In July, the Animal and Plant Health Inspection Service of USDA posted a notice in the Federal Register seeking public comment on the possibility of making RFID ear tags the only official identification for cattle moved in interstate shipment. (See story here).
The DHI system requires individual identification for dairy cattle on test and has long supported ear tags using the unique “840” number system and more recently, RFID electronic tags.
Following is the commentary submitted to APHIS by National DHIA and resolutions adopted by the Association as its annual meeting earlier this year.
Comments on the APHIS Docket-2020-0022
Regarding the proposed implementation of
Radio Frequency Identification Devices (RFID)
as official eartags for use in interstate movement of cattle
Submitted on behalf of the members, users and
of the National Dairy Herd Information System
The National Dairy Herd Improvement Association (DHI System) appreciates the opportunity to provide these comments relative to USDA’s APHIS proposed implementation of Radio Frequency Identification Devices (RFID) as official eartags for U.S. dairy cattle. As a part of this process, National DHIA strongly supports the need for premise and animal identification as a foundation for an Animal Disease Traceability (ADT) system to safeguard the national dairy and livestock herds and flocks. The DHI System works with over 65% of the animals in dairy herds in the United States in on-going efforts to provide information for management, decision making and animal health screening for these herds. This system includes 25 state and regional organizations, 42 milk component laboratories and 4 dairy data computing centers.
The DHI system supports the RFID technology as the best opportunity to assure consistency throughout the dairy industry infrastructure. At the present time, Low Frequency (LF) technology should be the preferred technology. Future technology developments should continue to be monitored. As new technologies become available and evaluated by the animal health, livestock production and commerce chain, these technologies should be implemented as expediently as possible.
Eliminating manual identification, such as National Uniform Eartagging System (NUES) will be a key part of the RFID implementation of a modern identification system for Animal Disease Traceability (ADT) and animal identification for event and location recording. The NUES system retirement will also eliminate duplicate animal ids, as the current NUES system can reuse or recycle NUES identification.
The DHI System recommends these official tags be matched sets of an RFID button and a dangle tag with the 840 AIN numbering system. This will provide backup identification in the event of loss or malfunction of an identification device.
Allocation of Official RFID Tags
The allocation of 840 RFID tags is key to the implemention of an enhanced ADT system. This requires having a premise identification associated with the 840 AIN devices. This will require a national allocation system (perhaps by commodity or species group) for the assignment of 840 devices to entities and individuals who will be identifying and applying the identification devices to the animals.
Identification Applied at Birth
As a supplement identification for vaccination an orange metal tag, zip tie or hole punches in 840 dangle tags are examples to indicate vaccination has occurred.
This reduction in identification devices, entering multiple identification into data systems and cross referencing the multiple identifications would be a benefit to livestock producers, animal health agencies and commerce channels. Reduced cost and overhead on the individual systems would allow for allocation of resources to support the effort.
Species Standards and Implementation
While the DHI System recognizes the advantages of having a universal, well-defined identification program, we strongly feel that the reality of different management styles and species issues will necessitate flexibility. Certain standards and common issues for identification can be addressed across species; however, some species-specific standards and operations must be considered for effective implementation. If species or sub-species commodity groups are ready to implement RFID technology, the flexibility should be allowed to have this implementation occur on shorter time frames based on commodity and animal health readiness.
The current timeline proposed of metal tags discontinuance on January 1, 2022 and RFID as the only official identification pursuant to documentation requirements for the traceability of livestock moving interstate beginning January 1, 2023 is fully supported by the DHI System and should not be delayed.
The DHI System supports appropriate federal budget allocation for animal identification and support infrastructure to be considered and provided. It is vital to develop and maintain the infrastructure for safeguarding the health of the national herds and flocks to ensure market access for animal agriculture products. Funding should supplement the implementation because much of the system is already in place and needs a direction for solution.
During its 120-year history, the DHI System has been involved in premises and animal identification in the role of providing dairy data and animal information. This includes a close and collaborative involvement since the early 1950’s with the DHI System as an authorized distributor of NUES tags as part of the Brucellosis Eradication Program with USDA-APHIS. The DHI System, partnering with other dairy and livestock industry cooperators and animal health agencies, advocates implementation of 840 animal identification and RFID technology as official identification on a short timeline. These current data and a long history of a well-proven data collection system, utilizing an extensive field force that is in place, provide a solid starting place for contributing to the ADT livestock management systems.
National DHIA encourages the adaptation of existing infrastructure, including the DHI System, to avoid duplication of efforts and resources.
The current DHI system is voluntary, producer driven, utilizes producer governance, and has the trust and confidence of the herd and flock owners and managers. Utilizing these resources and building on the producer trust for a simple, modern technology solution, such as RFID technology and 840 AINs, will benefit animal health agencies in safeguarding the health of the national livestock herds and flocks while meeting the needs of dairy herds and their herd management systems.
Allen Chester, President National DHIA
Elizabeth Straw, Chair National DHIA ID Task Force
Jay Mattison, CEO NDHIA
Resolution on Animal Identification in the DHI System
Passed at 2020 National DHIA Annual Meeting
Be it resolved, that within one year from March 5, 2020, National DHIA members prefer discontinuance of any identification other than 840 tags to be used as official identification of young animals enrolled in the DHI system.
Furthermore, The National DHIA Uniform Operating Procedures will prefer that all young stock entered into the DHI system will be identified with an official ‘840’ tag.
Be it further resolved, that on or before January 1, 2023, Item 6 dealing with – animal identification in the National DHIA Uniform Data Collection Procedures will be revised to reflect this animal identification procedure.
This motion was passed by the National DHIA Delegates at the National DHIA Annual Meeting, March 5th, 2020 in Savannah, Georgia