NAIS and Horses – A Timeline of the Inclusion of Horses in NAIS 2002 through 2006

By Karen Nowak

Copyright 2007 by Karen Nowak.  The following article may be distributed solely for personal and non-commercial use without prior permission from the author, as long as proper credit is given.  Any other distribution or republication requires the author's permission in writing.  Requests for such permission should be directed to the author at the address/phone/e-mail address below.

Karen Nowak

PO Box 260

Brookfield, NY 13314

315-899-7778

KNowak5170@aol.com

The issue of national equine ID has been discussed between animal health officials since at least 1987 but did NOT involve any organization representing the actual horse owning public until 2002.  The purpose of this lengthy article is to provide a reference document for the evolution of the plan to include equines in the National Animal Identification System.  A “timeline of events” from 2002 through 2006.  The inclusion of numerous quotes from actual organizational and government documents is quite deliberate.  Those of us who oppose this plan are frequently accused of spreading “misinformation” by the groups who have developed and promote the NAIS.  This document allows their own words and actions speak for themselves!

A committee of representatives from the American Association of Equine Practitioners (AAEP) Infectious Diseases Subcommittee on ID, the United States Animal Health Association (USAHA) Equine Infectious Diseases Committee and USAHA Livestock ID Committee plus the National Institute of Animal Agriculture (NIAA) Livestock ID Committee planned an Equine ID Symposium to be held sometime between the already scheduled 1994 and 1998 NIAA ID Symposium.  No record has been found that an Equine ID Symposium was actually held during that time frame.

At the Livestock Conservation, Inc (later reorganized as the NIAA) National Farm Animal Identification Symposium in 1998, 3 species groups were created to species-specific issues and needs.  These groups were cattle, swine and “other species” (sheep, goats, horses and llamas).  The members of these species groups are not identified, however, not a single equine organization is quoted in any of the LCI documents from that symposium.

Reading the membership of the NIAA is like reading a “Who’s Who” of corporate agribusiness, animal health officials, animal ID and software tracking companies.  There is very little representation of the small farmer.

2002

In early 2002, Dr. Timothy Cordes from the United States Dept of Agriculture (USDA), Veterinary Services Division, announced that an Equine ID Symposium was scheduled for July 2002.  To their credit, upon hearing this announcement, the American Horse Council (AHC) decided the Horse Industry MUST be involved in this symposium.  It is unclear who and how many of the equine related and breed organizations were notified of this pending symposium, but an attempt was made to have representatives of at least some of these organizations present. 

Position statements regarding their stance on a national Equine ID Program were made by the following people/organizations at this symposium:

Amy Mann – American Horse Council

Dr. Tom Lenz – American Association of Equine Practitioners

Dr. Cheryll Frank – USA Equestrian (now known as the US Equestrian Federation)

Ward Stutz – American Quarter Horse Association

Buddy Bishop and Rick Bailey – The Jockey Club

Bob Luehrman – United States Trotting Association

Jim Garrison – Arabian Horse Registry of America

Lili Thomas – BLM Wild Horse & Burro Program

Dr. Mary Giddens – Dutch Warmblood Studbook in North America
Jim Kelley - American Paint Horse Association
Tom Pettry – American Saddlebred Horse Association
Paul Berube and Jim Gowen - Thoroughbred Racing Protective Bureau

Transcripts of all of the above presentations EXCEPT for the American Paint Horse Association and the Thoroughbred Racing Protective Bureau were obtained. 

The following four people/organizations communicated a clear pro-National Equine ID Program stance:

Dr. Tom Lenz – American Association of Equine Practitioners

Ward Stutz – American Quarter Horse Association

Lili Thomas – BLM Wild Horse & Burro Program

Dr. Mary Giddens – Dutch Warmblood Studbook in North America

Amy Mann of the American Horse Council communicated a technically neutral stance, however, within a few short months the AHC’s pro-NAIS stance became quite clear.

The main objective for the two day Equine ID Symposium was to have participants consider an identification system that (a) would not endorse a specific modality, but (b) would provide for unique and permanent alpha-numeric (computer-compatible) identification for each horse/mule/donkey in the USA.

The objectives of the second day were for participants to share their views about a potential national equine ID system, focusing on the positive aspects of such a system, the issues to resolve and how to proceed when this session is over.

The positive aspects identified were:

1) Traceability of horses to allow owners, breed registries and government to track the movements of horses in cases of theft or loss, genetics and performance, and disease tracking respectively. 

2) Trade enhancement to help assure trading partners of genetics, performance and health. 

3) Integrity of Information to help prevent fraud and help in recovery of animals in cases of theft and natural disasters.

4) Accurate Census to help with national census of animals by breed, location, etc.

A total of 48 issues were identified that would need to be resolved with respect to a national Equine ID Program.  Aside from the obvious issues of cost, database control, confidentiality and incentives for horse owners/organizations was a clear intent that a campaign would need to be undertaken to educate the horse owning public about the program and that a feasibility study should be done.  As I read through the twelve page summary of the results of the discussion by the actual equine organization representatives, I realized they were right on track. 

What happened if they were so on track?
 At the end of the symposium, Glenn Slack, then President and CEO of the NIAA, asked the Equine Industry representatives the following question:  “Is Equine ID something that needs to be discussed beyond this meeting today?”  Seven of the twelve participants voted yes and five voted no.

Three key decisions were made by the NIAA at the end of this symposium:

1.  It was decided that the NIAA would establish a study group (to include representatives of industry organizations, the veterinary profession, government and other interested groups) to determine a direction for a national equine identification system

2. The NIAA would report on this issue at the USAHA, AAEP meetings (and other meetings as needed) and will be responsible for championing the study group mentioned above.  A report-out will be given at the USAHA meeting in October, but no concrete recommendations/action steps will be presented at that time.

3. Concrete recommendations/action steps to be given at the next national NIAA meeting in April 2003.

A follow up conference call by the Equine ID Symposium Planning Committee was held in September 2002.  It was decided that a Study Group be established and that J Amelita Facchiano chair that Study Group.  It is important to note that Ms Facchiano was not a representative of any official equine organization or breed registry.  She was well known as an advocate of Equine ID for the prevention of horse theft.  In addition, she was the Director of Sales and Marketing for GlobalVetLink, LLC, the corporation who developed electronic certificates for veterinary inspection and whose employer was a corporate member of the NIAA.

The USAHA annual meeting was held in October 2002.  There is NO mention in the proceedings that the NIAA reported on the July 2002 Equine ID Symposium as had been previously decided.  The National Identification Work Plan was presented, which did NOT include horses.

 In November 2002, the NIAA established the Equine ID Subcommittee as part of the existing Animal ID and Information Systems Committee.  Amy Mann of the AHC was appointed chair and J Amelita Facchiano, co-chair. 

Members of the first official NIAA Equine ID Subcommittee were as follows:

Chair:  Amy W. Mann, American Horse Council

Vice Chair:  J. Amelita Facchiano, GlobalVetLink, LLC

Committee Members:

Coffman, Leroy, Florida Department of Agriculture

Fischer, Glenn, Allflex USA

Fourdraine, Robert, Holstein Association USA

Goldberg, Marty, RMS Research Management Systems, USA, Inc.

Halstead, Steve, Michigan Department of Agriculture

Hammerschmidt, Neil, Wisconsin Livestock ID Consortium

Hwang, Kathleen, EZ-ID/ AVID ID Systems

Jordan, Karen, Dairy Farmers of America

Kelley, Jim, American Paint Horse Association

Marsh, Gary, CowTek, Inc.

Marsh, Stu, Farnam Companies

Mortensen, Ky, American Association of Equine Practitioners

Neale, Spencer, Virginia Farm Bureau Federation

Niedecken, Tim, eMerge Interactive

Notter, Don, Kentucky Department of Agriculture

Owen, Kevin, Digital Angel & Electronic ID

Wade, John, AVID Equine ID

It is disheartening to read that a full 50% of the committee members represented companies who sell animal ID and/or tracking software while only ONE equine breed registry and only ONE equine association were represented.  Of the remaining seven members, two represented the dairy industry (who already participates in an ID program) and the remaining five members were animal health officials, who clearly indicated a desire for a national Equine ID program.  The question that begs an answer is: “Was this initial effort spearheaded by those who stood to gain financially if such a system were put in place?” Clearly the needs and concerns of the equine industry as a whole were not fairly represented by this committee!

2003

The confusion continues in an AHC Press Release from January 22, 2003 titled “Equine Identification”.  It states “The issue of a national horse identification system has been discussed in various corners of the horse industry for years, but it wasn’t until the American Horse Council’s 2002 convention that the issue made its way to the industry’s national attention.”  

“Its sudden rise to importance resulted from a distinct change in the direction of the discussion over equine ID.  These discussions had moved away from a focus on monitoring the options available for identifying horses, such as use of lip tattoos, freeze branding, or electronic ID chips, to one of emphasizing the need for a national identification system using electronic chips and a national alpha-numeric system.  Supporters of a national identification system maintain that it would benefit the industry making it possible to trace where horses had been in case of a disease outbreak, to prevent horse theft, to help in emergency situations and benefit international trade.”

The most revealing statement of the progression of the inclusion of horses in NAIS may be found in the next paragraph of the AHC press release:

“The horse industry as a whole had never been asked to consider the merit of establishing a national alpha-numeric identification system for horses.  Yet, at a symposium on equine identification systems, held in July, 2002, there was a clear message that a national ID system for horses was being pushed, and pushed hard, at the industry.  It became quite clear at the July meeting that the industry organizations held a strong sentiment that adequate input is needed to determine if a need for such a national system exists.  The industry also insisted that any discussion steer clear of endorsing any specific modality for identification.”

“A focus group of industry representatives was formed as a result of the July symposium.  This group met in January, 2003 with the purpose of looking at whether the potential benefits of a national identification system outweighed the costs and difficulty of instituting one.  That meeting reiterated the feeling in the industry that there is a need for more specific information as to why a national identification system for horses would benefit the industry.”

The first version of the United States Animal Identification Plan, released in November 2002, the same month that the NIAA Equine ID Subcommittee was officially formed, did NOT include horses.  However, version 4.0 of the plan, dated September 29, 2003 DID include horses.  Version 4.0 was presented and approved by the USAHA at their annual meeting, held October 9-16, 2003.

While version 4.0 does not use the word “mandatory, the inference that this is the intent may be drawn from their own timeline:

·          all states have a premises identification system in place by July, 2004; unique, individual or group/lot numbers be available for issuance by February, 2004;

·          all cattle, swine, and small ruminants possess individual or group/lot identification for interstate movement by July, 2005;

·          all animals of the remaining species/industries identified above be in similar compliance by July, 2006.

A review of the minutes from the many organizational meetings during this time frame confirms this.  In every discussion, the theme that a voluntary program is “doomed to fail” is repeated.

An October 2003 Press Release from the AHC titled “National Identification System for Horses Debated at AHC Meeting”, states that “Speakers from the U.S. Department of Agriculture (USDA) and equine organizations continued the discussion at the recent AHC Annual Meeting in Washington, DC.  While no consensus on the need for a national ID system for horses was reached, it was apparent that there is an interest in the industry's continuing to explore the pros-and-cons of such a system.” 

The mystery is who was interested in continuing to explore this and what was their rationale?

Dr. Valerie Ragan, Assistant Deputy Administrator, Veterinary Services, U.S. Department of Agriculture (USDA), is quoted as stating “plans are progressing rapidly at this point in the other livestock sectors.  The focus is "on cattle and swine at the present time because those species are at the highest risks for disease situations.  We are not developing an equine identification system, we are not even there yet,” Yet, further on in her presentation she noted that there are plans "to expand into other sectors, like equine and aquaculture.  Nothing is mandatory at this stage.  We must have a system in place that is tried, and tested and proven and there is a reason for it before it might be made mandatory," she concluded.  "We will be developing this and we encourage you to look at this effort and decide if you want to join in.  We are happy to work with you if you do."

Jim Gowen of the Thoroughbred Racing Protective Bureau (TRPB) summed it up best.  The following is a direct quote from the AHC October 2003 Press Release:

"‘I will take the opposing view on national ID,’ said Gowen.  He noted that the TRPB has participated in conferences and discussions regarding this broad area for over a year and has heard from some federal and state officials that the system is supported by ‘the horse industry.’  The term has been used regularly by supporters, ‘but too loosely given the breadth of those involved in the industry, the different types and uses of horses.  Who is calling for and promoting this idea?  It seems to us that at this point it is being pushed by an ad hoc group of individuals with equine business interests who can hardly be called representatives of the industry’, he suggested.

‘In short, we see no compelling reason for a national ID system for horses.  We see no reason to expend further energies on this issue.  But we realize that others have a different view.  For this reason, we believe that any continuing discussions should be within the horse industry itself.  Once this is done, a clearer picture may emerge as to how important National ID actually is,’ Gowen concluded.”

A second press release was issued by the American Horse Council on the same date titled “AHC to Organize Task Force on National ID System for Horses”.  It states “Although there was no consensus reached on the need for a national ID system, there was agreement that the AHC should organize an Equine Identification Task Force to continue to inform, involve and educate the industry about the issues surrounding the potential of a national identification system for horses with the goal of arriving at some consensus.”

“Other livestock groups have been debating the issues surrounding a national identification system for their animals for over ten years and have reached a general consensus that a system is needed.  These other sectors are considering the implementation of a universal system that would be alpha-numeric, permanent, unique, and in addition to and integrated with existing systems already being used.  But the value of any such system to the horse industry, which has different needs and different challenges, has not been fully explored.  That will be one of the purposes of the ID Task Force.”

The following organizations were members of the AHC Equine ID Task Force, created in October 2003:

American Association of Equine Practitioners

American Endurance Ride Conference

American Miniature Horse Association

American Paint Horse Association

American Quarter Horse Association

American Saddlebred Horse Association

Arabian Horse Association

Back Country Horsemen of America

California Thoroughbred Breeders Association

Harness Tracks of America

Kentucky Thoroughbred Association

Mersant International Ltd.(commercial horse transporter, sponsors horse races)

NA/KWPN - Dutch Warmblood Studbook in North America

National Cutting Horse Association

National Reining Horse Association

National Thoroughbred Racing Association

Palomino Horse Breeders of America

Professional Rodeo Cowboys Association

Tennessee Walking Horse Breeders' & Exhibitors' Association

The Jockey Club

National Horsemen’s Benevolence & Protective Association (racing industry)

Thoroughbred Owners & Breeders Association

Thoroughbred Racing Protective Bureau

US Trotting Association

US Equestrian Federation

Western Stock Show Association

Of interest, while all these meetings and discussions were taking place, nothing was published on the AHC website until December 6, 2003.  It is highly possible that this was quite deliberate, to keep it under the radar from the NIAA.  Last, it is not clear if this information was actually submitted for publication in any horse related publications.

Both of the above quoted press releases were dated October 2003 but it is unclear who they were released to.  They were not published on the AHC website until February 9, 2004.

2004

The AHC Equine ID Task Force met on January 16, 2004 in Los Angeles and again on March 18, 2004 in Dallas Texas.  Four subcommittees were designated:  Horse ID & Technology, Premises ID, Movement & Tracking and Communications.  The AHC Equine ID Task Force evolved into the USAIP Equine Species Work Group in early 2004.

In 2004, twenty-four representatives of horse organizations met with then Secretary of Agriculture Ann Veneman.

The results of that meeting were published on May 4, 2004 in an AHC memorandum to “AHC Industry Members”.

The portion of this memo pertaining to NAIS is reprinted below (I have bolded portions of the text for emphasis):

“Two dozen horse industry leaders met with Department of Agriculture Secretary Ann Veneman in her office during the National Issues Forum of the American Horse Council.  The meeting lasted 45 minutes and Secretary Veneman was very interested, engaged and generous with her time.  USDA Under Secretary Bill Hawks, Deputy Under Secretary Floyd Gaibler, and Chief of Staff Dale Moore were also present. The meeting provided the industry representatives with an opportunity to explain to the Secretary and her staff the economic importance of the horse industry; how we are participating in the Department’s initiative to develop a national identification system for livestock; our efforts to make horses eligible for federal disaster assistance; and the importance of the USDA’s upcoming meetings with our European Union trading partners.   

National Animal Identification and the Horse Industry 

Several members of the AHC Task Force on Equine Identification were present and updated the Secretary on the involvement of the horse industry in the Department’s efforts to institute a national ID system for livestock in case of a disease outbreak.

   
Dan Fick, of The Jockey Club and chair of the Task Force, explained that the horse industry had held several meetings and saw benefits to a national identification system involving the horse industry.  He noted that there were still many critical issues to be considered and resolved.

   
Dr. Jim Morehead, of the American Association of Equine Practitioners and chair of the Premises ID Subcommittee of the Task Force, explained that one of the many difficult issues to be fleshed out was the definition of a “premises” for the horse industry.  He explained that under the proposed ID system a “premises” for the horse industry could be quite different from that for other livestock groups.  Dr. Morehead noted that there could be many more locations involved and that the Subcommittee was trying to define such locations and identify the potential responsibilities of any “premises manager” under a national identification system.  

Ward Stutz, of the American Quarter Horse Association and chair of the Tracking/Movement Subcommittee, explained that horses move more frequently than other animals and often individually, thus making the task of tracking their movement difficult. 

Recommendation #14: New technologies should be pursued and researched to provide more efficient, cost effective and accurate methods of equine identification, i.e., Biometrics, DNA Testing, etc.

Recommendation #15: To ensure that the horse owners and industry stakeholders do not unduly bear the costs of the development and implementation of a national equine identification program, the USDA should provide adequate funding in 2005-2006 for cooperative agreements with states and tribes that include equine field trials recommended by the ESWG, and adequate funding in 2006-2007 for assistance to begin implementation of the National Equine Identification Program.

Recommendation #16: The ESWG should be allowed to contract with a consortium of horse industry stakeholders to design, develop and maintain an independent equine industry database for equine data/information necessary to provide horse identification, traceability and trace-back capabilities for the NAIS.

2005

On May 6, 2005 the USDA published the NAIS Draft Strategic Plan and Draft Program Standards in the Federal Register.  Now the intent for a mandatory system is clear:

Key milestones:

• July 2005: All States capable of premises registration.

• July 2005: Animal Identification Number system operational.

• April 2007: Premises registration and animal identification “alerts”.

• January 2008: Premises registration and animal identification required.

• January 2009: Reporting of defined animal movements required; entire program mandatory.

On May 25, 2005, the ESWG submitted their second set of recommendations to the USDA regarding horses in the NAIS.

They were identical to the December 2004 recommendations EXCEPT recommendation 13 was changed as follows:

“Recommendation #13:  Whenever appropriate, equine identification systems currently in use should be incorporated into the national equine identification program, especially radio frequency identification devices (RFID), normally microchips. Existing microchips should be incorporated into the NAIS for equines.

From this date forward, the ISO/ANSI compatible RFID chip (11784/85, 134.2 kHz) is the recommended standard of electronic equine identification for the purpose of disease control for the uniformity and compatibility necessary to successfully achieve the goals of the USDA National Animal Identification System.

The recommended implantation site for the microchip is the nuchal ligament on the left side, in the middle third of the neck, halfway between the ears and the withers.

Suppliers of RFID readers and scanners should make an immediate effort to provide readers and scanners for distribution to the U.S. animal identification industry to read the ISO 11784/17785 livestock microchips, and read or at least detect all 125 kHz frequency companion animal microchips.”

AND a 17^th recommendation was added:

“Recommendation #17: The buyer and seller shall mutually be responsible to report any change of ownership of an equine to the appropriate equine registries and other databases recording the identification of equines.”

It is important to note that microchips CURRENTLY used in the US for Equine ID are the 125kHz frequency, NOT the frequency now recommended by the ESWG.

In July of 2005 the AHC listed the new members of the ESWG on their website:

Mr. Alan Balch American Saddlebred Horse Association  
Dr. Marvin Beeman, co-chair ESWG, Vet & horseman, past President of AAEP, also on the Board of the AHC but is not listed as representing them.
Mr. Remi Bellocq The National H.B.P.A., Inc. (National Horsemen’s Benevolence & Protective Association - racing)  
Mr. Doug Burge California Thoroughbred Breeders Assn.  
Ms. Cindy Chilton Palomino Horse Breeders of America  
Dr. Tim Cordes USDA/APHIS/VS  
Mr. Paul Estok Harness Tracks of America  
J.Amelita Facchiano USDA/APHIS/VS/CEAH 
Mr. Dan Fick, co-chair ESWG, The Jockey Club  
L. B. Fleming, DVM American Endurance Ride Conference  
Mr. Alan Foreman Thoroughbred Horsemen’s Associations, Inc. (deals with racing commissions for states) 
Ms. Debbie Fuentes Arabian Horse Association  
Dr. Pete Gibbs Texas A&M University

Dr. Mary Giddens NA/KWPN    
Mr. Jim Gowen Thoroughbred Racing Protective Bureau  
Dr. Nancy Halpern New Jersey Dept. of Agriculture 
Dr. Steven Halstead Michigan Department of Agriculture 
Mr. Neil Hammerschmidt USDA/APHIS/VS 
Dr. James Heird Colorado State University  
Ms. Peggy Hendershot National Thoroughbred Racing Association  
Mr. James Hickey American Horse Council 
Mr. Alan Hill Back Country Horsemen of America  
Mr. Jeff Hooper National Cutting Horse Association  
Mr. Charles Hulsey Tennessee Walking Horse Breeders’ & Exhibitors’ Association

Ms. Bonnie B. Jenkins U. S. Equestrian Team  
Dr. Albert Kane USDA/APHIS/VS 

Mr. Jim Kelley  American Paint Horse Association    
Dr. Maxwell Lea, Jr. Louisiana State Veterinarian 
Mr. Bob Luehrman U. S. Trotting Association  
Ms. Amy Mann, co-chair ESWG, American Horse Council 
Mr. C. J. Marcello, Jr. Paso Fino Horse Association  
Mr. Dan Metzger Thoroughbred Owners & Breeders Association  
Dr. Jim Morehead American Association of Equine Practitioners

Ms. Lori Rawls U. S. Equestrian Team
Mr. Joe Santarelli Mersant International Ltd. (sponsors races, transports horses) 
Ms. Cindy Schonholtz American Youth Horse Council  

Dr. Billy Smith American Quarter Horse Association  
Dr. Bob Stout Kentucky Department of Agriculture  
Mr. Ward Stutz American Quarter Horse Association  
Mr. David Switzer Kentucky Thoroughbred Association  
Mr. Dan Wall National Reining Horse Association    
Ms. Christine White Michigan Office of Racing Commissioner

Notice the heavy representation of the racing industry?  I certainly did!  My question, since this group was first formed, was why the heavy representation of the racing industry?  The AHC’s own statistics prove they are NOT the majority of the horse owners in this country.  The American Horse Council’s “The Economic Impact of the Equine Industry” documents an equine census of 9.2 million horses.  Of these horses, 9% are used for racing, 29% for showing, 42% for recreation and 19% for other (ranching, commercial use, etc).  Their rationale cannot be economic either.  Their own study documents that in terms of jobs and contribution to the Gross Domestic Product (GDP), racing accounts for 26%, showing 28%, recreation 31% and other 14%.  Separating out the number of jobs in the equine industry does not support this unequal representation.  Racing contributes to 27% of the jobs, while showing contributes 27%, recreation 31% and other 15%. It is clear that the largest group of horse owners have essentially NO representation whatsoever.

In addition, another important segment of our society of horse owners have been totally ignored – the people who practice “plain faiths” (e.g.: the Amish).  The Amish sect has members living in 20 states in the USA.  Horses are a vital part of their everyday life for transportation, farming, etc.  NAIS is a clear violation of their constitutional right of freedom of religion under the first amendment.  The economic burden on this group would be enormous.  That such a large group of individuals, for whom NAIS would threaten their very way of life, is a disgrace!

So why the heavy representation of the racing industry?  Part of the answer may be found in reviewing the legislative issues the American Horse Council was involved with at the time.  The advent of internet and off shore gambling was taking a toll on the horse racing industry.  The AHC was lobbying hard for legislation that would protect and benefit the US racing industry. 

The other part of the answer may be found in reviewing the composition of the AHC itself.  Seventy-one percent of the AHC Board of Directors have direct ties to the racing industry.  Sixty-eight, or 42%, of the organizations who are members of the AHC directly represent the racing industry. 

While unfair to the rest of the horse owning public, it is easy to see why the AHC appointed such a heavy representation of the racing industry.  While smaller in number in terms of ownership of horses, they invest millions of dollars into the horses they do own.  Not unlike the composition of the other species working groups!

On July 25, 2005 the ESWG submitted their comments to the Federal Register during the open comment period for the NAIS Draft Strategic Plan and Draft Program Standards.  Their specific comments are reproduced below as I believe it is vital that the horse owning public actually read the ESWG response (I have bolded portions of the text for emphasis):

“The ESWG supports the general principles set forth by USDA. 

We would like to emphasize that a very important concern to the horse industry is the confidentiality of any data collected pursuant to a national animal ID system and the access to such data.  The confidentiality, protection and safety of such data is critical to the industry and a fundamental basis for any support of a national animal ID system.  Data collected should only be made available when there is a disease emergency and information on movement is necessary to trace the animals affected, or potentially affected, by a disease outbreak.  Without confidence that any data collected is secure, and accessible only to individuals who need it under limited circumstances, the industry cannot support a national animal ID system.

USDA sets out in the ANPR several key objectives for a national identification system.  The ESWG supports each of these objectives, with the following additional comments.  According to USDA, such a system should:

1.                               Allow producers the flexibility to use current systems or adopt new ones.

There are various forms of identification used in the horse industry now, including tattoos, brands, DNA, blood-typing, micro-chipping and others.  All are valid and all must be available for use.  But at some point in the future, standards may be recommended by a particular species and as animals come into the system they can be identified with then-existing technology creating a system that will evolve into a standard system naturally.

2.                               Be technology neutral so that existing technologies and new ones can be utilized.

3.                               Build upon national data standards to ensure that a uniform and compatible system evolves. 

There may be some confusion regarding what USDA means by “technology neutral.”  We suggest that USDA specifically clarify what it means and intends by this concept.  If it means that USDA will propose uniform national data standards for identification, that service providers and the industry can work toward, we can support that principle.  But any system must allow the technology a species requires and be flexible enough so that new processes may be developed. 

4.                               Allow producers to be able to use it with systems that respond to market incentives.

Any national ID system should respond to the specific and individual needs of the species involved.  There is no “one-size-fits-all” system. 

5.                               Not unduly increase the role and size of the federal government.

We support the concept that the national animal ID system should not unduly increase the role and size of the federal government.  But it seems likely that any new federal system will eventually require federal funding and additional employees.  Since this program is intended to protect American agriculture from diseases, some potentially spread by those intending to disrupt the U.S. industry, federal funds will have to be appropriated for the effort.  Since disease control is of national import and under the supervision of the federal government, the major portion of any funding should be provided by the federal government as part of the federal budget.  While there may be some cost-sharing required, if this program proves more expensive than the benefits it provides to the horse industry that will make it even more difficult to institute.

Specific Comments Sought

In the ANPR, USDA invites comment on questions about the NAIS:

1.                               When and under what circumstances should the program transition from voluntary to mandatory?

This is a very difficult question to answer at this time.  With so many questions outstanding regarding the national animal ID system, it is almost speculative to predict when a program should transition from a voluntary to a mandated system.  Nonetheless, making any animal ID system mandatory should only be considered after confidentiality is ensured, a consensus on the national standards formed, and technology and procedures tested, implemented and found successful.  Making a system mandatory for any species before that species can comply with it will cause irreparable harm to this effort.

Even when a system is in place and working, we suggest that the there be a transition period from voluntary to mandatory and that any requirements be phased-in for different livestock sectors as proposed by species working groups, including the ESWG. 

1.                               What species should be covered, both initially and in the longer term?  Specifically, should the initial emphasis be on cattle or also cover other species?  If so, which?  Which species should be covered by the program when it is fully implemented?  What priority should be given to including different species?

All species subject to USDA oversight should eventually be covered by a national animal ID system, including horses.  But the initial focus should be on food animals.  Because of the scope of the required system, other animals, such as horses and animals that come into contact with and can pose a disease threat to food animals, can be included in the longer-term as the system proves workable.  The application of the system to each species should be pursuant to a timetable laid out by the various species working groups.

The Equine Species Working Group appreciates the opportunity to provide these comments to the USDA and looks forward to working with the Department in this important effort to protect American agriculture from diseases and their effects.  If you have any questions, please contact us.”

The above letter is signed “Dan Fick, Marvin Beeman DVM, Amy Mann, Co-Chairs – ESWG and included a list of the members of the ESWG.

It is worth noting that 100 comments were received by the Federal Register regarding the initial NAIS documents but not ONE equine breed registry or association commented.  How can this be given the mandatory deadline in these documents?  Could it be because the ONLY place information was published was on the AHC website?  How many members of the horse owning public are members of the AHC?  How many are aware of the importance of regularly checking the Federal Register for documents that might pertain to horse ownership?  How many have access to the internet?  Surely the AHC was aware of these issues!  In fact, I found one ONE comment from a person who solely owns and works with horses:

Comment in the Federal Register, docket ID APHIS-2005-0044, Document ID APHIS-2005-0044-0563 from Steve Kirk, Horse trainer for Volante Farms, LLC in NY:

“I firmly believe that this proposal poses an unnecessary financial burden on the owners of show and race horses which will never be introduced into the human food chain.  The implantation of a micro-chip in every horse is not well thought out in respect to the costs to the owners, estimated by Amy Mann to be around $150; The burden on Veterinarians for recording the details of every implantation and the associated costs to track the movements.”

On August 28, 2005 the American Horse Council published a “white paper” titled “The NAIS and Horses: Why Horses Should be Included”. 

“The National Animal Identification System (NAIS) is a tool developed to ensure the health of the national livestock herds by facilitating the traceback and traceforward of animals associated with a significant disease outbreak. Often, when the topic of the NAIS is raised a familiar refrain is heard: “why are horses included?  They don’t carry diseases that affect

humans or other livestock.” This paper is intended to examine that question and determine whether its accuracy.

Although rarely experienced in the U.S., horses are in fact susceptible to numerous diseases that can also affect

people.  In most cases, horses do not play a role in spreading these diseases to humans. Lyme disease is an example of a disease that affects horses and humans but horses do not give Lyme disease to humans. In some cases, horses serve as sentinels for human disease surveillance. For example, West Nile Fever and Eastern and Western Equine Encephalomyelitis are diseases that frequently appear in horses before cases are seen in humans.  However, horses can also contract infectious diseases that they can pass on or transmit to humans. Examples of zoonotic diseases of horses include Rabies, Salmonella, Ringworm, Leptospirosis, Brucellosis, and Anthrax.

The following is a listing of some of the zoonotic diseases that horses can share with humans and other livestock species. In addition, there are several diseases that are common to horses and to other livestock species as well as to humans, which are considered multispecies diseases.”

Their statements for each disease are “bulleted”.  My comments are below each individual disease in italics:

·    Anthrax - Anthrax is an acute infectious disease caused by the spore-forming bacterium Bacillus anthracis. Anthrax most commonly occurs in wild and domestic lower vertebrates (cattle, sheep, goats, horses, camels, antelopes, and other herbivores), but it can also be transmitted to humans exposed to infected animals or tissues from infected animals.”

Between 1950 – 2001 there were a total of 48 cases in humans in the USA: 9 inhalational anthrax (all occupational involving handling of goat hair).  39 cutaneous anthrax (all but 2 cases were occupational.  12 involved handling goat hair, 1 wool, rest handled carcasses of infected animals - 7 of those animals were identified as cattle, other 2 cases type of animal not specified). 
In other countries humans have become infected with gastrointestinal anthrax by eating undercooked meat from infected animals.  I found NO cases of horse to human spread of Anthrax.

·    Borna Disease - Borna disease (BD), first described more than 200 years ago in southern Germany as a fatal neurologic disease of horses and sheep, owes its name to the town of Borna in Saxony, Germany, where a large number of horses died during an epidemic in 1885.  Infection results in movement and behavioral disturbances akin to some neuropsychiatric syndromes. (Some have suggested that the virus is linked to selected neuropsychiatric disorders in humans but the evidence for this is not conclusive).

Cases have occurred in Germany, other areas of Europe, Israel, Iran, Japan and the USA.  Has also been found in cattle, rabbits, goats, deer, alpacas, cats, sloth, veri monkeys and pigmy hippoppotamus'.  Neither the reservoir nor the mode of transmission of natural infection is known. *Assumed* transmission via saliva, nasal and conjunctival secretions or contaminated food and water.  NOT HIGHLY CONTAGIOUS!
Has received alot of press on and off as possible cause of some mental illness but nothing scientifically proven.

·    Brucellosis - On infrequent occasions, horses have been known to contract brucellosis caused by Brucella abortus and have, on even less frequent occasions, been a source of human infection.

There are 100 to 200 cases per year in the USA.  Sheep, goats, cattle, deer, elk, pigs, dogs and several other animals listed as usual species affected.  Most common cause in humans is eating/drinking contaminated milk products and slaughterhouse or meat packing plant workers handling carcasses of infected animals.  Few cases via inhalation method in laboratory workers culturing the bacteria. I found not one case in a search of the infectious disease literature of a human contracting brucellosis from a horse.

From the “Summary of Notifiable Diseases --- United States, 2003”, Centers for Disease Control MMWR, 52(54);1-85 April 22, 2005:
"Brucellosis By 2003, the National Brucellosis Eradication Program had nearly eliminated Brucella abortus infection from U.S. cattle herds. The risk of contracting brucellosis through occupational exposure to livestock in the United States or consumption of domestically produced dairy products therefore is minimal. Consumption of unpasteurized dairy products from outside the United States continues to pose a risk of infection with B. abortus or B. melitensis. The majority of U.S. cases of brucellosis occur among returned travelers or recent immigrants from areas in which Brucella species are endemic. Hunters exposed to infected wildlife might also be at increased risk for infection. Laboratory personnel working with Brucella species should follow recommended biosafety precautions. Brucella species are considered category-B biologic threat agents. "

·    Encephalomyelidities (West Nile Fever, Eastern, Western) – horses do not play a role in transmission of these diseases to humans.  The same infection occurs in horses and in humans. All three diseases occur in the U.S.  However, horses do play a role in the transmission of another mosquito-borne disease, Venezuelan Equine Encephalomyelitis (VEE), to humans (see separate heading below).  It should be emphasized that this disease has been exotic to the USA since the early 1970s.

See comments under VEE (listed separately toward end of listing).  We already have vaccines for these diseases.
 
·    Glanders – Glanders is one of the oldest known equine diseases that is of important biosecurity concern.  It is a disease of horses, mules and donkeys.  Glanders is not currently found in the U.S.  It is a disease that can be spread from horses to humans and it was used as a biological warfare weapon by the German army in World War I.  The disease continues to exist in various parts of the world, including both eastern and western hemispheres.  The U.S. requires that all horses imported into the U.S., including those temporarily exported for competition purposes be tested negative for Glanders before being permitted entry (or re-entry as the case may be) .