Speer: EIDs – Signal Versus Noise

“Use of Electronic Identification Eartags (EIDs) as Official Identification in Cattle and Bison”.  USDA’s proposed rule change to the Animal Disease Traceability (ADT) framework has given rise to several recurring arguments which muddy the water.  Some of those are addressed below related to EIDs and the proposed rule (in no particular order, albeit the last being the most important). 

ADT vs PVP:  There’s always confusion (some of it intentional) regarding ADT requirements versus Process Verified Programs (PVPs).  Simply stated, they don’t overlap.  

One, ADT is mandatory and regulated by USDA:APHIS; PVPs are voluntary, market-driven and overseen by USDA:AMS.   Two, PVPs cover feeder cattle through slaughter; ADT regulations apply only to interstate movement of sexually intact animals over 18 months of age (and animals sourced from a dairy).  Three, 840 tags, as proposed in the new ADT rule, are NOT required for PVP programs; manufacturer-coded, tamper-proof tags are sufficient. 

While we’re on the topic, let’s also address affidavits and verification.   Most notably, there’s no such thing as “verified through affidavits.” That statement is inherently self-contradictory.  

Affidavit-based programs do NOT require verification – nor individual animal identification (they’re not PVPs).  Equally, PVP programs do NOT allow for affidavits; they require third-party verification of all program criteria and precise documentation of chain of custody of animals through slaughter (e.g. see Where Food Comes From). 

Packers and Exports:  Some critics suggest the new rule serves only to create value for packers. That is, EIDs will somehow establish new export opportunities with packers being the sole beneficiaries.    

First, packers are NOT the beneficiaries of exports – the benefit goes to producers.   Second, the proposed rule change is NOT intended to open up export markets.   Those markets are already open for business and growing year-over-year.  

Rather, the EID requirement, in the event of an outbreak, helps speed the investigation process.    USDA explains this way:  “This requirement would enhance our traceback investigation capabilities because…EID eartags and electronic recordkeeping allow for greater efficiency and accuracy [versus] non-EID eartags and paper records.”

That capability, in the event of a stop movement order, potentially helps facilitate regionalizing an outbreak and consequently speed up reestablishment of commerce continuity.  In turn, that should help shorten time required to restore international trade.       

EIDs:   EIDs carry no information other than a 15-digit number.  Once it’s been encoded (e.g. 840 XXX XXX XXX XXX) there’s no capability to write additional information to the tag (despite some claims to the contrary).  An EID, by itself, provides no knowledge; it’s simply a tool for expediting accurate searches.   Per USDA:  “EID tags enable producers or officials to capture accurately animal identification numbers almost instantly, without the need for animal restraint, and to transmit those numbers to a connected electronic database.”   

China:  Some critics of the proposed rule suggest EIDs provide an opening for foreign countries (China) to gather meaningful intelligence.  The argument being chips manufactured in China might surreptitiously possess capability to send AND receive information, thereby leaving the nation’s food infrastructure vulnerable to attack. What about that claim? 

1. The proposed regulation surrounds low-frequency EIDs - the maximum read range is ~2-to-3 feet (depending on whether they’re FDX or HDX tags).   Meanwhile, the major point of resistance towards full traceability (i.e. including feeder cattle) has always revolved around limitations of LF EIDs and subsequent speed of commerce.  But now the same tags might be read by high-altitude surveillance objects?  None of that meshes.  
2. On one hand, some argue this is a perfunctory mandate because ADT only covers ~11% of the cattle population anyway. On the other hand, the same people argue the EID requirement will provide valuable information to China.  That, too, doesn’t mesh.          
3. The chips may be manufactured in another country, but the tags are ultimately encoded (15-digit number) by the manufacturer in the U.S. – and subsequently managed only by USDA approved allocators.    
4. There’s no need for sophisticated surveillance schemes to know / understand the U.S. cattle industry.  It’s well-documented (e.g. USDA’s cattle inventory, cattle-on-feed, and daily auction market reports).  Moreover, USDA has documented and published key livestock movement channels across the U.S.

National Security:  Of course, national security is THE most important consideration.   Nearly twenty years ago, I had the privilege to collaborate in a multi-disciplinary agroterrorism project sponsored by the National Institute of Justice.  The study noted, the “single greatest threat to the agricultural economy is foot-and-mouth disease, which has the potential to produce economic chaos.”  

Complacency is a devastating option.  As a result, one of the key recommendations from the study addressing that concern being development of “a mandatory national animal identification system.”   To that end, USDA’s newest proposed rule-making is a small step in the right direction.  And maybe, just maybe, it’ll lead to something even more meaningful in the future.      

Nevil Speer is an independent consultant based in Bowling Green, KY.  The views and opinions expressed herein do not reflect, nor are associated with in any manner, any client or business relationship.  He can be reached at nevil.speer@turkeytrack.biz.