Copied with permission from another site..

NAIS & Poultry: Good Intentions Gone Awry

The National Animal Identification System (“NAIS’) was first promulgated in response to Mad Cow disease. The NAIS has been broadened from its original intent – to safeguard the food supply – to a system designed to register every type of livestock animal in the United States, and to register every farm under GPS coordinates and a federal identification system. The NAIS in its current form should be stricken because it is void for lack of statutory authority, it represents an unwarranted intrusion into the privacy and property rights of Americans, and because its negative effect will outweigh its apparent value. With regard to poultry, consider the following:

1. Its application to all livestock is an unduly burdensome system that will create an appearance of government management of diseases (i.e., avian influenza)
· Without improving on current disease control methods
· Without materially protecting the United States population

2. Its application of a system designed to control diseases in cows, to poultry owned by hobbyists and small farmers will create an economic burden that will result in the end of:
· standard bred poultry shows
· encouragement of future breeders of poultry
· breeding, and preserving, heritage breeds of poultry
· loss of diverse poultry gene pools

3. The NAIS will cause the loss of substantial business in the poultry, feed, animal equipment, and hatchery industries.
· It involves the hatcheries, breeders, shippers, Post Office, airlines, feed stores, manufacturers of hatching, housing, feeding and watering equipment, feed, bedding, and construction materials for barns and other housing.

4. The NAIS will be fraught with inequities, and the opportunity for selective, discriminatory enforcement, due to
· Lack of exceptions for small farms, hobbyists, 4H and FFA youth, and recreational owners of livestock
· Inherent unmanageability of proposed database system
o 160,500,000 datapoints on bird movements each year; no industry to run the database for small farmers and poultry owners
· Exceptions for people exempt based on religious grounds.
· Large number of people who won’t know how or won’t be able to register

5. Unwarranted destruction (“depopulation”) of poultry flocks
· Death of breeds of birds due to misapplication of blanket testing procedures on birds unable to withstand current testing methods
· Lack of capacity or timeliness in disease testing system

6. Poultry owners take AI seriously, but tagging every bird in the country won’t keep AI from reaching our human population
· Other outbreaks (END and AI) in the past have been controlled without registering every farm or tagging individual animals


NAIS Executive Summary

Regulations and legislation are working through governmental bodies in an attempt to create and launch a National Animal Identification System (NAIS). Regardless of technicalities, such as no enabling legislation, NAIS is an ill-conceived, unworkable system designed to imbue the American public with a false sense of security regarding efforts to block or monitor transmission of animal diseases into human populations.

NAIS envisions a system that tracks all potential vectors (carriers) of high-visibility illnesses such as “mad cow” disease and avian influenza, a.k.a “bird flu.” Species covered by NAIS would include, but not be limited to: cattle, sheep, swine, goats, chickens, geese, ducks, horses, llamas, alpacas, bison and others.

The NAIS system would require a central registry of all domestic livestock, on an individual basis, as well the ability to track the movements of each animal to and between various premises, such as hatcheries, farms, animal auctions, country fairs, pure-bred animal shows and retail markets, including pet and feed stores or grocery stores, butchers, etc.

NAIS is troublesome on multiple levels. At its most onerous, it is a flagrant violation of Constitutional rights. It imposes cost-prohibitive restrictions on farmers, producers and hobbyists involved with any form of covered livestock. More, NAIS would mandate creation of a system the size and scope of which is unimaginable. Record keeping efforts and administrative support/enforcement would dwarf all activities of the IRS, INS and Social Security systems, combined.

The bottom line is that NAIS is a feel-good, happy-talk solution to a real problem that requires real solutions, not a smoke screen designed to mollify the public and lull Americans into a false sense of security.

Areas of Concern

· NAIS relies on “industry” support and participation, including funding of the registry. There is no such thing as a centralized “livestock industry” or even a coalition of industry groups. The Federal government has no intention of funding such efforts.

· Terms such as “livestock,” “disease” and “premises” are not defined by NAIS.

· No system of enforcement or oversight is suggested except for local veterinarians being required to report observed movement of animals they suspect are not registered with NAIS.

· Standard testing protocols are not established, largely because “disease” is not defined.

· The most likely source of outbreaks for diseases such as avian influenza are infected birds (including imported livestock and migratory waterfowl) or humans traveling to or entering the Americas from “hot spots” such as S.E. Asia. NAIS does nothing to address these issues.

Attempts to monitor and control domestic movement of livestock are not only impractical, but do not get to the heart of the problem.

The problem – and therefore, the solution – lies in monitoring and controlling points of entry for pathogens that or may move beyond restricted geographic areas or particular species. Animal quarantines, bans on importation of at-risk animals and foodstuffs and limits on travel are more practical and more effective means of preventing the introduction and spread of potentially harmful pathogens. Specific tracking programs, if appropriate at all, should be species and disease specific.