The Technology Behind the National Animal Identification
System
By Judith McGeary, Executive Director, Farm and
Ranch Freedom Alliance
The government’s proposed National Animal Identification System (“NAIS”)
poses numerous problems: massive government intrusion into our lives, unnecessary
and burdensome costs, the lack of a real need for such a program, and the fact
that tracking does not solve disease issues. Looking more closely just at the
last issue, the USDA’s disease control claims rely on the assumption that
nationwide tracking is even possible. In truth, the technology is flawed in
many ways, ranging from problems with the microchips to problems with the databases.
The USDA and multiple trade associations have repeatedly stated that NAIS is
"technology neutral," implying that no particular identification devices
have been designated. This is false. Over a year ago, the USDA published Draft
Program Standards that specified that cattle should be identified with Radio
Frequency Identification (RFID) devices in their ears. The Equine Species Working
Group (ESWG) has recommended that horses be identified with RFIDs implanted
under the skin of the neck. Although they may allow some other forms of identification
in the phase-in period, it is clear that NAIS will ultimately require cattle
and horse owners to use electronic devices for identification.
The very nature of RFID technology raises questions. Electronic devices become
obsolete very quickly. Yesterday’s $2,000 personal computer is now a piece
of worthless junk that cannot run modern software. Will we have to re-chip our
horses every few years? Moreover, RFID technology, like any electronic device,
is subject to problems that do not exist with traditional identification methods
such as branding or tattoos. Depending on the security of the technology used,
one can clone microchips, using a device that can be hidden in someone’s
hand and passed over the chip in just seconds. And a recent study shows that
RFID tags are susceptible to computer viruses. This means that anyone wishing
to cause problems (terrorist or not) could not only tamper with tags within
their control, but could spread problems to all other tags scanned using the
same equipment. Imagine a busy sale barn, with every animal’s tag corrupted
by the infected scanner…
But the technological problems don’t end there. Both the USDA and the
ESWG specified the exact type of RFID to be used: the ISO 11784/11785 chip.
Insisting on one type of technology may appear reasonable at first. After all,
consistency is a good thing, right? But what if that technology has flaws that
make it impossible to achieve the stated goals? ISO 11784/85 chips are not designed
to provide unique identification numbers to allow traceback of animals, which
is the entire purpose of NAIS. In other words, the government plan, by its own
terms, cannot work.
ISO, or the International Organization for Standardization, creates so-called
“open standards,” essentially a recipe that any manufacturer may
follow to create a product that complies with the standard. This approach to
standardization works well for modem protocols, paper sizes, and other items
of daily life that need to be interchangeable. But the ISO design standards
do not guarantee unique ID numbers. Rather, the standards provide for chips
that can be programmed in the field before they are applied to the animals,
or even reprogrammed after they are in the animal. Manufacturers all over the
world have been selling these reprogrammable chips for years. They have also
been selling “ISO programming units” that allow any person –
you, a thief, or a terrorist – to reprogram the numbers with just a wave
of the wand. This problem with the ISO standard is well known in the technology
community and has been debated for years.
How can you trace an animal if someone can change its identity at any time?
These specific RFIDs can be programmed to read any number the customer desires,
including ID code duplicates. Using a programming unit – a legally-available
device -- someone could steal your horse and reprogram the microchip to read
the same number as another horse they legitimately own. Or a person with a sick
animal could re-program the tag to a non-existent number, or even the ID number
of someone else’s animal, to shift the blame. The opportunities for avoiding
true identification are legion.
You may wonder why this technology is used at all. ISO 11784/85 chips are useful
in what’s called “closed loop systems.” So, for example, they
can help a dairy farmer track his own cows, monitor their milk production or
weaning weights, etc., precisely because they allow the farmer to reprogram
the chips with new information. After all, the farmer wants to be able to change
the information on the chip to reflect changes in the animal, and he or she
has no reason to reprogram the ID number and exchange identities among his own
cows. But the chips will not work for a national identification system.
You will also need an unnecessarily expensive reader to read these microchips.
This is because the ISO standard reflects a “compromise” that incorporates
two mutually incompatible technologies. This will require two readers in one
box.
Significantly, the ISO 11784/85 chip is not the type of microchip that has been
generally used in horses in the United States for private purposes, and it emits
on a different frequency, 134.2 kHz, rather than standard 125 KHz. Thus, most
of the scanners and microchip readers in the U.S. today would not read or even
detect these ISO chips. Every facility will have to buy expensive new scanners
in order to comply with the USDA- and ESWG-recommended technology, which provides
less protection for our horses than the currently-used technology.
The existing system for microchipping horses is privately run and represents
a choice that horse owners can make. The information is released only with permission
of the horse owner. This is a very different thing than a government-mandated
program.
The objections to NAIS go far beyond the technology problems, and even if the
technology were workable, there are many reasons to oppose NAIS. But the fact
that this technology will not work raises some intriguing questions. Why are
the government, private companies, and various associations promising traceability
that they cannot deliver?
In looking for the answer to that question, it is worth thinking about who will
profit from NAIS. Obviously, the companies selling the RFID tags stand to gain
a large new market. But NAIS does not stop there; animals must not only be tagged,
they must be tracked. This will require huge databases, which will be privately-owned
and managed – which in turn means that someone or multiple someones will
make a profit on them. Interestingly, in January of this year, several associations
joined together to form the United States Animal Identification Organization
(USAIO) to manage the “industry-led animal movement database.” The
USAIO board of directors is made up of representatives from the Southeastern
Livestock Network, the Northwest Pilot Project, the National Bison Association,
the National Cattlemen’s Beef Association, and the American Farm Bureau.
Have any of these associations sought your opinion on whether you want NAIS?
The profit trail is long and complicated, and will require a separate article.
But the next time an association or company tells you NAIS is a good thing,
you should consider what their interest is.
Establishing these databases will be a monumental task. There are over a hundred
million cattle in the U.S., and millions more horses, chickens, sheep, goats,
pigs, deer, elk, bison, and other livestock animals. These animals are taken
to local shows, sold in auction houses, sold in private transactions between
individuals, slaughtered, and otherwise moved for a multitude of reasons. The
technological aspects of setting up such huge databases are daunting. And the
databases are only as good as the information that is entered. There will be
literally hundreds of millions of opportunities for human error in this system.
But regardless of how flawed the databases are, the companies running them will
be guaranteed a profit because everyone will be forced to participate under
the threat of government fines or even criminal penalties.
There are many winners under NAIS: the technology companies who will sell the
RFID tags and readers; the associations who will run the databases; the government
agencies who will grow to oversee this huge program. Notably absent from the
list of winners is the average horse owner, who will gain no extra protection
for their animals, just extra expense and loss of privacy.