USDA moves toward all-RFID system for officially identifying cattle
The USDA has reopened the debate in the cattle industry on radio-frequency tags with a new proposal that has the stated goal of increasing overall traceability in case of disease outbreaks in cattle. It asked the industry to weigh in with comments on its plan to make low-frequency identification tags, commonly known as RFID tags, the only official tags for use in interstate movement of cattle within a few years.
Under its current timeline, the agency wants to require RFID tags for beef cattle, dairy cattle and bison moving interstate by January 1, 2023. (Feeder cattle or those moving directly to slaughter might be exempt from the RFID requirement.)
Animals affected by this requirement would include cattle that are sexually intact and 18 months of age or older; those used for shows and exhibitions; and all female dairy cattle and all male dairy cattle born after March 11, 2013. If an animal has only a metal ear tag when that deadline passes, it would need to be retagged in order for it to be moved.
The agency said that metal “National Uniform Ear-tagging System” tags – those metal tags that the veterinarian puts in a calf’s ear when doing brucellosis vaccinations -- will remain available as USDA continues to take comments and evaluate next steps on its proposed RFID transition timeline. The official comment period ran through Oct. 5. Next steps at the USDA include responding to those comments and revising the rule, if they feel it’s necessary.
To access that proposal and see comments, see https://bit.ly/2TMR8A6
Comments we looked at varied, and some were submitted without names. Some enthusiastically supported a changeover to RFID tags, stating that the United States is one of very few developed countries that are not using this type of system. Another said that the RFID requirement “puts an untenable hardship on many family farms. Where numbers of cattle are low on these small family farms, there is not enough profit to absorb the cost of labor and equipment. The requirement will favor large operators and accelerate the decline of small, startup and family farms.”
An anonymous commenter said, “More costs for the producer. If the USDA is so worried about tracking and origin of cattle then why not mandate the Country of Origin Labeling on beef?”
Another commented that RFID data is “captured with accuracy, speed and less stress to the cow. We need traceability in this country. Our trading partners require it!”
In tandem with its push to make RFID the official tag of the industry, the USDA’s Animal and Plant Health Inspection Service (APHIS) awarded contracts to purchase up to 8 million RFID ear tags so interested livestock producers can get them for free. The contract will allow APHIS to purchase additional tags each year for up to five years.
In announcing the purchase of the tags, the USDA’s Under Secretary for Marketing and Regulatory Programs, Greg Ibach, said “USDA continues its commitment to protect our nation’s agriculture by increasing traceability in the cattle and bison sectors,” with the program to provide the free RFID tags.
Officials at the agency believe that RFID devices like these will provide states and the cattle industry the best opportunity to rapidly contain the spread of disease. “Use of RFID tags better positions the livestock industry, along with state and federal veterinarians to quickly trace animals exposed to or infected with potentially devastating diseases before they can do substantial damage to the U.S. livestock industry,” the agency said in its press release.
Proposal withdrawn last year
The agency tried and then retracted the same proposal last year because of pushback from some cattle organizations who complained that electronic tags are expensive and the technology is unproven.
These tags, also called passive RFID tags, are powered by the radio frequency energy transmitted from RFID readers or antennas. The signal sent by the reader or antenna is used to power-on the tag and reflect the energy back to the reader.
The electronic tag-reading devices cost from $1,000 to slightly over $1,300 per unit. (A cheaper reader is available but it has no display. It is designed to be used with an iPhone or iPad and costs less than $400.)
If purchased, the tags cost from $2 to $4.50 per tag. (In an online search, we found a bag of 1,000 RFID tags for $2,857 – under $3 per tag.)
Under the USDA’s recently announced purchase, tags will be provided to animal health officials and will be distributed for use on farms in replacement breeding cattle (and bison) at no cost to the producer. RFID button tags are available for official calfhood vaccination when animals get brucellosis vaccinations from the veterinarian.
Bill Bullard, CEO of the cattle organization called R-CALF, said he wasn’t surprised the USDA is trying again with this RFID proposal. His group sued last year to stop the RFID mandate and he says he is not surprised they are trying again. (See sidebar for more on R-CALF’s position.)
In its lawsuit last year R-CALF, along with the New Civil Liberties Alliance, and several rancher plaintiffs, responded to a USDA Fact Sheet on its plan to mandate RFID tags. They argued that the mandate was in opposition to the USDA’s own policy that had allowed various kinds of tags, including metal ear clips. In February 2020, a federal judge in Wyoming dismissed the case after the agency argued that the Fact Sheet was “no longer representative of the current agency policy.”
Since that time R-CALF filed a new suit in April, contending that the USDA is still promulgating plans to force ranchers and farmers to use RFID technology. The group has staunchly opposed a government requirement for ranchers to use RFID tags.
Other cattle groups, including the National Cattlemen’s Beef Association (NCBA) have weighed in with concerns about who will end up paying for all the technology and whether or not there will be protections for individual farmer and rancher information that is held in a database. That was reflected in several of the comments that were submitted in response to the APHIS proposal.
It seems likely that cost to farmers and ranchers continues to be one of the arguments against this technology – especially in the courts -- and may be why the USDA is providing the tags for free through state agencies.
Contracts for tags
Contracts for the current USDA purchase of RFID tags were awarded to three U.S. tag companies which are all compliant with the “Buy American Act” – Allflex, Datamars, and Y-Tex. USDA said that contracting with all three companies will allow the agency to procure the number of tags needed to meet an industry volume equivalent to the number of replacement heifers in the United States.
APHIS distributed more than 1.1 million RFID tags to 38 states between January and July 2020. Each state veterinarian is allowed to distribute the tags in a way that best serves the industry in their state.
The “Animal Disease Traceability” framework at APHIS was established, the agency contends, to improve the ability to trace animals back from slaughter and forward from premises where animals are officially identified, in addition to tracing the animals’ interstate movements.
“Knowing where diseased and at-risk exposed animals are, as well as where they have been and when, is indispensable to emergency response and ongoing disease control and eradication programs,” the agency’s document states. “The ability to accurately and rapidly trace animals does not prevent disease epidemics but does allow state and federal veterinarians to contain potentially devastating disease outbreaks early before they can do substantial damage to the U.S. cattle industry.”
Official eartags approved by APHIS “must be tamper-resistant and have a high retention rate in the animal.”
APHIS has used metal tags for animal identification in disease programs for many decades and has approved both those metal tags and RFID tags for use as official identification devices in cattle (and bison) since the implementation of the regulations in 2013.
According to the document, USDA says it is “committed to a modern disease traceability system that tracks animals from birth to slaughter using affordable technology that allows for quick tracing of sick and exposed animals to stop disease spread.”
The USDA noted that “in the event of fast-moving diseases with short incubation periods, the time to trace animals and contain an outbreak is essential to protect the economic viability and competitive advantage of the U.S. cattle industry.
“For diseases like foot-and-mouth disease that could devastate the U.S. cattle industry, emergency response exercises demonstrate that every hour counts toward the successful containment of an outbreak,” the document added.
While APHIS focuses mainly on interstate movements of livestock, states and Tribal Nations are responsible for traceability of livestock within their jurisdictions. Each year, APHIS partners with state veterinary officials to test the performance of states’ animal disease traceability systems. According to the federal officials, these test exercises show that when state veterinary officials are provided with an official identification tag, either metal or RFID, that has been entered accurately into a data system, over half of the states can trace through any one of four types of movement in less than an hour.
The crucial data in those cases includes: the state where an animal was tagged; the location in-state where the animal was tagged; the state from which an animal was shipped out of; and the location in-state that an animal was shipped out-of-state from.
Lengthy times in the trace-test exercises resulted when numbers from visual (metal) tags were transcribed inaccurately, movement records were not readily available or information was only retrievable from labor-intensive paper filing systems. According to APHIS, the RFID tags and electronic record systems “provide significant advantage over metal tags” in order to “rapidly and accurately read and record tag numbers and retrieve traceability information.”
As part of its plan to convert official identification of cattle to RFID, the agency has proposed the following timeline:
*Beginning on January 1, 2022, USDA would not 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.
*A year later, on January 1, 2023, RFID tags would become the only identification devices approved as an official eartag for cattle (and bison).
*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.
In its document, APHIS notes that state veterinary officials in states sending and receiving cattle could agree to accept alternative forms of identification, like registered brands, tattoos and other identification methods that are acceptable to breed associations in place of an official eartag. However, they note that any tags applied on or after January 1, 2023 would require an RFID component for the number that could be read visually as well as electronically.