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Article
RFID Searches for a Home on the Range

While the use of RFID to track livestock is fertile ground for humor, the story in this arena plays out all the issues inherent in any large scale Business Process Improvement (BPI) project but colored by stakeholders who are fiercely independent and complicated by whether market forces or governmental regulation will drive implementation.


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When I first proposed writing an article on the uses of RFID technology in the livestock industry, my colleagues immediately had great fun with punish titles and jokes that the subject matter naturally evokes. The idea of applying high tech devices to the age old agrarian industry elicited comments about how ranchers would no doubt be steering clear of cow chips, suggestions that the collaboration of high tech and agriculture might best be termed as Hiagro, or questions about whether RFID would have enough brand appeal.

But once the laughter subsides, and one explores why the USDA and agribusiness is even considering employing RFID technology on a larger scale, a sobering discussion ensues. Most of us are now familiar with Mad Cow disease (Bovine Spongiform Encelopathy or BSE), but have you also heard of Foot and Mouth Disease, Scrapies (BSE for goats and sheep) or West Nile Virus (fatal to horses)? Considering that livestock products increasingly arrive at our tables via more complex, even global distribution systems, then one understands that these scary sounding pathologies now provide increasingly potential threats to the food we eat. Add the fears of terrorist activities focused on our livestock distribution networks, and the argument grows for improved containment mechanisms should a threat be detected. Still laughing?

The RFID story in this arena plays out all the issues inherent in any large scale Business Process Improvement (BPI) project but colored by stakeholders who are fiercely independent and complicated by whether market forces or governmental regulation will drive implementation. As the livestock industry and the USDA face off, can this be a modern day version of High Noon?

A Brief History of Animal Identification

“Trust your neighbor but brand your cattle anyway.”

As Humans began to domesticate livestock, they quickly discovered the need to identify their animals and distinguish them from their neighbors. Livestock represented wealth, and confusion about ownership could quickly escalate to violent disputes. Originally, low tech means such as the “Earmark” (uniquely notching or decorating the animals’ ears, but now another term for a congressional pork-barrel project) were used on smaller livestock, and the use of branding for larger livestock dates back 4000 years. In the 1940s, with the government coordinated efforts to control Brucellosis, vaccination ear-tags along with ear tattoos became widely employed in the cattle industry.

By the 1970s, the horse industry began to employ subcutaneously implanted microchips (implanted under the skin or in the muscle of the horse’s neck area) which were implemented primarily as a more fool-proof and covert means to identify high-dollar race horses and breeding stock. Today, some international racing associations make this a requirement for new born foals. During this period, the cattle industry also began to use the microchip technique with high value registered breeding stock. The key points to remember about this early application of technology are that it was not widespread and was targeted as a means to uniquely identify animals but not to track their movement.

Why Apply RFID to Livestock?

With the discovery of Mad Cow Disease in the UK in the 1980s and later, the first occurrence in the US in 2003, the USDA determined that they needed an improved system to uniquely identify cattle and their sources, and to track their movement throughout the distribution chain as a way to more effectively and quickly contain potential outbreaks of disease if an infected animal is detected. After concerted US industry discussions in 2002, the National Animal Identification System was born. The key components of the system were: 1) Premises Identification; 2) Animal Identification; and 3) Animal Tracking. 

Noble guiding principles for the NAIS were also established which stated that the system should have uniform data standards but be flexible to allow for integration with existing corollary systems, be inclusive of all livestock industries, be a cooperative government and industry joint partnership, and finally protect the confidentiality of the data. The tactical goal of the NAIS would be to provide the capability of a “48 hour traceback” of an animal if they are detected as being infected with a “Foreign Animal Disease (FAD)”.

In April, 2004, Agriculture Secretary Ann Veneman announced a framework for implementing the NAIS. During this same period, the USDA established Species Working Groups to develop methods and guidelines for implementing the NAIS within the various livestock industries. The USDA has stated clearly that they do not believe that “one size fits all” in terms of the specific processes and technologies that work best within a specific livestock group. Furthermore, the government agency says that they are technology neutral as to the final industry solutions. So in terms of approach and principles, the USDA seems to be putting forth some reasonable assertions in providing standards and process requirements without trying to define the solutions.

Finally, the Cattle Species Working Group is the only group to date to agree on a proposed technology to implement the NAIS. They have chosen ear tags with embedded RFID chips that are readable for up to 30 inches. The practical part of this solution is that the tags could also be imprinted with the animal identification number for visual reading without any RFID device which will obviate the need for cattle raisers to necessarily have RFID reading devices.

 

 

Current Status of NAIS Activities:

Premise Identification: USDA standards for a 7 digit premise identification number were released, and all states were capable of beginning to register premises as of 2005. As of March, 2006, about 12% of premises were registered on a national basis. In Texas, attempts to begin registering premises on a voluntary basis were put on hold until 2007 after strong objections by small ranch and farm owners.

Animal Identification Number (AIN) :  In March, 2006, the USDA published standards for a 15 digit animal identification number, detailed performance standards for the ear tags, and delineated responsibilities of the ear tag manufacturers and ear tag “managers” in the distribution network. They also began allocating AINs to tag manufacturers. The initial release of the AINs focuses on the cattle industry.

Data Management Architecture: The USDA published a conceptual document in 2004 describing a multi-tiered architecture of IT applications with a single portal providing access to the metadata (i.e. data about data) layers for maintaining Premise and Animal Id. Numbers and for tracking the movement of animals. The concept envisioned using a combination of state and industry applications with the federal government providing architectural standards and serving as the overall system architect. The design of the Animal Trace Processing System (ATPS) will be conducted throughout 2006 in conjunction with cooperative governmental and industry organizations with a targeted implementation date of early 2007. Finally, Agriculture Secretary Mike Johanns confirmed one key design principle in 2005 by stating that all animal tracking data will be maintained in state or industry databases with the USDA having ready access to the necessary data.

Implementation Strategies: In April, 2006, the USDA published a document entitled “Strategies for the Implementation of NAIS”. Part of the content of the paper detailed the major implementation milestones which are summarized in the graphic below.

Free Market Incentives vs. Government Regulation

Ranchers and farmers are by nature fiercely independent and generally wary of government regulations. While many if not most of the commercial livestock breeders understand the need to combat serious threats of foreign disease infestation, the main issues can be distilled down to two concerns: 1) Cost - what is it and who will bear it; and 2) Privacy – what data will be stored by whom and who will have access to it. Will there be added liability to livestock producers?

The most vocal opposition to date has come from small livestock owners who are not commercial breeders and do not want to be saddled with a government regulation that requires them to register their 20 acres, one cow, and record when they sell one calf at auction. While they may be small-time agrarians, they represent a significant number of livestock owners and can be quite vocal. One commentator that I read went so far as to say it “threatens the traditional freedoms of the rural way of life.” In Texas, it was this contingent of the livestock owners who caused the state to delay implementation of premise identification for at least one year.

The industry associations have generally been caught in the middle of their constituency and the government. While recognizing the need to provide containment controls and protect their marketplace, they also are generally resistant to governmental mandates and prefer voluntary programs. The larger associations have mostly aligned around a voluntary approach, cajoling their membership to follow along while actively lobbying to influence any proposed legislation or regulations.

Of course, on the sidelines of this great shoot-out sit the manufacturers of animal RFID equipment (Digital Angel, EZ-ID/AVID ID Systems, Micro Beef Technologies) just salivating at the chance to provide RFID ear tags for the approximately 97 million beef cattle in the US or even just the 32 million that are annually harvested. Talk about market potential!

Which brings us to an important point, the USDA has allowed the implementation of the NAIS to remain voluntary during the design and initial implementation phases. Their approach has been that they want the livestock industry and marketplace to provide incentives to stimulate compliance to acceptable levels. They have argued for other benefits to this system for the producers beyond just disease containment (ex. improved id. security, inventory mgt., etc.), but not with great success. Based on their milestone objectives, they will monitor whether this is occurring at a sufficient rate to achieve full participation by 2009. Essentially, the USDA position inherently posits that the NAIS will be mandatory, and the question remains whether the marketplace will drive it or governmental regulation. In July, 2006, the USDA will publish a proposed “rule” on what their final approach will be. Stay tuned.

Cost vs. Benefit???

Astute project management dictates that during the initial phases of chartering any large project, one performs a cost benefit analysis to determine the payback or ROI. When this approach is applied to human health concerns, it generates some controversy, since how can you value a human life? But for discussion sake, let’s review the numbers anyway.

So what are the costs of implementing the NAIS system or even more specifically, just implementing an RFID based tag system for the cattle industry. The USDA readily admits that no one knows! While the USDA allocated a little over $50 million of its own budget in 2004 and 2005 on the program, they argue that the costs of the system cannot be estimated since the design is not complete. 

The other counter arguments to implementation are that the US has already invoked countermeasures that altered cattle feeding and slaughter practices and which at least reduced the probability of BSE entering the food chain. Thus, many in the cattle industry believe that the problem is already contained without implementing further tracking requirements.

Ok, so let’s discuss the benefit side of the equation. This issue of containing an incidence of deadly disease in the cattle distribution system seems to be a classic quality control issue. As a manufacturing professional, if I put on my Statistical Process Control (SPC) hat and do a quick calculation, the US had one incident of BSE in 2003 and one in 2005, and in both years roughly 32 million cattle were harvested (note that neither of the cattle entered into the food chain). Doing the math yields an incidence rate of considerably less than the 3 defects per million necessary to achieve Six Sigma quality. The USDA testing plan works out to about a 1.1% sampling plan which is not out of line considering their incidence rate. All is well! Right?

The answer is absolutely no, if you consider that the marketplace of beef eaters doesn’t understand one iota about SPC and doesn’t care to know. All it would require is for one case of a BSE infected cow to enter the food chain or for one human case of BSE to develop in the US, and the potential harm to the beef market is incalculable. What a great story line for a TV disaster movie to match ABC’s recently released “Fatal Contact:  

At any rate, what is the Cost/Benefit of implementing the RFID tracking in the beef industry? No one seems to know. For a best guess, perhaps, just flip a cow chip (the real kind!).

Conclusion:

For those of us versed in formal project management, let’s do a little analysis on the prospects of implementing the NAIS in the cattle industry by 2009.  First, we have a project without strong sponsorship or even just singular leadership. Second, we can’t do a valid Cost/Benefit analysis as both elements are really unknown. Third, one of the primary stakeholder groups, the cattle producers, represents an independent and contrary bunch whose participation is voluntary at this point and to whom the benefits of this program are suspect, all the while knowing that it will cost them something. Finally, the project timeline is tentative (even the USDA suggests that the schedule will likely slip). Other than that, the NAIS implementation seems to be as solid a new born cow chip.

Keep your eyes on the horizon as the USDA announces their rule (mandatory vs. voluntary) in July, 2006. This could prove one of the more interesting if not humorous applications of RFID technologies and will certainly require some creative yet persistent implementation strategies to succeed. Of course, some unexpected increase in incidences of BSE could change all that faster than you can say RFID.

Many thanks to my colleagues, Carla Reed and Laura Faught, for providing the title of this article and more humorous one-liners than I could possibly use.




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