GAO Letter Report on USDA / NAIS: 90-page "Letter Report" receives analysis
By Julie Kay Smithson
Oct 24, 2007 - 1:09:07 AM
GAO Letter Report on USDA / NAIS:
90-page "Letter Report" receives analysis
August 4, 2007
I've carefully analyzed the 90-page GAO report: "Report to the Chairman, Committee on Agriculture, Nutrition, and Forestry, U.S. Senate: NATIONAL ANIMAL IDENTIFICATION SYSTEM - USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback."
The following should be of substantial interest to all that own animals and/or property. Like "voluntary compliance," "voluntary until mandatory" is the agenda.
There is no "opt out."
Premises registration equates to giving up one's ability to allow or deny access to private property. Premises registration effectively reduces property owners to tenants, with the USDA and its partners as the landlords, landlords that may enter any part of your property to "inspect" with no advance notice.
Say No now until the USDA and its accomplices, or live with the consequences in the future. The scope is so much larger and more ominous than the GAO, USDA, etc., will admit. How many steps is it from tracking movement of animals to movement of pets ... to movement of people? How many steps is it from radio-frequency ID for animals to RFID for people? Look at the number of manufacturers, from "Digital Angel" to "VeriChip." Will that, too, be "voluntary" until "mandatory?" The Amish and Mennonites believe such things to be the "mark of the beast." Who's to say they are not correct in their belief?
Years of experience and research point to the sea of red flags waving a warning to us all.
"Hindsight is 20-20." Clear and present warnings now can prevent years of regret later.
http://www.gao.gov/cgi-bin/getrpt?GAO-07-592 (90 pages; 3.60 MB)
See pages:
6/11 (first bulleted item)
"1. USDA does not require potentially critical information - such as the species, date of birth, or approximate age of animals - to be recorded in NAIS animal ID and tracking databases. This information can be critical for efficient traceback because it helps limit the scope of an investigation, thus saving time and potentially minimizing the economic impact. USDA officials told us that although animal-specific data can be valuable, the agency is collecting the minimum amount of information needed due to some producers' concerns about protection of their proprietary information in NAIS databases."
7/12 (first full paragraph)
(excerpt) "...we are recommending that USDA reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory ..."
11/16 (second paragraph)
(excerpts) "During the first 2 years of the program's implementation, USDA stated several times that participation in NAIS would initially be voluntary but would eventually become mandatory to achieve full participation ..." "The plan also provided a timeline for implementation, with premises registration and animal ID to be required by January 2008 and the reporting of defined animal movements to be required by January 2009, under what would become an entirely mandatory program. The plan stated that this phased-in approach was "to support the transition from voluntary to mandatory as full implementation is achieved." In addition, the plan also stated that, "While market forces may eventually create more inclusiveness, the clear stakeholder support for transitioning to a mandatory program ..."
12/17 (second full paragraph)
(excerpt) "... USDA first needs to resolve several key implementation issues before making participation mandatory." (see text of entire paragraph, which continues on the following page)
14/19
(excerpt) "... the experts we surveyed say the program will likely need to become mandatory to achieve the levels of participation that are necessary ..." and "...
for instance, USDA reported that most individuals who spoke about this subject at the agency's 2004 listening sessions preferred, by a ratio of 3:1, a mandatory program to a purely voluntary program. USDA also reported at that time that a survey of National Institute of Animal Agriculture members showed even stronger support, by a ratio of 8:1, for a program that is or will become mandatory."
15/20 (first paragraph)
(excerpt) "... For example, officials from one major agricultural state [NOTE: This is almost certainly Colorado] told us that USDA's changed direction on whether the program would become mandatory has challenged the state's premises registration efforts, because many producers are motivated by compliance with federal requirements, not necessarily by NAIS's traceback goal alone. These officials also said that the lack of participation benchmarks had compromised the state's credibility with producers and its ability to make progress in implementation. As of early June 2007, this state had less than 16 percent of its premises registered, and the officials believed there is little incentive for producers to participate in NAIS. Moreover, three states where premises registration is mandatory by state law - Indiana, Michigan,9 and Wisconsin - accounted for about 26 percent of USDA's total premises registered nationally as of that time.."
(next paragraph, excerpt) "Overall, 27 of the 32 experts said participation in NAIS should definitely or probably be mandatory."
20/25 (first full paragraph)
"For NAIS not to impose undue costs on producers by requiring additional ID devices, stakeholders say the program must be integrated with preexisting programs and systems. However, USDA faces challenges in integrating NAIS with other animal ID requirements. For example, Sheep Working Group members told us that because the scrapie program already assigns a flock ID number to each premises-plus a unique, individual ID number to each animal-sheep producers do not see the need to participate in NAIS, which involves different premises and individual animal ID numbering systems. Another challenge is that brands identify all animals raised by a specific producer as a group, not as individuals, and the same brands are often used in different states or even in different counties within the same state. USDA's NAIS User Guide states that registered brands are not considered to be an official, individual animal ID as called for by NAIS because cattle typically move through the production process as individuals. In addition, NAIS animal tracking requirements may differ operationally from state brand laws and practices. For example, New Mexico requires state authorities to inspect all livestock moving across brand district lines, which contrasts with NAIS, where the responsibility of reporting animal movement lies with the premises receiving animals. New Mexico officials told us that if they were to implement NAIS as envisioned, the time required for state inspections would at least double if inspectors were required to read and report ID tags. The Cattle Working Group recommended, in 2004, that USDA develop protocols for integrating existing brand laws with NAIS individual animal ID requirements and for the reporting of animals' movements from brand law states to nonbrand law states."
28/33 (last paragraph)
"In fiscal years 2004 and 2005, USDA also awarded field trial cooperative agreements. Specifically, in fiscal year 2004, USDA awarded 16 cooperative agreements totaling $9.7 million to 15 states and 1 tribe. USDA estimates that $1.8 million of the $9.7 million awarded was used to support premises registration activities. The remainder was used for field trials to develop, test, and offer solutions for applying animal ID devices and collecting animal tracking information. For example, 1 cooperative agreement with the Wyoming Livestock Board tested whether existing brand inspection personnel and infrastructure could be used to track livestock changing ownership and livestock entering into interstate commerce through Wyoming livestock markets. In fiscal year 2005, USDA awarded 7 cooperative agreements totaling $1.9 million to 6 states and 1 tribe for field trials to support research, including the assessment of existing and novel ID technologies."
53/58
"Part III. Implementation of NAIS - NAIS is being implemented for all livestock species, including bison, camelids, cattle (beef and dairy), cervids, equine, goats, poultry, sheep, and swine. Countries that have already implemented national animal ID programs (e.g., Canada, EU, Australia) generally started with cattle and, in some cases, later extended their program to cover a few other species. No other country has attempted to reach the number of species that USDA aims to cover with NAIS, nor has any other country implemented a program for multiple species simultaneously."
63/68 (bottom of page)
Canada:
Julie Kay Smithson, property rights researcher
[email protected]
http://www.propertyrightsresearch.org
"The three great rights are so bound together as to be essentially one right. To give a man his life, but deny him his liberty, is to take from him all that makes his life worth living. To give him his liberty, but take from him the property which is the fruit and badge of his liberty, is to still leave him a slave." - George Sutherland, Associate Justice of the United States Supreme Court, 1921.
© Copyright 2002-2007 by Magic City Morning Star
http://www.magic-city-news.com/Letters_ ... 8830.shtml
JULY 2007
NATIONAL ANIMAL IDENTIFICATION SYSTEM USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback
July 6, 2007 The Honorable Tom Harkin Chairman Committee on Agriculture, Nutrition, and Forestry United States Senate Dear Mr. Chairman: U.S. agriculture provides an abundant supply of food and other products for Americans and others around the world, annually generating more than $1 trillion in economic activity, including more than $68 billion in exports in 2006. Because of the economic importance of the agriculture sector and the risks to public health as well as the economy, we have designated the federal oversight of food safety as a high-risk area.1 Within the broader sector, livestock production contributed nearly $123 billion to the U.S. economy in 2006, including $13.4 billion in livestock, poultry, and dairy exports.2 One way to protect the health of livestock animals—which are critically important to the integrity and safety of the nation's food supply, the well-being of Americans, and the U.S. economy—is through a national animal identification (ID) system to trace back and contain diseases that spread rapidly. Our recent work has described animal diseases and their economic and, in some cases, human health consequences. For example, a highly pathogenic strain of avian influenza has spread to nearly 60 countries over the past few years, resulting in the death and destruction of millions of wild and domestic birds and infecting almost 300 humans, more than one-half of whom have died—creating serious concerns that the virus could reach North America at any time.3 In addition, the first known U.S. case discovered in December 2003 of one cow infected with bovine spongiform encephalopathy (BSE) caused the U.S. beef industry to lose more than 80 percent of its export trade, or an estimated $2 billion,
between January and September 2004.4 Commonly known as mad cow disease, BSE has been linked by scientists to a fatal neurological disease in humans known as variant Creutzfeldt-Jacob disease. Another disease of particular concern is foot-and-mouth disease (FMD), a highly contagious livestock disease that does not typically affect humans and last occurred in the United States in 1929. According to several estimates, the direct costs of controlling and eradicating a U.S. outbreak of FMD could range up to $27 billion in current dollars.5In response to concerns about such outbreaks occurring in the United States and in recognition that speed and accuracy are critical factors in controlling a disease, the U.S. Department of Agriculture (USDA) announced in December 2003 that it would lead the design and implementation of a nationwide program—later named the National Animal Identification System (NAIS)—to enable USDA, states, and industry to quickly and efficiently locate all infected and potentially exposed animals and premises that have had contact with a foreign or domestic disease of concern. USDA recognized that a fully functional animal tracking system will keep the United States competitive in international markets, can help reassure foreign consumers about the health of U.S. livestock, and may satisfy other countries' import requirements. Internationally, some of the United States' major trading partners—such as the European Union (EU), Japan, and Canada—already have mandatory national animal ID programs in place for certain species. The Animal Health Protection Act authorizes the Secretary of Agriculture to carry out operations and measures to detect, control, or eradicate livestock pests and diseases,6 and USDA has delegated this responsibility to its Animal and Plant Health Inspection Service's (APHIS) Veterinary Services. USDA cites this broad authority for implementing NAIS as either a voluntary or mandatory program. NAIS is currently being implemented for nine livestock species groups: bison; camelids (llamas and alpacas); cattle (beef and dairy); cervids (deer and elk); equine (horses, mules, donkeys, and burros); goats; poultry;
sheep; and swine. Since 2004, USDA has received input on the design and implementation of the program from various stakeholders, including industry groups, individual producers, livestock markets, slaughter facilities (processors), and state animal health officials. USDA says that because NAIS is a state-federal-industry partnership, the agency has used stakeholder input to adjust the program as NAIS has evolved, and it encourages continued stakeholder input. NAIS consists of three components: (1) registering all "premises" that manage or handle livestock, such as farms, feedlots, veterinary clinics, and livestock markets; (2) identifying livestock animals; and (3) tracking animal movements throughout the production process, from their premises of origin to their slaughter or death. Initially, USDA stated that NAIS would start as a voluntary program and later become mandatory, but, in late 2006, the agency decided that NAIS would remain voluntary. The agency also provided a timeline for implementation and set participation benchmarks that called for gradually increasing the percentages of premises registered, animals identified, and animals tracked. By August 2005, all states had the capability of registering premises, and, as of late May 2007, USDA reported that more than 390,000 premises, or 27.5 percent of the national estimate, were registered in NAIS. Of the total $85.0 million funding made available for NAIS from fiscal years 2004 through 2006, USDA has awarded $35.0 million in cooperative agreements to states, territories, and tribes to help identify effective approaches to register premises and to identify and track animals. In fiscal year 2007, Congress appropriated another $33.0 million to develop and implement NAIS, and the President's Budget in fiscal year 2008 requested an additional $33.1 million for the program. Premises registration is currently funded by USDA, states, territories, and tribes and, therefore, is free to the producer. The costs of animal ID and tracking are to be borne by the livestock industry and will vary, depending on the choices made by individual producers. In this context, we determined (1) how effectively USDA is implementing NAIS and, specifically, the key implementation issues identified by livestock industry groups, market operators, state animal health officials, and others; (2) how USDA has distributed cooperative agreement funding to help states and industry prepare for NAIS and evaluated the agreements' results; and (3) what USDA and others estimate are the costs for USDA, states, and the livestock industry to implement and maintain NAIS.
Page 3 GAO-07-592 National Animal Identification System
To address all three objectives, we reviewed USDA documents, interviewed agency officials responsible for implementing NAIS, and conducted site visits to selected livestock markets and cooperative agreement field trials. We also conducted structured interviews in person or via telephone with animal health officials in seven states. These states were selected on the basis of their geographic dispersion; the range in the number of premises located in each state; and, in some cases, their high levels of livestock production. We also conducted structured interviews in person or via telephone with, and reviewed documents from, representatives from numerous stakeholder organizations, including several NAIS industry working groups. In addition, for the first and third objectives, we convened a Web-based panel of 32 experts to learn their beliefs and opinions on various aspects of USDA's implementation of NAIS. We selected experts who were actively involved in the development or implementation of NAIS and were knowledgeable of its details; who had conducted research on animal ID, or had published in peer-reviewed journals on animal ID; or who were recognized by their peers as an expert on NAIS. For the second objective, we also reviewed USDA documentation related to cooperative agreements signed between USDA and states, territories, tribes, and industry groups from fiscal years 2004 through 2007. For the third objective, we asked USDA and others for any NAIS cost estimates they had developed, and we reviewed federal guidance for developing cost-benefit analyses. A more detailed description of our scope and methodology is presented in appendix I. We conducted our work from June 2006 to May 2007 in accordance with generally accepted government auditing standards. USDA has steadily increased the number of livestock premises registered in the nation and taken some steps to address stakeholder concerns in implementing NAIS. However, the agency has not effectively addressed several key issues identified by livestock industry groups, market operators, state animal health officials, and others that, if left unresolved, could undermine the program's goal of rapid and effective traceback and thus hinder its success. Foremost among these issues is USDA's decision in late 2006 to continue implementing NAIS as a voluntary program and to drop participation benchmarks that were intended to gauge progress. Many industry groups, state animal health officials, and experts say this approach may affect the agency's ability to attract the necessary levels of participation to quickly and efficiently locate all animals that are potentially exposed to a disease. However, some industry groups oppose the program being mandatory because they believe that NAIS could succeed as a voluntary program or that USDA first needs to resolve several Results in Brief
Page 4 GAO-07-592 National Animal Identification System
implementation issues. USDA officials told us that the agency is analyzing what participation levels are necessary to meet the program's goal, and that it may introduce new, risk-based benchmarks, accordingly. In addition, several other key problems hinder the agency's ability to implement NAIS effectively, as follows: • USDA has not prioritized the implementation of NAIS by species or other criteria. Instead, the agency is implementing NAIS for numerous species simultaneously, regardless of the species' economic value, their risk of diseases of concern, the potential human health impact of these diseases, or other criteria. Consequently, federal, state, and industry resources for NAIS have been allocated widely, rather than being focused first on the species of greatest concern and allowing other species to be included later, on the basis of lessons learned. Twenty-one of the 32 expert panel members said USDA should definitely or probably implement NAIS incrementally by species and suggested criteria to prioritize the order of implementation. USDA officials told us that prioritizing implementation may be appropriate, such as focusing on specific diseases of concern or commercial operations, and that the states should determine their own priorities for implementation. • Although USDA aims to minimize the financial and practical impact on producers and others in implementing NAIS, the agency has not developed a plan to integrate NAIS with preexisting animal ID requirements, such as scrapie ear tags and brands, for other USDA and state animal health programs. As a result, producers have generally been discouraged from investing in new ID devices for NAIS, according to industry groups we interviewed. • USDA has not established a robust process for selecting, standardizing, and testing ID and tracking technologies. While international programs have generally used specific animal ID devices for their national animal ID programs, USDA has taken a "technology-neutral" position to allow market forces to determine what devices are most effective and practical. In addition, industry groups, experts, and others told us that electronic ID technologies do not always perform well in production environments, such as livestock markets, and that the agency has not independently tested any ID or tracking devices. Consequently, producers, livestock markets, and others are reluctant to invest in new ID or tracking devices for NAIS, according to industry groups and the experts. • USDA does not clearly define the time frame for rapid animal disease traceback. The definition of "rapid traceback" may vary by disease because some diseases spread more quickly than others, but by not clearly
Page 5 GAO-07-592 National Animal Identification System
defining a rapid response for a given disease, there could be a slower response and greater economic losses. A senior USDA official told us the agency first needs to identify current baselines for traceback before the agency can determine time-sensitive traceback goals for NAIS. • USDA does not require potentially critical information—such as the species, date of birth, or approximate age of animals—to be recorded in NAIS animal ID and tracking databases. This information can be critical for efficient traceback because it helps limit the scope of an investigation, thus saving time and potentially minimizing the economic impact. USDA officials told us that although animal-specific data can be valuable, the agency is collecting the minimum amount of information needed due to some producers' concerns about protection of their proprietary information in NAIS databases. USDA awarded 169 NAIS cooperative agreements totaling $35 million to 49 states, 29 tribes, and 2 territories from fiscal years 2004 through 2006 to help identify effective approaches to register premises and identify and track animals. To date, USDA has not consistently monitored cooperative agreements, and, as a result, the agency cannot be assured that the agreements' intended outcomes have been achieved. In addition, USDA has not formally evaluated or consistently shared the results of cooperative agreements with state departments of agriculture, industry groups, and other NAIS stakeholders, which would enable lessons learned and best practices to inform the program's progress. USDA officials told us the quality of reports submitted to the agency varies, and USDA has had insufficient resources to conduct additional oversight. In fiscal year 2007, USDA plans to increase oversight of all cooperative agreements awarded that year by assessing progress midyear. Furthermore, USDA plans to give those states with greater numbers of premises registered some flexibility in using cooperative agreement funds to subsidize the purchase of animal tracking equipment for livestock markets. For the first time, in fiscal year 2007, USDA also plans to award $6 million in cooperative agreements to nonprofit industry and other groups to increase premises registration efforts. Although USDA began to implement NAIS in 2004, no comprehensive cost estimate or cost-benefit analysis for the implementation and maintenance of NAIS currently exists. As a result, it is not known how much is required in federal, state, and industry resources to achieve rapid and effective traceback or whether the potential benefits of the program outweigh the costs. Twenty-nine of the 32 expert panel members said that USDA should definitely or probably publish a cost-benefit analysis for NAIS. The NAIS
Page 6 GAO-07-592 National Animal Identification System
working groups, other livestock industry representatives, and state animal health officials we interviewed also said that the cost of implementing NAIS remained one of their biggest concerns. USDA officials plan to hire a contractor to conduct a cost-benefit analysis, in part, to more precisely forecast the program's economic effects. Moreover, the Senate Committee on Appropriations and the House of Representatives have raised concerns over how USDA has spent funds to develop and implement NAIS. Finally, the experts had mixed views on the impact that NAIS would have on the livestock industry, such as whether NAIS may lead to changes in market structure or affect prices. To ensure that USDA continues to take steps to address unresolved issues, we are making several recommendations aimed at improving USDA's efforts to implement NAIS more effectively and efficiently. For example, we are recommending that USDA reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory or creating incentives to achieve those levels of participation. In addition, we are recommending that USDA establish a robust process to select, standardize, and independently test and evaluate the performance of animal ID and tracking devices to ensure they meet minimum standards. We are also recommending that USDA increase the monitoring of NAIS cooperative agreements, evaluate and publish the results of cooperative agreements on a timely basis, and publish the planned analysis of the costs and benefits of NAIS following criteria established in Office of Management and Budget (OMB) guidance. In commenting on a draft of this report, USDA stated that it appreciated our comprehensive evaluation of NAIS and generally agreed with our recommendations. However, regarding our recommendation that USDA establish a robust process to select, standardize, and independently test and evaluate the performance of animal ID and tracking devices to ensure they meet minimum standards, USDA believed that these standards must be defined through a consensus of affected stakeholders and that working with stakeholders to resolve this issue is imperative before selecting specific technologies for NAIS. We recognize the need for USDA to work with stakeholders before determining which ID and tracking devices are most appropriate for NAIS. However, we emphasize that the sooner USDA selects specific technologies, the sooner the animal ID and tracking components of the program will be implemented effectively and efficiently. See the "Agency Comments and Our Evaluation" section and Page 7 GAO-07-592 National Animal Identification System
The concept of animal ID is not new, in the United States or abroad. For decades, American producers have kept records on, and used ID methods for, livestock animals for both commercial and regulatory purposes. Specifically, several USDA and state animal disease eradication programs—such as programs for tuberculosis (TB) in cattle, pseudorabies in swine, and scrapie in sheep and goats—include animal ID requirements. Certain species and classes of animals require officially recognized ID devices for interstate commerce, and all live animals imported into, or exported from, the United States require official ID. Thus, many livestock animals are already identified in the United States by ear tags, branding, tattoos, or other devices. However, the use of ID devices varies by breed, species, and state, and, until NAIS, no attempt had been made to create a uniform animal ID system of national scope and across multiple species using a universal numbering system and central data repository. Due to serious concerns about the United States' ability to safeguard its livestock from the harmful effects of disease, in 2002, the National Institute of Animal Agriculture—an organization of producers, veterinarians, scientists, government representatives, and allied industries—initiated a state-USDA-industry task force of approximately 70 representatives to create a national animal ID system. In 2003, USDA expanded upon this work and established a development team consisting of more than 70 industry associations, organizations, and government agencies. That team ultimately produced the United States Animal Identification Plan in December 2003, which provided the foundation for NAIS. Although early versions of the plan focused on food animals only, other livestock species were later incorporated. The plan was being finalized when the nation's first case of BSE was confirmed on December 25, 2003. Five days later, the Secretary of Agriculture announced measures to guard against BSE and indicated that USDA would expedite the implementation of a national animal ID system. Since 2004, USDA has solicited public comments on draft NAIS policy documents, held public listening sessions, and met with industry groups and others in its efforts to design and implement NAIS. In addition, USDA has received input from 10 working groups comprising producers, academics, and others representing the various livestock species and industry sectors currently included in NAIS. These working groups make recommendations to the NAIS Subcommittee, a group of state and Background
Page 8 GAO-07-592 National Animal Identification System
SNIP...
Key NAIS Implementation Issues Are Unresolved and Could Undermine the Program's Goal of Rapid and Effective Traceback
USDA has steadily increased the number of livestock premises registered in the nation and has taken some steps to address stakeholder concerns in implementing NAIS. However, the agency has not effectively addressed a number of key issues identified by livestock industry groups, market operators, state animal health officials, and others that, if not ultimately resolved, could undermine the program's goal of rapid and effective traceback, thus hindering its success. USDA's decision to implement NAIS as a voluntary program without benchmarks to measure progress may affect the agency's ability to attract the necessary levels of participation to quickly and efficiently locate all animals potentially exposed to a disease. In addition, USDA has not prioritized the implementation of NAIS by species or other criteria. Furthermore, USDA has not developed a plan for integrating NAIS with other USDA and state animal ID requirements, nor has it established a robust process for selecting, standardizing, and testing ID and tracking technologies. The agency also does not clearly define the time frame for rapid traceback. Finally, USDA does not require potentially critical information for efficient traceback to be recorded in NAIS databases.
SNIP... see full text 90 pages ;
http://www.gao.gov/new.items/d07592.pdf
Section 2. Testing Protocols and Quality Assurance Controls
In November 2004, USDA announced that its rapid screening test, Bio-Rad Enzyme Linked Immunosorbent Assay (ELISA), produced an inconclusive BSE test result as part of its enhanced BSE surveillance program. The ELISA rapid screening test performed at a BSE contract laboratory produced three high positive reactive results.40 As required,41 the contract laboratory forwarded the inconclusive sample to the APHIS National Veterinary Services Laboratories (NVSL) for confirmatory testing. NVSL repeated the ELISA testing and again produced three high positive reactive results.42 In accordance with its established protocol, NVSL ran its confirmatory test, an immunohistochemistry (IHC) test, which was interpreted as negative for BSE. In addition, NVSL performed a histological43 examination of the tissue and did not detect lesions44 consistent with BSE.
Faced with conflicting results, NVSL scientists recommended additional testing to resolve the discrepancy but APHIS headquarters officials concluded no further testing was necessary because testing protocols were followed. In our discussions with APHIS officials, they justified their decision not to do additional testing because the IHC is internationally recognized as the "gold standard." Also, they believed that conducting additional tests would undermine confidence in USDA's established testing protocols.
http://www.usda.gov/oig/webdocs/50601-10-KC.pdf
NOW, post December 2003 MAD COW BSE CASE IN WASHINGTON, and post TWO atypical H-BSE BASE cases, one in Alabama, and one in Texas, and NOT TO FORGET the other stumbling and staggering mad cow in Texas that was successfully covered up, by sending straight to the render, without any mad cow test at all, what did r-calf say before all this $$$
Dr. Detwiler: I'll play devil's advocate. If the US found a case tomorrow,
what would we ask of the world? I think that's valid to ask. It's valid to
turn the mirror back on yourself.
Dr. Thornsberry: I guarantee you that we would immediately have individual
animal ID and it wouldn't be two years later.
FULL TEXT;
Completely Edited Version
PRION ROUNDTABLE
Accomplished this day, Wednesday, December 11, 2003, Denver, Colorado
The roundtable presentations and discussions
were recorded. A transcript will be made available
to the Academy of Veterinary Consultants, the
American Association of Bovine Practitioners, and
the Colleges of Veterinary Medicine throughout the
United States and Canada. A condensed version
translated for the livestock industry will be made
available to educate livestock producers about
prion related diseases.
http://www.r-calfusa.com/Newsletter/2004January.pdf
WELL, it's almost 2008, and were still waiting. ...TSS
By Julie Kay Smithson
Oct 24, 2007 - 1:09:07 AM
GAO Letter Report on USDA / NAIS:
90-page "Letter Report" receives analysis
August 4, 2007
I've carefully analyzed the 90-page GAO report: "Report to the Chairman, Committee on Agriculture, Nutrition, and Forestry, U.S. Senate: NATIONAL ANIMAL IDENTIFICATION SYSTEM - USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback."
The following should be of substantial interest to all that own animals and/or property. Like "voluntary compliance," "voluntary until mandatory" is the agenda.
There is no "opt out."
Premises registration equates to giving up one's ability to allow or deny access to private property. Premises registration effectively reduces property owners to tenants, with the USDA and its partners as the landlords, landlords that may enter any part of your property to "inspect" with no advance notice.
Say No now until the USDA and its accomplices, or live with the consequences in the future. The scope is so much larger and more ominous than the GAO, USDA, etc., will admit. How many steps is it from tracking movement of animals to movement of pets ... to movement of people? How many steps is it from radio-frequency ID for animals to RFID for people? Look at the number of manufacturers, from "Digital Angel" to "VeriChip." Will that, too, be "voluntary" until "mandatory?" The Amish and Mennonites believe such things to be the "mark of the beast." Who's to say they are not correct in their belief?
Years of experience and research point to the sea of red flags waving a warning to us all.
"Hindsight is 20-20." Clear and present warnings now can prevent years of regret later.
http://www.gao.gov/cgi-bin/getrpt?GAO-07-592 (90 pages; 3.60 MB)
See pages:
6/11 (first bulleted item)
"1. USDA does not require potentially critical information - such as the species, date of birth, or approximate age of animals - to be recorded in NAIS animal ID and tracking databases. This information can be critical for efficient traceback because it helps limit the scope of an investigation, thus saving time and potentially minimizing the economic impact. USDA officials told us that although animal-specific data can be valuable, the agency is collecting the minimum amount of information needed due to some producers' concerns about protection of their proprietary information in NAIS databases."
7/12 (first full paragraph)
(excerpt) "...we are recommending that USDA reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory ..."
11/16 (second paragraph)
(excerpts) "During the first 2 years of the program's implementation, USDA stated several times that participation in NAIS would initially be voluntary but would eventually become mandatory to achieve full participation ..." "The plan also provided a timeline for implementation, with premises registration and animal ID to be required by January 2008 and the reporting of defined animal movements to be required by January 2009, under what would become an entirely mandatory program. The plan stated that this phased-in approach was "to support the transition from voluntary to mandatory as full implementation is achieved." In addition, the plan also stated that, "While market forces may eventually create more inclusiveness, the clear stakeholder support for transitioning to a mandatory program ..."
12/17 (second full paragraph)
(excerpt) "... USDA first needs to resolve several key implementation issues before making participation mandatory." (see text of entire paragraph, which continues on the following page)
14/19
(excerpt) "... the experts we surveyed say the program will likely need to become mandatory to achieve the levels of participation that are necessary ..." and "...
for instance, USDA reported that most individuals who spoke about this subject at the agency's 2004 listening sessions preferred, by a ratio of 3:1, a mandatory program to a purely voluntary program. USDA also reported at that time that a survey of National Institute of Animal Agriculture members showed even stronger support, by a ratio of 8:1, for a program that is or will become mandatory."
15/20 (first paragraph)
(excerpt) "... For example, officials from one major agricultural state [NOTE: This is almost certainly Colorado] told us that USDA's changed direction on whether the program would become mandatory has challenged the state's premises registration efforts, because many producers are motivated by compliance with federal requirements, not necessarily by NAIS's traceback goal alone. These officials also said that the lack of participation benchmarks had compromised the state's credibility with producers and its ability to make progress in implementation. As of early June 2007, this state had less than 16 percent of its premises registered, and the officials believed there is little incentive for producers to participate in NAIS. Moreover, three states where premises registration is mandatory by state law - Indiana, Michigan,9 and Wisconsin - accounted for about 26 percent of USDA's total premises registered nationally as of that time.."
(next paragraph, excerpt) "Overall, 27 of the 32 experts said participation in NAIS should definitely or probably be mandatory."
20/25 (first full paragraph)
"For NAIS not to impose undue costs on producers by requiring additional ID devices, stakeholders say the program must be integrated with preexisting programs and systems. However, USDA faces challenges in integrating NAIS with other animal ID requirements. For example, Sheep Working Group members told us that because the scrapie program already assigns a flock ID number to each premises-plus a unique, individual ID number to each animal-sheep producers do not see the need to participate in NAIS, which involves different premises and individual animal ID numbering systems. Another challenge is that brands identify all animals raised by a specific producer as a group, not as individuals, and the same brands are often used in different states or even in different counties within the same state. USDA's NAIS User Guide states that registered brands are not considered to be an official, individual animal ID as called for by NAIS because cattle typically move through the production process as individuals. In addition, NAIS animal tracking requirements may differ operationally from state brand laws and practices. For example, New Mexico requires state authorities to inspect all livestock moving across brand district lines, which contrasts with NAIS, where the responsibility of reporting animal movement lies with the premises receiving animals. New Mexico officials told us that if they were to implement NAIS as envisioned, the time required for state inspections would at least double if inspectors were required to read and report ID tags. The Cattle Working Group recommended, in 2004, that USDA develop protocols for integrating existing brand laws with NAIS individual animal ID requirements and for the reporting of animals' movements from brand law states to nonbrand law states."
28/33 (last paragraph)
"In fiscal years 2004 and 2005, USDA also awarded field trial cooperative agreements. Specifically, in fiscal year 2004, USDA awarded 16 cooperative agreements totaling $9.7 million to 15 states and 1 tribe. USDA estimates that $1.8 million of the $9.7 million awarded was used to support premises registration activities. The remainder was used for field trials to develop, test, and offer solutions for applying animal ID devices and collecting animal tracking information. For example, 1 cooperative agreement with the Wyoming Livestock Board tested whether existing brand inspection personnel and infrastructure could be used to track livestock changing ownership and livestock entering into interstate commerce through Wyoming livestock markets. In fiscal year 2005, USDA awarded 7 cooperative agreements totaling $1.9 million to 6 states and 1 tribe for field trials to support research, including the assessment of existing and novel ID technologies."
53/58
"Part III. Implementation of NAIS - NAIS is being implemented for all livestock species, including bison, camelids, cattle (beef and dairy), cervids, equine, goats, poultry, sheep, and swine. Countries that have already implemented national animal ID programs (e.g., Canada, EU, Australia) generally started with cattle and, in some cases, later extended their program to cover a few other species. No other country has attempted to reach the number of species that USDA aims to cover with NAIS, nor has any other country implemented a program for multiple species simultaneously."
63/68 (bottom of page)
Canada:
Julie Kay Smithson, property rights researcher
[email protected]
http://www.propertyrightsresearch.org
"The three great rights are so bound together as to be essentially one right. To give a man his life, but deny him his liberty, is to take from him all that makes his life worth living. To give him his liberty, but take from him the property which is the fruit and badge of his liberty, is to still leave him a slave." - George Sutherland, Associate Justice of the United States Supreme Court, 1921.
© Copyright 2002-2007 by Magic City Morning Star
http://www.magic-city-news.com/Letters_ ... 8830.shtml
JULY 2007
NATIONAL ANIMAL IDENTIFICATION SYSTEM USDA Needs to Resolve Several Key Implementation Issues to Achieve Rapid and Effective Disease Traceback
July 6, 2007 The Honorable Tom Harkin Chairman Committee on Agriculture, Nutrition, and Forestry United States Senate Dear Mr. Chairman: U.S. agriculture provides an abundant supply of food and other products for Americans and others around the world, annually generating more than $1 trillion in economic activity, including more than $68 billion in exports in 2006. Because of the economic importance of the agriculture sector and the risks to public health as well as the economy, we have designated the federal oversight of food safety as a high-risk area.1 Within the broader sector, livestock production contributed nearly $123 billion to the U.S. economy in 2006, including $13.4 billion in livestock, poultry, and dairy exports.2 One way to protect the health of livestock animals—which are critically important to the integrity and safety of the nation's food supply, the well-being of Americans, and the U.S. economy—is through a national animal identification (ID) system to trace back and contain diseases that spread rapidly. Our recent work has described animal diseases and their economic and, in some cases, human health consequences. For example, a highly pathogenic strain of avian influenza has spread to nearly 60 countries over the past few years, resulting in the death and destruction of millions of wild and domestic birds and infecting almost 300 humans, more than one-half of whom have died—creating serious concerns that the virus could reach North America at any time.3 In addition, the first known U.S. case discovered in December 2003 of one cow infected with bovine spongiform encephalopathy (BSE) caused the U.S. beef industry to lose more than 80 percent of its export trade, or an estimated $2 billion,
between January and September 2004.4 Commonly known as mad cow disease, BSE has been linked by scientists to a fatal neurological disease in humans known as variant Creutzfeldt-Jacob disease. Another disease of particular concern is foot-and-mouth disease (FMD), a highly contagious livestock disease that does not typically affect humans and last occurred in the United States in 1929. According to several estimates, the direct costs of controlling and eradicating a U.S. outbreak of FMD could range up to $27 billion in current dollars.5In response to concerns about such outbreaks occurring in the United States and in recognition that speed and accuracy are critical factors in controlling a disease, the U.S. Department of Agriculture (USDA) announced in December 2003 that it would lead the design and implementation of a nationwide program—later named the National Animal Identification System (NAIS)—to enable USDA, states, and industry to quickly and efficiently locate all infected and potentially exposed animals and premises that have had contact with a foreign or domestic disease of concern. USDA recognized that a fully functional animal tracking system will keep the United States competitive in international markets, can help reassure foreign consumers about the health of U.S. livestock, and may satisfy other countries' import requirements. Internationally, some of the United States' major trading partners—such as the European Union (EU), Japan, and Canada—already have mandatory national animal ID programs in place for certain species. The Animal Health Protection Act authorizes the Secretary of Agriculture to carry out operations and measures to detect, control, or eradicate livestock pests and diseases,6 and USDA has delegated this responsibility to its Animal and Plant Health Inspection Service's (APHIS) Veterinary Services. USDA cites this broad authority for implementing NAIS as either a voluntary or mandatory program. NAIS is currently being implemented for nine livestock species groups: bison; camelids (llamas and alpacas); cattle (beef and dairy); cervids (deer and elk); equine (horses, mules, donkeys, and burros); goats; poultry;
sheep; and swine. Since 2004, USDA has received input on the design and implementation of the program from various stakeholders, including industry groups, individual producers, livestock markets, slaughter facilities (processors), and state animal health officials. USDA says that because NAIS is a state-federal-industry partnership, the agency has used stakeholder input to adjust the program as NAIS has evolved, and it encourages continued stakeholder input. NAIS consists of three components: (1) registering all "premises" that manage or handle livestock, such as farms, feedlots, veterinary clinics, and livestock markets; (2) identifying livestock animals; and (3) tracking animal movements throughout the production process, from their premises of origin to their slaughter or death. Initially, USDA stated that NAIS would start as a voluntary program and later become mandatory, but, in late 2006, the agency decided that NAIS would remain voluntary. The agency also provided a timeline for implementation and set participation benchmarks that called for gradually increasing the percentages of premises registered, animals identified, and animals tracked. By August 2005, all states had the capability of registering premises, and, as of late May 2007, USDA reported that more than 390,000 premises, or 27.5 percent of the national estimate, were registered in NAIS. Of the total $85.0 million funding made available for NAIS from fiscal years 2004 through 2006, USDA has awarded $35.0 million in cooperative agreements to states, territories, and tribes to help identify effective approaches to register premises and to identify and track animals. In fiscal year 2007, Congress appropriated another $33.0 million to develop and implement NAIS, and the President's Budget in fiscal year 2008 requested an additional $33.1 million for the program. Premises registration is currently funded by USDA, states, territories, and tribes and, therefore, is free to the producer. The costs of animal ID and tracking are to be borne by the livestock industry and will vary, depending on the choices made by individual producers. In this context, we determined (1) how effectively USDA is implementing NAIS and, specifically, the key implementation issues identified by livestock industry groups, market operators, state animal health officials, and others; (2) how USDA has distributed cooperative agreement funding to help states and industry prepare for NAIS and evaluated the agreements' results; and (3) what USDA and others estimate are the costs for USDA, states, and the livestock industry to implement and maintain NAIS.
Page 3 GAO-07-592 National Animal Identification System
To address all three objectives, we reviewed USDA documents, interviewed agency officials responsible for implementing NAIS, and conducted site visits to selected livestock markets and cooperative agreement field trials. We also conducted structured interviews in person or via telephone with animal health officials in seven states. These states were selected on the basis of their geographic dispersion; the range in the number of premises located in each state; and, in some cases, their high levels of livestock production. We also conducted structured interviews in person or via telephone with, and reviewed documents from, representatives from numerous stakeholder organizations, including several NAIS industry working groups. In addition, for the first and third objectives, we convened a Web-based panel of 32 experts to learn their beliefs and opinions on various aspects of USDA's implementation of NAIS. We selected experts who were actively involved in the development or implementation of NAIS and were knowledgeable of its details; who had conducted research on animal ID, or had published in peer-reviewed journals on animal ID; or who were recognized by their peers as an expert on NAIS. For the second objective, we also reviewed USDA documentation related to cooperative agreements signed between USDA and states, territories, tribes, and industry groups from fiscal years 2004 through 2007. For the third objective, we asked USDA and others for any NAIS cost estimates they had developed, and we reviewed federal guidance for developing cost-benefit analyses. A more detailed description of our scope and methodology is presented in appendix I. We conducted our work from June 2006 to May 2007 in accordance with generally accepted government auditing standards. USDA has steadily increased the number of livestock premises registered in the nation and taken some steps to address stakeholder concerns in implementing NAIS. However, the agency has not effectively addressed several key issues identified by livestock industry groups, market operators, state animal health officials, and others that, if left unresolved, could undermine the program's goal of rapid and effective traceback and thus hinder its success. Foremost among these issues is USDA's decision in late 2006 to continue implementing NAIS as a voluntary program and to drop participation benchmarks that were intended to gauge progress. Many industry groups, state animal health officials, and experts say this approach may affect the agency's ability to attract the necessary levels of participation to quickly and efficiently locate all animals that are potentially exposed to a disease. However, some industry groups oppose the program being mandatory because they believe that NAIS could succeed as a voluntary program or that USDA first needs to resolve several Results in Brief
Page 4 GAO-07-592 National Animal Identification System
implementation issues. USDA officials told us that the agency is analyzing what participation levels are necessary to meet the program's goal, and that it may introduce new, risk-based benchmarks, accordingly. In addition, several other key problems hinder the agency's ability to implement NAIS effectively, as follows: • USDA has not prioritized the implementation of NAIS by species or other criteria. Instead, the agency is implementing NAIS for numerous species simultaneously, regardless of the species' economic value, their risk of diseases of concern, the potential human health impact of these diseases, or other criteria. Consequently, federal, state, and industry resources for NAIS have been allocated widely, rather than being focused first on the species of greatest concern and allowing other species to be included later, on the basis of lessons learned. Twenty-one of the 32 expert panel members said USDA should definitely or probably implement NAIS incrementally by species and suggested criteria to prioritize the order of implementation. USDA officials told us that prioritizing implementation may be appropriate, such as focusing on specific diseases of concern or commercial operations, and that the states should determine their own priorities for implementation. • Although USDA aims to minimize the financial and practical impact on producers and others in implementing NAIS, the agency has not developed a plan to integrate NAIS with preexisting animal ID requirements, such as scrapie ear tags and brands, for other USDA and state animal health programs. As a result, producers have generally been discouraged from investing in new ID devices for NAIS, according to industry groups we interviewed. • USDA has not established a robust process for selecting, standardizing, and testing ID and tracking technologies. While international programs have generally used specific animal ID devices for their national animal ID programs, USDA has taken a "technology-neutral" position to allow market forces to determine what devices are most effective and practical. In addition, industry groups, experts, and others told us that electronic ID technologies do not always perform well in production environments, such as livestock markets, and that the agency has not independently tested any ID or tracking devices. Consequently, producers, livestock markets, and others are reluctant to invest in new ID or tracking devices for NAIS, according to industry groups and the experts. • USDA does not clearly define the time frame for rapid animal disease traceback. The definition of "rapid traceback" may vary by disease because some diseases spread more quickly than others, but by not clearly
Page 5 GAO-07-592 National Animal Identification System
defining a rapid response for a given disease, there could be a slower response and greater economic losses. A senior USDA official told us the agency first needs to identify current baselines for traceback before the agency can determine time-sensitive traceback goals for NAIS. • USDA does not require potentially critical information—such as the species, date of birth, or approximate age of animals—to be recorded in NAIS animal ID and tracking databases. This information can be critical for efficient traceback because it helps limit the scope of an investigation, thus saving time and potentially minimizing the economic impact. USDA officials told us that although animal-specific data can be valuable, the agency is collecting the minimum amount of information needed due to some producers' concerns about protection of their proprietary information in NAIS databases. USDA awarded 169 NAIS cooperative agreements totaling $35 million to 49 states, 29 tribes, and 2 territories from fiscal years 2004 through 2006 to help identify effective approaches to register premises and identify and track animals. To date, USDA has not consistently monitored cooperative agreements, and, as a result, the agency cannot be assured that the agreements' intended outcomes have been achieved. In addition, USDA has not formally evaluated or consistently shared the results of cooperative agreements with state departments of agriculture, industry groups, and other NAIS stakeholders, which would enable lessons learned and best practices to inform the program's progress. USDA officials told us the quality of reports submitted to the agency varies, and USDA has had insufficient resources to conduct additional oversight. In fiscal year 2007, USDA plans to increase oversight of all cooperative agreements awarded that year by assessing progress midyear. Furthermore, USDA plans to give those states with greater numbers of premises registered some flexibility in using cooperative agreement funds to subsidize the purchase of animal tracking equipment for livestock markets. For the first time, in fiscal year 2007, USDA also plans to award $6 million in cooperative agreements to nonprofit industry and other groups to increase premises registration efforts. Although USDA began to implement NAIS in 2004, no comprehensive cost estimate or cost-benefit analysis for the implementation and maintenance of NAIS currently exists. As a result, it is not known how much is required in federal, state, and industry resources to achieve rapid and effective traceback or whether the potential benefits of the program outweigh the costs. Twenty-nine of the 32 expert panel members said that USDA should definitely or probably publish a cost-benefit analysis for NAIS. The NAIS
Page 6 GAO-07-592 National Animal Identification System
working groups, other livestock industry representatives, and state animal health officials we interviewed also said that the cost of implementing NAIS remained one of their biggest concerns. USDA officials plan to hire a contractor to conduct a cost-benefit analysis, in part, to more precisely forecast the program's economic effects. Moreover, the Senate Committee on Appropriations and the House of Representatives have raised concerns over how USDA has spent funds to develop and implement NAIS. Finally, the experts had mixed views on the impact that NAIS would have on the livestock industry, such as whether NAIS may lead to changes in market structure or affect prices. To ensure that USDA continues to take steps to address unresolved issues, we are making several recommendations aimed at improving USDA's efforts to implement NAIS more effectively and efficiently. For example, we are recommending that USDA reestablish participation benchmarks to gauge progress in registering premises and identifying and tracking animals; monitor participation; and, if participation does not meet the benchmarks, take further action, such as making participation mandatory or creating incentives to achieve those levels of participation. In addition, we are recommending that USDA establish a robust process to select, standardize, and independently test and evaluate the performance of animal ID and tracking devices to ensure they meet minimum standards. We are also recommending that USDA increase the monitoring of NAIS cooperative agreements, evaluate and publish the results of cooperative agreements on a timely basis, and publish the planned analysis of the costs and benefits of NAIS following criteria established in Office of Management and Budget (OMB) guidance. In commenting on a draft of this report, USDA stated that it appreciated our comprehensive evaluation of NAIS and generally agreed with our recommendations. However, regarding our recommendation that USDA establish a robust process to select, standardize, and independently test and evaluate the performance of animal ID and tracking devices to ensure they meet minimum standards, USDA believed that these standards must be defined through a consensus of affected stakeholders and that working with stakeholders to resolve this issue is imperative before selecting specific technologies for NAIS. We recognize the need for USDA to work with stakeholders before determining which ID and tracking devices are most appropriate for NAIS. However, we emphasize that the sooner USDA selects specific technologies, the sooner the animal ID and tracking components of the program will be implemented effectively and efficiently. See the "Agency Comments and Our Evaluation" section and Page 7 GAO-07-592 National Animal Identification System
The concept of animal ID is not new, in the United States or abroad. For decades, American producers have kept records on, and used ID methods for, livestock animals for both commercial and regulatory purposes. Specifically, several USDA and state animal disease eradication programs—such as programs for tuberculosis (TB) in cattle, pseudorabies in swine, and scrapie in sheep and goats—include animal ID requirements. Certain species and classes of animals require officially recognized ID devices for interstate commerce, and all live animals imported into, or exported from, the United States require official ID. Thus, many livestock animals are already identified in the United States by ear tags, branding, tattoos, or other devices. However, the use of ID devices varies by breed, species, and state, and, until NAIS, no attempt had been made to create a uniform animal ID system of national scope and across multiple species using a universal numbering system and central data repository. Due to serious concerns about the United States' ability to safeguard its livestock from the harmful effects of disease, in 2002, the National Institute of Animal Agriculture—an organization of producers, veterinarians, scientists, government representatives, and allied industries—initiated a state-USDA-industry task force of approximately 70 representatives to create a national animal ID system. In 2003, USDA expanded upon this work and established a development team consisting of more than 70 industry associations, organizations, and government agencies. That team ultimately produced the United States Animal Identification Plan in December 2003, which provided the foundation for NAIS. Although early versions of the plan focused on food animals only, other livestock species were later incorporated. The plan was being finalized when the nation's first case of BSE was confirmed on December 25, 2003. Five days later, the Secretary of Agriculture announced measures to guard against BSE and indicated that USDA would expedite the implementation of a national animal ID system. Since 2004, USDA has solicited public comments on draft NAIS policy documents, held public listening sessions, and met with industry groups and others in its efforts to design and implement NAIS. In addition, USDA has received input from 10 working groups comprising producers, academics, and others representing the various livestock species and industry sectors currently included in NAIS. These working groups make recommendations to the NAIS Subcommittee, a group of state and Background
Page 8 GAO-07-592 National Animal Identification System
SNIP...
Key NAIS Implementation Issues Are Unresolved and Could Undermine the Program's Goal of Rapid and Effective Traceback
USDA has steadily increased the number of livestock premises registered in the nation and has taken some steps to address stakeholder concerns in implementing NAIS. However, the agency has not effectively addressed a number of key issues identified by livestock industry groups, market operators, state animal health officials, and others that, if not ultimately resolved, could undermine the program's goal of rapid and effective traceback, thus hindering its success. USDA's decision to implement NAIS as a voluntary program without benchmarks to measure progress may affect the agency's ability to attract the necessary levels of participation to quickly and efficiently locate all animals potentially exposed to a disease. In addition, USDA has not prioritized the implementation of NAIS by species or other criteria. Furthermore, USDA has not developed a plan for integrating NAIS with other USDA and state animal ID requirements, nor has it established a robust process for selecting, standardizing, and testing ID and tracking technologies. The agency also does not clearly define the time frame for rapid traceback. Finally, USDA does not require potentially critical information for efficient traceback to be recorded in NAIS databases.
SNIP... see full text 90 pages ;
http://www.gao.gov/new.items/d07592.pdf
Section 2. Testing Protocols and Quality Assurance Controls
In November 2004, USDA announced that its rapid screening test, Bio-Rad Enzyme Linked Immunosorbent Assay (ELISA), produced an inconclusive BSE test result as part of its enhanced BSE surveillance program. The ELISA rapid screening test performed at a BSE contract laboratory produced three high positive reactive results.40 As required,41 the contract laboratory forwarded the inconclusive sample to the APHIS National Veterinary Services Laboratories (NVSL) for confirmatory testing. NVSL repeated the ELISA testing and again produced three high positive reactive results.42 In accordance with its established protocol, NVSL ran its confirmatory test, an immunohistochemistry (IHC) test, which was interpreted as negative for BSE. In addition, NVSL performed a histological43 examination of the tissue and did not detect lesions44 consistent with BSE.
Faced with conflicting results, NVSL scientists recommended additional testing to resolve the discrepancy but APHIS headquarters officials concluded no further testing was necessary because testing protocols were followed. In our discussions with APHIS officials, they justified their decision not to do additional testing because the IHC is internationally recognized as the "gold standard." Also, they believed that conducting additional tests would undermine confidence in USDA's established testing protocols.
http://www.usda.gov/oig/webdocs/50601-10-KC.pdf
NOW, post December 2003 MAD COW BSE CASE IN WASHINGTON, and post TWO atypical H-BSE BASE cases, one in Alabama, and one in Texas, and NOT TO FORGET the other stumbling and staggering mad cow in Texas that was successfully covered up, by sending straight to the render, without any mad cow test at all, what did r-calf say before all this $$$
Dr. Detwiler: I'll play devil's advocate. If the US found a case tomorrow,
what would we ask of the world? I think that's valid to ask. It's valid to
turn the mirror back on yourself.
Dr. Thornsberry: I guarantee you that we would immediately have individual
animal ID and it wouldn't be two years later.
FULL TEXT;
Completely Edited Version
PRION ROUNDTABLE
Accomplished this day, Wednesday, December 11, 2003, Denver, Colorado
The roundtable presentations and discussions
were recorded. A transcript will be made available
to the Academy of Veterinary Consultants, the
American Association of Bovine Practitioners, and
the Colleges of Veterinary Medicine throughout the
United States and Canada. A condensed version
translated for the livestock industry will be made
available to educate livestock producers about
prion related diseases.
http://www.r-calfusa.com/Newsletter/2004January.pdf
WELL, it's almost 2008, and were still waiting. ...TSS
