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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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