraska, Lincoln:
* Dr. Bret D. Marsh, State Veterinarian, Indiana State Board of Animal
Health, and immediate past president of the United States Animal Health
Association:
* Dr. James D. McKean, Extension Veterinarian and University Professor,
Department of Veterinary Diagnostic & Production Animal Medicine,
College of Veterinary Medicine, Iowa State University:
* Mr. Douglas O'Brien, Co-Director, National Agricultural Law Center,
University of Arkansas School of Law, and Staff Attorney, Drake
University Agricultural Law Center:
* Dr. James W. Oltjen, Professor and Extension Specialist, Animal
Management Systems, Department of Animal Science, University of
California, Davis:
* Dr. Derrell Peel, Professor, and Livestock Extensionist, Department
of Agricultural Economics, Oklahoma State University:
* Dr. Valerie Ragan, President, AgWorks Solutions LLC, and former
Assistant Deputy Administrator for USDA's Animal and Plant Health
Inspection Service, Veterinary Services:
* Dr. Kris Ringwall, Animal Scientist and Director of the Dickinson
Research Extension Center, North Dakota State University, and Executive
Secretary, North Dakota Beef Cattle Improvement Association:
* Dr. Joan Dean Rowe, Associate Professor, Department of Population
Health & Reproduction, University of California, Davis:
* Dr. Ted Schroeder, Professor and Director of Graduate Program,
Department of Agricultural Economics, Kansas State University:
* Dr. Clifford F. Shipley, Clinical Associate Professor, College of
Veterinary Medicine, University of Illinois:
* Dr. Ronnie E. Silcox, Associate Professor and Extension Beef
Specialist, Animal & Dairy Science Department, University of Georgia:
* Dr. Michael A. Tomaszewski, Professor and Extension Dairy Specialist,
Department of Animal Science, Texas A&M University:
* Dr. Glynn Tonsor, Assistant Professor, Department of Agricultural
Economics, Michigan State University:
* Dr. Wendy J. Umberger, Assistant Professor and Extension Economist,
Department of Agricultural and Resource Economics, Colorado State
University:
* Dr. Kelly Zering, Associate Professor, Department of Agricultural and
Resource Economics, North Carolina State University, Raleigh:
[End of section]
Appendix IV: GAO Expert Panel Questions and Responses on NAIS:
Expert Panel: USDA's Implementation of the National Animal
Identification System:
We conducted the following survey as part of our review of USDA's
implementation of NAIS. We received a 100 percent response rate from a
panel of 32 experts who filled out a Web-based questionnaire in late
December 2006 and early January 2007. For presentation purposes in this
appendix, we have combined the category "No expertise on topic" with
"No answer" and the category "50% or less" with "51 to 60%." However,
when the experts filled out the questionnaire, those categories were
not combined. The views expressed by the panel members do not
necessarily represent the views of GAO.
Part I: Participation in the NAIS Voluntary Program:
In USDA's November 2006 draft National Animal Identification System
(NAIS): A User Guide and Additional Information Resources (NAIS User
Guide), USDA states that NAIS is a voluntary program that helps
producers and animal health officials respond rapidly and effectively
to animal disease events for livestock and poultry in the United
States. The next three questions ask for your opinion on likely
participation levels for the three components of NAIS (premises
registration, animal identification, and animal tracking) under a
voluntary program.
In this questionnaire, the term "producer" refers to all individuals
engaged in the ownership, management, or marketing of any of the
species of livestock included in NAIS. For example, in the beef cattle
industry, this refers to cow-calf producers as well as stocker,
backgrounder, and feedlot operators. While owners or managers of
certain species, for example horses, may not typically be referred to
as producers, these individuals are included in this definition of
producer. This definition is consistent with USDA's draft NAIS User
Guide (pg. 5). The term "livestock market" refers to livestock auction
markets, sale barns, and sale yards.
Q1. What do you believe will be the percentage of premises registered
for each sector of livestock production under the NAIS voluntary
program?
a. Producers;
60% or less: 24;
61-70%: 4;
71-80%: 2;
81-90%: 1;
91- 100%: 0;
No expertise/ No answer: 1;
Number of respondents: 32.
b. Livestock Markets;
60% or less: 9;
61-70%: 4;
71-80%: 5;
81-90%: 6;
91-100%: 5;
No expertise/ No answer: 3;
Number of respondents: 32.
c. Slaughter Facilities;
60% or less: 6;
61-70%: 1;
71-80%: 3;
81- 90%: 12;
91-100%: 8;
No expertise/ No answer: 2;
Number of respondents: 32.
[End of table]
Q2. What do you believe will be the percentage of animals identified
(as individuals or, where applicable, as a group) for each species of
animal under the NAIS voluntary program?
a. Bison;
60% or less: 18;
61-70%: 1;
71-80%: 1;
81-90%: 0;
91-100%: 1;
No expertise/ No answer: 11;
Number of respondents: 32.
b. Camelids (e.g., alpacas, llamas);
60% or less: 14;
61-70%: 1;
71- 80%: 2;
81-90%: 1;
91-100%: 0;
No expertise/ No answer: 14;
Number of respondents: 32.
c. Cattle (beef);
60% or less: 24;
61-70%: 2;
71-80%: 2;
81-90%: 1;
91-100%: 0;
No expertise/ No answer: 3;
Number of respondents: 32.
d. Cattle (dairy);
60% or less: 10;
61-70%: 4;
71-80%: 7;
81-90%: 5;
91-100%: 3;
No expertise/ No answer: 3;
Number of respondents: 32.
e. Cervids (e.g., deer, elk);
60% or less: 14;
61-70%: 3;
71-80%: 0;
81-90%: 1;
91-100%: 1;
No expertise/ No answer: 13;
Number of respondents: 32.
f. Equine (e.g., horses, donkeys, mules);
60% or less: 22;
61-70%: 1;
71-80%: 0;
81-90%: 0;
91-100%: 1;
No expertise/ No answer: 8;
Number of respondents: 32.
g. Goats;
60% or less: 18;
61-70%: 3;
71-80%: 1;
81-90%: 0;
91-100%: 0;
No expertise/ No answer: 10;
Number of respondents: 32.
h. Poultry (commercial);
60% or less: 8;
61-70%: 1;
71-80%: 2;
81- 90%: 8;
91-100%: 7;
No expertise/ No answer: 6;
Number of respondents: 32.
i. Poultry (non-commercial);
60% or less: 25;
61-70%: 0;
71-80%: 0;
81-90%: 0;
91-100%: 0;
No expertise/ No answer: 7;
Number of respondents: 32.
j. Sheep;
60% or less: 15;
61-70%: 4;
71-80%: 5;
81-90%: 1;
91-100%: 1;
No expertise/ No answer: 6;
Number of respondents: 32.
k. Swine (individual);
60% or less: 28;
61-70%: 0;
71-80%: 0;
81- 90%: 1;
91-100%: 0;
No expertise/ No answer: 3;
Number of respondents: 32.
l. Swine (group);
60% or less: 8;
61-70%: 3;
71-80%: 3;
81-90%: 11;
91-100%: 4;
No expertise/ No answer: 3;
Number of respondents: 32.
[End of table]
Q3. What do you believe will be the percentage of animals tracked for
each sector of livestock production under the NAIS voluntary program?
a. Producers;
0-25%: 17;
26-50%: 12;
51-75%: 2;
76-100%: 0;
No expertise/ No answer: 1;
Number of respondents: 32.
b. Livestock markets;
0-25%: 10;
26-50%: 9;
51-75%: 8;
76-100%: 2;
No expertise/ No answer: 3;
Number of respondents: 32.
c. Slaughter facilities;
0-25%: 7;
26-50%: 6;
51-75%: 5;
76-100%: 10;
No expertise/ No answer: 4;
Number of respondents: 32.
[End of table]
Part II: Achieving Rapid and Effective Trace Back:
The next four questions ask for your opinion on the participation
levels in NAIS that are necessary for producers and animal health
officials to respond quickly and effectively to animal disease events
by tracing livestock animals throughout the production process.
Q4. USDA's draft NAIS User Guide does not define the time period for
rapid trace back. In your opinion, what time period defines a "rapid"
trace back in an animal disease event?
24 hours or less: 10;
25-48 hours: 15;
49-72 hours: 3;
73-96 hours: 2;
Other: 1;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q5. What percentage of premises registered do you believe is necessary
to achieve the NAIS program's goal of rapid and effective animal
disease trace back?
a. Producers;
60% or less: 2;
61-70%: 2;
71-80%: 1;
81-90%: 11;
91- 100%: 16;
No expertise/ No answer: 0;
Number of respondents: 32.
b. Livestock markets;
60% or less: 0;
61-70%: 0;
71-80%: 1;
81-90%: 3;
91-100%: 27;
No expertise/ No answer: 1;
Number of respondents: 32.
c. Slaughter facilities;
60% or less: 0;
61-70%: 0;
71-80%: 1;
81- 90%: 2;
91-100%: 28;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q6. What percentage of animals identified is necessary to achieve the
goal of rapid animal disease trace back?
a. Bison;
60% or less: 3;
61-70%: 0;
71-80%: 3;
81-90%: 5;
91-100%: 11;
No expertise/ No answer: 10;
Number of respondents: 32.
b. Camelids (e.g., alpacas, llamas);
60% or less: 3;
61-70%: 0;
71- 80%: 3;
81-90%: 4;
91-100%: 9;
No expertise/ No answer: 13;
Number of respondents: 32.
c. Cattle (beef);
60% or less: 1;
61-70%: 0;
71-80%: 8;
81-90%: 5;
91-100%: 17;
No expertise/ No answer: 1;
Number of respondents: 32.
d. Cattle (dairy);
60% or less: 1;
61-70%: 0;
71-80%: 6;
81-90%: 8;
91-100%: 16;
No expertise/ No answer: 1;
Number of respondents: 32.
e. Cervids (e.g., deer, elk);
60% or less: 0;
61-70%: 2;
71-80%: 4;
81-90%: 4;
91-100%: 10;
No expertise/ No answer: 12;
Number of respondents: 32.
f. Equine (e.g., horses, donkeys, mules);
60% or less: 2;
61-70%: 3;
71-80%: 5;
81-90%: 3;
91-100%: 10;
No expertise/ No answer: 9;
Number of respondents: 32.
g. Goats;
60% or less: 3;
61-70%: 1;
71-80%: 4;
81-90%: 7;
91-100%: 10;
No expertise/ No answer: 7;
Number of respondents: 32.
h. Poultry (commercial);
60% or less: 0;
61-70%: 1;
71-80%: 4;
81- 90%: 5;
91-100%: 17;
No expertise/ No answer: 5;
Number of respondents: 32.
i. Poultry (non-commercial);
60% or less: 1;
61-70%: 0;
71-80%: 4;
81-90%: 3;
91-100%: 18;
No expertise/ No answer: 6;
Number of respondents: 32.
j. Sheep;
60% or less: 1;
61-70%: 2;
71-80%: 5;
81-90%: 6;
91-100%: 15;
No expertise/ No answer: 3;
Number of respondents: 32.
k. Swine (individual);
60% or less: 5;
61-70%: 1;
71-80%: 3;
81-90%: 4;
91-100%: 15;
No expertise/ No answer: 4;
Number of respondents: 32.
l. Swine (group);
60% or less: 0;
61-70%: 1;
71-80%: 4;
81-90%: 7;
91-100%: 18;
No expertise/ No answer: 2;
Number of respondents: 32.
[End of table]
Q7. What percentage of animals tracked is necessary to achieve the goal
of rapid animal disease trace back?
a. Producers;
0-25%: 2;
26-50%: 1;
51-75%: 7;
76-100%: 22;
No expertise/ No answer: 0;
Number of respondents: 32.
b. Livestock markets;
0-25%: 2;
26-50%: 0;
51-75%: 2;
76-100%: 27;
No expertise/ No answer: 1;
Number of respondents: 32.
c. Slaughter facilities;
0-25%: 2;
26-50%: 0;
51-75%: 2;
76-100%: 27;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Part III: Implementation of NAIS:
NAIS is being implemented for all livestock species, including bison,
camelids, cattle (beef and dairy), cervids, equine, goats, poultry,
sheep, and swine. Countries that have already implemented national
animal ID programs (e.g., Canada, EU, Australia) generally started with
cattle and, in some cases, later extended their program to cover a few
other species. No other country has attempted to reach the number of
species that USDA aims to cover with NAIS, nor has any other country
implemented a program for multiple species simultaneously.
Q8. What types of incentives do you believe could be used to achieve a
high level of participation in the premises registration, animal
identification, and/or animal tracking components of NAIS?
Number of experts who provided a response: 32;
No expertise/No response: 0.
[End of table]
Q9. In your opinion, should participation in NAIS be mandatory?
Definitely yes: 17;
Probably yes: 10;
Uncertain: 2;
Probably no: 2;
Definitely no: 1;
No expertise/ No answer: 0;
Number of respondents: 32.
[End of table]
Q10. How would you characterize USDA's effectiveness in communicating
roles and responsibilities for NAIS?
a. Producers;
Very effective: 0;
Generally effective: 2;
Neither effective nor ineffective: 3;
Generally ineffective: 18;
Very ineffective: 7;
No expertise/ No answer: 2;
Number of respondents: 32.
b. Livestock markets;
Very effective: 0;
Generally effective: 5;
Neither effective nor ineffective: 3;
Generally ineffective: 14;
Very ineffective: 5;
No expertise/ No answer: 5;
Number of respondents: 32.
c. Slaughter facilities;
Very effective: 1;
Generally effective: 9;
Neither effective nor ineffective: 4;
Generally ineffective: 6;
Very ineffective: 5;
No expertise/ No answer: 7;
Number of respondents: 32.
d. State animal health officials;
Very effective: 4;
Generally effective: 14;
Neither effective nor ineffective: 2;
Generally ineffective: 3;
Very ineffective: 3;
No expertise/ No answer: 6;
Number of respondents: 32.
[End of table]
Q11. If you believe that USDA's communications are not as effective as
they could be, please describe any actions that USDA could take to make
communications better.
Number of experts who provided a response: 27;
No expertise/No response: 5.
[End of table]
Q12. In your opinion, should USDA limit NAIS to one or a few species or
continue with its current approach to include all species?
Definitely limit to one or few species: 6;
Probably limit to one or few species: 4;
Uncertain: 1;
Probably continue with current approach of including all species: 16;
Definitely continue with current approach of including all species: 5;
No expertise/ No answer: 0;
Number of respondents: 32.
[End of table]
Q13. In your opinion, should USDA implement NAIS incrementally by
species, or continue with its current approach to implement NAIS for
all species simultaneously?
Definitely implement incrementally by species: 13;
Probably implement incrementally by species: 8;
Uncertain: 2;
Probably continue with current approach of implementing for all species
simultaneously: 6;
Definitely continue with current approach of implementing for all
species simultaneously: 2;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q14. In your opinion, what criteria should be used to determine the
priority given to each species in implementing NAIS?
Number of experts who provided a response: 30;
No expertise/No response: 2.
[End of table]
Q15. In your opinion, what priority should be given to each species in
implementing NAIS?
a. Bison;
Lowest priority: 5;
Low priority: 8;
Medium priority: 7;
High priority: 5;
Highest priority: 3;
No expertise/ No answer: 4;
Number of respondents: 32.
b. Camelids (e.g., alpacas, llamas);
Lowest priority: 14;
Low priority: 9;
Medium priority: 2;
High priority: 2;
Highest priority: 0;
No expertise/ No answer: 5;
Number of respondents: 32.
c. Cattle (beef);
Lowest priority: 0;
Low priority: 0;
Medium priority: 1;
High priority: 7;
Highest priority: 23;
No expertise/ No answer: 1;
Number of respondents: 32.
d. Cattle (dairy);
Lowest priority: 0;
Low priority: 0;
Medium priority: 1;
High priority: 6;
Highest priority: 24;
No expertise/ No answer: 1;
Number of respondents: 32.
e. Cervids (e.g., deer, elk);
Lowest priority: 4;
Low priority: 11;
Medium priority: 6;
High priority: 4;
Highest priority: 4;
No expertise/ No answer: 3;
Number of respondents: 32.
f. Equine (e.g., horses, donkeys, mules);
Lowest priority: 7;
Low priority: 7;
Medium priority: 11;
High priority: 3;
Highest priority: 0;
No expertise/ No answer: 4;
Number of respondents: 32.
g. Goats;
Lowest priority: 4;
Low priority: 8;
Medium priority: 11;
High priority: 1;
Highest priority: 5;
No expertise/ No answer: 3;
Number of respondents: 32.
h. Poultry (commercial);
Lowest priority: 1;
Low priority: 1;
Medium priority: 5;
High priority: 9;
Highest priority: 13;
No expertise/ No answer: 3;
Number of respondents: 32.
i. Poultry (non-commercial);
Lowest priority: 3;
Low priority: 5;
Medium priority: 10;
High priority: 6;
Highest priority: 6;
No expertise/ No answer: 2;
Number of respondents: 32.
j. Sheep;
Lowest priority: 2;
Low priority: 5;
Medium priority: 8;
High priority: 10;
Highest priority: 6;
No expertise/ No answer: 1;
Number of respondents: 32.
k. Swine (individual);
Lowest priority: 3;
Low priority: 12;
Medium priority: 5;
High priority: 5;
Highest priority: 6;
No expertise/ No answer: 1;
Number of respondents: 32.
l. Swine (group);
Lowest priority: 1;
Low priority: 1;
Medium priority: 2;
High priority: 11;
Highest priority: 16;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Part IV: Costs and Benefits of NAIS:
USDA has not released detailed information on the cost of implementing
and maintaining NAIS for producers, livestock markets, slaughter
facilities, states, and others that are subject to NAIS. In the
November 2006 draft NAIS User Guide (pg. 12) USDA states that it plans
to conduct a cost-benefit analysis that will help forecast more
precisely the potential economic effects of NAIS.
Q16. Should USDA publish a cost-benefit analysis for NAIS that contains
detailed cost and benefit information for the different sectors of the
livestock industry, states, and USDA?
Definitely yes: 21;
Probably yes: 8;
Uncertain: 2;
Probably no: 1;
Definitely no: 0;
No expertise/ No answer: 0;
Number of respondents: 32.
[End of table]
Q17. Do you believe there are other actions that USDA should take to
address the cost(s) of implementing and maintaining NAIS?
Definitely yes: 14;
Probably yes: 15;
Uncertain: 2;
Probably no: 0;
Definitely no: 0;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q18. If you answered "Definitely yes" or "Probably yes" to question 17,
what other actions should USDA take to address the cost of implementing
and maintaining NAIS?
Number of experts who provided a response: 29;
No expertise/No response: 3.
[End of table]
Q19. Do you believe there are other actions that USDA could take to
make known the benefit(s) of implementing and maintaining NAIS?
Definitely yes: 19;
Probably yes: 10;
Uncertain: 2;
Probably no: 1;
Definitely no: 0;
No expertise/ No answer: 0;
Number of respondents: 32.
[End of table]
Q20. If you answered "Definitely yes" or "Probably yes" to Question 19,
what other actions could USDA take to make known the benefit(s) of
implementing and maintaining NAIS?
Number of experts who provided a response: 29;
No expertise/No response: 3.
[End of table]
Q21. In your opinion, what overall, net effect (considering all costs
and benefits) will NAIS likely have on producers, livestock markets,
and/or slaughter facilities?
a. Producers;
Definitely negative: 1;
Probably negative: 6;
No effect: 0;
Probably positive: 13;
Definitely positive: 11;
No expertise/ No answer: 1;
Number of respondents: 32.
b. Livestock markets;
Definitely negative: 1;
Probably negative: 6;
No effect: 3;
Probably positive: 9;
Definitely positive: 11;
No expertise/ No answer: 2;
Number of respondents: 32.
c. Slaughter facilities;
Definitely negative: 0;
Probably negative: 2;
No effect: 6;
Probably positive: 8;
Definitely positive: 14;
No expertise/ No answer: 2;
Number of respondents: 32.
[End of table]
Part V: Impact on the Livestock Industry and Consumers:
This section asks about vertical coordination, which refers to the way
products are exchanged between different stages of production in a
market, such as between farmers, processors, and retailers. The three
basic types of vertical coordination are: (1) open-production, where a
firm purchases a commodity from a producer at the market price
determined at the time of purchase; (2) contract-production
(contracting), where a firm commits to purchase a commodity from a
producer at a price established in advance of the purchase; and (3)
vertical integration, where a single firm controls the flow of the
commodity across two or more stages of production. There are also
questions about horizontal consolidation, the process by which
production is organized into fewer, but larger, plants or farms.
Q22. In your opinion, will NAIS make contracting, vertical integration,
and/or horizontal consolidation in the livestock industry (all species)
more or less likely to occur?
a. Contracting;
Definitely more likely: 3;
Probably more likely: 13;
No effect: 15;
Probably less likely: 1;
Definitely less likely: 0;
No expertise/ No answer: 0;
Number of respondents: 32.
b. Vertical integration;
Definitely more likely: 4;
Probably more likely: 8;
No effect: 18;
Probably less likely: 2;
Definitely less likely: 0;
No expertise/ No answer: 0;
Number of respondents: 32.
c. Horizontal consolidation;
Definitely more likely: 0;
Probably more likely: 16;
No effect: 15;
Probably less likely: 1;
Definitely less likely: 0;
No expertise/ No answer: 0;
Number of respondents: 32.
[End of table]
Q23. In the textbox below, please provide a brief explanation for why
you think NAIS will make contracting, vertical integration, and/or
horizontal consolidation more or less likely to occur.
Number of experts who provided a response: 31;
No expertise/No response: 1.
[End of table]
Q24. In what ways, if any, should USDA address any of the effects NAIS
could have on the industry due to contracting, vertical integration,
and/or horizontal consolidation?
Number of experts who provided a response: 29;
No expertise/No response: 3.
[End of table]
Q25. In your opinion, will NAIS result in higher or lower prices for
meat and/or other animal products?
Definitely higher: 3;
Probably higher: 9;
No effect: 15;
Probably lower: 2;
Definitely lower: 0;
No expertise/ No answer: 3;
Number of respondents: 32.
[End of table]
Q26. In your opinion, if NAIS causes costs of livestock markets and/or
slaughter facilities to increase, what effect will that have on the
prices paid to producers for livestock?
Definitely increase: 0;
Probably increase: 2;
No effect: 8;
Probably decrease: 17;
Definitely decrease: 4;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q27. In your opinion, if NAIS causes costs of livestock markets and/or
slaughter facilities to decrease, what effect will that have on the
prices paid to producers for livestock?
Definitely increase: 2;
Probably increase: 14;
No effect: 13;
Probably decrease: 1;
Definitely decrease: 0;
No expertise/ No answer: 2;
Number of respondents: 32.
[End of table]
Part VI: Animal Identification and Tracking Technologies:
Canada and Australia have adopted standards that limit the acceptable
identification and tracking technologies to certain electronic devices
for their national animal (cattle) ID programs. However, USDA has taken
a "technology-neutral" position so that many different types of ID
devices, both visual and electronic, are acceptable under NAIS. Some of
USDA's NAIS Species Working Groups have recommended specific ID devices
for their industries, such as cattle RFID ear tags and equine neck
microchips, but USDA has not adopted these recommendations as NAIS
standards.
Q28. Does USDA's "technology-neutral" position encourage or discourage
investment by producers in animal identification technology (e.g.,
individual animal ID devices)?
Definitely encourages: 3;
Probably encourages: 3;
Neither encourages nor discourages: 2;
Probably discourages: 14;
Definitely discourages: 9;
No expertise/ No answer: 1;
Number of respondents: 32.
[End of table]
Q29. Please use the space below to elaborate on your answers to
Question 28.
[End of table]
Q30. Does USDA's "technology-neutral" position encourage or discourage
investment in animal tracking technology (e.g., ID readers, databases,
and retrofitting facilities) by producers, livestock markets, and
slaughter facilities?
a. Producers;
Definitely encourages: 1;
Probably encourages: 1;
Neither encourages nor discourages: 5;
Probably discourages: 12;
Definitely discourages: 12;
No expertise/ No answer: 1;
Number of respondents: 32.
b. Livestock markets;
Definitely encourages: 1;
Probably encourages: 1;
Neither encourages nor discourages: 4;
Probably discourages: 14;
Definitely discourages: 8;
No expertise/ No answer: 4;
Number of respondents: 32.
c. Slaughter facilities;
Definitely encourages: 1;
Probably encourages: 3;
Neither encourages nor discourages: 6;
Probably discourages: 11;
Definitely discourages: 6;
No expertise/ No answer: 5;
Number of respondents: 32.
[End of table]
Q31. Please use the space below to elaborate on your answers to
Question 30.
Number of experts who provided a response: 30;
No expertise/No response: 2.
[End of table]
Q32. Do you know of any specific problems regarding the
interoperability (compatibility) of animal ID and tracking devices made
by different manufacturers? If yes, please describe below.
Number of experts who provided a response: 18;
No expertise/No response: 14.
[End of table]
Q33. What actions could USDA take to address problems affecting the
interoperability of animal ID and tracking devices?
Number of experts who provided a response: 21;
No expertise/No response: 11.
[End of table]
Q34. Do you know of any specific problems affecting the accuracy of
animal tracking devices? If yes, please describe below.
Number of experts who provided a response: 18;
No expertise/No response: 14.
[End of table]
Q35. What actions could USDA take to address problems affecting the
accuracy of animal tracking devices?
Number of experts who provided a response: 19;
No expertise/No response: 13.
[End of table]
Q36. Do you know of any specific problems affecting the longevity of
animal ID or tracking devices? If yes, please describe below.
Number of experts who provided a response: 16;
No expertise/No response: 16.
[End of table]
Q37. What actions could USDA take to address problems affecting the
longevity of animal ID or tracking devices?
Number of experts who provided a response: 21;
No expertise/No response: 11.
[End of table]
Q38. Do you know of any specific problems affecting the ability of
animal tracking devices to keep up with the "speed of commerce" when
animals change ownership? If yes, please describe below.
Number of experts who provided a response: 23;
No expertise/No response: 9.
[End of table]
Q39. What actions could USDA take to address any problems affecting the
ability of animal tracking devices to keep up with the speed of
commerce?
Number of experts who provided a response: 22;
No expertise/No response: 10.
[End of table]
Part VII: Databases for Tracking Animals:
USDA's original plan for animal tracking, the third component of NAIS,
was for USDA to manage a centralized database that would contain all
animal movements input by industry in the birth-to-slaughter production
process. To address concerns about the protection of proprietary
information, Secretary Johanns announced in August 2005 that USDA would
allow data from approved state and private animal tracking databases
(ATDs) to be transferred to a USDA information system. However, some
industry groups and states have expressed concerns about the cost,
quality, and timeliness of this new, decentralized approach.
Q40. What actions could USDA take to address any concerns about the
cost(s) of the decentralized approach?
Number of experts who provided a response: 29;
No expertise/No response: 3.
[End of table]
Q41. What actions could USDA take to address concerns about the quality
and timeliness of the decentralized approach?
Number of experts who provided a response: 28;
No expertise/No response: 4.
[End of table]
Part VIII: Final Comments:
Q42. Are you in favor of a national animal ID program?
Definitely yes: 25;
Probably yes: 4;
Uncertain: 2;
Probably no: 0;
Definitely no: 0;
No answer: 1;
Number of respondents: 32.
[End of table]
Q43. Are you in favor of NAIS as it is currently planned?
Definitely yes: 0;
Probably yes: 7;
Uncertain: 5;
Probably no: 15;
Definitely no: 5;
Number of respondents: 32.
[End of table]
Q44. If applicable, please explain any discrepancy in your answers to
Questions 42 and 43.
Number of experts who provided a response: 29;
No expertise/No response: 3.
[End of table]
Q45. What changes, if any, would you make to NAIS as it is currently
planned? (Please limit to the 3 most important issues.)
Number of experts who provided a response: 32;
No expertise/No response: 0.
[End of table]
Q46. If you have additional comments about NAIS that you would like to
make, please do so here.
Number of experts who provided a response: 19;
No expertise/No response: 13.
[End of table]
[End of section]
Appendix V Select International Animal Identification and Tracking
Programs:
Table:
Country: Argentina;
Select International Animal Identification and Tracking Programs:
Program name/Law title: Export Cattle Identification System;
Select International AnimaI Identification and Tracking Programs:
Species: Cattle;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory for export;
Select International AnimaI Identification and Tracking Programs: Year
implemented: 2003;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Visual ear tag;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to slaughter.
Country: Australia;
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: National Livestock Identification System;
Select International AnimaI Identification and Tracking Programs:
Species: Cattle, sheep, and goats;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: Cattle: premises registration since 1960s;
individual identification in 2005;
Sheep and goats: initial implementation in 2006;
full implementation in 2009;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Cattle: electronic (radio frequency
identification) ear tag or ear tag/rumen bolus combination;
Sheep and goats: visual ear tags;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to slaughter.
Country: Brazil;
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: Brazilian System of Identification and
Certification of Origin for Bovine and Buffalo;
Select International AnimaI Identification and Tracking Programs:
Species: Cattle and bison;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: First phase (2002): mandatory participation only by those
exporting beef to the European Union;
Second phase (2006): mandatory participation for all foreign exports;
Third phase (2006): mandatory requirement for all foot-and-mouth
disease affected areas, regardless of whether the product is being sold
overseas;
Fourth phase (2007): all beef producers must participate, regardless of
whether the product is being exported;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Visual ear tag combined with one of the
following: button ear tag, electronic device, tattoo, or iron brand;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to slaughter.
Country: Canada;
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: Canadian Cattle Identification Program;
Select International AnimaI Identification and Tracking Programs:
Species: Cattle and bison;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: 2001;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Radio frequency identification;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to carcass inspection or
export.
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: European Union: Canadian Sheep Identification
Program;
Select International AnimaI Identification and Tracking Programs:
Species: European Union: Sheep;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: European Union: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: European Union: 2004;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: European Union: Visual ear tags;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: European Union: Farm of origin to carcass
inspection.
Country: European Union;
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: N/A;
Select International AnimaI Identification and Tracking Programs:
Species: Cattle, buffalo, bison, sheep, goats, equine, and swine;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: Cattle, buffalo, bison, and equine: 2000;
Sheep and goats: 1992;
Swine: 1992;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Cattle, buffalo, and bison: double ear
tag and passport;
Equine: passport;
Sheep and goats: double identification (two ear tags or one ear tag and
a tattoo, mark on the pastern (for goats only), or electronic
identifiers);
Swine: ear tags or tattoos;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to retail.
Country: Japan;
Select International AnimaI Identification and Tracking Programs:
Program name/Law title: Beef Traceability Law;
Select International AnimaI Identification and Tracking Programs:
Species: Beef cattle;
Select International AnimaI Identification and Tracking Programs:
Voluntary or mandatory: Mandatory;
Select International AnimaI Identification and Tracking Programs: Year
implemented: 2003;
Select International AnimaI Identification and Tracking Programs:
Current type of ID device used: Ear tags with minimum requirements;
Select International AnimaI Identification and Tracking Programs:
Production cycle covered: Farm of origin to retail.
Source: GAO summary of reports and articles on international animal ID
programs. Note: We did not independently verify the information on
foreign countries' animal ID systems.
[End of table]
[End of section]
Appendix VI: Information on NAIS Cooperative Agreements:
Table 2: USDA Funding for NAIS Cooperative Agreements to States,
Territories, and Tribes, Fiscal Years 2004 through 2006:
[See PDF for table]
Source: GAO analysis of USDA data.
Note: This information was compiled from data provided by USDA
summarizing signed cooperative agreements between USDA and state,
territory, and tribal governments; we did not independently assess
whether states received funding in these amounts. The award amounts
listed have been adjusted to reflect additional obligations, or
deobligations, reported by USDA.
[A] Some of these pilot projects were funded from CCC fiscal year 2004
funding. Awards that have been committed, but not yet signed, are not
included in this column.
[B] The Fort Belknap Indian Community of the Fort Belknap Reservation
of Montana fiscal year 2006 cooperative agreement for $35,000 included
funding for the following tribes: Fort Belknap Indian Community of the
Fort Belknap Reservation of Montana; Confederated Tribes of the Warm
Springs Reservation of Oregon; and Ute Indian Tribe of the Uintah &
Ouray Reservation, Utah.
[C] The Shoshone Tribe of the Wind River Reservation, Wyoming fiscal
year 2006 cooperative agreement for $115,000 included funding for the
following tribes: Shoshone Tribe of the Wind River Reservation,
Wyoming; Crow Tribe of Montana; Shoshone-Paiute Tribes of the Duck
Valley Reservation, Nevada; Yomba Shoshone Tribe of the Yomba
Reservation, Nevada; Te-Moak Tribe of Western Shoshone Indians of
Nevada (South Fork Band); Washoe Tribe of Nevada & California; Skull
Valley Band of Goshute Indians of Utah; Pyramid Lake Paiute Tribe of
the Pyramid Lake Reservation, Nevada; Arapahoe Tribe of the Wind River
Reservation, Wyoming; and Blackfeet Tribe of the Blackfeet Indian
Reservation of Montana.
[End of table]
Table 3: Species Covered by USDA NAIS Cooperative Agreement Field
Trials, Fiscal Years 2004 and 2005:
Recipient of award: California Department of Food and Agriculture;
Species[A]: Award amount: $752,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: [Empty];
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: ;
Camelids: .
Recipient of award: Colorado Department of Agriculture;
Species[A]: Award amount: 1,214,579;
Bison: Check;
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: Check;
Poultry: [Empty];
Cervids: Check;
Goats: Check;
Camelids: Check.
Recipient of award: Florida Department of Agriculture;
Species[A]: Award amount: 531,840;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Fort Belknap Indian Community;
Species[A]: Award amount: 200,000;
Bison: Check;
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Idaho State Department of Agriculture;
Species[A]: Award amount: 1,164,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: Check;
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: Check;
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Kansas Animal Heath Department;
Species[A]: Award amount: 805,000;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Kentucky Department of Agriculture;
Species[A]: Award amount: 269,093;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Minnesota Board of Animal Health;
Species[A]: Award amount: 434,578;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: Check;
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Montana Department of Livestock;
Species[A]: Award amount: 431,928;
Bison: Check;
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: Check;
Goats: [Empty];
Camelids: [Empty].
Recipient of award: North Dakota State Board of Animal Health;
Species[A]: Award amount: 515,000;
Bison: Check;
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Oklahoma Department of Agriculture;
Species[A]: Award amount: 675,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: Check;
Poultry: [Empty];
Cervids: Check;
Goats: Check;
Camelids: [Empty].
Recipient of award: Pennsylvania Department of Agriculture;
Species[A]: Award amount: 615,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: South Dakota Animal Industry Board;
Species[A]: Award amount: 505,240;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: Check;
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Texas Animal Health Commission;
Species[A]: Award amount: 1,000,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: Check;
Poultry: [Empty];
Cervids: Check;
Goats: Check;
Camelids: [Empty].
Recipient of award: Utah Department of Agriculture and Food;
Species[A]: Award amount: 182,100;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: [Empty];
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: Check;
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Wyoming Livestock Board;
Species[A]: Award amount: 361,929;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: Check;
Sheep: Check;
Equine: Check;
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Fiscal year 2005 funding[B].
Recipient of award: California Department of Food and Agriculture;
Species[A]: Award amount: 350,000;
Bison: [Empty];
Dairy cattle: Check;
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Colorado Department of Agriculture;
Species[A]: Award amount: 295,227;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: Check;
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: Check;
Camelids: [Empty].
Recipient of award: Kansas Animal Health Department;
Species[A]: Award amount: 441,430;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Virginia Department of Agriculture and Consumer
Services;
Species[A]: Award amount: 220,000;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: Check;
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Cheyenne River Sioux Tribe of the Cheyenne River
Reservation, South Dakota;
Species[A]: Award amount: 250,000;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Tennessee Department of Agriculture;
Species[A]: Award amount: 142,973;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: Check;
Swine: [Empty];
Sheep: [Empty];
Equine: [Empty];
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Recipient of award: Pennsylvania State University;
Species[A]: Award amount: 205,856;
Bison: [Empty];
Dairy cattle: [Empty];
Beef cattle: [Empty];
Swine: [Empty];
Sheep: [Empty];
Equine: Check;
Poultry: [Empty];
Cervids: [Empty];
Goats: [Empty];
Camelids: [Empty].
Total;
Species[A]: Award amount: $11,562,773;
Bison: 4;
Dairy cattle: 13;
Swine: 20;
Sheep: 5;
Equine: 11;
Poultry: 5;
Cervids: 0;
Cervids: 6;
Goats: 4;
Camelids: 1.
Source: GAO analysis of USDA data.
[A] This information was compiled from applications to USDA by
cooperative agreement recipients. We did not independently assess
whether the cooperative agreements involved work with these species.
Additional cooperative agreements are undergoing final revisions but
have not yet been signed.
[B] Fiscal year 2004 funding was provided for both field trials and
premises registration activities. Fiscal year 2005 funding was provided
exclusively for field trial activities.
[End of table]
Table 4: NAIS Premises Registration Statistics, by State, as of June 4,
2007:
State: Alabama;
Estimated number of premises[A]: 35,538;
Premises registered[B]: 3,881;
Percentage of premises registered: 10.9%.
State: Alaska;
Estimated number of premises[A]: 354;
Premises registered[B]: 59;
Percentage of premises registered: 16.7.
State: Arizona;
Estimated number of premises[A]: 5,170;
Premises registered[B]: 610;
Percentage of premises registered: 11.8.
State: Arkansas;
Estimated number of premises[A]: 37,614;
Premises registered[B]: 7,463;
Percentage of premises registered: 19.8.
State: California;
Estimated number of premises[A]: 32,500;
Premises registered[B]: 5,017;
Percentage of premises registered: 15.4.
State: Colorado;
Estimated number of premises[A]: 22,951;
Premises registered[B]: 6,280;
Percentage of premises registered: 27.4.
State: Connecticut;
Estimated number of premises[A]: 2,539;
Premises registered[B]: 17;
Percentage of premises registered: 0.7.
State: Delaware;
Estimated number of premises[A]: 1,553;
Premises registered[B]: 651;
Percentage of premises registered: 41.9.
State: Florida;
Estimated number of premises[A]: 28,731;
Premises registered[B]: 3,972;
Percentage of premises registered: 13.8.
State: Georgia;
Estimated number of premises[A]: 35,431;
Premises registered[B]: 3,793;
Percentage of premises registered: 10.7.
State: Hawaii;
Estimated number of premises[A]: 1,391;
Premises registered[B]: 288;
Percentage of premises registered: 20.7.
State: Idaho;
Estimated number of premises[A]: 18,754;
Premises registered[B]: 18,046;
Percentage of premises registered: 96.2.
State: Illinois;
Estimated number of premises[A]: 30,046;
Premises registered[B]: 8,151;
Percentage of premises registered: 27.1.
State: Indiana;
Estimated number of premises[A]: 34,790;
Premises registered[B]: 28,581;
Percentage of premises registered: 82.2.
State: Iowa;
Estimated number of premises[A]: 47,273;
Premises registered[B]: 18,136;
Percentage of premises registered: 38.4.
State: Kansas;
Estimated number of premises[A]: 39,346;
Premises registered[B]: 5,048;
Percentage of premises registered: 12.8.
State: Kentucky;
Estimated number of premises[A]: 61,251;
Premises registered[B]: 12,095;
Percentage of premises registered: 19.7.
State: Louisiana;
Estimated number of premises[A]: 19,677;
Premises registered[B]: 1,121;
Percentage of premises registered: 5.7.
State: Maine;
Estimated number of premises[A]: 4,213;
Premises registered[B]: 416;
Percentage of premises registered: 9.9.
State: Maryland;
Estimated number of premises[A]: 7,837;
Premises registered[B]: 1,332;
Percentage of premises registered: 17.0.
State: Massachusetts;
Estimated number of premises[A]: 3,555;
Premises registered[B]: 1,685;
Percentage of premises registered: 47.4.
State: Michigan;
Estimated number of premises[A]: 29,011;
Premises registered[B]: 18,351;
Percentage of premises registered: 63.3.
State: Minnesota;
Estimated number of premises[A]: 44,193;
Premises registered[B]: 11,741;
Percentage of premises registered: 26.6.
State: Mississippi;
Estimated number of premises[A]: 29,312;
Premises registered[B]: 1,405;
Percentage of premises registered: 4.8.
State: Missouri;
Estimated number of premises[A]: 79,018;
Premises registered[B]: 13,546;
Percentage of premises registered: 17.1.
State: Montana;
Estimated number of premises[A]: 19,708;
Premises registered[B]: 790;
Percentage of premises registered: 4.0.
State: Nebraska;
Estimated number of premises[A]: 30,841;
Premises registered[B]: 13,616;
Percentage of premises registered: 44.1.
State: Nevada;
Estimated number of premises[A]: 2,522;
Premises registered[B]: 1,209;
Percentage of premises registered: 47.9.
State: New Hampshire;
Estimated number of premises[A]: 2,277;
Premises registered[B]: 39;
Percentage of premises registered: 1.7.
State: New Jersey;
Estimated number of premises[A]: 5,315;
Premises registered[B]: 992;
Percentage of premises registered: 18.7.
State: New Mexico;
Estimated number of premises[A]: 11,250;
Premises registered[B]: 962;
Percentage of premises registered: 8.6.
State: New York;
Estimated number of premises[A]: 25,559;
Premises registered[B]: 16,132;
Percentage of premises registered: 63.1.
State: North Carolina;
Estimated number of premises[A]: 36,142;
Premises registered[B]: 9,455;
Percentage of premises registered: 26.2.
State: North Dakota;
Estimated number of premises[A]: 14,085;
Premises registered[B]: 8,209;
Percentage of premises registered: 58.3.
State: Ohio;
Estimated number of premises[A]: 48,073;
Premises registered[B]: 5,697;
Percentage of premises registered: 11.9.
State: Oklahoma;
Estimated number of premises[A]: 71,420;
Premises registered[B]: 7,150;
Percentage of premises registered: 10.0.
State: Oregon;
Estimated number of premises[A]: 28,634;
Premises registered[B]: 2,503;
Percentage of premises registered: 8.7.
State: Pennsylvania;
Estimated number of premises[A]: 42,302;
Premises registered[B]: 27,658;
Percentage of premises registered: 65.4.
State: Rhode Island;
Estimated number of premises[A]: 504;
Premises registered[B]: 5;
Percentage of premises registered: 1.0.
State: South Carolina;
Estimated number of premises[A]: 16,120;
Premises registered[B]: 2,418;
Percentage of premises registered: 15.0.
State: South Dakota;
Estimated number of premises[A]: 22,356;
Premises registered[B]: 4,950;
Percentage of premises registered: 22.1.
State: Tennessee;
Estimated number of premises[A]: 68,010;
Premises registered[B]: 13,375;
Percentage of premises registered: 19.7.
State: Texas;
Estimated number of premises[A]: 187,118;
Premises registered[B]: 28,616;
Percentage of premises registered: 15.3.
State: Utah;
Estimated number of premises[A]: 12,460;
Premises registered[B]: 8,606;
Percentage of premises registered: 69.1.
State: Vermont;
Estimated number of premises[A]: 4,438;
Premises registered[B]: 306;
Percentage of premises registered: 6.9.
State: Virginia;
Estimated number of premises[A]: 37,673;
Premises registered[B]: 4,388;
Percentage of premises registered: 11.6.
State: Washington;
Estimated number of premises[A]: 22,155;
Premises registered[B]: 1,415;
Percentage of premises registered: 6.4.
State: West Virginia;
Estimated number of premises[A]: 17,670;
Premises registered[B]: 8,671;
Percentage of premises registered: 49.1.
State: Wisconsin;
Estimated number of premises[A]: 51,373;
Premises registered[B]: 57,742;
Percentage of premises registered: 112.4.
State: Wyoming;
Estimated number of premises[A]: 8,227;
Premises registered[B]: 1,216;
Percentage of premises registered: 14.8.
Source: USDA NAIS Web site,
http://animalid.aphis.usda.gov/nais/premises_id/update.shtml, updated
weekly.
Note: According to USDA, this information represents a snapshot of the
progress being made with regard to premises registration in each state.
The figures are USDA estimates, and we did not independently verify
this information.
[A] The National Agriculture Statistics Survey estimates 1.4 million
livestock farms in the United States (premises more than $1,000 in
annual income). Premises with more than one species are counted one
time.
[B] Premises registered in the National Animal Identification System.
[End of table]
Table 5: USDA's Criteria for Distributing NAIS Cooperative Agreement
Funding in Fiscal Year 2007:
State.
AL;
Reserved amount: $276,000.
AK;
Reserved amount: 80,000.
AZ;
Reserved amount: 178,000.
AR;
Reserved amount: 277,000.
CA;
Reserved amount: 575,000.
CO;
Reserved amount: 376,000.
CT;
Reserved amount: 80,000.
DE;
Reserved amount: 80,000.
FL;
Reserved amount: 277,000.
GA;
Reserved amount: 180,000.
HI;
Reserved amount: 81,000.
ID;
Reserved amount: 278,000.
IL;
Reserved amount: 180,000.
IN;
Reserved amount: 179,000.
IA;
Reserved amount: 474,000.
KS;
Reserved amount: 673,000.
KY;
Reserved amount: 375,000.
LA;
Reserved amount: 178,000.
ME;
Reserved amount: 80,000.
MD;
Reserved amount: 81,000.
MA;
Reserved amount: 80,000.
MI;
Reserved amount: 179,000.
MN;
Reserved amount: 279,000.
MS;
Reserved amount: 179,000.
MO;
Reserved amount: 572,000.
MT;
Reserved amount: 279,000.
NE;
Reserved amount: 672,000.
NV;
Reserved amount: 82,000.
NH;
Reserved amount: 80,000.
State.
NJ;
Reserved amount: 80,000.
NM;
Reserved amount: 276,000.
NY;
Reserved amount: 276,000.
NC;
Reserved amount: 179,000.
ND;
Reserved amount: 277,000.
OH;
Reserved amount: 276,000.
OK;
Reserved amount: 575,000.
OR;
Reserved amount: 276,000.
PA;
Reserved amount: 277,000.
RI;
Reserved amount: 80,000.
SC;
Reserved amount: 177,000.
SD;
Reserved amount: 474,000.
TN;
Reserved amount: 279,000.
TX;
Reserved amount: 1,200,000.
UT;
Reserved amount: 179,000.
VT;
Reserved amount: 81,000.
VA;
Reserved amount: 277,000.
WA;
Reserved amount: 179,000.
WV;
Reserved amount: 177,000.
WI;
Reserved amount: 378,000.
WY;
Reserved amount: 276,000.
Total;
Reserved amount: $13,609,000.
Source: GAO analysis of USDA data.
[A] States with less than $82,000 reserved and states that have
achieved greater than 25 percent of premises registered are not subject
to a midyear performance review and are eligible to apply for an amount
up to the total reserved amount. States that have awards larger than
$82,000 and have achieved 25 percent or less of premises registered are
subject to a midyear performance review. States subject to this review
will be provided only 90 percent of the reserved amount at the
beginning of the funding period. Depending on successful achievement of
measurable outcomes proposed in the initial work plan as of a midyear
review, the remaining 10 percent, or appropriate portion of the
remaining 10 percent, of the reserved amount may be allocated to the
state for the remaining 6 months of the funding period.
[B] Premises registration information is current as of application
announcement in November 2006. The remaining funds can be spent on
automatic data collection equipment for livestock markets and dealers
to support NAIS integration with established state/federal cooperative
animal health programs and for incentives, such as promotional items,
to encourage producers to implement portions of NAIS.
[End of table]
[End of section]
Appendix VII: Comments from the U.S. Department of Agriculture:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
USDA:
United States Department of Agriculture:
Office of the Secretary:
Washington, D.C. 20250:
Jun 7 2007:
Ms. Lisa Shames, Director:
Natural Resources and Environment:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shames:
The United States Department of Agriculture (USDA) has reviewed the
U.S. Government Accountability Office's (GAO) draft report, "National
Animal Identification System: USDA Needs to Resolve Several Key
Implementation Issues to Achieve Rapid and Effective Disease Traceback"
(07-592). USDA appreciates GAO's comprehensive evaluation of the
National Animal Identification System (NAIS), which has been, and will
continue to be, a top priority for the USDA. USDA concurs with most of
the GAO's eight recommendations but also provides points of
clarification to several as well as discussion about parts of
recommendations that conflict with established Departmental policies.
Specific details regarding each recommendation are provided below,
along with current and future actions that the Administrator of the
Animal and Plant Health Inspection Service (APHIS) has taken or will
undertake in the near future.
USDA concurs with Recommendation 1 to reestablish participation
benchmarks to gauge progress, and believes these benchmarks are an
appropriate measure of the progress of NAIS premises registration,
animal identification, and tracing animals. APHIS understands that
implementation strategies are critical to ensure necessary levels of
participation are achieved, but remains committed to a voluntary
program that will meet the needs of the industry.
Regarding the actions to achieve effective traceback, APHIS is
utilizing a variety of different methods and tools to determine the
most effective and efficient strategies to maximize traceability for
animal diseases. APHIS will establish priorities in populations or
industry sectors of significant economic importance where current voids
or shortfalls exist in traceability. Also, APHIS will develop, in
collaboration with various Species Working Groups, a NAIS Short-Term,
and Long-Term Implementation Strategies document that will contain
actions for the remainder of 2007 through 2011.
The Short-Term Implementation Strategies document, targeted for
publication in August 2007, will outline strategies through 2009 and
will target species/industry sectors that have the greatest needs for
advancing premises registration, animal identification, and tracing.
The Long-Term Implementation Strategies document will be distributed in
early 2008 and will feature longer-term participation benchmarks
through 2011. The Long-Term plan will call for an evaluation of
participation through 2009 to determine what actions, such as
incentives, if any, are needed to accelerate participation while
maintaining the voluntary program. Of critical importance, APHIS will
continue to maintain collaboration with the industry to fine tune the
short-term strategies and to advance the longer-term plans.
With regard to Recommendation 2, APHIS acknowledges that the need to
advance traceability for certain sectors is greater than for others and
concurs that implementing certain components of the NAIS or addressing
issues that are more species-specific, incrementally by species and/or
sectors is necessary and appropriate at this time.
APHIS appreciates GAO's comments in prioritizing implementation of
NAIS. However, animal diseases are not always species-specific. For
example, Foot-and-Mouth disease (FMD) was first diagnosed in swine in
the UK outbreak but soon affected cattle and sheep. Therefore, APHIS
recognizes that NAIS must be inclusive for all livestock and poultry.
Thus, the initial development and implementation efforts of NAIS
involved the establishment of standards for data elements that are
basic for all species to ensure systems would not require changes as
more species participate. The foundation of NAIS, premises
registration, continues to be appropriate for all species, in
particular for operations that have multiple species to avoid
duplication and/or inefficiencies for the registration of premises.
Since premises registration is the foundation for the system and is
appropriate for all species, APHIS will continue to encourage
participation of all producers and animal owners in this component of
the program, rather than implementing premises registration
incrementally by species.
Regarding the other two components of the program - animal
identification and animal tracing-APHIS recognizes the value of GAO's
recommendation for prioritizing implementation. To address this need,
the NAIS Short-Term Implementation Strategies document will also
identify the major food animal species and others that have significant
economic impact to animal agriculture as "Tier 1" priorities with the
balance of the species targeted as "Tier 2." Such an approach will
ensure that all industries continue to maintain dialogue and
collaborate in the development of plans that support AIS, while the
immediate implementation strategies target "Tier 1" industries.
For Tier 1, methodologies are being defined to prioritize species and/
or industry sectors as well as strategies for maximizing traceability
for animal disease. The factors being considered include: (1) the
potential of the species industry having a disease event of significant
economic impact; (2) the risk of such disease to human health; (3) the
void in current traceback capabilities; (4) the economic importance of
the species from a value of production standpoint; and (5) potential
association of disease spread with other species.
For Recommendation 3, APHIS is accelerating actions to further advance
the integration with existing disease programs. Additionally, APHIS is
participating in a Brand State Working Group to explore and consider
recommendations on how brand systems can be utilized more extensively
in NAIS. The November 2004 interim rule on Alternative Numbering
Systems established the Premises Identification Number (PIN) as a
standard for identifying locations that manage and/or hold livestock.
The use of the PIN format is being established as the standard for all
disease programs regardless of participation in NAIS to ensure the
locations are uniquely identified across all disease programs. The
Animal Identification Number (AIN) was established as an additional
official numbering system and is official for all disease program
activities (Bovine Tuberculosis (TB), Brucellosis, Scrapie, etc.) if
its use is preferred by the producer. In Michigan, for example, the AIN
has become the standard numbering system for its TB eradication
program.
As another example, the National Scrapie Eradication Program
extensively uses a unique individual numbering system that combines the
flock identification number with a unique herd management number. The
Code of Federal Regulations recognizes this as an official numbering
system and NAIS also incorporates this numbering system, since it is
nationally unique and easy to determine the origin of the animal.
Future strategies will be established to ensure the PIN is linked to
locations that manage sheep to ensure a uniform location identifier,
while recognizing that the flock identifier remains important for the
sheep industry, and in many cases, may be maintained by the producer.
APHIS will undertake steps to advance the integration of NAIS with
existing disease programs. The Short-Term Implementation Strategies
document will further define plans to advance integration. The NAIS
User Guide will be updated in October 2007 to more clearly reflect the
use of other official identification numbers within NAIS, and the NAIS
Program Standards document will clearly list all current official
identification devices. APHIS will publish a Notice of Availability in
the Federal Register for both documents. As with all previous NAIS
plans, stakeholders will be encouraged to comment on these documents.
USDA concurs, in part, with Recommendation 4. Specifically, APHIS
agrees with the need to establish more robust processes for having
identification devices tested to meet minimum performance standards and
will continue to call for appropriate public standards like those
defined through the International Organization for Standardization
(ISO). However, with regard to GAO's recommendation to establish a
process to select devices, APHIS acknowledges that there remains
controversy within the industry regarding the capabilities of existing
animal identification technologies and believes that working with
stakeholders to resolve such issues is imperative before determination
and selection of technologies is made.
APHIS has already endorsed the incorporation of technical standards,
such as ISO 11784 and 11785 for the Radio Frequency Identification of
Animals. APHIS believes such standards are imperative to achieve
compatibility of a technology across multiple vendors. In addition,
APHIS believes that in-depth measurable performance standards must be
clearly defined through a consensus of affected stakeholders. This
approach will ensure the technologies can successfully be applied for
other uses beyond NAIS, including management and marketing
opportunities.
APHIS has initiated dialogue with an international organization that
can provide the necessary venue for facilitating the development of
performance standards for livestock animal identification. The first
action item of the organization will be to establish a Task Force of
industry experts. The organization anticipates organizing this task
force in the third quarter of 2007, but until the task force can define
a work plan, it is premature to suggest a timeline for the publication
of resulting performance standards. As the performance standards are
established and tested, the selection of such devices will then be
warranted and well-documented.
APHIS maintains that testing of devices be done in the private sector
at the expense of the device manufacturer. As part of the evaluation
process, APHIS will specify the testing standards and protocols and
then review the manufacturer's documentation of laboratory testing and
field trials.
USDA concurs with Recommendation 5 that certain traceback timelines and
goals should be established in consultation with Species Working Groups
and State and industry partners. USDA would like to add that the proper
interpretation of the goal is necessary. Specifically, APHIS believes
that a time frame and goals should be established for when information
is to be available to animal health officials after the detection of a
disease of concern. These administrative time frames are independent of
species, animal industry sector, or disease entity.
While the timeline or level of urgency for response to different
disease varies, highly contagious diseases require the timeliest
response possible. APHIS also recognizes that the degree of tracing
required may differ depending on the disease in question. For instance,
when a highly contagious disease such as FMD is detected, animal health
officials recognize that the animal has not been infected for very long
because of the relatively short incubation period (2-14 days). In this
case, tracing the location of the infected animal may only need to
account for the 2-3 incubation periods prior to detection. On the other
hand, a slow incubating disease such as TB may need to be traced to the
premises of birth. For this reason, it may take less time to trace an
FMD-infected animal than one infected with TB.
APHIS continues to support 48-hour traceback capability as the
ultimate, long-term goal of NAIS and believes it is a reasonable goal
from which to work. However, we intend to continue to develop
reasonable time frames consistent with the needs of different disease
eradication efforts. We will also need to assess current levels of
manpower and other resources that might impact the attainment of an
acceptable tracing time frame. In order to accomplish this assessment,
we will be working with State and Federal animal health officials,
veterinary epidemiologists, and program staff experts.
Developing a system that can support the response to the worst case
scenario is imperative. While not all responses would utilize all the
system capabilities, it is important that the system is robust and can
receive and manage large volumes of data efficiently and effectively.
In addition to the timeline itself, determining the reliability of the
system for achieving an effective and complete traceback or trace
forward within a specified time is a critical but complex issue.
USDA appreciates GAO's recommendation regarding the development of
species-specific plans and will work through the working groups to
document and define current capabilities within each respective
industry in order to establish practical, realistic, and cost effective
traceback goals that are warranted for each species. The Long-Term
Implementation document will include general timelines for progressing
toward acceptable goals.
For Recommendation 6, USDA concurs. APHIS has conducted significant
discussion on this issue with stakeholders through the Species Working
Groups and in collaboration with industry. Participants identified the
minimum data elements needed to conduct a traceback investigation.
APHIS incorporated these data requirements into NAIS through the Animal
Tracking Databases' (ATDs) requirements. Other data elements, such as
species, date of birth, and gender, are often contained in information
systems maintained by service providers in animal agriculture and may
be provided when necessary. Requiring additional information for an
animal record to be considered a "qualifying" record, however, must be
closely evaluated so as not to exclude otherwise valuable information.
USDA appreciates GAO's insightfulness and believes there is
justification in evaluating this issue to ensure information necessary
to conduct a traceback is available to animal health officials. Through
the development of the ATDs, APHIS has established a process to ensure
that any consideration of expanding data elements is done in
collaboration with the Species Working Groups and through the
recommendation of the NAIS Subcommittee. Experience with the ATDs as
they come on-line with the Animal Trace Processing System will allow
APHIS to document the availability of necessary information. APHIS
anticipates that ATDs will be used more fully in late 2008/early 2009
and that GAO's recommended evaluation be considered at that time. If
warranted, discussions with the Species Working Groups and through the
Subcommittee to consider additional required data elements can also be
considered at that time.
USDA concurs with Recommendation 7. The majority of the NAIS
cooperative agreements are provided to States and Tribes to implement
the program. Premises registration and outreach activities have been a
priority and APHIS publishes the level of premises registration
achieved by each State on a weekly basis on the NAIS Web site. In 2007,
a base plus performance system has been implemented that provides an
incentive for States to advance NAIS and offers the States flexibility
for moving forward with animal identification as premises registration
progresses in their State. APHIS will continue to provide participation
levels by State on our Web site. Further, APHIS has published three
reports on the initial Pilot Projects funded through the 2004 Commodity
Credit Corporation funds. Several additional field trial projects have
been awarded since the initial pilot projects, and, as part of their
approval, more defined measurable and documented outcomes are being
established for monitoring as well as reporting outcomes. These
criteria, currently in place, will ensure results can be more fully
published in a timelier manner.
USDA concurs with Recommendation 8 regarding the planned analysis of
the costs and benefits of NAIS following the criteria established in
OMB guidance for conducting cost-benefit analyses for federal program.
As such, the request for proposal was published on March 21, 2007 with
a proposal deadline of June 4, 2007. It is anticipated that the
agreement for the analysis can be made in early June with approximately
twelve months planned for conducting and preparing the report. The
publication of the cost-benefit analysis is targeted for mid-2008.
And lastly, USDA appreciates the opportunity to work with GAO on the
evaluation of this program. NAIS has been, and will remain, a top
priority for USDA, and specifically for APHIS, because it supports one
of our most important missions: maintaining the health of U.S. animals.
Identification of animals in the production chain is a critical tool
for safeguarding our Nation's herds and flocks from disease. USDA has
invested a great deal of time and resources into the program, and we
are encouraged by the progress being made. As we continue to move
forward, we believe GAO's evaluation and recommendations are of great
value to the NAIS.
Sincerely,
Signed by:
Bruce I. Knight:
Under Secretary:
Marketing and Regulatory Programs:
The following are GAO's comments on the U.S. Department of
Agriculture's letter dated June 7, 2007.
GAO Comments:
1. We added a statement about USDA's developing, in collaboration with
the species working groups, a NAIS Short-Term and Long-Term
Implementation Strategies document that will contain actions for the
remainder of 2007 through 2011.
2. We added a statement about USDA's plans to update the NAIS User
Guide in October 2007 to more clearly reflect the use of other official
ID numbers within NAIS.
[End of section]
Appendix VIII: GAO Contact and Staff Acknowledgments:
GAO Contact:
Lisa Shames, (202) 512-3841 or ShamesL@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Josey Ballenger and Heather
Hill made significant contributions to this report. Kevin Bray, Nancy
Crothers, John de Ferrari, Mary Denigan-Macauley, Barbara El-Osta, J.
Erin Lansburg, Allen Lomax, Lynn Musser, Shannin O'Neill, and Susan
Ragland also provided key assistance.
FOOTNOTES
[1] GAO, High-Risk Series: An Update, GAO-07-310 (Washington, D.C.:
January 2007).
[2] In this report, we use the word "livestock" to refer to all animals
involved in livestock production, including poultry.
[3] GAO, Avian Influenza: USDA Has Taken Important Steps to Prepare for
Outbreaks, but Better Planning Could Improve Response, GAO-07-652
(Washington, D.C.: June 11, 2007).
[4] GAO, Mad Cow Disease: FDA's Management of the Feed Ban Has
Improved, but Oversight Weaknesses Continue to Limit Program
Effectiveness, GAO-05-101 (Washington, D.C.: Feb. 25, 2005).
[5] GAO, Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must
Remain Vigilant and Resolve Outstanding Issues, GAO-02-808 (Washington,
D.C.: July 26, 2002).
[6] 7 U.S.C. § 8308.
[7] Livestock Identification;
Use of Alternative Numbering System, 69 Fed. Reg. 64,644 (Nov. 8,
2004).
[8] USDA, National Animal Identification System (NAIS): A User Guide
and Additional Information Resources, Draft Version (November 2006).
[9] In March 2007, Michigan regulations took effect that require
electronic ear tags for all cattle prior to leaving their premises of
origin.
[10] RFID is an automated data-capture technology that can be used to
electronically identify, track, and store information contained on an
object (in the case of NAIS, an animal).
[11] We did not independently verify the information on foreign
countries' animal ID systems.
[12] Two of the 32 experts were uncertain, and 1 expert did not answer
this question.
[13] USDA, National Animal Identification System (NAIS): Administration
of Official Identification Devices with the Animal Identification
Number (Feb. 23, 2006).
[14] Two experts responded that investment in animal ID technology is
neither encouraged nor discouraged, and 1 expert replied as having no
expertise on this topic.
[15] However, in commenting on a draft of this report, USDA told us
that continued testing and modification of systems in several pilot
projects demonstrated high readability rates of 90 percent to 99
percent for systems that initially showed high variability and low
readability rates of 50 percent to 60 percent.
[16] GAO, Information Security: Radio Frequency Identification
Technology in the Federal Government, GAO-05-551 (Washington, D.C.: May
27, 2005).
[17] GAO, Electronic Government: Progress in Promoting Adoption of
Smart Card Technology, GAO-03-114 (Washington, D.C.: Jan. 3, 2003).
[18] Domestic Working Group, Grant Accountability Project, Guide to
Opportunities for Improving Grant Accountability (Washington, D.C.:
October 2005). The Domestic Working Group is an organization made up of
19 federal, state, and local audit organizations.
[19] Some cooperative agreement projects from fiscal years 2004 through
2007 were still ongoing at the time of our review;
therefore, reports for these agreements were not available.
[20] USDA, National Animal Identification System (NAIS): Pilot
Projects/Field Trials Summary: 2004 Initial Pilot Projects Final Report
and 2005-07 Project Descriptions (May 2007).
[21] GAO, Grants Management: Enhancing Performance Accountability
Provisions Could Lead to Better Results, GAO-06-1046 (Washington, D.C.:
Sept. 29, 2006).
[22] GAO, Economic Performance: Highlights of a Workshop on Economic
Performance Measures, GAO-05-796SP (Washington, D.C.: July 2005).
[23] OMB, Circular A-94 Revised, Guidelines and Discount Rates for
Benefit-Cost Analysis of Federal Programs (Washington, D.C.: updated
Jan. 26, 2006).
[24] The term "obligation" is a definite commitment that creates a
legal liability of the government for the payment of goods and services
ordered or received.
[25] Unobligated funds are the difference between total funding
available and actual obligations.
[26] Contracting is where a firm commits to purchase a commodity from a
producer at a price established in advance of the purchase. Vertical
integration is where a single firm controls the flow of the commodity
across two or more stages of production. Horizontal consolidation
refers to the process by which production is organized into fewer, but
larger, plants or farms.
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