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RE: APHIS 2020-0022, Use of Radio Frequency Identification Tags as Official Identification in Cattle

Updated: Oct 7, 2020

On behalf of our producer participants and industry partners, U.S. CattleTrace appreciates the opportunity to provide feedback on the future of animal disease traceability in the U.S. cattle industry. U.S. CattleTrace is a national organization focused on the development of a disease traceability infrastructure, and we strongly support the proposed transition to RFID as official identification for interstate cattle movement. One critical factor in a disease traceability infrastructure for beef producers is that the system operates at the speed of commerce. Since our inception in 2018, U.S. CattleTrace has supported the use of RFID technology to achieve that producer priority to ensure a national disease traceability infrastructure does not impede the natural flow of business and we urge USDA to adopt the proposed transition.

While metal tags and brands have historically provided a level of traceability in the cattle industry, they are not a 21st century solution to a challenging issue in a dynamic industry. U.S. CattleTrace identified RFID and emerging technologies as tools to accomplish disease traceability for the following reasons: the ability to trace animal movements through the beef supply chain at the speed of commerce, opportunities to allow for value-added programs and expanded marketing capabilities, and the ability to trace animals from birth to tag retirement when the animal is harvested.

Speed of Commerce

U.S. CattleTrace was established as initiative to bring a solution to the beef cattle industry by the beef cattle industry. Our decisions are based in direct feedback from the very producers putting tags in calves’ ears and installing reader networks within their operations. One of the most frequent and common pieces of producer feedback was the need for a hands-free system that would not disrupt the current speed of commerce required for day-to-day operations within auction markets, feedyards and cattle harvest and beef processing facilities. Low-frequency RFID technology has established a place for identification purposes within the cattle industry. However, the emergence of ultra-high frequency (UHF) technology and its capabilities has allowed segments of the supply chain to collect data without disruption to daily operations. For example, a Northwestern ranch manager has found success with UHF read rates, consistently achieving a 99 percent read rate on over 4,000 head of cattle.

In addition to allowing for the collection of movement data at the speed of commerce, the implementation of RFID could allow for a more rapid return to normal operations in the case of an animal disease outbreak. In the current U.S. CattleTrace model, the Kansas Animal Health Commissioner, as a partner in the original CattleTrace pilot project, demonstrated the ability to conduct more timely traces as compared to paper-based investigations. Further, producers whose cattle are not affected, and can ruled out based on movement data in the U.S. CattleTrace database, could resume normal operations with significantly less disruption.

Value-Added Opportunities

After distributing over 77,000 UHF tags to producers in Kansas through the pilot project and through newly formed relationships with innovators across the country, U.S. CattleTrace has witnessed producers utilize UHF technology to not only assist in building an animal disease traceability infrastructure, but also streamline their daily operations. A Kansas ranching family has utilized the UHF tags they received in the pilot project to track inventory on their livestock for the Sandhills Calving System. This is but one example of an innovative producer using RFID technology for multiple purposes. U.S. CattleTrace sees many opportunities to use RFID technology not only to trace movement for disease traceability purposes but to add value throughout the beef supply chain – from inventory management systems to tracking different production practices or marketing claims, and more.

Building a nationally significant disease traceability infrastructure will take all producers and stakeholders in the industry collaborating, and that includes USDA. The agency’s recognition of RFID technology as an official form of identification will allow for disease traceability entities, like U.S. CattleTrace, to more seamlessly collaborate with private value-add enterprises because we can all rely on one tag, one technology, to meet all of our needs.

Birth to Harvest Tracking

Working in tandem with the 2018 USDA goal to “enhance the ability to track animals from birth to slaughter through a system that allows tracking data points to be connected,” RFID, and specifically UHF, technology provides U.S. CattleTrace with the means to collect four unique data points, including GPS coordinates, time, date, and individual I.D. number. These data points allow for contact tracing to occur at points of comingling. The data is kept in a private database, with animal health officials being granted requested information upon approval of a producer-led board in the case of an animal disease outbreak.

U.S. CattleTrace has worked with industry partners to determine optimal placing of the equipment and troubleshoot issues related to UHF equipment, which has resulted in higher accuracy of read rates. These reads are a crucial starting point in building the disease traceability infrastructure. However, if we are going to develop a nationally significant disease traceability system for the U.S. beef cattle industry, we cannot continue exempting cattle under the age of 18 months. Feeder calves move from ranch of origin to a stocker operation, a finishing feedyard and finally to harvest, and stop along the way and transfer ownership at auction facilities. These movements and points of commingling will be paramount in stopping disease spread. We continue to urge USDA to consider a rulemaking to expand official animal disease traceability to all cattle.

U.S. CattleTrace strongly supports USDA’s proposed transition to recognize RFID as a form of official identification, but we also urge USDA to continue pushing forward in the development of Global ISO standards for UHF tags to allow a competitive marketplace for manufacturers to produce official forms of identification for individual producers.

U.S. CattleTrace looks forward to working with APHIS and the USDA to implement RFID technology by January 2023. Thank you for the opportunity to comment.


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