The Goat Working Group is comprised of volunteers representing the major
sectors within the U.S. goat industry and is charged by USDA with developing a
viable plan for permanent identification for goats and addressing other
species-specific components related to the NAIS. USDA requested
direction as to how NAIS could achieve its goals with the opportunity for the
Working Group to offer suggestions on benchmarks that would provide incremental
progress towards the ultimate 48-hour traceback objective. With this
challenge, the Goat Working Group has developed the following comments and
recommendations. This document is a work in progress, and additional
comments will be provided in a future report. The committee is continuing
to work on a number of issues and clarifications.
BACKGROUND
While some species do not have uniform identification methods in place, official
identification of most breeding goats is currently required under the USDA,
National Scrapie Eradication Program (NSEP).
We
believe the basic ID components of this existing program should be utilized as a
framework for at least an interim NAIS ID program for goats.
Efforts to achieve full industry compliance with the Scrapie Program have led to
a greater understanding by producers of the methods used and the infrastructure
needed for animal identification, disease surveillance and traceback.
This
background experience will be valuable as a transition to the implementation of
a plan that more completely and uniformly addresses the goals and methods
outlined in the NAIS documents.
Initially, a combined Sheep and Goat Working Group was established. The
inherent differences between sheep and goats (as well as other species) require
different needs for identification, so the two groups split into individual
working groups, but continue to share information and considerations with the
chairs and several other working group members on both committees. This
also allows for more diverse representation from each industry.
The goat, as a small ruminant species, shares several similarities with the
sheep. However, the differences between these animals include, but are not
limited to, eating habits (sheep graze and goats browse, thus tag retention is a
serious concern); animal interaction with fencing of various types; ear
thickness, texture, and range of ear types; and the broad uses of goats in
general. Goats are utilized for a range of operations, including:
dairy, meat, fiber, companion, packing/hiking, brush control (weed abatement and
fire control), and biotechnology. Also, the large number of goats in very
small herds and the lower value per animal, when compared to other species,
contribute to an economy of scale issue that would create financial burdens if
producers were required to use only electronic devices.
Additionally,
age and source verification does not add value for global trade in the goat
industry. This is primarily because the U.S. does not export any significant
amount of Chevon (goat meat) and thus, in contrast with the beef industry, it
has no financial
incentive for goat producers.
The number of digits to be placed on tags is also a challenge for both sheep and
goats since the tag would need to be small and lightweight, and yet to include
15 digits will make the numbers very small and possibly not legible during many
handling applications, such as movement through market sales. Therefore, it will
be a challenge to establish a single method of tag identification that can be
effective in all applications while meeting the 15 digit standard for NAIS.
Premises ID
Goat owners currently are
already assigned premises ID numbers with the mandatory NSEP (Scrapie) program,
although the definition of a NSEP premise is not consistent with the NAIS
premise definition. Some states have decided to automatically
assign a NAIS Premises ID number to all individuals with an assigned NSEP
premises number. Some producers have received this negatively, and we
believe it has contributed to less participation in NAIS. Since the definition
of “Premises” varies between the NAIS and the NSEP programs, these discrepancies
will need to be addressed and explained to producers. If the Scrapie
program premises number is linked in the database with the new NAIS premises
number, this should facilitate the transition.
While understanding that this is a state-by-state decision, it is our
recommendation that producers be contacted regarding obtaining the new NAIS
number rather than having an automatic assignment. We feel the assignment
of a Premise ID should be only at the express consent or by request from the
premises owner. We ask that USDA provide this recommendation to the individual
states.
Identification Methods/Devices
Goat breeders currently
utilize a range of individual ID methods for management and/or registry
purposes. Each has specific advantages and disadvantages.
Currently, approved metal ear tags, plastic ear tags, RFID tags, electronic
implants and tattoos are all accepted methods of identification for the Scrapie
(NSEP) program. We recommend these options continue to be available for
goat breeders to utilize for the NAIS program. Rumen boluses are a possible ID
method which is currently being tested. Freeze branding is being used on some
goats in the brand state areas.
Ear tags, in general, have been found to be significantly unreliable, as
retention is a major issue reported by breeders. Infection at the site of tag
placement has also been often reported. Application methods seem to
significantly contribute to retention, and this needs to be addressed with
education for producers. Research with RFID devices for goats is underway
in other countries, however only limited research is being conducted in the US.
The technology is widely promoted and may prove to be acceptable as ID programs
move forward, but there has been insufficient testing in goats in a variety of
managements as of this date. Completion of objective trials of RFID
devices and readers for goats must address the wide range of managements and
marketing systems in the U.S. as well as the variety of breeds of goats, which
have a range of coats as well as ear types. We acknowledge that the move
to a more uniform ID program is desirable for efficiency, however the
flexibility of options that can be utilized to accommodate the uniqueness of
goats and the range of uses and managements needs to be in place. For
example, the LaMancha breed of dairy goats has a very small ear that makes it
extremely difficult to utilize ear tags effectively. Currently,
caudal (tail) tattoos are used for ID purposes in this breed (ear tattoos are
used in other dairy breeds, and some meat breeds as well).
When one considers the necessity of shearing fiber goats such as the Angora and Cashmere breeds, fiber removal in the head and neck region increases the possibility of shearers accidentally cutting off ear tags. A combination of design change; additional ID options, as well as educational efforts aimed at reducing this potential problem will be critical to a successful ID program for goats.
Electronic implants (EIDs) are being used in increasing numbers by goat
breeders, and are accepted by several goat registries. Breeders typically
use caudal (tail), auricular (ear) and dorsal thoracic (withers) locations for
implants. The advantages include ease of application, retention, and less
“cosmetic” damage to the animal, particularly those with show breeding stock.
The disadvantages include cost; lack of consistency among manufacturers (thus
requiring different readers); no visual ID component; and lack of a USDA/FSIS
approved site for the implantation. EIDs are favored by many goat owners,
but since there is no USDA approved site for electronic implants in goats, this
area needs attention to address possible food safety concerns. The
auricular (ear) implant site is approved for sheep. We recommend the
caudal area (distal portion of tail – so as not to interfere with tattoo
placements) for electronic implants, when used in goats.
We acknowledge the need for
visual and electronically readable forms of ID as a longer-range
goal. Electronic tags would facilitate accuracy and speed of reading and
recording information in commercial settings, but there hasn't been sufficient
testing to recommend at this time. This, coupled with the expense
per animal in proportion to the value of the animal, means that this should not
be the sole method of ID in goats at this time. In a disease outbreak, it would
be also be desirable to be able to identify necropsied animals if readers aren't
readily available.
We recommend that goat breeders have the option to use all methods of ID currently approved for the NSEP program. This includes these optional forms of identification: any official scrapie tag; or tattoos (legible individual registry tattoos issued by breed associations may also be used as official identification when the animal is accompanied by its registration certificate listing the tattoo); or electronic ID (if the goat breed registry recognizes electronic microchips or RFID tags as an authorized form of ID and the number is recorded on the registration certificate, then electronic ID is acceptable). Owner must also have registration or identity certificate (or a copy of it) or a Certificate of Veterinary Inspection which includes the microchip number that matches the one on the registration/identification certificate. We recommend the caudal area (distal portion of tail – so as not to interfere with tattoo placements) be used for electronic implants. This addresses the need for a consistent implant location and also addresses food safety concerns. All tails could then be condemned at slaughter.
Further, an animal record should contain all reported identification
methods for that animal, and the fields of information should be linked so that
an animal can be easily located based on any identification reported.
We recommend that USDA Cooperative Agreements be made available for specific
research for goat identification addressing a variety of breeds and management
methods, as well as market place environments. Further, the results of any
research should be made available to the Goat Working Group for further
consideration.
We recommend
that RFID reader and scanner manufacturers and suppliers be encouraged to
provide readers and scanners that can read ISO/ANSI 11784/11785 livestock
microchips, and read or at least detect all 125 kHz frequency companion animal
microchips.
We recommend that currently
used microchips be accepted for a period of time to be determined as
appropriate.
Implementation Time Table
Until electronic
identification (RFID or other method) has been fully tested under the range of
managements and environments; other methods of identification currently accepted
with the Scrapie program should continue to be acceptable for goat ID. As
those trials are completed and design changes identified, the transition to a
uniform method consistent with NAIS protocol could then move
forward. Sufficient funds to conduct this research and funds to assist
producers in the purchase of the devices should be made available before the
consideration of any required electronic identification program for goats.
Additionally, many believe that the NAIS program should be more developed (with
ongoing opportunities for feedback) before any steps are taken to have any
portions of the program become mandatory. People are being asked to sign
up for a premises ID without knowing full details and implications of what might
actually be implemented later. Full disclosure of the program and plan
should be available before making any transition from voluntary to mandatory
components.
While we understand the value of having total participation in NAIS, we
recommend that a voluntary program continue until more consideration can be
given to questions raised by many. The most value in the
program will be realized if producers are provided the opportunity to
continue to offer input and help in identifying potential areas for change and
improvement.
We recommend continuation of the current cost-sharing approach as used for the Scrapie program, as the program develops.
Group Lot Identification
Management systems that keep
groups of goats together from birth to slaughter should have the option of using
a Group Lot ID system, when such ID might be necessary. This arrangement
is common particularly in raising kids for the holiday markets that go directly
to slaughter. Another example would be the pasture-to-pasture movement for
herds used in forest management and weed abatement programs. In cases such as
these, each group lot would have a unique identification number that would
include the premises number, date assembled and two additional digits.
Using the option when practical would be a cost savings for breeders.
Individual animals leaving the group would be required to have individual
identification, if triggered by a required event for ID.
We recommend the optional use of a group lot identification program, when
applicable, for goats.
Movement Reporting
Significant numbers and a wide variety of movements occur within goat breeding operations. These can range from travel to the office of a veterinarian or a trip to a local school to a large exhibition involving hundreds of animals being commingled. Requiring movement reporting of all movements would be overwhelming to the goat industry in general, and would not be practical to implement. Since the methods of reporting and even the location of storage of movement information are still undetermined, at this stage it seems reasonable to concentrate only on those movements which would be at highest risk for disease transmission and those movements which are currently already being documented through existing regulatory reporting. This would include a Certificate of Veterinary Inspection or any other inspection or permit process required in moving goats.
We acknowledge that identification information contained in a Certificate of Veterinary Inspection does not actually indicate that an animal moved. In the event of a disease outbreak, however, it would provide information for contacting the premises representative to determine which animals may have actually been moved. The information in the CVI is maintained by the involved states, and would have the necessary information as to the point of origin and destination. By using this existing system, it would not create any undue burden on the owner to provide this information to a separate reporting repository.
Since the National Scrapie Eradication Program (NSEP) has specific requirements
for identification of sheep and goats, those requirements would also help to
meet the needs of tracking movements during a disease outbreak. However,
goats in categories/classes not included in the NSEP program would not be
exempted in the NAIS program.
We recommend utilization of existing methods of collecting and reporting
movement information such as the Certificate of Veterinary Inspections or when
required for current regulatory programs. Only these movements would be
reported until further assessment of NAIS program logistics can be conducted,
and additional comment then offered by species working groups. Any
mandatory reporting would be done by the receiving premise, but ideally the
owner should have an option to report movement on a voluntary basis.
We encourage goat
registries to begin consideration of mechanisms to document movement of goats at
events such as sponsored shows, to assist with providing this information in the
event of a critical disease outbreak.
Work To Date
In an effort to provide information regarding the work of our group and NAIS in
general, we have developed a website (USAnimalID.com). We have
received a large number of comments from goat breeders over the past three
years. There has been objection to the program in general and many
comments strongly oppose the program. Additionally, concerns have been
raised over confidentiality of producer records; practicality of the
implementation process has been questioned; concerns raised about program cost;
lack of details about mechanisms and cost of reporting movements; concerns about
privately held databases, and general objections to any requirement of providing
information to a government entity. With regard to those who have
commented to provide opinions on the type of ID to be accepted for NAIS, there
has been almost unanimous agreement that there needs to be flexibility to allow
the currently used ID methods already accepted in the Scrapie (NSEP) program.
Successful Implementation
1. The implementation of a successful National Animal Identification System program should address and include the following components:
2. A gradual transition to any new identification protocol by using the existing Scrapie program-approved ID methods Continued flexibility of ID methods/devices should be allowed and exploration of new technology as it becomes available.
3. Evaluate a system that would allow existing ID methods to be incorporated into a uniform National ID System. For example, the unique tattoo or electronic implant requirement of a dairy goat registry could be tied to a registration number that conforms to NAIS standards.
4. Adequate research and field trials using a range of goat breeds and management environments.
5. Cost-sharing approach for all involved parties.
6. Recognition that the cost of ID devices/methods for goats can be significant when compared to market value per head, and should not hinder the economic viability of the industry. There is a large number of goats in small herds, and it is important to protect small farm operations from unnecessary burden and cost, while identifying ways to achieve disease surveillance to protect animal agriculture in general.
7. Involvement of industry (including producers, registries, organizations, markets, veterinarians and others ) as the planning process continues, to assure a realistically designed plan and to help ensure industry acceptance and participation.
8. Continued cooperative efforts between the sheep and goat industries that will identify similarities between the plans for each species, while also recognizing the differences that require alternative considerations for each specie.
9. Systems that can be incorporated with existing production/management information would encourage more producer participation.
10. Reasonable record keeping that combines with data electronically obtained and submitted. Protecting of confidentiality of producer information is a priority among producers. Any records requirement should not exceed current program requirements (for example, Scrapie program requires 5 years).
11. A comprehensive educational effort that can offer information and accurate answers for producers, markets, consumers and veterinarians. Training and outreach programs should be available for veterinarians, producers, inspectors, truckers and markets. They need to learn how to recognize signs of foreign animal diseases and to know what follow-up steps would be taken in such a disease outbreak, and more specifics about what the NAIS involves.
12. We believe it is important for individual states to also consider the recommendations of the species working groups should states separately implement programs prior to full implementation of NAIS on a national basis. Further, if there is not uniformity among states, there will continue to be confusion and frustration about animal identification in general.
13.
Adequate funding to provide adequate staffing to handle existing
regulatory programs and port inspections should be ensured. Federal
incentive programs for encouraging new veterinarians would help ensure qualified
employees are available.
We also recommend ongoing communication with our trading partners in North America while also communicating with other global partners to address animal identification in general.
We
also appreciate the clarifications offered in the NAIS
Guide for
Small-Scale or Non-Commercial Producers, which includes the following (in part):
The focus of NAIS is animal health, primarily within the commercial animal
production
sector in which animals move from their birthplace to a subsequent location(s) over the
animal’s life cycle. USDA’s NAIS efforts will largely focus on commercial operations
and animals at such locations due to their higher risk of spreading diseases among
multiple locations and for greater distances.
Animal identification and tracking:
• If animals never leave the farm of birth or are only moved for custom slaughter for
personal consumption, owners will not be asked to identify them or report their movement.
• Animal owners who choose to participate in the animal identification and tracking
components of the NAIS, are not expected to report all animal movements.
• Reportable movements are those that involve a high risk of spreading disease, such as
moving livestock from a farm to an event where a large numbers of animals are brought
together from many sources.
• USDA will only request animal identification data to respond to an animal disease
outbreak or other emerging animal health concern.
• USDA fully recognizes that NAIS must be practical and affordable for all sectors of
agriculture.
The primary purpose of the NAIS is to enable rapid animal tracing and disease
containment in the case of an animal disease outbreak or other emerging animal health
concern among U.S. livestock and poultry. USDA will only request data and combine
information from the databases when animal health officials need information to respond
to such a disease outbreak or emerging animal health concern.
Definition of Non-Commercial Producer
Under the NAIS, the following criteria describe non-commercial producers:
1. Individuals whose animals are not moved to auction barns or from their location to those of commercial producers.
2. Individuals whose animal movements are limited to those moved directly to custom
slaughter; movement within a single producer’s premises; local fairs and local
4-H (and/or other youth organization events).
{
Note:
The GWG believes there needs to be further clarification with regard to
non-commercial producer definitions and determinations as well as fairs and
other exhibitions }.
Guidance for Non-Commercial Animal Identification and Reporting Animal Movements:
Scenarios that would not call for animals to be identified and/or movements reported in the NAIS include:
− animals that never leave the farm/location of birth;
− animals moved from their birth premises directly to custom slaughter for personal use
of the animal’s owner;
− livestock moved from pasture-to-pasture within one’s operation;
− participation in local fairs and parades;
− the local trading of birds among private individuals; and
− animals that “get out” and cross over into the neighbor’s land.
Also, animals used for recreational purposes do not need to be identified if they are permanently cared for at their birth premises. Comprehensive recommendations for identifying animals and reporting movements are in development in cooperation with the species-specific working groups and State-Federal animal health authorities.
The Goat Working Group appreciates the opportunity to contribute to the discussion by operating as a separate Species Working Group. We encourage solicitation of continued input via this committee as well as representation on an Oversight Committee or other body as may be established. We ask for continued opportunity to provide additional comment and recommendations as the program evolves.
Activity |
Goats |
Registration of Premises |
Owner of Premises |
Responsible party for the identification of the animals. |
Owner of animals at current premises (lessee of a leased animal). |
When is the animal to be officially identified? |
When an event
triggers the need for Official ID such as: |
What animals must be identified? |
All classes of goats, when moved from the birth premises under the event triggers as identified herein. |
Events that "trigger" the requirement of official identification? |
1) When
Certificates of Veterinary Inspection or permits are required for
movements. |
ID Method to be used |
All methods currently accepted for the National Scrapie Eradication Program. |
Report of Movements who is responsible? |
Person responsible for the animals at the receiving premises. |
Who reports Interstate Movement? |
Accredited
Veterinarian when Interstate Certificate of Veterinary Inspection is
required. |
Time frame requirements for reporting movements |
As required for any existing regulatory programs. |
NAIS Goat Working Group Members:
Linda S. Campbell,
Chair |
Stan Potratz |
Barry Arnett |
Jeff Ramseyer |
Jan Carlson |
Joe David Ross, DVM |
Charley Christensen |
Joan Dean Rowe, DVM
Producer |
Bennie Cox |
Lisa Shepard |
Bonnie Chandler |
Marvin F. Shurley |
Carolyn Eddy |
Robert Swize |
Rene DeLeeuw |
Cindy Wolf, DVM |
Ray Hoyt |
Linda Worley |
ADVISORS: |
|
Diane L. Sutton |
David L. Morris, DVM,
PhD |
This report is provided by Linda Campbell, Chair of the Goat Working Group. Please read and direct comments to Linda