Not so NAIS: Animal-tracking program is solution to wrong problem
Thanks to Marc R. for calling my attention to the Government Accountability Office's recent report on the National Animal Identification System (NAIS). NAIS, which first saw the light of corner offices at the USDA in 2002, flaunts a meaty goal: to identify and track the movement of all livestock animals and poultry in the United States. While producer participation is currently "voluntary" (we'll get back to that in a minute), the program is gearing up to go mandatory in 2009. No worries, according to the USDA: just throw a transmitter tag on Old Bessie's ear; log her info (and yours) into an online database; update it every time you move her or if she gets lost, gets sick, loses her tag, or dies ... and you're good to go.
The USDA claims that once fully implemented, NAIS will allow it to track sick animals to the premises on which they are housed and identify the animals these sickies have come near in 48 hours or less. With all this E. coli, mad cow, and foot and mouth up in our business lately, we should be elated at the prospect of such a program — yes? Because it will improve the safety of our food supply — right?
Maybe, says the GAO. Probably not, say many small farm and food safety advocates (including, incidentally, Walter Jeffries at noNAIS.org, the farmer featured in Peter's most recent post). They argue that NAIS, in the words of Alemany Farm's Jason Mark, is "simply a way for the largest food corporations to sell more products overseas without addressing some of the key weaknesses in the U.S. food system." Never one to shy away from drama and intrigue, I thought I'd take a closer look.
NAIS in a nutshell
NAIS applies to all U.S. residents who own one or more livestock animals, a list that includes everything from cattle, hogs and poultry to horses, buffalo, and llamas. Once the program is mandatory, all livestock owners will be required to register their premises with the federal government. Animals will receive individual identification numbers and will be tagged, usually with either an implanted microchip or a radio frequency device. The one exception to the individual ID requirement is if a group of animals is managed together from birth to death and does not commingle with other animals; in those cases, the whole group can be registered with just one ID. In practice, group IDs will likely apply only to confinement poultry operations or farrow-to-finish hog CAFOs (since when was the last time you knew of a pastured animal that didn't commingle with animals outside its group?).
Once the tags are on, owners must report any change in the animal's status to the government within 24 hours. The most obvious change in status would be slaughter, but owners will also be required to report locational changes — every time an animal is taken to auction, exhibited at a show, brought to the county fair.
The USDA maintains that NAIS is still voluntary for producers, but it has pushed states to implement mandatory participation through a cooperative grant program. States like Wisconsin and Indiana have adopted mandatory regs and others are moving in that direction, sometimes denying credit or other assistance to producers who are not enrolled, according to a December 2006 report from the Weston A. Price Foundation. I visited Wisconsin in the midst of the implementation process and heard stories of Amish and Mennonite farmers, whose religious beliefs prohibit the use of the ID technology, selling their livestock in droves before the state cracked down.
The GAO report treats NAIS as a foregone conclusion, which is unfortunate given the weight of some of the issues it raises. Key among them:
- The USDA doesn't have a "robust process" for selecting and testing the ID technology. That's really too bad, because the program's critics — including the Farm and Ranch Freedom Alliance, whose website has one of the best overviews of NAIS issues I've seen yet — expect NAIS technology to be costly and hard to manage. Producers will have to purchase the tags and equipment to implant them; sales barns or slaughterhouses will have to purchase ID readers and are expected to pass some of their cost off to producers in the form of lower livestock prices. Farmers and ranchers, an occupational category not generally associated with free time, will be burdened with the additional responsibility of logging every animal movement into the Feds' database (with computers the program assumes they have, at a moment when rural internet access is woefully lagging).
- While we're on the subject of costs, might I make a humble observation? When you're about to implement "one of the largest systematic changes ever faced by the livestock industry," it might be useful to conduct a cost-benefit analysis — you know, estimate how much this thing might set us back. But the USDA has yet to do anything of the sort. "As a result," says the GAO assessment, "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." Similar programs have been studied in the UK and Australia, where analysts estimate the costs at between $37 and $69 per animal. Presumably, costs will be higher for smaller producers, while larger producers can take advantage of economies of scale (or that handy group registration for CAFOs mentioned earlier). But no cost is too great when our security's at stake, right?
- Finally, adding insult to injury, the GAO chides the USDA for failing to monitor or evaluate how NAIS is working in the states that have already implemented it. "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" — i.e., that this thing actually works.
That brings us to an important final question: what exactly is NAIS supposed to achieve, again? The stated purpose of the program is to prevent animal disease and increase the safety of our food supply. But many of the most common food-borne illnesses — E. Coli, salmonella, campylobacter — are bacterial, spread most often at the slaughterhouse or by unhygienic food handlers. NAIS tracking ends at the time of slaughter, so by definition, it will not address contamination once meat enters the food supply.
Equally disconcerting is the fact that the proposed rollout of NAIS has not been accompanied by increased funding to test animals for disease. That means that the chances of finding sick animals before they get into the food supply isn't any better than it was before; it just means that on the off-chance that we do find a sick animal, we'll know where it grew up.
If history is any guide, though, it won't really matter whether or not we know what kind of rearing conditions lead to diseases in tracked animals. In 2003, USDA researchers published an article in the journal Avian Diseases that found that "high density confinement rearing methods" gave avian flu "a unique chance to adapt to the new species." A report by the Humane Society of the U.S. cites the USDA's lead avian flu researcher as asserting that "there has never been a recorded emergence of [one of the high-grade poultry viruses] in any backyard flock or free-range poultry operation." Last time I checked, the USDA wasn't telling Tyson switch to pastured poultry in the interest of our nation's food security. NAIS does nothing to address the main causes of disease in livestock: feeding them things they shouldn't eat (remember how mad cow started?) and raising them in confinement conditions.
Grassroots lobbying efforts against mandatory NAIS are well underway, and the groups involved are celebrating a recent victory. In yet another tidbit to file under "small but positive reforms in the Farm Bill," the Liberty Ark Coalition reports that a provision in the House bill tying the implementation of Country of Origin Labeling (COOL) to mandatory NAIS was defeated. LAC's site has updated information on the status of NAIS and tools to take action — cause you know you want to — as the Farm Bill moves into the Senate.
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