The National Animal Identification
System
May 20,
2006
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:
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:
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.
© 2006
Lynn M Stuter – All Rights Reserved