Final Animal Disease Traceability Rule
March 11, 2013
The final USDA (United States Department of Agriculture) Animal Disease Traceability Rule will go into effect March 11, 2013. Wyoming State Veterinarian Jim Logan provided an update on how the final rule will affect producers during the Wyoming Farm Bureau Federation (WyFB) Annual Legislative Meeting in Cheyenne on Feb. 19.
"Many states, including Wyoming, already have import regulations for cattle, sheep, swine and poultry in place that do include identification requirements. The APHIS (Animal Plant Health Inspection Service) rule isn't really anything totally brand new," explained Logan, adding that the rule is designed to reduce the overall impact on the livestock industry, and expedite traceability to point of origin, should there ever be a disease outbreak.
The rule will require any sexually intact beef cattle or bison over 18 months of age to have official identification prior to moving interstate. Recreational and exhibition cattle of any age and gender will all be required to have official identification, and all dairy cattle of any age will also need official identification. There are certain exceptions, including one for those animals going directly to custom slaughter.
The final rule follows two extensive public comment periods, and Logan noted that for the most part, he feels those public comments were listened to, with efforts made to keep common sense within the rule in most instances. However, that isn't to say there won't be changes and challenges going forward.
"The part that will make the most impact and be the most difficult for livestock producers and veterinarians to comply with says, 'official ID tag numbers for any animal that is required to be identified will have to be recorded on the official certificate of veterinary health inspection as an individual tag number.'
"You can't put 'this animal is identified with official ID.' That will not be sufficient anymore, nor will a range of tag numbers with the identified animal falling within that range," explained Logan of the biggest hurdle and change the rule will result in.
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This applies to interstate movement of animals, and Logan noted that several western states, including South Dakota and Nebraska, already require individual identifications numbers to be recorded on a health certificate. Prior to the rule, Wyoming did not require individual numbers being recorded.
The exception to having the veterinarian record ID on the health certificate is that the state may generate a form on which producers (or vets) can record individual identification numbers, thus allowing individual numbers to be recorded prior to the veterinarian examining the cattle for the health certificate.
"Wyoming has already devised a form. I realize this will be a pain in the neck and will slow commerce down. But, at least with this form, the producer can record all the individual tags (for animals that will move interstate) as he runs animals through the chute, which can be done in the absence of a vet. That way the vet doesn't have to stand there all day while cattle are going through the chute, charging an hourly fee just to issue a health certificate," noted Logan.
Official identification includes multiple accepted ear tags, breed registry ID's and brands on cattle and bison.
"However, to accept a brand, the states being shipped to and from have to agree to use them as official identification. We have polled every state vet in the country, and we've got answers from about 90 percent, and the answer from every one of our primary state trading partners is that not a single one will accept brands alone as official identification," stated Logan. "Except in the case of commuter permits for seasonal grazing."
However, the metal brucellosis vaccination tag, or bangs tag, will be considered official identification. The new orange RFID Brucellosis Vaccination tag, the Wyoming green tag, and 840 RFID (or non-RFID) tags, and the USDA-APHIS silver "BRITE" tag will all also qualify as official identification.
The Wyoming Livestock Board is currently purchasing orange RFID Brucellosis vaccination tags through a cooperative agreement at no additional cost to producers, and Logan noted that producers can request those through their vet. Wyoming green tags are also distributed free of charge from the Livestock Board for identification purposes. Yellow 840 RFID tags have primarily been used in herds involved in Brucellosis testing to simplify the process when going back through those herds for subsequent testing.
"I hope that if we gravitate toward more RFID tags that sale barns and vets will be able to acquire better technology capabilities, and be able to utilize that technology in recording those tag numbers. Use of metal tags in the short term is something that will slow things down when you're selling cattle," commented Logan.
Producers can switch from metal to RFID tags, but Logan said there would be some red tape to work through in that situation. It would also require that the metal tags be left in, and correlated to the added RFID tags.
"If your animal already has one official tag – any of those that are approved, do not just add another identification tag to them. We're telling vets and sale barns the same thing. Sometimes to speed things up, a vet will run cattle through and instead of recording what's already there, they will add a metal silver clip to a group of cattle, and we know of cattle running through barns that have three or more of those tags. That is not allowed in this rule, for many good reasons," said Logan, listing confusion and inability to find actual point of origin during trace back as two examples.
Inconsistency between states, and within some states, on which ear to put official RFID vaccination tags has caused confusion regarding where an official tag is supposed to be.
"Numerous other states have allowed the use of the RFID vaccination tag to be in the left ear. To me, that does nothing but confuse the issue, and I know it's already confusing vets. I have always been a proponent of the right ear being for the official tag, bangs tag, etc…" explained Logan.
Sheep and goats will continue to follow the scrapie program, as they have for several years. Horses, donkeys, burros and mules will not be required to be electronically identified. The negative coggins test, official certificate of health inspection, and a brand inspection when crossing state lines will continue to comprise the equine requirements.
For producers wanting to know more, Logan encouraged them to visit the APHIS website and download the entire rule, adding that the "guts" are on pages 125-146. People with questions or comments after reading it are encouraged to contact the state vet's office or the Wyoming USDA-APHIS office in Cheyenne. To download the entire rule, please visit http://www.aphis.usda.gov/traceability.