Tag, you’re it: USDA proposes phasing out metal id tags by 2023
The U.S. Department of Agriculture is advancing quickly toward replacing the official metal tag – the most common being the “bangs tag” – with RFID tags.
In July of 2020, USDA Animal and Plant Health Inspection Service (APHIS) published a proposal in the Federal Register to phase out the metal clip tags and replace them with RFID (radio frequency identification) tags.
Under the recent proposal, USDA would stop recognizing metal clip tags (including bangs tags) as official identification for cattle and bison, and would only recognize RFID tags by 2023. Beginning in 2022, they would not allow the use of the metal clip tags for official USDA use such as for bangs vaccination identification.
In April of 2019, USDA published a similar plan, but after being sued by R-CALF USA, and two ranching families, they pulled the rule. The lawsuit alleged that the USDA proposal constituted a rule change, which required them to take public comment before deciding how to proceed. That very public comment is what USDA seeks now, however, USDA does not refer to the proposal as a “rule change.”
With comments due on Oct. 5, 2020, 178 comments had been received as of press time.
Harriet Hageman, the attorney for the R-CALF lawsuit opposing USDA’s forcible implementation of a mandatory RFID rule, said USDA is outside the scope of its authority to require the use of RFID tags.
“USDA’s approach is blatant slight-of-hand. It is pretending that it is engaging in official rulemaking, while sidestepping the requirements of the APA and ignoring the protections set forth in the 2013 rule which actually prohibits any effort to mandate the use of RFID for livestock that is moved across state lines,” she said.
Because the 2013 final rule allows for the use of eartags, back tags, brands, tattoos and group identification numbers, Hageman said USDA’s new proposal is “quasi-rulemaking.”
“USDA estimated in 2013 that an RFID mandate could cost between $1.2 and $1.9 billion dollars. I have been told that the actual cost would be substantially higher,” she said.
She also says RFID is not feasible in many areas of the country, and would put producers in states without packing facilities, such as Wyoming, at a disadvantage because most of those cattle are required to cross state lines at some point in their lifecycle.
“Eartag companies stand to make billions of dollars off this requirement, actual producers will only incur additional costs,” she said.
Another concern of Hageman and her clients is the need for producers to obtain a “premises identification number” in order to maintain RFID data.
The current federal rules jive pretty well with South Dakota’s rules regarding official identification in cattle. South Dakota requires that any breeding cattle over the age of 18 months must bear an official individual identification (an orange metal bangs tag if the animal was bangs vaccinated or a silver clip tag if not) when changing ownership and/or being transported out of state.
According to South Dakota’s state veterinarian, even under current rules, the only intact breeding age animal that does not need a form of official individual identification would be home-raised cows or bulls that have never left the state or been sold.
But the new proposed rules would require that, moving forward, those animals that now bear the metal tag would instead be required to carry an RFID tag. Those animals currently bearing a metal tag would be “grandfathered in” so that the producer is not required to put in an RFID tag into an animal currently bearing a metal tag.
While RFID has been one of the types of identification accepted by USDA as official identification since their 2013 rule was published, Dr. Oedekoven said he thinks it’s rare that a producer chooses to use an RFID tag rather than a metal clip.
USDA currently supplies metal clip tags free to the livestock owner. There is no such provision for the RFID tags in the Federal Register notice.
USDA did announce in July that it will purchase “up to” 8 million low frequency RFID tags to be provided to producers. The USDA news release says the contract allows APHIS to purchase additional tags each year for up to five years, but there is no guarantee this will happen, or that USDA will provide RFID tags after the five year time period.
Dr. Oedekoven said he does not believe most of South Dakota’s livestock markets are equipped to handle low frequency RFID tags at the speed of commerce.
According to Oedekoven, low frequency tags must be read from a distance of approximately two feet or less, and tags must be read one at a time.
While he isn’t necessarily in favor of requiring the use of any RFID tags, ultra high frequency tags would likely be more suitable for most of the trading done within South Dakota’s cattle industry, than the low frequency tags, said Oedekoven. With ultra high frequency tags and readers, an entire pen of cattle could be “read” and recorded all at once. One challenge in a salebarn setting will be adjusting readers properly so as to read the correct cattle, and not cattle in neighboring pens, he said.
The readers are not interchangeable and Dr. Oedekoven said he is not aware of a dual-purpose reader on the market.
NCBA endorses CattleTrace
Two years ago, a group of RFID enthusiasts put together a Kansas-based pilot project to learn more about how the industry could utilize higher tech animal identification methods.
“It was a pilot project in Kansas to see if a traceability program would work,” said one of groups’ spokesmen, Callahan Grund.
The pilot project was focused on learning whether RFID tags could work with the speed of commerce, and to figure out how a system could work without the cow calf guy “bearing the brunt” of the cost, he said.
The project, which was funded 1/3 by USDA, 1/3 by the state of Kansas, and 1/3 by private industry, was completed in June of this year, and those overseeing the project then created a non-profit organization called CattleTrace. The organization is focused on maintaining a nationwide database of livestock movements, for disease traceability purposes. Grund said they figure 70 percent of the nation’s cattle will need to be included, in order for it to work well.
Grund said CattleTrace does not support a mandatory RFID requirement, but acknowledges that “that’s a lot of people to get to that point.”
If around 70 percent of producers voluntarily RFID’d their cattle, animal health officials could more easily track cattle with disease issues or who may have been exposed to diseases, he says.
But Dr. Oedekoven, who successfully handled a TB case in South Dakota recently, and has overseen the traceback of other diseases in his state, said the current system works.
“We don’t have a preference. In my mind, as long as the tags are recorded accurately, from my point of view, as a state animal health official, it doesn’t matter whether a producer uses RFID or traditional metal clip tags,” said Oedekoven.
He and his team often utilize RFID tags for certain disease issues – TB for example, because the cattle are required to travel through the chute multiple times to determine which animals are likely to be infected. In these types of cases, he asks the producer’s permission to utilize RFID tags, and generally his request is met with acceptance.
In their pilot project, the CattleTrace group studied the usefulness of ultra high frequency tags, and any Kansas cattle owner interested in taking part in the project could do so for $1 per head, which included an ultra high frequency tag.
About 77,000 tags were distributed through the program, and they achieved about 500,000 “sightings” or readings of the tags, which could have been done at salebarns, loading or unloading at feedlots, etc.
No salebarns or other entities were required to purchase readers, but some already employ the readers for business purposes. The “sightings” gathered by the project coordinator were done on a voluntary basis, by any entity with a reader who may have read the tagged cattle over the two-year period. The project coordinator is still sifting through the data to determine where and how often the cattle were sighted, and more.
CattleTrace hopes producers will become members and will utilize their database services which will record the individual identification number of each animal, as well as the date, time and location for significant activities such as movement through a salebarn or transportation to a slaughter plant, he said.
The National Cattlemen’s Beef Association recently announced it had adopted policy to support CattleTrace.
“The policy resolution calls for NCBA to support the expansion of U.S. CattleTrace and directs the organization to encourage and help facilitate state affiliate support and educational efforts,” said an NCBA news release.
State cattle affiliate groups from Florida, Kansas, Kentucky, Missouri, Tennessee, Texas and Washington brought forward the policy at the organization’s summer meeting, said the news release.
Current state of affairs
Dr. Oedekoven thinks the state of South Dakota is “doing well” with it’s current rules overseeing disease traceability.
“We’ve had good cooperation from our producers and we’ve come through some difficult disease issues. Because South Dakota’s producers are complying, the industry is doing well,” he said regarding the state’s current rules requiring some kind of official identification for intact breeding cattle over 18 months of age, that are sold or moved out of state, which can include a metal tag.
Low frequency vs. ultra high frequency tags
*Cost: $2.50-$3 per tag
*Must be read at a close proximity – about 2 feet – more than likely would require stopping each animal in the headcatch
*Cost: $3.90+ per tag
*groups of cattle can be read at a distance, such as in a sale ring or corral
• Beginning January 1, 2022, USDA would no longer approve vendors to use the official USDA shield in production of metal ear tags or other ear tags that do not have RFID components.
• On January 1, 2023, RFID tags would become the only identification devices approved as an official eartag for cattle and bison pursuant to § 86.4(a)(1)(i).
• For cattle and bison that have official USDA metal clip tags in place before January 1, 2023, APHIS would recognize the metal tag as an official identification device for the life of the animal.
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