July 12, 2005\
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Dr. Ron DeHaven\
United States Department of Agriculture\
Animal and Plant Health Inspection Service\
4700 River Road Unit 118 Station 3C71\
Riverdale, MD 20737-1238\
\
Dear Dr. DeHaven:

The National Pork Producers Council (NPPC) appreciates this opportunity
to provide comments on the National Animal Identification System (NAIS)
Draft Strategic Plan and Draft Program Standards, Docket Number
05-015-1. We appreciate the great effort made by APHIS to build and
implement a NAIS, and encourage APHIS to continue working jointly with
animal agriculture on the Systems' continued development.

Pork producers support the development and implementation of a mandatory
animal ID system by 2008 for all relevant livestock species. The system
should be compliant with the identification formats established by USDA
in the NAIS for premises, individual animals and group/lot. It is
important that the NAIS be species specific so existing identification
and tracking systems can be utilized.

The NPPC believes the system currently proposed by USDA will not meet
our desired goals. The current plan would take too long to implement,
and would also be too expensive for complete implementation for all
species at one time. USDA should realize that there are significant
differences among species production systems that will delay the
implementation of one national plan for all species.

Current attitudes on Capital Hill contend that a privately-held system
should be driven forward by industry, thus avoiding the need for
legislation that would likely be slow-moving. Additionally,
confidentiality of producer data continues to be an issue for some
producers. To some degree, this issue could be overcome by adapting an
existing program with which producers are already comfortable and one
which was developed as a producer initiative and supported by USDA.

Pork producers believe the goals of the NAIS can be more rapidly
achieved if proper consideration is given to ideas which require the
system to be species specific. The PRV Eradication Program, in use since
1988, requires the identification of swine and reporting of interstate
movements via a Certificate of Veterinary Inspection (CVI) or an
Interstate Movement Report (IMR). The adaptation of this existing
program developed and implemented by producers in cooperation with USDA,
will track the majority of swine movements in the U.S.

The PRV-based system would need enhancements in some areas to make it
fully operational. Adoption of the premises registration, individual
animal and group/lot numbering formats as established by APHIS would be
necessary. Additionally, the establishment of a protocol to individually
identify cull breeding stock and animals not eligible for group/lot
identification would need to be developed.

Accurate movement data will play a crucial role in a successful NAIS.
Current interstate movement data is reported via a CVI or IMR, and
international movements are reported as required on international health
certificates. Intrastate movements and movements directly to slaughter
are recorded as a normal part of business operations with that
information being retained at the farm level. These records are made
available to state and federal officials as needed to address animal
health issues. State departments of agriculture do not currently have
the resources to collect, manage and retain this data and thus rely on
producer records to traceback animal movements. Until USDA Develops a
plan with an established funding source, we do not believe producers
should pay the cost of the forward reporting of these intrastate
movements.

USDA has set the standards for the NAIS through the establishment of
identification formats and delineation of the data necessary to achieve
48 hour traceback. Each individual species group should be required to
develop a system to ensure that this information is collected in a
manner that allows for access by designated state and federal officials
as required to achieve the goals of the NAIS. USDA should certify these
species-specific programs as to their compliance with the stated goals
of the NAIS.

Again, NPPC appreciates this opportunity to comment on the National
Animal Identification System (NAIS) Draft Strategic Plan and Draft
Program Standards. We are thankful for the opportunity for pork
producers to work in concert with USDA to develop such a program that is
necessary to ensure the continued safety and security of the swine
industry.

Sincerely,

![](media/image1.png){width="1.5in" height="0.75in"}

Don Buhl\
NPPC President