U.S. States Further Livestock RFID Use Despite USDA Pause

By Claire Swedberg

Although the Animal and Plant Health Inspection Service hit the brakes on RFID cattle-tagging requirements, some states have continued to promote and support the use of LF RFID tags to bring traceability to beef and dairy animals.

Citing the benefits of disease traceability and automated reporting, several beef and dairy cattle farmers, as well as state agriculture departments, are moving forward on the RFID tagging of cows and bison, even as the USDA's Animal and Plant Health Inspection Service (APHIS) has placed a pause on its RFID requirements.

Last year, the federal agency announced that its prior mandate, that all interstate moving cattle come with an RFID tag for the purpose of unique identification, would not be enforced as previously scheduled. That followed an initial timeline that RFID tags would be required for new cattle by January 2021. In 2023, RFID tags would then have had to be attached to the ears of every cow that moved between states.

The official tag being used is the passive LF RFID 840 tag, typically attached to an animal's ear (see USDA APHIS Proceeds With RFID Deployment Timeline). All states still must comply with the USDA's Animal Disease Traceability (ADT) rule, which requires official identification of all cattle. However, it does not require RFID.

The RFID-based cattle-tracking system was conceived two years ago to improve animal traceability. At that time, the USDA held nine listening sessions with members of the livestock industry and veterinarians. The US Animal Health Association and the National Institute for Animal Agriculture recommended the transition to RFID identification in order to create digital records of the lives, health and movements of each cow. The USDA was expected to share the cost of the RFID tags, at 50 cents per tag.

Last April, APHIS posted a factsheet to provide producers with information about the agency's guidelines and goals related to animal disease traceability. Since the factsheet was posted, says Joelle Hayden, USDA spokesperson, "APHIS has listened to the livestock industry's feedback." Additionally, executive orders released in October 2019 (Orders 13891 and 13892) indicated that government agencies could not enforce rules against the public unless those rules were promulgated as "regulations" in compliance with the Administrative Procedure Act (APA).

In light of negative feedback from the cattle industry and current U.S. Executive Branch policy, Hayden says, APHIS believes that it should revisit those guidelines. APHIS removed the RFID-based factsheet from its website, he adds, since it is no longer representative of current agency policy. Several states, however, have indicated that they will continue to promote RFID through a variety of programs.

Washington
In the State of Washington, for instance, RFID enables automated reporting for dairy and beef cattlemen. The technology provides disease traceability, and the Washington State Department of Agriculture (WSDA) is continuing to build up infrastructure to support its use, says Chris McGann, the WSDA's media relations coordinator. "We continue to promote and support the use of official RFID as a great form of disease traceability," he states, and one of the related initiatives is RFID-based Electronic Cattle Transaction Reporting (ECTR), which enables producers to meet their inspection requirement electronically.

The ECTR program was taken live in November 2019 for both dairy and beef cattle producers, while it was used prior to that by dairy farmers only. With ECTR, cattle producers using official LF RFID 840 tags can complete sales transactions or out-of-state transportation without requiring a state inspection. Each official tag uses a 15-digit number starting with 840. The data is captured via an RFID reader, and the details are then stored in the ECTR system.

To support these efforts, the WSDA provides free RFID tags for up to 100 head to producers who sign up for the ECTR system. "We still think there's a lot of value in RFID," McGann says. "That's the direction [in which] the state and the world are going." So even as the USDA delays its own timeline, the state continues to promote and support it.

The ECTR effort is supported by the Washington Cattlemen's Association to enable self-reporting by producers. "That potentially could save a lot of input and overhead costs," says Danny DeFranco, the Washington Cattlemen's Association's executive VP. The LF 840 tag was first used for ECTR reporting by beef and dairy farmers in fall 2019, and the numbers of participants are still being reviewed. "I believe personally that it will be used more and more every year," DeFranco states.

Some Washington dairy farmers have already been using RFID tags internally, but those may not be the official 840 tags. DeFranco, who owns a beef cattle ranch, says he tags his own calves, steers and heifers even though there is no requirement that he do so. While some producers oppose an RFID mandate, he adds, others "see it as an opportunity to cut some costs and maybe open a potential for more marketing opportunities worldwide." He notes that countries in Asia and elsewhere often require the kind of digital history for cattle that RFID would provide.

"Over time, I will use the tags as a management tool," DeFranco says. "Right now, I'm using it as a technology with a potential to provide greater value [to beef products]." Because the ECTR program launched recently, the association and the WSDA expect to review and observe results, and to then make changes based on those results. "We're setting the table to start out," he states. "I would assume we will be modifying the program as we go along. It will be a living, breathing thing."

Kentucky
In the meantime, cattle in Kentucky are also being tagged with RFID to uniquely identify animals, according to Bradley Keough, Kentucky's deputy state veterinarian. Many Kentucky cattlemen elect to purchase and apply RFID, he says, while the Kentucky Department of Agriculture (KDA) provides LF RFID tags and applies them to cattle in several stockyards that have elected to work in cooperation with the agency.

Although the USDA has paused the federal mandate, Keough says, adding, "Currently, the only change to our plans here in Kentucky is that we will continue to provide metal ear tags this year." The original transition timeline discontinued that process on Jan. 1, 2020. The KDA plans to continue working with its livestock markets to boost the application of tags and reader infrastructure in order to read and electronically report RFID numbers.

In 2017, the KDA initiated its own RFID program to increase the use and electronic reporting of RFID tags with cattle. KDA also developed its own electronic reporting form that imports RFID read data. Several of the livestock markets with which the agency worked in the early stages of this program now use the application and reporting system on their own, Keough reports. "KDA will continue to expand our partnership with additional livestock markets," he states, "to ensure our cattle industry is prepared for the inevitable transition to RFID as required official identification. "

The RFID data that the KDA can collect, Keough says, is stored in the agency's database and is not openly shared unless ordered by a court. "Data housed in the KDA database remains confidential," he explains, "and can only be shared with other official agencies to prevent or respond to livestock disease."

The KDA is also working with a Kansas Cattle Trace project to research the use of UHF RFID in feeder cattle. The KDA leverages USDA funding to purchase and install UHF reader equipment, while also providing UHF RFID tags to participating livestock markets. "Although this class of cattle do not require official identification," Keough says, "data on the efficacy of UHF as a technology to allow data collection at the speed of commerce is essential for future decisions the USDA may make."

Kentucky currently has one livestock market participating in the project, and the state is actively seeking another. "KDA's objective is to support our livestock markets with infrastructure and technology," Keough says, "to ensure our producer's cattle can move interstate at the speed of commerce."

Texas
The Texas Animal Health Commission (TAHC) reports a 42 percent increase in the number of premises that registered to use RFID during 2019, says Andy Schwartz, the TAHC's executive director and state veterinarian. In order to use RFID, he explains, a producer must have a premises or location ID number. "We currently have a total of 33,399 premises ID numbers issued in Texas," he states, adding, "We are seeing an increase in producers and veterinarians choosing to use RFID when individual animal identification is required, or when desired for management reasons."

The agency is currently in the process of supporting private veterinarians to get set up to use RFID. As part of this effort, the TAHC is providing Texas veterinarians who conduct regulatory work with an incentive to sign up as RFID tag allocators, by offering up to 100 free RFID tags. The TAHC is also conducting RFID pilot projects with cattle industry groups.

That state-level effort continues despite delays on the federal level, Schwartz says. "We are waiting for the USDA to make an announcement," he notes, "but we are also being proactive and looking ahead." The TAHC sees an inevitable transition to electronic identification, he adds, that has only been postponed. "We also encourage the use of electronic certificates of veterinary inspection. Electronic identification devices can be quickly scanned and the number accurately and legibly recorded on these certificates."

In the meantime, the USDA is still reviewing its path going forward. In a public statement, the agency stated that its animal disease traceability goals have not changed. "While the need to advance a robust joint federal-state-industry animal disease traceability capability remains an important USDA-APHIS objective, we will take the time to reconsider the path forward and then make a new proposal, with ample opportunity for all stakeholders to comment."

The USDA continues to recommend the use of RFID to provide a digital record of each animal, based on financial gains related to better visibility into each animal's health, condition and history. "We continue to believe that RFID devices will provide the cattle industry with the best protection against the rapid spread of animal diseases, as well as meet the growing expectations of foreign and domestic buyers," the agency stated.