Animal Disease Traceability

Assessment Report Executive Summary

April 2017

The objective of this assessment is to evaluate the Animal Disease Traceability (ADT) program 

and the effectiveness of the Code of Federal Regulations (CFR) Title 9 Part 86, Animal Disease 

Traceability, to enhance our tracing capabilities for emergency response, disease control and 

eradication programs. The assessment is based on an evaluation of traceability parameters since 

the publication of Part 86 through September 30, 2016.

On January 11, 2013, the United States Department of Agriculture (USDA) published the final 

rule, “Traceability for Livestock Moving Interstate.” Official identification requirements for 

beef feeder cattle were excluded from the final rule based on comments received from 

stakeholders. USDA acknowledged that the component of traceability for beef cattle under 18 

months of age would be addressed in a separate rulemaking process or implementation phase, 

and would be considered after assessing whether the requirements were being implemented 

effectively throughout the production chain for the cattle and bison covered under the initial 

phase.

The ADT framework was established to improve the ability to trace animals back from slaughter 

and forward from premises where animals are officially identified in addition to tracing animals’ 

interstate movements. While the Animal and Plant Health Inspection Service (APHIS) focuses 

on interstate movements of livestock, States and Tribal Nations remain responsible for the 

traceability of livestock within their jurisdictions. This approach was designed to embrace the 

strengths and expertise of States, Tribes, and producers, while giving them the flexibility to find 

and use the most effective traceability approaches to identify animals moving interstate 

nationally.

APHIS established trace performance measures (TPM) to document progress in ADT, and by 

these measures the ADT program has been very successful in its administration in the context of 

the framework of official identification and movement documentation for covered livestock. 

Specifically the elapsed times to complete TPMs has decreased, and the percent of traces 

successfully completed for each fiscal year has increased. This improvement can largely be 

attributed to the timely retrieval of official identification records (records of tags distributed and 

tags applied) and movement documents through the use of databases for storing the associated 

information in an easily searchable format. However, while ADT has been successful in the 

context of the intended framework, significant gaps still exist within our tracing capabilities 

since the publication of 9 CFR Part 86:

• The most significant impediment resulting from the current framework is the restriction 

that the official identification requirement is only applicable to livestock that move 

interstate. Cattle movements are quite diverse, often with multiple congregation points 

and opportunities for local spread of disease prior to moving interstate. The requirement 

that official identification be limited to interstate movements also creates significant 

confusion in marketing channels and creates enforcement challenges and complications. 
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• The ADT framework relies on the use of the basic, cost-effective identification methods 

used in APHIS’ disease eradication programs and are widely accepted by producers.

However, the challenges and limitations resulting from visual-only low cost identification 

eartags are evident. Yet the implementation of radio frequency identification (RFID) 

technology, while preferred by many, also has obstacles. The implementation of a RFID 

solution for traceability, if undertaken, would be a significant challenge and would 

require a lengthy implementation period and a well thought out and detailed plan. 

• Although there are other fundamental gaps in the traceability framework that need to be 

addressed foremost, APHIS views the inclusion of feeder cattle in the traceability 

regulations as an essential component of an effective traceability system in the long-term. 

The success of animal disease control efforts hinges on including all sectors of the cattle 

industry. However, it is important to note that the requirement for collecting official 

identification numbers on movement documents and/or interstate certificate of veterinary 

inspection (ICVIs) for feeder cattle will be unduly cumbersome with visual only tags and 

therefore should only be considered when an RFID infrastructure is in place.

• Lastly, while all federally approved slaughter plants are required to collect all 

identification devices at slaughter and maintain correlation of the devices to the carcass 

through final inspection, compliance with this regulation is inconsistent. Although 

successful tracing is not guaranteed by the availability of identification collected at 

slaughter, it provides a significant advantage for regulatory personnel in disease 

investigations. In addition, the termination or retirement of official identification numbers 

at slaughter would greatly increase tracing efficiency as it would document which 

animals have been removed from the population. While the termination of visual-only 

tags is not logistically feasible, it would systematically be achieved at the slaughter plants 

when the RFID technology and infrastructure is established. 

APHIS is confident that the basic framework of ADT is being successfully implemented and 

believes discussions with industry to consider potential next steps are appropriate at this time. It 

is essential for producers and other industry stakeholders to offer their opinions on relevant 

issues to help define the level of traceability they want to achieve and how best to reach those 

goals. Just as APHIS worked through issues and achieved compromises in the initial ADT 

framework that resulted in improved buy-in and support from many stakeholders, the next phase 

needs to follow that collaborative approach. APHIS has numerous outreach efforts scheduled in 

2017 to obtain feedback from all sectors of the industry and will be providing more information 

on those activities.