Livestock Marketing Association 10510 NW Ambassador Drive, Kansas City, MO 64153 800-821-2048 816-891-0502 Email: lmainfo@lmaweb.com LMA Fax: 816-891-7926 LMIA Fax: 816-891-0552 LBT Fax: 816-891-7108

USAIP Market/Processor Working Group Report

May 17, 2004

Role
The role of the Market/Processor Working Group is to advance the USAIP through the development of more precise transition, implementation, and continuity plans consistent with the established standards and goals of the USAIP in concert with the Species Working Groups.

Scope
The Market / Processor Working Group focuses particularly on implementation plans in Section V of the USAIP developed in 2003, but also focuses on key elements of the USAIP that may affect the marketing and processing sectors. Updates, both additions and/or revisions (if necessary) to implementation plans, are to support the industry's ability to achieve the 48-hour traceback objective.

Background
Early discussions were held by the Market / Processor Working Group and revealed the primary areas of concern and challenge to the participating members as follow:

• The cost of any system developed must not impose an undue burden on any segment of the industry, from producer to packer, and should be shared among the government and industry stakeholders.
• The costs and requirements on the marketing and packing sectors should be minimized wherever possible.
• Competitive disadvantages cannot be created in the marketing system as a result of animal identification requirements.
• Safety of personnel at marketing facilities and packing facilities should be ensured as related to applying, reading, and harvesting identification devices.
  • All information (data) must be strongly protected from Freedom of Information Act inquiries and be exempt from access by government agencies other than APHIS and designated state animal health officials.
• Events which require that an animal's identification to be "read" must be clearly defined and required equitably among the industry segments and participants.
  • Compliance respective to the recording of animal movements by those outside fixed facility marketing and processing channels should be expected.
• The USDA's technology-neutral approach is troublesome as it may lead to multiple technology requirements within the marketing channels.
• Radio Frequency Identification (RFID) should be fully evaluated and its practical application to cattle movements through auction markets be determined.
• Determination of the responsible party for application of identification devices should be clearly defined.
• Animal welfare should be of utmost importance in the application and reading of identification devices.
• A method of including an animal's date of birth as a part of its identification should be fully explored and made part of the USAIP if possible.
• The major standards of the USAIP must be known before the true costs of the system can be determined (i.e. technology, tracking requirements, etc.).
• What will be the overall effects of a national ID system on individual producers?
• It is possible a "black market" will develop caused by certain dealers not requiring animals be identified before they purchase them.
• The costs to markets will be substantial. It was suggested by one member that it cost his company $54,600 to equip only one multi-species market.
  • Technologies should continue to be evaluated in order to ensure the most cost-effective and appropriate systems are used.

Observations:

• A national animal identification system, to be optimally effective and manageable for animal owners, managers, marketers, and processors, must operate as simply as possible. Therefore, reported movements should be kept to a minimum necessary to ensure adequate records to facilitate traceback and trace-out functions.
• Very clear, unambiguous definitions of reportable events and responsible parties are critical for industry stakeholders to understand their responsibilities and what changes it may mean in their operations.
• Attention at this time should be focused on reporting events most necessary to achieve the goals of the USAIP.
• The term interstate "commerce" is not the best term to use regarding reportable events. Commerce implies a change of ownership and, indeed, many "movements" of animals, either interstate or not, may necessitate reporting even if a change of ownership does not occur.

Specific Recommendations:

1. Animals moving through markets should be read only one time to indicate an animal has been at a given premises on a given date. This should only be required if there is adequate technology available that will not slow the marketing process and reading at the market does not cause excessive negative economic impact on individual markets. (Example: unrealistic expenses associated with setting up, maintaining, and operating a system).
2. Radio Frequency Identification (RFID), adequately tested and proven workable, should be the recommended identification technology used in the beef and dairy cattle industries.
3. A long-term economic impact study should be required as a part of any ID pilot project being funded. The study should seek to determine the impacts on all levels of producers and stakeholders associated with the ID system being tested.
4. Application of identification devices to animals should be the responsibility of the owner/operator of the premises of origin. Such tagging could occur at authorized tagging stations or auctions if available, but responsibility would still reside with the original premises owner/operator.
5. It is recommended that the term "receiving premises" be used in establishing the responsible party for reporting movement to the National Animal Identification Database.

   Definition: Receiving Premises - The premises to which animals are moved and at which a responsible party (not necessarily the buyer) is responsible for reporting to the National Animal Identification Database that identified animals have arrived at that premises.

   1. This would require only one reporting of the movement as opposed to reporting an animal's arrival and departure, thus enabling the rapid traceback/traceout of animals at any given location on a determinate date will have been reported to the National Animal ID Database.
   2. In addition, it would significantly reduce the seller's liability, as it is impossible for a "seller" of livestock to know whether he/she is accurately reporting the premises receiving the livestock, whereas the "receiving premises" is able to do so with a high degree of accuracy.
   3. Requiring a "seller" to report the receiving premise would require a breech in confidentiality since the receiving "buyer" would have to share his/her premises number with the seller or the seller's agent.
   4. While "receiving premises" would be responsible for reporting, opportunities should exist for other parties (i.e. markets, order buyers, transporters, etc.) to report, as a service, for the receiving premises.

6. Any movement of cattle to a distinctly different premises and to a premises where commingling may occur must be reported to the National Animal Identification Database, regardless if a change of ownership has occurred.
   1. Although there may be some instances where, as a result of management practices, a movement to another premises within the area of the home premises is not necessary to report, all movements that are interstate or that may involve the potential for commingling should be reported.
   2. In accordance with needs for a successful traceback strategy the USAIP should outline uniform parameters for "reportable" and "non-reportable" movements.
   3. Reportable movements should include movements to exhibitions, veterinary facilities, etc. as those movements would most certainly involve the potential for commingling.
7. It is recommended that all cattle be individually identified.
   1. Application of identification devices to cattle should be the responsibility of the owner/operator of the premises of origin. Such tagging could occur at authorized tagging stations or auctions if available, but responsibility would still reside with the original premises owner/operator.
   2. Although it has been suggested some cattle may meet the guidelines in the USAIP to be moved as a group/lot, the Market / Processor Working Group believes the potential for abuse in exercising this option would be significant and would cause major inequities in the marketing arena.
   3. Also, the potential for cattle to be commingled is significantly higher than in other species and it is strongly felt that by having all cattle individually identified, this potential inequity could be averted.

Respectfully submitted,
Scott Stuart, Working Group Leader