My thoughts on the
National Animal Identification
System...
2006
I'm a small producer of dairy and meat
goats. I don't have a "mega-farm". While
the interest and numbers of goat
operations are increasing, goats don't
even have a functioning national commodity
group organization that
covers meat/dairy fiber. As
producers, we tend to be
independently-minded (!) and
we want to
express our individual opinions and are
outside of what many think of
"traditional" farm operations.
I've been following the
development of a national identification
program since 2002 and have thoroughly
read virtually every document developed.
Trade issues....As
a goat producer, my farm is not directly
impacted by whether or not another country
allows trade that can significantly impact
the large cattle or swine producers. While
goat breeding stock is often exported (and some countries are
asking that animals they purchase be part
of an ID program),
goat products in general are not.
The U.S. imports
substantial
amounts of goat cheese and goat meat and
can't produce enough domestic goat
products to satisfy the growing demands.
But...in general,
what happens in the global picture
of trade does affect me.
While we prefer to
produce our own foods when we can, and buy
from others with the same standards we set
for ourselves, we are still
consumers of many of those products of
larger producers or other products
produced by various segments related to
agriculture. The viability of those
segments of agriculture can impact me
personally as a consumer and as a farmer.
Increased costs or the lack of products
available due to the impacts of foreign
animal disease outbreaks in the US would
affect me and my family.
Animal Health...The
health and viability of my herd of goats
is important to me. The possible
devastation from disease outbreaks in the
US could well mean the end of my
goat operation
and many small operations on the US.
There could be a loss
of 30+ years of genetic selections.
We
can't afford short term, much less long
term loss of income that could happen in a
disease outbreak that takes time and
resources to try to reduce.
It seems to me that having
premises identification for all
farming-related operations would
significantly reduce the time it takes to
find the affected animals and cut the
possible losses for all of us - large and
small producers. That alone could mean the
difference of stopping the disease before
it reached my operation. That alone is a
good incentive for me to participate in
having my premises information added to
the list of others.
Sustainable...
While my operation is small, over
the past 30+ years it has meant a source
of food and income
for my family. It has been a source
of income to help raise
our family and send
our four
daughters to college. It has been a source
of enjoyment for our family. (My father
always told me
that farming wasn't just a "job" it was a
way of life...as usual, his wisdom was
right). Our family operation has relied on
sustainable practices to raise our goats,
hogs, chickens, beef,
fruits and vegetables for our
food supply and to sell.
We want to be good stewards of our land
and protectors of our natural resources as
well as responsible caretakers for our
animals. Some of my friends
have said that NAIS would destroy our
ability as organic, sustainable or
nontraditional farmers to survive. I have
always respected their opinions, but
that's not the picture I see.
Costs and reporting....The
few pieces of information needed to
register my premise can be found on the
web already, or in many other sources. It's just a physical
address, my name as contact and the
species of animals I raise. That's it.
That information is on every page of my
website. When it
gets to the USDA premises database, my
street address is then linked to GPS
coordinates. GPS coordinates
simply help reach
infected premises areas quickly and
efficiently.
I look at the costs of the
program, and I look at the costs of
disease outbreaks. I weigh the risks and
costs of both. Looking
at what is in the NAIS plan, the direct costs to me as a
producer are not significant.
There was
no cost to me to
register my premise. The cost of
identifying my animals is negligible for me. I already
tattoo them, and the NAIS Goat Working
Group is recommending that would be
acceptable identification for goats that
go to a show, for example (and trips to
places like nursing homes or school events
or goat packing aren't a part of any
proposed reporting). If I take them to a
market, I can use the free Scrapie program
tags as an acceptable
ID (electronic implants or RFID tags would
be an option - not a requirement - if I
chose to use them).
When technology
improves and prices for electronic devices
come down in the future, it might be more
viable for us. Right now, there
hasn't been a RFID tag that has been
tested enough in goats to demonstrate a
good ability to be retained, and the price
is still high, particularly if used with
young stock. That's why the
NAIS Goat Working Group is recommending
the continued acceptance of the free
scrapie tags. If the Goat Working Group
not recommended that tattoos be
acceptable ID, I feel very positive that
tags would now be the only option
accepted. By participating in the
process and making our collective voices
heard, we have the option. Some
say we should have simply refused to
participate in the discussion and the
working group process.
It is clear to me that this would simply
have closed the door on our input for
options. By participating in the
discussion, I know my input helped
ensure ID options for all goat owners.
"If" a
reporting/tracking program is ever put into
place, the recommended
reporting at the
auction market would be done by
the market. There are currently
no proposed
requirements or costs for any other
reporting movements, unless I wanted to
participate with one of the optional
commercial privatized databases that will record animal
movements. If the movement records
are just a part of my state's animal
health databases (for example, taken from
health certificates I might need for my
animals when traveling), there are no
additional costs to me for reporting
movements. I realize that the future could
bring changes and possible costs. I
also know that
the price of feed and supplies
and other operational
expenses I might
incur could also increase. Those
are costs of doing business that I will
have to face.
I know I am only one small piece of the
very large and diversified agricultural
community, but my contributions to US
agriculture, as small as they might be in relation to large
operations,
are important to me. I believe a national
animal identification program can help us
protect the health of the livestock and
poultry being raised in the US, whether
that is a large producer, or those of us
with small operations. It can also help
protect food safety and human health. NAIS doesn't increase
my liability as a producer. I am
already liable for animals or products I
offer to the public. Yes, it would
make it easier to locate and trace
diseased animals or food safety threats
faster (which is a good thing, in my
opinion), but my responsibilities and
liabilities are the same whether there is
an animal identification system or not.
Impacts and
changes...From the beginning, I
have had concerns about some components of
the program, but I am seeing many of those
concerns addressed. While there are
areas of the NAIS that I think need
continued consideration and work,
and I think there are
many logistical problems, I think
the idea of a national and uniform program
makes sense, in the larger picture. It
might cause some inconveniences and
changes in the way I operate my farm, but
I will do my best to adjust, just as I
have adjusted to many changes
throughout my life
as a farmer. The USDA
is encouraging and
using the feedback of the various
working groups who are now looking at NAIS
and trying to establish what will work
with each individual species,
so we can have a
program that accommodates the uniqueness
of our species. We need to make sure any
required reporting is actually necessary,
and we need to find ways to make it as
inexpensive, accurate,
least intrusive and as easy as
possible to do. I don't think that's an
impossibility. Using the good feedback
from our producers of all sizes will be
critical. Remaining open-minded and
flexible and adapting to better ways of
getting this done will be essential if
implementation is to be successful.
The facts...I
know that many of my friends and fellow
small farmers have expressed different
opinions on how NAIS might impact their
operations, and while I
appreciate their input, I am
concerned that many of those opinions have
been based on information that has not
been accurate or complete.
As I read them, the NAIS
guidelines do not affect/involve animals
that we raise on our farms and never leave
the farm. They never have.
If we raise them for our family's
home use,
they are not a part of NAIS. If we butcher our animals on
the farm or take them for custom
slaughter, they are not part of NAIS.
Our
laying hens that provide eggs and meat for
our families are not part of NAIS. The goats and cows
we keep at home for our milk or meat
supply are not a part of NAIS. Will any of these ever
be a part of a national animal ID program?
I certainly can't answer that.
But,
everything that is in the NAIS draft
and published materials has always specifically
addressed animals leaving the farm and
commingling, as that is a disease
transmission risk.
If we take our animals to markets, where
they would be mixed (commingled) with
other animals, and at high risk for
getting or transmitting diseases, they
would be part of an animal identification
program, if individual
ID is required. If we take them to
shows, they would need to be identified
(which they already are for every show).
Being able to know what animals
were together at a particular place and
event helps narrow the search for animals
that could be affected with disease,
should an outbreak occur. It reduces the
possible spread of the disease, and could
save the lives of many animals in a
disease outbreak. To
paraphrase a friend, "if we can't find the
problem, we can't fix it".
There is currently no proposal for
requiring a show to report the animals at
that show, but it is likely that records
will need to be kept and available in a
disease outbreak. The "24 hour"
reporting that some people are referencing
in the NAIS Guidelines applies to
slaughterhouses.
My opinions and
actions...There is room for a
lot of opinions on this complex issue.
Diversity of opinion is important and
should be encouraged. Developing those opinions based on facts is the only
way we can work together to have a program
that can be effective, and not overly burdensome. If you want to
effectively argue for change, make your
arguments based on facts, not hearsay and
assumptions.
I think some national
identification program will be put into
place. I prefer a voluntary program,
but I don't know if that would give us the
depth of information that would be most
useful in a disease outbreak, but it
certainly is more than what is currently
available. If we participate on a
voluntary basis, there is much higher
likelihood that a mandatory program is
not needed. I am
willing to be a part of working with
others to help give constructive
feedback to make sure
that whatever is developed is something
that we can work with as goat producers. I am willing to participate in a
program to protect the health of my
animals and the animals in the herds and
flocks of my friends and fellow farmers
across the US and even around the world. I
am willing to post a sign at my farm gate
that says it is a USDA Registered Premise.
I am willing to do my part
(and maybe a sign would also discourage
'would be' goat thieves!).
Please note: To
address questions raised about my
involvement with NAIS: I am not an
employee of USDA. No one has asked me to
make these comments. I am expressing
my own thoughts. My opinions are
subject to change as new information might
become available. One question I
have been asked repeatedly is: 'since so
many large groups are expressing
opposition to NAIS, how could they all be
"wrong"?' If one looks at the
various groups, many are all
basing opinions on the same pieces of
misinformation (for example, incorrectly
stating that that all animals will
be required to be tagged with electronic
IDs; or every animal at one's farm needs
to be IDd/tagged, regardless of whether
they leave or not; or absolutely every movement will need
to be recorded with fees paid; or animals
will be tracked via satellite, etc.). If
those things were true, I couldn't
participate in a national identification program
either! I'm not saying those
opinions are "wrong", as everyone has a
right to an individual opinion, however if
they are based on information that is not
correct, then that makes it a very
different situation, from my perspective.
For more information
on the work of the NAIS Goat Working
Group, Go
Here
For some facts and
myths about NAIS,
Go Here.
For details on my
involvement with ADGA as it relates to
animal identification,
Go Here.
Before forming your
opinion about this program, I encourage
you to find and consider the facts.
Linda Campbell
2008 Update: I support keeping the
NAIS program voluntary!
2009 Update: I continue to contact
my legislators, and I hope you will do
so as well. Here's the letter I
have written:
Dear Honorable XXXXX,
I am once again
contacting you with regard to potential
legislation that would require that the
National Animal Identification System (NAIS)
be implemented on a mandatory basis. As
I have asked previously, I am asking for
your support to help ensure it remains a
voluntary program.
As a goat producer and small farm
owner, I feel it is vital that certain
current details of the voluntary program
remain in place, such as:
1)
No ID requirements for livestock
and poultry that are raised for our
food supply or otherwise do not leave
the farm.
2)
No requirement to participate in
all components of the program. That it,
it is acceptable to have a premises
identification (PIN) but no movement
reporting is necessary, but is optional.
3)
No requirement to use RFIDs or
other specific tags for our goats. With
the current voluntary program, we have
the flexibility to use ID methods that
are already approved for the National
Scrapie Eradication Program (NSEP) and
that includes our use of tattoos for our
registered animals. I, along with many
of my fellow producers, have found that
tattoos are the most effective and
lowest cost option for identifying our
animals. Requiring RFID or other tags
would be an economic detriment, and has
not been proven to be effective for
goats, as retention is still an
identified problem. I feel it is
important to allow the industries to
evaluate and implement what works best
in the respective species.
While I understand
that a mandatory program may provide
more information about livestock
premises that could be of value in an
animal disease emergency, I also believe
there are inherent costs to producers
and taxpayers that have not been
adequately identified. I am also
concerned that sufficient critical
information has not been gathered and
considered. I strongly believe that
providing a voluntary program that
allows those who wish to participate to
do so is the best approach. It sets
uniform standards for an identification
program without mandating compliance for
those who believe it is not in their
best interest to participate for their
own individual reasons, including their
freedom to choose what information they
want to make available.
I have appreciated
the opportunity to speak with your
Legislative Aides, who were most
hospitable and helpful during my
visits. I am always happy to answer any
questions you or your staff may have
with regard to my opinions on this
important topic and am grateful for the
opportunity to do so.
Thank you again
for consideration of my opinions and for
your continued dedication to
agricultural concerns.
Respectfully,
Linda S. Campbell
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