The National Animal
Identification System

June 6, 2006

Lynn M. Stuter

Haven’t heard of the National Animal Identification System (NAIS)? Don’t feel bad, you join millions of Americans, including the majority of those who will be forced to identify their animals with radio frequency identification (RFID) technology in January 2009.

Believe it or not, the whole concept of animal identification with RFID technology didn’t begin with the Patriot Act back in 2001, PL 107-56. A document from the National Institute for Animal Agriculture (NIAA), “NAIS Facts and Myths”, dated March 2006, states, “Although discussions on animal ID have taken place for many years and started well before 2002 …” Another document entitled “Summary and Future Action” published by NIAA, carries the remarks of individuals gathered at a symposium on animal identification in 1994. It is obvious from remarks made in this document that the participants were drawn from an international field:

“Let me just say to all of you, how much I appreciate your attendance … and for many of our participants, you have had to come from abroad …”

The document addresses a national animal identification system. Other statements in the document make reference to ISO — International Standards Organization — which has/is establishing standards of global uniformity, consistent with the needs of global government and global systems.

Participants in this symposium included private enterprise, the United States Department of Agriculture (USDA), livestock associations, foreign organizations, and institutes focusing on animal health and science. The focus of the symposium was a voluntary uniform system of animal identification.

As with so many other things, the events of September 11, 2001 provided opportunity to reframe the debate around issues of security. From Public Law, 107-56, otherwise known as the Patriot Act of 2001,

Section 1013(9): “Improvements must be made in assuring the safety of the food supply,”

Section 1016(d)(2)(B): “Acquisition from State and local governments and the private sector of data necessary to create and maintain models of such systems and of critical infrastructures generally.”

Section 1016(e): “CRITICAL INFRASTRUCTURE DEFINED. ­In this section, the term ‘‘critical infrastructure’’ means systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters.”

Portions of two laws, passed in 2002 - Public Law 107-171 and 107-188 - were codified into United States Code as 7 USC, Sections 8301 through 8321, deemed the Animal Health Protection Act. In this section of code, 7 USC, Section 8320, provides the authority for NAIS. However, there is no authority, beyond the authority given the Secretary of Agriculture and/or Secretary of Homeland Security to establish rules, for the dates that have been decided for implementation, January 2009 being the date stated when ALL meat producers MUST be registered, have premises identifications numbers (PIN) and animal identification numbers (AIN).

In documents published by the USDA and private organizations advocating NAIS, three issues are addressed as impetus for NAIS:

1. tracing and eradicating communicable and contagious diseases among livestock,
2. food safety, and
3. national security.

Most prevalent among diseases pointed to in the above noted published documents is Mad Cow Disease (BSE) and Foot and Mouth Disease (FMD). Mad Cow Disease is not a communicable disease among cattle; it is an acquired disease through contaminated feed; cows can pass it to their calves if the calves are born after symptoms of the disease are onset. A cow fed contaminated feed may not show signs for years. In that period of time, the cow may have been sold many times. A group of cattle, fed the same feed, may be scattered far and wide before symptoms of the disease become apparent in any one animal in the group. The claim is made that NAIS will provide a system of 48 hour trace back to other animals at risk.

In the past three years, there have been three incidents in which cattle have tested positive for BSE in the United States — one in Washington State, one in Alabama, and one in Texas. The epidemiology report on the cow testing positive in Texas more than adequately makes the case for why NAIS will not be effective in tracing BSE in the interests of food safety. Other cattle, deemed at risk, either because they were fed the same feed as the BSE positive cow or were offspring of the BSE cow within two years of the BSE cow showing symptoms of the disease, were largely found to have already been slaughtered. No database, focused on a 48 hour trace back on diseases such as BSE, is going to change the reality that other at-risk cattle have already been slaughtered and consumed by the public.

It has been years since an outbreak of Foot-and-Mouth disease has occurred in the United States. It is a disease that can be vaccinated for ­— the easiest tool to prevention if the disease is known to be endemic to an area. Current measures taken have obviously been quite effective in controlling the disease in the United States for some time. Other known diseases are being similarly controlled.

It becomes apparent that no huge mandatory national database, in the hands of the federal government, housing information on private citizens and livestock on the premises of those private citizens, is it going to change the reality that animals exposed to communicable or contagious diseases may have been slaughtered during the incubation period with the meat already having reached the consumer. Unless the Animal Identification Number (AIN) follows the meat to consumption, there is no way that NAIS is going to make the meat industry “safe” for the consumer. It is apparent that this fact is known to those advocating NAIS as documents published state that if the AIN number follows the meat through slaughter to the consumer, liability becomes an issue. Obviously, contrary to what has been stated in government documents concerning NAIS, protecting consumers from meat-born disease is not the focus or concern of NAIS, is not at issue with NAIS.

On the level of national security, considering diseases indigenous to livestock, incubation periods and likelihood of discovery, is it feasible to believe that it would be cost effective and results effective for terrorists to introduce pathogens to livestock in the hopes of killing a large number of people when terrorists focus on more bang for the buck? While a document of the National Food Animal Identification Task Force, titled “Safeguarding Animal Agriculture, National Identification Work Plan”, 2002, concludes that an animal identification crisis looms and speaks directly of threats to biosecurity, again the AIN will not follow the meat through the slaughter process to the consumer. Any crisis that might come from purposely introduced pathogens to cattle is not going to be diminished by the National Animal Identification System.

The National Animal Identification System will consist of three components:

1. Premises Identification (PIN)
2. Animal Identification (AIN)
3. Animal Tracking

Each premises where livestock are kept will be required to have a premises identification number (PIN). Registration will require premises GPS coordinates. Each animal on that premises will be required to have an animal identification number (AIN) except where animals are moved by group in which case they will be assigned a group identification number (GIN). The RFID implanted AIN number will be either attached to the animal by means such as an ear tag (cattle) or implanted sub-dermal in the animal, either of which must be readable by hand-held or stationary ISO certified technology. Using the PIN, AIN and GIN, animals will be tracked from birth to slaughter.

For purposes of identifying possible exposure to communicable or contagious disease, any time an animal leaves the GPS coordinates correlating to its AIN, the federal government, by regulation, will have to be notified. “Any time” means just that.

Problems abound with the National Animal Identification System. One of the more apparent has already been identified — the failure of the AIN to follow the animal through slaughter to the consumer negating the government claim of a safe food supply.

Another has to do with technology and RFID tags. The internet has been rampant with articles concerning the ease with which RFID technology can be hacked. Imagine the fun a hacker could have in a flock of sheep or a herd of cattle changing RFID implanted AINs. While laws make it a crime to alter the AIN, the likelihood of hacked RFID implanted AINs being found readily is remote. It could be months before reason might present itself to scan the RFID implanted AIN number on any given animal. And, if the hacker really wanted to created chaos and frustration, he would visit areas resident to large ranches with a large number of animals present and he would change some AINs, just enough to make it impossible to ascertain which RFID implanted AINs have been hacked without scanning the entire animal populace. Ever been on a large cattle roundup where the animals are wilder than a coot? Imagine running 1500 wild-eyed, nervous, cattle by a scanner one at a time to check AINs for hacking. Once scanned, in a herd of 1500 animals, how can the “chain” of correlation between cow and offspring be reconnected when the AIN has been hacked? Imagine the fun a hacker could have on a feedlot housing thousands of cattle, hogs, or sheep where GINs may identify AINs from multiple sources. Imagine loading commercial haulers with cattle consigned for sale, hauling those cattle hundreds of miles to a sale yard and discovering the AINs on some of the animals do not correlate with the PIN, having been changed by hackers.

In sum, there is no way the RFID technology can be made secure. As such, if hacked, the cost will be prohibitive, not to the government implementing this mandatory system, not to the various livestock associations supporting NAIS, but to the owner of that animal.

In the same vein, government documents indicate that AIN numbers will be assigned by lot, so many numbers per given location. How those lot numbers will be divided up across the United States has not been made clear. However, it stands to reason that however lot numbers are assigned, the capability for issuing identical AIN numbers exists unless those numbers come from a centralized databank of available numbers, one with the capability to keep up with the rapid demand for numbers. There is also the capability for data entry errors. The federal government has never been known to be terribly efficient or accurate in that department. And there is the capability for computer glitches and viruses resulting in data loss.

The cost of the technology, the implants, hacked AINs, duplicate AINs, data errors, data loss, computer systems and personnel, all add up to costing the producer more money. The likelihood of recouping that cost at the sale yard is negligible if markets are competitive. If they are not, the cost to the consumer will be prohibitive. The effect, while purported to increase the value of meat, will not increase the value enough to offset the cost, especially as the AIN will not follow the meat through slaughter to the consumer. The ultimate effect will be to put small producers out of business and make meat prices prohibitive to the consumer.

Now we turn to the USDA Animal and Plant Health Inspection Service (APHIS). APHIS has been given oversight of NAIS. The APHIS Strategic Plan, 2003-2008, states as one of its three goals “Safeguard the health of animals, plants, and ecosystems in the United States.” This same document also states, “What is new (in this document), however, is that APHIS is being more specific about approaching its protection activities as a system of interdependent strategies.” (emphasis in original)

This document makes it very apparent that NAIS is about transformation of the animal and plant production industry to coalesce systems governance in which systems are established and maintained for no other reason than the sustainable global environment.

Across the United States, state legislatures have rushed to pass laws in pursuit of federal seed money via discretionary grants which will cede to the federal government state control over animal production.

Livestock associations have climbed on a moving train purposely destined for their destruction. Dissension is growing. Articles showing up in livestock publications and published in newspapers across the U.S. in late 2005 indicate dissension with what has now become a federally mandated and housed database of information of individuals inside the United States. While measures to insure confidentiality are assured, there is no such thing as security in technology. Hackers have accessed supposedly secure systems all across the United States, including the Pentagon. Beyond this, there is no reason, beyond oppression, that the federal government should have this information.

Right now, the 2009 mandatory date for have PINs, AINs and GINs is in regulation only. Legislation has been introduced making it law.

Where does this stop? Can we reasonably expect it to stop with animals or will the mass implantation of RFID technology in humans for the purpose of identification be next? We are already seeing signs of it. It is naive to believe that a world system of nation states, bent on data-basing every aspect of life on earth for the purposes of controlling every system on earth to keep all systems in balance in the pursuit of a sustainable global environment, will not target the people, euphemistically referred to as “human capital”, devalued to just another system needing to be managed and controlled.

© 2003 Lynn M. Stuter - All Rights Reserved

Mother and wife, Stuter has spent the past ten years researching systemstheory with a particular emphasis on education.  She home schooled twodaughters, now grown and on their own.  She has worked with legislators,both state and federal, on issues pertaining to systems governance and education reform.  She networks nation-wide with other researchers andcitizens concerned with the transformation of our nation.  She has traveled the United States and lived overseas. Web site: http://www.learn-usa.com/   E-Mail: lmstuter@mail.icehouse.net  

NOTE: In accordance with Title 17 U.S.C. section 107, any copyrighted material herein is distributed without profit or payment to those who have expressed prior interest in receiving this information for non-profit research and educational purposes only. For further information please refer to: http://www.law.cornell.edu/uscode/17/107.shtml

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