Impact of NAIS on Horse Owners

The equine community has been divided over the issue of the National Animal Identification System (NAIS). While many have argued that we need to stop NAIS, others have believed that horses would be exempted. Any hope for an exemption, however, has been laid to rest by the USDA’s latest document, the Business Plan for NAIS, released in late December 2007. The Plan states that horses are in “Tier 1” as a “targeted species” for implementing NAIS.

See open letter to American Horse Council — February 20, 2008

Which horses will be included in NAIS? Earlier announcements from USDA indicated that only “competition horses” would be in Tier 1 of the Business Plan to implement NAIS. But the actual Plan states: “Horses that, when moved, require either a test for Equine Infectious Anemia or a health certificate, are also included in Tier 1.” (USDA Business Plan to Advance Animal Disease Traceability, Dec. 12, 2007, p.2) In Texas and many other states, a Coggins test for Equine Infectious Anemia is required annually if the horse is sold, participates in any “assembly”, including parades, rodeos, shows, and trail rides, or is even stabled within 200 yards of someone else’s horse. So just about every horse in many states fits squarely within the USDA’s definition of Tier 1 animals for implementing NAIS.

And the USDA plans to try to expand the number of horses caught under NAIS:

“Efforts are underway to develop a USDA national State-Federal cooperative program for the control of EIA that would establish national EIA (Coggins) testing requirements for (a) interstate movement and (b) change of ownership. … Overall, establishing regulations to require premises registration in association with Coggins testing would substantively increase the number of both premises registered and horses identified. … Though impossible to quantify nationally, experience has shown that the number of Coggins tests performed annually increased three-fold following implementation of a ‘change-of-ownership’ testing requirement in Texas.” (Plan, p.26-27)

In other words, the USDA plans to increase the number of horses who must be tested for Coggins. These plans are not based on any scientific evidence that increased testing is needed for health reasons, but are simply a back-door method for forcing NAIS on more horse owners!

How will NAIS be put into place for horses? The Business Plan sets out two strategies for horses to be placd in NAIS: (1) breed registries and (2) equine service organizations.

USDA has set a goal of having 90% of horses that are moved or sold individually identified by January 2009. (Plan p.55) The key step towards that goal is the “implementation of the 840 AIN RFID technology by all industry organizations that provide services to horse owners/breeders.” (Plan, p.55 & p.27). To translate the jargon: “840 AIN” means a 15-digit internationally unique identification number, and RFID means a Radio Frequency Identification Device. In other words, each horse would have to be implanted with a specific type of microchip in its neck. Among other things, this shows that brands and other non-electronic forms of identification will not be considered sufficient under NAIS.

Plans to use breed registries? The USDA’s Business Plan includes a strategy for “harmonizing” NAIS with existing systems that already use individual identification. Harmonization involves changing the existing programs so they use the NAIS-compliant Animal Identification Numbers (AIN’s). (Business Plan, pp.28-29). As part of its harmonization strategy, USDA proposes having breed registries begin using AINs. (Plan, p.55). The AIN is a 15-digit internationally unique identification number. It starts with “840” which identifies the animal as coming from the US. (Plan, p.30). And in order to get an AIN under NAIS, you have to register your property (“premises registration” in NAIS terminology). So if breed registries were to require NAIS-AIN’s, this would effectively force their members to comply with the first two stages of NAIS in one fell swoop.

“Breed registry and performance recording programs present a significant opportunity to advance traceability if current identification approaches adopt the common data standards proposed in this plan.” (Plan, p.28). The Business Plan then includes the following statement in a table of planned actions and target dates: “initiate use of AIN in breed registry programs,” with an “action target date” of March 2008. (Business Plan, p.55).

Why would a breed registry agree? Some may be led by people who believe NAIS is good for animal husbandry and the economy, because they haven’t asked the hard questions about what the program will and will not do in reality. More likely, however, one investigative reporter hit it on the head when he remarked, “The only organizations I find in favor of NAIS are going to make money off it!” What kind of money is at stake? A lot! For example, the American Angus Association was awarded a $500,000 contract to promote NAIS. Like all of the 2008 Cooperative Agreements, the receiving organization has to meet certain performance goals, to get all the funding promised. One might guess that the breed organizations who start requiring AIN’s are doing it for the money. Another money trail leads to companies that run the databases that manage animal identification and tracking systems. Several non-profit associations have for-profit subsidiaries or related businesses that stand to make a hefty profit on NAIS by running those databases.

Who gets to decide whether a breed registry will require NAIS? Will it be a decision by the “leadership”? Will the leadership of the organization be influenced by the prospect of a federal grant? Or the potential for making money on managing the databases? What will be the basis for their decision? Or will the members be educated on both sides of the issue and allowed to vote? To our knowledge, only one equine organization has ever presented its membership with both sides of the issue and asked for a membership vote on what position it should take. That vote was unanimously against NAIS.

“CONA [Carriage Operators of North America] members oppose a mandatory National Animal Identification System (NAIS). Additionally CONA members oppose any mandatory or voluntary movement tracking of all equine species other than the current system of veterinarian certificates and coggins tests.”

Will this really happen? The interesting thing is that the USDA’s Business Plan does not seem to reflect the current reality. Although the Plan calls for breed registries to implement use of the AINs in March 2008 – in other words, now – so far no registry is admitting to requiring AINs. This seems true for cattle, sheep, goat, and horse registries. It appears that USDA may have been trying to make NAIS look easier to implement than it really is. After all, if USDA can make NAIS seem inevitable, then it can discourage people from opposing the program and convince Congress to keep funding it.

But before we assume that we are safe from having the registries implementing NAIS, we need to look closer. Several registries, while stating that they do not plan to require NAIS AIN’s in 2008, have left the door wide open to requiring it in the future. For example, the one association’s statement specifically lists 2010 as a possible date for a mandatory NAIS for horses in general, referencing the Equine Species Working Group’s recommendations, while other associations have made vague references to “giving members plenty of warning” if they develop plans to implement NAIS.

Several of the associations that have been contacted have touted the alleged benefits of NAIS, regurgitating the government’s claims. But just like the government, the industry groups have no response when asked to provide scientific evidence for the alleged benefits. Their willingness to repeat the government’s propaganda is a cause for concern. Will these associations simply change their minds in return for government benefits – in the form of dollars or tax breaks — in a few months or a couple of years?

The Equine Species Working Group (ESWG). The ESWG can submit recommendations to the USDA about how NAIS should or should not apply to horses, but the USDA is totally free to ignore any and all of the recommendations. As a concrete example, according to the ESWG website, “the ESWG has recommended that official identification is necessary when a horse is transported to any premises where a Certificate of Veterinary Inspection (CVI), Brand Inspection, VS-127 permit, or International CVI is required.” Yet the USDA’s most recent document states that “Horses that, when moved, require either a test for Equine Infectious Anemia or a health certificate, are also included in Tier 1.” Since a Coggins test for Equine Infectious Anemia is required in many situations where a health certificate is not needed, the USDA has apparently decided to reject the ESWG’s recommendation.

The ESWG website contains a prominent link for “benefits” of NAIS, although no hard facts or scientific evidence are offered at that website to support how NAIS will be better than existing disease control programs. No discussion is included of the costs of NAIS to individual horse owners, the equine industry, and taxpayers. AHC and ESWG do not mention the cost of microchipping, the associated equipment, the time spent complying with the program, the loss of privacy, or the recent report that microchipping may increase the risk of cancer in horses. They simply promote NAIS.

What Can You Do?

• Educate your community by downloading materials from our Take Action or Media Centers and putting them out at local riding stables, feed stores, sales barns, horse shows, etc.

• Contact your U.S. Representatives and Senators, telling them that Congress needs to explicitly limit USDA’s authority and to stop funding NAIS through our federal tax dollars. You can find out who your elected officials are by going to www.house.gov or www.senate.gov, or by calling the Capitol Switchboard at 202-224-3121.

• Contact your breed registry and any other equine association that you belong to. Tell them that you do not want them to be a tool for implementing the government’s plan for NAIS! If they plan to force their members into NAIS, then consider finding another association to meet your needs.