Animal Disease Traceability 

Summary of Program Reviews and Proposed 

Directions from State-Federal Working Group

April 2018

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Veterinary Services

This report provides an overview of the Animal Disease Traceability (ADT) Program 

review, a summary of stakeholder feedback received during listening sessions in 2017, and 

the preliminary recommendations of the State-Federal Animal Disease Traceability 

Working Group.

USDA does not necessarily endorse the recommendations included in this report. USDA 

will continue to review and explore opportunities and recommendations to improve the 

current ADT Program and enhance animal disease traceability.
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Animal Disease Traceability

Summary of Program Reviews and 

Preliminary “Next Step” Proposals

Table of CONTENTS

Preface.................................................................................................................................... 3

Introduction and ADT Program Description .............................................................................. 4

Background.................................................................................................................................................................. 4

ADT Focus.................................................................................................................................................................... 4

ADT Reviews............................................................................................................................ 6

Internal APHIS Review ................................................................................................................................................. 6

ADT Program Assessment............................................................................................................................................ 8

Public Meetings........................................................................................................................................................... 8

Summary of Feedback on the ADT Program............................................................................ 11

1. INTERSTATE MOVEMENTS THAT DO NOT APPLY TO THE TRACEABILITY REGULATIONS....................................................... 15

2. CATTLE POPULATION COVERED IN THE OFFICIAL IDENTIFICATION REGULATIONS............................................................. 15

3. LIMITING OFFICIAL IDENTIFICATION REQUIREMENT TO INTERSTATE MOVEMENTS........................................................... 16

4. ELECTRONIC IDENTIFICATION SYSTEM FOR CATTLE..................................................................................................... 16

5. ADMINISTRATION OF ELECTRONIC RECORDS .............................................................................................................. 19

6. ENFORCEMENT OF ADT REGULATIONS ..................................................................................................................... 20

7. COLLECTION OF ID AND ITS CORRELATION TO THE CARCASS AT SLAUGHTER PLANTS ........................................................ 21

8. PUBLIC/PRIVATE INFORMATION SYSTEM................................................................................................................... 21

9. EXEMPTIONS FOR OFFICIAL IDENTIFICATION REQUIREMENTS ....................................................................................... 22

10. ICVI EXEMPTIONS AND MOVEMENT DOCUMENTS...................................................................................................... 23

11. UNIFORMITY OF STATE IMPORT REGULATIONS......................................................................................................... 23

12. UNIFORM OFFICIAL IDENTIFICATION EARTAGS ......................................................................................................... 24

13. OFFICIAL EID TAG FOR IMPORTED CATTLE .............................................................................................................. 24

14. OFFICIAL IDENTIFICATION OF BEEF FEEDERS ........................................................................................................... 25

Appendix............................................................................................................................... 27

Appendix I – List of Acronyms.................................................................................................................................... 27

Appendix II – Working Group on Slaughter Plant ID Collection & Correlation........................................................... 28

Appendix III – Official Identification and ICVI Exemptions......................................................................................... 30
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Preface

This report provides a brief overview of the ADT framework and summarizes the reports prepared 

and the reviews conducted to evaluate its overall impact on animal disease traceability. Feedback 

obtained from industry stakeholders, and State and Federal animal health officials during extensive 

outreach efforts in 2017 provides details on the progress of ADT, successes, and challenges or

problematic areas of the initial framework. 

A State and Federal working group with substantial experience and knowledge of animal disease 

traceability comprehensively reviewed stakeholder feedback and prepared the preliminary proposals 

contained in this report. Members of the working group presented a preliminary draft of these 

proposals at the Traceability Forum hosted by the National Institute for Animal Agriculture (NIAA)

and the United States Animal Health Association (USAHA) in Denver, Colorado on September 26 

and 27, 2017. 
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Introduction and ADT Program Description

Background

The U.S. Department of Agriculture (USDA) provides various programs that support the economic 

viability of animal agriculture. The Veterinary Services (VS) unit of the USDA’s Animal and Plant 

Health Inspection Service (APHIS) works to improve the health, productivity, and quality of life for 

animals and people by maintaining and promoting the safety and availability of animals, animal 

products, and veterinary biologics.

Animal disease traceability- or knowing the whereabouts of diseased and at-risk animals are, where 

they have been, and when – is important to ensuring a rapid response when animal disease events 

take place. Although animal disease traceability does not prevent disease, an efficient and accurate 

traceability system reduces the number of animals and response time involved in a disease 

investigation, which, in turn, reduces the economic impact on owners and affected communities.

ADT Focus

The current approach to traceability in the United States is the result of significant discussion and 

compromise. Federal policy regarding traceability has been amended several times over the past 

decade based on stakeholder feedback, particularly from the cattle industry. In early 2010, USDA 

announced a new approach for responding to and controlling animal diseases, referred to as the 

ADT framework. Key principles of the 2010 framework include:

 Application to animals moved interstate.

 Administration by the States and Tribal Nations to increase flexibility.

 Encouraging utilization of lower cost technology.

 Transparent implementation through the full Federal rulemaking process.

USDA published a proposed rule, “Traceability for Livestock Moving Interstate,” on 

August 11, 2011, and the final rule on January 9, 2013. Under the final rule, unless specifically 

exempted, livestock moved interstate must be officially identified and accompanied by an interstate 

certificate of veterinary inspection (ICVI) or other documentation. Covered livestock include cattle 

and bison, horses and other equine species, poultry, sheep and goats, swine, and captive cervids. The 

requirements do not apply to livestock moving: 

 Entirely within Tribal land, that straddles a State line and for which the Tribe has a 

separate traceability system from the States in which its lands are located. 

 To a custom slaughter facility in accordance with Federal and State regulations for 

preparation of meat. 

As currently structured, ADT is a “bookend” system (Figure 1) which enables animal health 

officials to trace a covered animal forward from the location of official identification and 

backward from the animal’s last location, which is often the termination point or slaughter plant.

The rule includes identification (ID) and movement documentation exemptions that support the 

principle of flexibility at local levels. 
5

Figure 1. U.S. Traceability with ADT – “Bookend System.”

ADT also focuses on interstate animal movements to provide information on the originating and 

destination premises for animals moved from one State to another. Animal disease programs, brand 

inspection and in certain situations, industry programs like breed registries, performance recording 

systems, or marketing programs also provide traceability data.

While 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 leverage the strengths and expertise of States, Tribes, and producers and provide them the 

flexibility to develop the most effective traceability approaches to identify animals moving 

interstate nationally.

Although the requirements apply to multiple livestock species, the ADT program’s primary focus 

has been enhancing traceability in cattle as bovine disease eradication programs are phased out. 

For example, the success of the U.S. brucellosis eradication program, while certainly a positive 

development, has resulted in a steep decline in the number of cattle required to be tested and 

therefore officially identified. As a result of fewer cattle with official ID, the time required to trace 

animals during a disease investigation had steadily increased until the implementation of the ADT 

program. 

Since the rule went into effect in March 2013, the focus of ADT has been the following areas:

 Educating stakeholders about the requirements;

 Identifying animals by using official ID;

 Collecting animal movement information;

 Increasing the number of records in searchable data systems; and 

 Monitoring compliance. 

Traceability performance measures (TPM), administered through trace test exercises, examine the 

successful administration of key ADT program elements, particularly official ID devices, ICVI and 

other movement documents.
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ADT Reviews

ADT has been one of APHIS’ top ten priorities since 2013, after the Agency issued a final rule to 

improve the United States’ ability to trace livestock and poultry when disease events occur. In fiscal 

year (FY) 2015, the APHIS Administrator selected the ADT program for an internal review, as part 

of ongoing periodic assessments of Agency activities. More recently, APHIS initiated a program and 

stakeholder review in late 2016, to determine the effectiveness of the framework, as well as 

implementation successes and shortfalls over the past 3 years. In addition to the program staff 

assessment, APHIS conducted extensive outreach activities in 2017 with State, Tribal, and Federal 

animal health officials and industry to obtain grassroots feedback from producers and other sectors of 

the livestock industry. 

The multiple reviews provide insight into how well the program is being managed; the efficiencies 

gained in administering tracebacks, aspects of ADT that are working well, traceability regulations 

that are problematic and/or creating confusion, and gaps remaining in tracing capabilities since the 

implementation of the framework. Such program reviews provide essential feedback, which APHIS 

uses to identify program priorities and future collaborative opportunities with industry.

Internal APHIS Review

In FY 2015, two years after the publication of the ADT final rule, the APHIS Administrator selected 

the program for review by an independent Agency assessment staff that conducts periodic reviews of 

the effectiveness, efficiency, and performance of 

APHIS programs and activities. The review team 

evaluated the effectiveness of the ADT program from 

the perspective of the animal health organizations and 

officials that implement it. The assessment provided an 

objective gauge of how well ADT program officials 

were implementing goals and managing resources. It

also provided information regarding challenges to 

program performance and opportunities for 

improvement.

In brief, the review team found: 

 The ADT program was well managed, had 

clearly defined goals and objectives, and 

was helping State and Federal animal health 

officials achieve incremental improvements 

in their animal disease tracing capability. 

 APHIS was managing its ADT resources 

capably. APHIS applied the majority of ADT funding to cooperative agreements with the 

States, Tribes, and Territories, and to Agency employee salaries. In both cases, direct 

links existed between the resource application and program activities, outputs, and 

outcomes. The review team noted, however, that FY 2015 resource levels might not be 

sufficient to sustain continual program improvement.
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 Achieving a more comprehensive and effective traceability system was still a distant goal. 

Despite the progress recorded, at the time of the 2015 review, most animal health officials 

indicated that to achieve a truly effective traceability system, the ADT program must:

o Mandate electronic ID devices for cattle (after officials ensured that appropriate 

tag and reader technology solutions were available); 

o Incorporate beef cattle under 18 months into the ADT rule.

The review listed several outstanding challenges that APHIS and its cooperators faced in ADT 

implementation: (1) the program’s flexibility, which helped it achieve broad support but also allowed 

for differing regulatory requirements among the States, potentially affecting compliance, traceability 

efficiency, and long-term feasibility; (2) available technology, which was limited by effectiveness, 

cost, and acceptance by stakeholders; (3) resource levels, which may not have been adequate to 

sustain continual ADT improvement into the future; and (4) the lack of compelling external forces or 

messaging to influence stakeholders who were opposed or ambivalent towards ADT.

The review also noted opportunities on which APHIS could focus to ensure the program was as well 

positioned as possible for continuing successful ADT implementation. These opportunities included: 

(1) conducting more data analysis to focus implementation efforts; (2) continuing to invest in 

technology that would allow individual animal movements to be recorded at a reasonable cost 

without impeding commerce; (3) encouraging greater Federal/State collaboration at all levels; (4) 

setting priorities for ADT funds that became available unexpectedly; (5) leveraging stakeholder 

relationships to spread information about ADT; and (6) ensuring an updated plan is in place for a full 

traceability system should a worst-case scenario animal disease event occurrence prompt the 

immediate implementation of such a system.

In addition to the identified challenges and opportunities, the review team recommended the ADT 

program focus on establishing definitive performance levels within the current system and structure, 

identifying the ultimate goal for ADT, and ensuring APHIS is positioned to achieve this goal over 

the long term. 
8

ADT Program Assessment

The objective of the assessment conducted by ADT 

program staff in late 2016 was to evaluate the program 

and the effectiveness of Title 9, Code of Federal 

Regulations (9 CFR) Part 86 pertaining to animal disease 

traceability related to cattle and bison. The assessment 

included evaluation of documentation on actual program 

traces (e.g., tuberculosis) and trace exercises administered 

to capture TPMs under the ADT cooperative agreements 

with States; review of monitoring and compliance efforts 

including Investigative and Enforcement Services (IES)

investigations; and informal discussions with State and 

Federal animal health officials.

The assessment report reflects that the basic framework of 

ADT established in 2013 is successfully implemented. 

The TPMs denote an improvement in the administration 

of official ID and movement documentation for covered 

livestock. Specifically the elapsed times to complete TPMs have decreased, and the percent of 

traces successfully completed each fiscal year has increased. The TPM improvements are primarily 

attributed to the timely retrieval of electronic records for official ID (tags distributed and tags 

applied) and movement documents.

While APHIS is confident that implementation of the basic ADT framework was successful, some 

of its parameters limit the progress of the program, and significant gaps still exist within current

tracing capabilities. Examples of these gaps include:

 Application of the official ID requirement only to livestock moving interstate creates

significant confusion in marketing channels and enforcement challenges.

 Use of visual-only low cost ID eartags presents obstacles for collecting animal ID

efficiently and accurately. 

 The traceability regulations do not include feeder cattle, which APHIS views as an 

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

 Some federally approved slaughter plants could improve the collection of ID devices at 

slaughter and the correlation of the devices to the carcass through final inspection.

The full assessment report is available at:

https://www.aphis.usda.gov/traceability/downloads/adt-assessment.pdf

Public Meetings

As an adjunct to the ADT program assessment, APHIS felt it was essential for industry stakeholders

from all sectors of the cattle industry to offer their opinions on relevant issues to help define 

traceability objectives and how they want to achieve those goals. APHIS conducted nine ADT public 
9

meetings at the locations listed below as part of the outreach efforts in 2017. The purpose of these 

meetings was to solicit industry input regarding their experiences with ADT: What areas are working 

well? What aspects are challenging, confusing, or problematic? How can these obstacles be 

rectified? What level of traceability should be considered if we are to move beyond the basic 

traceability framework?

Stakeholders also had the opportunity to comment on the current ADT framework via 

regulations.gov through July 31, 2017. APHIS received 462 written comments during this period. A 

summary of the feedback obtained from the public meetings and written comments are included on

page 11.

Location / Dates of Public Meetings

Oklahoma City, OK – April 11, 2017

Riverdale, MD – April 13, 2017

Nashville, TN – April 20, 2017

Bloomington, MN – May 2, 2017

Denver, CO – May 4, 2017

Sacramento, CA – May 11, 2017

Billings, MT – May 24, 2017

Omaha, NE – July 18, 2017

Fort Worth, TX – July 20, 2017

State Federal ADT 2017 Working Group

In 2017, APHIS established a State-Federal ADT Working Group in accordance with the Federal 

Advisory Committee Act to assist APHIS in reviewing the ADT regulation, examine feedback from 

the public meetings and written comments, and provide input based on their experiences with
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disease traceability issues. ADT staff worked through the National Assembly of State Animal 

Health Officials to obtain representation for each U.S. Animal Health Association district. The 

working group focused on aspects of ADT related to cattle and bison. The group met every two 

weeks via conference call starting March 21, 2017.

Members of the working group are listed below and the working group’s preliminary proposals for 

addressing key traceability issues are covered on page 16 of this report.

Name Affiliation

Geiser-Novotny, Sunny Cattle Health Staff/ ADT Veterinarian, APHIS VS SPRS

Hammerschmidt, Neil Manager, ADT, APHIS VS SPRS

Halstead, Steve District Director, APHIS VS SPRS

Hickam, Linda State Veterinarian, Missouri Department of Agriculture

Hughes, Dennis Nebraska State Veterinarian, Nebraska Department of Agriculture

Kitchen, Diane Veterinarian Manager, Florida Department of Agriculture and Consumer 

Services

Linfield, Tom Assistant District Director, APHIS VS SPRS 

Massengill, Rose Animal Identification Coordinator, APHIS VS SPRS

McGraw, Paul State Veterinarian, Wisconsin Department of Agriculture, Trade and 

Consumer Protection

Odom, Rick Animal Health Information Systems Manager, Virginia Department of 

Agriculture

Schwabenlander, Stacey Senior Veterinarian, Minnesota Board of Animal Health

Scott, Aaron National Preparedness and Incident Coordination Center (NPIC), APHIS 

VS SPRS

Smith Justin Deputy Animal Health Commissioner, Kansas Department of Agriculture

Steck, Allie Animal Disease Traceability Coordinator, Pennsylvania Department of 

Agriculture

Turner, Alex Traceability Veterinarian, Colorado Department of Agriculture

Westly, Rolf Veterinary Medical Officer, APHIS VS SPRS

Winslow, Thatch Assistant State Veterinarian, Wyoming Livestock Board

Zaluski, Marty State Veterinarian , Montana Department of Livestock
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Summary of Feedback on the ADT Program

Since the publication of 9 CFR Part 86 in January 2013, APHIS has sought feedback on the ADT 

framework from industry, State, Tribal, and Federal animal health officials with the goal of 

enhancing our tracing capabilities for emergency response, disease control, and eradication 

programs. This report summarizes the most recent stakeholder feedback that APHIS received during 

a series of nine public meetings held across the nation this year and through a Federal Registry 

notice requesting comment on the program. 

Participants in attendance at the ADT public meetings expressed appreciation for the opportunity to 

discuss the ADT framework and collaborate with APHIS on future traceability objectives. Both 

meeting attendees and written comments acknowledged that the general framework has been 

successful in improving the official ID of covered livestock, the documentation of interstate 

movement, and the availability of those records. The information below summarizes the concerns 

with the original framework and considerations of future traceability opportunities.

General Concerns

Confidentiality and Security of Information Systems: The issue of confidentiality continues to be 

an issue of concern among producers, as is the overall security of the information technology (IT)

systems. The producers indicated support for the ADT implementation changes that placed more 

responsibility for holding their information at the State-level.

Liability: Producer liability remains an area of concern. Previous discussions on animal ID 

primarily focused on producer liability when diseased animals are traced to a premises that may 

have held the animal prior to the infection. Recent discussions involved concern about the liability 

related to injury of animals or personnel when working cattle for tagging, manually reading tags, 

etc.

Cost: Meeting attendees and commenters stated that the cost of traceability must be distributed

across all sectors of the industry. In particular, if electronic ID (EID) technology is implemented as 

the only method of official ID, the cow/calf industry should not cover the cost of EID tags when the 

entire industry benefits. Some commenters noted that other sectors would contribute significantly to 

the cost of the infrastructure for EID and as a result, the cost to implement EID would not be borne 

by the cow/calf sector alone.

Small Producers: APHIS should consider issues associated with requiring small producers to 

comply with an enhanced traceability regulation, including costs that are proportionally higher for 

this segment of the industry due to economy of scale and management limitations (for example, the 

ability to tag their own cattle). This sector includes a significant number of producers and cattle.

Thus, their viability impacts markets and other service providers. Producers that sell their beef 

products direct to consumers provided many written comments that expressed their concerns about 

the cost and burden associated with animal ID, in particular, electronic methods. Individuals from 

this sector also noted that their animals are already traceable from custom slaughter facilities back 

to their premises.
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Common Issues Regarding the Current ADT Framework

Focus of ADT: Some participants believe that APHIS should administer ADT for animal disease 

control and leave marketing opportunities to Agricultural Marketing Service (AMS) programs and 

the private sector. However, feedback also acknowledged the need for the United States to have a 

national traceability program to meet international trading partners’ requirements for animal disease 

control and felt the two topics are linked to one another.

Beef Feeder Cattle (Beef Feeders): The inclusion of beef feeders in the official ID requirement 

was the primary topic of discussion at public meetings. While a large number of stakeholders 

acknowledged that beef feeders need to be part of the official ID requirements at some point, the 

consensus was to address the gaps in the current framework, which covers beef breeding cattle over 

18 months of age and all dairy, before expanding the official ID requirements to beef feeder cattle.

Additional points of consensus regarding the official ID for beef feeders included:

 The expansion of regulations for the official ID of beef feeder cattle under18 months of 

age must conform to normal rulemaking procedures. 

 Beef feeders could be included after an expanded framework is fully functional for 

breeding animals, including the requirement for official EID and the supporting 

infrastructure.

 Other individuals suggested incremental implementation of beef feeder requirements; 

with the initial objective to obtain birth premises ID and tag retirement, then as 

infrastructure becomes established, phase in the collection of movement data. 

 While beef feeder cattle official ID requirements should be delayed, discussion on the 

processes to include beef feeders in the ADT program should continue ensuring 

preparation of an implementation plan.

 APHIS should conduct a cost-benefit analysis on official ID/traceability of beef feeder 

cattle to support future discussions/decisions on this topic and to determine the level of 

traceability warranted for beef feeder cattle.

 Livestock markets, while supportive of tagging sites for the population currently 

covered, explained that the burden of tagging beef feeders at their auctions is not feasible 

and solutions to tagging at the farm/ranch or before arriving at the auctions are essential. 

An alternative suggestion was to apply the official tag for these cattle at the first 

receiving premises when working these cattle for management purposes. The records of 

tags applied should provide contact information of the person responsible for the cattle 

when sold at the markets.

 Some individuals expressed concern that the official ID of all beef feeders would 

diminish market advantages and premiums of added-value programs. 

ID to Birth Premises: To better achieve traceability, most individuals supported the need to apply 

official ID at the birth premises for animals covered by the official ID regulation. If that is not 

practical, they supported tagging at change of ownership or first point of commingling, versus at the 

time of first interstate movement, provided the animals are traceable to the birth premises. Since 

beef cattle under 18 months of age would remain exempt until determined otherwise, producers 

would officially identify adult beef animals when first shipped after 18 months of age for change of 

ownership or commingling.
13

Flexibility and Exemptions: Feedback from the meetings indicated that industry feels the current 

framework is too flexible and that there are too many exemptions, which confuse the interpretation 

of the regulations. While recalling the reasons for the exemptions and their intent, there was strong 

consensus that the exemptions create too many traceability gaps in the classes of cattle and bison 

covered under the current rule. The exemptions also make enforcement of the existing regulation 

more challenging, as it is difficult to determine if an animal at subsequent locations required official 

ID earlier in life.

State Differences: There was a strong consensus more standardization and uniformity of State 

import requirements is necessary. Preparing interstate certificates of veterinary inspection (ICVIs)

has become very complicated. Individuals referenced the requirement by some States to record 

official ID numbers of dairy steers on ICVIs as one example of how State regulations differ from 

the Federal regulation and from one State to another. 

Uniform Enforcement: The livestock markets voiced concerns that enforcement of the current 

regulation is inconsistent and unfairly targets markets, while private treaty sales and online auctions 

are not monitored or held to the same degree of accountability. They identified the lack of 

enforcement for other industry sectors as a gap that must be rectified. There was a strong sentiment 

that more stringent enforcement actions at the markets would drive sales through non-market 

venues. However, most individuals agreed that compliance would automatically improve if all cattle 

(less beef feeders) required official ID on first movement from the birth premises.

EID Technology: Many industry participants and animal health officials agreed that EID is 

necessary to achieve cost-effective traceability. Producers, market managers, accredited 

veterinarians, and others expressed concerns about cattle handling challenges and economic losses 

created by the need to restrain cattle to manually read and record the official ID number on small 

visual-only eartags. While the National Uniform Eartagging System (NUES) tags – traditionally 

known as the metal clip “brite” tags – are inexpensive to purchase, individuals from across the 

industry indicated there is significant expense throughout the production chain associated with their 

use. Feedback also indicated that many support the phase-out of free NUES tags and that APHIS 

should eliminate them as an official method of ID. However, multiple issues need to be addressed 

before the transition to EID can occur, including:

 If radio frequency ID (RFID) is to be utilized, the establishment of standards, including 

one technology (low-frequency (LF) vs ultra-high frequency (UHF)) is critical. Most 

stakeholders supported a dual technology tag as an interim measure.

 The infrastructure must be in place to support the transition to EID.

 Cost remains the primary concern of producers and representatives from other sectors of 

the industry for both the reader infrastructure and tags; however, the use of EID would 

provide substantial savings due to the increased efficiency associated with the 

technology. 

 Availability and use of electronic forms, in particular, electronic ICVIs. Obtaining 

records electronically would decrease cost and improve the completeness and accuracy 

of the data. Additionally, retiring animal numbers at slaughter would be feasible, where 

it has been cost-prohibitive with visual-only tags. 

 A cost analysis on metal NUES tags to show the full cost of tags when working cattle to 

manually record ID numbers (labor, stress and shrink, injury, etc.), as well as their 

limitations relative to traceability, e.g., tag retirement, to more accurately illustrate the 
14

costs of both visual-only and EID tags. 

 Proportionally higher implementation costs for smaller producers, who sell direct to 

consumers and believe their livestock are already highly traceable.

Movement Documents: Discussions around movement documents focused primarily on the need 

for an ADT program definition of a movement document, including the necessary data elements as 

the minimum standards. Importing States should determine additional requirements for animal 

health certificates, ICVIs, permits, etc. The proposal to establish a nationally standardized, 

electronic movement document alternative to ICVIs garnered participant support. Additionally,

there was support to increase the value and volume of owner-shipper statements (OSS) by 

implementing an efficient process to collect and store OSS information by offering an electronic 

version.

Collection of ID at Slaughter: As reported in the ADT assessment, APHIS noted inconsistencies

with tag collection and their accurate correlation to the carcass at some slaughter facilities. APHIS 

is working with field personnel and the Food Safety Inspection Service (FSIS) to address the issue. 

State animal health officials and industry recognize this shortfall and identify it as a high-priority 

gap in the current framework that needs to be rectified.

Other Comments

Official ID Tags: There are differing views on using the same eartag for both official ID and 

management. Some producers prefer the same tag for both purposes, as it makes the tagging process 

more efficient and the official tag works well with herd management practices. Other producers 

commented that when they purchase cattle with official IDs with existing management numbers on 

the same tag, it creates conflict with their management numbering systems and subsequently, they 

prefer not to have such tags used for ADT. However, there was consensus that APHIS should 

consider the use of one basic official eartag to increase the awareness of which tag is official, lessen 

accidental removal, and improve compliance. Additionally, commenters recommended that ID 

devices approved for AMS’ Process Verified Program (PVP) and those designated as official by 

APHIS ADT should be compatible.

Brand certificates and inspection: Individuals commented on the long-term value of brands and

brand inspection. Commenters stated that official ID tags should not be represented as an alternative 

or promoted to replace brands. Animal health officials in brand States noted the value of brands and 

brand inspection for proof of ownership and providing information when conducting traceback 

investigations, but admitted that brands alone do not provide the level of traceability needed for 

disease control.

Outreach: Many commenters indicated that APHIS and States would need to ensure enhanced 

outreach efforts to reach producers regarding revisions to traceability requirements.

Recording Official ID Numbers: Participants raised the issue of recording individual ID numbers 

on ICVIs, and provided the suggestion to list ranges of numbers to avoid having to rework cattle 

after a sale to obtain the specific IDs going to each premises. Individuals also suggested that a 

premises ID number tag could suffice for traceability to avoid the current challenge of recording 

individual IDs. 
15

Cattle Imported to the United States: Some industry participants expressed concern regarding 

mandated traceability in the domestic herd for ADT while allowing importation of animals and/or

products from countries affected with foot-and-mouth disease (FMD) and tuberculosis (TB), such as 

Brazil and Mexico, respectively. Additionally, attendees raised concerns about the quality of 

diagnostic tests and vaccination options related to TB and brucellosis, and the lack of available 

funding to improve those and the FMD vaccine bank.

Data Systems: Many State animal health officials expressed concern that APHIS’ data systems are 

not efficient and indicated that even enhanced traceability would fail without efforts to increase 

electronic submission of data and data sharing capabilities.

*Proposed Direction from State-Federal Working Group1

The State-Federal ADT 2017 Working Group reviewed the ADT regulation, examined feedback 

from the public meetings and written comments, and provided input based on their experiences with 

disease traceability issues to provide the following preliminary proposals pertaining to traceability of 

the cattle sector. 

1. INTERSTATE MOVEMENTS THAT DO NOT APPLY TO THE TRACEABILITY 

REGULATIONS

Smaller producers that raise cattle for direct sale of meat products to consumers express 

concern regarding the cost of future traceability requirements. The regulation does not pertain 

to interstate movements to a custom slaughter facility for preparation of meat (in accordance 

Federal and State regulations) as such cattle are highly traceable to the premises of origin in 

the event of disease detection at the slaughter facility. 

Proposal

Maintain the policy that traceability regulations do not apply to interstate movements to a 

custom slaughter facility in accordance with Federal and State regulations for preparation of 

meat. 

Note: The proposal listed in #3 below clarifies that the exclusion of movements to custom 

slaughter would pertain only to animals that were born on the premises that ships directly to 

the custom slaughter facility. 

2. CATTLE POPULATION COVERED IN THE OFFICIAL IDENTIFICATION REGULATIONS

The initial ADT regulation excluded beef cattle under 18 months of age from the official ID

requirement. While most stakeholders acknowledged that the regulation should include this

sector of the cattle industry at some point, there is overwhelming support to address several 

shortfalls or gaps within the current ADT framework first. Proposal 14 of this report 

specifically addresses the requirement of official ID for beef feeder cattle.

 

1 The proposed direction provides a summary of stakeholder feedback, but does not necessarily represent the position 

of USDA
16

Proposal

Maintain the current population of livestock covered by the official ID requirements. The 

ADT rule will continue to include: 

 All dairy

 Beef cattle > 18 months of age

 All rodeo and exhibition cattle

Industry leaders should evaluate the merit and practicality of including official ID

requirements for beef bulls and beef heifers under 18 months of age specifically sold for 

breeding purposes. This approach aligns with the priority to identify breeding animals and 

would align with some existing State requirements. The working group acknowledges the 

potential confusion and difficulty of enforcing this requirement, thus recommends industry 

provide feedback on this issue.

3. LIMITING OFFICIAL IDENTIFICATION REQUIREMENT TO INTERSTATE MOVEMENTS

The most significant impediment to disease traceability resulting from 9 CFR Part 86 is the 

restriction that the official ID requirement applies only to livestock that move interstate. 

Cattle movements are quite diverse, often with multiple congregation points and 

opportunities for disease spread prior to interstate movement. An individual animal infected 

with a highly contagious disease may never leave the State where it was born, remaining 

unidentified while spreading disease to many other animals that subsequently move to 

several new states.

The regulation creates significant confusion in marketing channels where cattle of differing 

requirements may be mixed, as well as enforcement challenges and complications. The 

interstate ID requirement often places the onus on livestock markets, where the sorting and 

tagging of animals is often cumbersome and may fall short of full compliance. Additionally, 

the ability to determine compliance with the official ID requirement at slaughter plants is 

nearly impossible due to limited resources. 

Proposal

Cattle should be identified to their birth premises2, thus the official ID records must provide 

birth premises information for the animal. APHIS should revise Federal regulations to 

include interstate commerce and the appropriate authority – either USDA or State officials –

should establish regulations that trigger official ID requirements at:

 Change of ownership

 First point of commingling

 Interstate movement (may reflect no sale and no commingling)

4. ELECTRONIC IDENTIFICATION SYSTEM FOR CATTLE

Possibly the most significant change in stakeholder opinion since the establishment of the 

 

2 The phrase, “identified to birth premises” is referenced in this report. While it is preferred that cattle are tagged at 

their birth premises, it is acknowledged that there are situations where the tagging process can be accomplished more 

efficiently at subsequent locations. The phrase “identified to the birth premises” allows for tagging at other locations 

with the acknowledgment that the record of tag applied provides the birth premises information for the animal 

tagged.
17

current ADT framework in 2013 is an increase in support for EID for cattle. Stakeholders 

expressed interest in moving forward with EID, or specifically RFID, at each of the nine 

ADT public meetings in 2017. However, there continues to be some stakeholders that are 

not supportive of EID for livestock in general.

Many animal health officials, as well as industry stakeholders, acknowledge that the level of 

traceability necessary in the United States is unachievable with visual only tags. While the 

NUES tags, traditionally known as the metal clip “brite” tags are inexpensive to purchase, 

there is significant expense throughout the production chain associated with their use. 

Producers, market managers, accredited veterinarians and others express concern about 

animal handling challenges and economic losses created by the need to restrain cattle to 

manually read and record the official ID number on NUES. 

APHIS is conducting a study on the costs associated with NUES tags to reflect the full cost 

associated with the manual collection of NUES numbers and the inability to retire these 

numbers after slaughter due to expense.

The ultimate success of an EID system hinges on identifying a high majority of the cattle 

population with a compatible EID tag to gain the greatest efficiencies possible from the 

technology. Maintaining a parallel visual only eartag system that requires manual recording 

of ID’s on a significant portion of cattle would make the cattle handling processes more 

cumbersome and increase cost. 

Many additional questions exist when considering comprehensive EID solutions; 

particularly, regarding the cost of tags and readers and how to standardize the technology in 

order to ensure system compatibility across manufacturers. Multiple, or competing, EID 

technologies would cause significant confusion, conflicts, and financial challenges. 

Therefore, it will be highly desirable to define a single technology standard. It is also

essential that any new standards support the movement of animals at the speed of 

commerce3.

Proposal

The United States must move toward an EID system for cattle with a target implementation 

date of January 1, 2023. A comprehensive plan is necessary to address the multitude of 

very complex issues related to the implementation of a fully integrated electronic system. A 

specialized industry-lead task force with government participation should develop the plan, 

with a focus on several key objectives, including:

Standardization

 Propose minimum performance standards that work at the speed of commerce for 

all cattle handling environments at a highly effective read rate (e.g., >95% read 

rate). 

 Propose a non-proprietary, cost-efficient, and effective technology solution, based 

on results of performance evaluations that adhere to established technical 

communication standards and will ensure compatibility of devices across 

manufacturers.

 

3

Interpretation of “speed of commerce”: Referred to as, “compatible with existing accepted commerce systems; the ID 

device/method shall be compatible with existing accepted commerce systems, allowing for the reading/recording of 

official ID in a safe and humane manner at a pace that does not impede the normal and accepted processing time; and 

shall be compatible with Beef Quality Assurance (BQA) and Dairy Animal Care and Quality Assurance (DACQA) 

standards and practices.”
18

Transitional technology solutions

 Identify solutions that will “bridge” or incorporate other electronic solutions 

during a defined transition period (ensure workability of current/existing 

technologies). 

Timelines 

 Propose a realistic timeline with key steps to support the transition to a fully 

integrated EID system. Key steps should include: 

o Set a date for when visual only official tags will no longer be available 

(manufactured, distributed, sold or provided; including “brite” NUES 

tags from USDA). The objective would be to use a phase-out period to 

deplete visual tag inventories. Cattle with official visual only tags prior

and through the transition period would not need be retagged with an 

EID tag.

o Set a date for when all cattle needing official ID must be identified with 

official EID, e.g., January 1, 2023. Cattle with visual only tags after 

this date will require retagging with an official EID tag. 

Funding 

 Consider funding options for addressing cost concerns, such as,

o Federal startup funds.

o Startup incentives; cost share, etc.

o Allow small producers to obtain equivalent of volume discounts, etc. (e.g. 

1st 20 tags for $x.00 regardless of volume purchased).

o Spread cost equitably across industry sectors.

o Utilize funds currently in place to support NUES tag acquisition and 

distribution on EID investments.

In addition, the working group recommends the following actions related to EID:

 APHIS should first discontinue providing free NUES tags, then phase them out 

according to the EID implementation timeline. 

 Utilize compatible EID tags in all cattle disease programs, for example the 

brucellosis program should move to an orange Official Calfhood Vaccinate EID 

tag exclusively. 

 Reexamine the requirement to record existing official ID numbers when applying 

an EID tag to individual animals already officially identified with visual only tags. 

Waiving the recording of the official number of the visual tag(s) when first 

enacting the official EID tag requirement will help minimize the burden to the 

industry to fulfill this requirement.

 Solicit industry and other stakeholder feedback on the proposed plan after 

publication by the task force. USDA should only consider rule making that 

defines the selected official EID method for cattle if a majority of the cattle 

industry is supportive of the proposed EID implementation plan.

 Develop an extensive communication plan to support the clear understanding of 

future requirements. 
19

5. ADMINISTRATION OF ELECTRONIC RECORDS

The working group acknowledges that the full utilization of electronic records is essential 

for effective administration of the ADT program and considers them part of the overall 

electronic system. Tremendous gains have been achieved over the past several years in 

increasing the volume of electronic records to support animal disease control programs. In 

addition, the establishment of independent State surveillance and traceability information 

systems has been well received. However, data sharing between these independent systems 

is becoming an increasing issue of concern among animal health officials since there is no 

established mechanism for data sharing from State to State or between Federal and State 

systems. The investments in obtaining electronic records, particularly converting paper 

based forms to electronic media, has been both successful and costly. Opportunities to 

capture data electronically in the field is highly supported and essential to minimize ongoing 

and costly data entry and scanning processes associated with paper documents.

Proposal

APHIS and States must make the advancement of electronic records an immediate high 

priority. The enhancements recommended below would increase the ease of collecting data 

in a standardized format and subsequently provide access to accurate data in near real-time, 

greatly enhancing the effectiveness of U.S. traceability and disease control programs. The 

responsible parties should address the following points:

Data Element Standardization and Communication Protocol for Information Exchange

 APHIS should develop an expandable messaging service independent of all 

sending or receiving data systems, to support information sharing among States 

and Federal stakeholders without concerns about the type of systems originating 

or receiving the data.

 Address shortfalls in the USAHA Data Standards subcommittee-developed 

electronic ICVI schema; implement state requirements for electronic ICVI 

vendors to adhere to standardized formats; and confirm USDA adherence to the 

standard in the Veterinary Services Process Streamlining (VSPS) system while 

providing the ability for sharing and receiving information from other ICVI 

systems.

 Develop a data exchange schema for surveillance events such as tuberculosis 

testing, brucellosis testing, and vaccination.

 APHIS should provide a web-based application available to State and Federal 

animal health officials and accredited veterinarians for uploading and manually 

entering testing, vaccination and movement information, generating the 

associated forms if necessary and allowing electronic data capture from the web 

application into the above messaging service. 

Animal Health Event Repository (AHER) 

AHER provides a comprehensive search tool for internal APHIS data systems that store 

animal records containing official ID numbers, including VSPS, Surveillance Collaboration 

Services (SCS), Animal Identification Management System (AIMS) and the Emergency 

Management Response System (EMRS). Access to AHER is currently only available 

through an EMRS investigation or the TPM utility.

 Develop external State and private system messages that feed into the above 
20

messaging service to forward metadata information to AHER.

 Fund private system message development through ADT cooperative agreements 

and invite States to participate at their discretion. Make improvements to the 

existing user interface to assist with other types of animal tracing queries while 

providing clear and concise results.

6. ENFORCEMENT OF ADT REGULATIONS

A high level of compliance with the ADT regulations is imperative for successful animal 

tracing results. The working group discussed feedback from the public meetings regarding 

the need for greater uniformity of enforcement, particularly concerning private treaty sales. 

They also note that increased levels of monitoring are necessary in environments where 

disease spread is a higher risk and where the disease event would have the most significant 

impact. These locations are where cattle commingle from various premises and then move to 

multiple additional premises. Such congregating locations include livestock markets, 

buying stations, consignment sales, etc. The working group also notes that fewer exemptions 

and revising the regulation to cover more than interstate movement would improve the 

ability to monitor for compliance as the current rule allows for many cattle to move 

unidentified. These exemptions and limitations complicate the recognition of animals 

moving interstate not in compliance with the official ID requirement. 

Proposals 

 Continue to target noncompliance by repeat offenders with enforcement actions.

 Work with IES to conduct more timely investigations.

 Maintain a higher level of enforcement oversight at locations where there is a 

higher risk of disease spread, or which would have the most detrimental impact 

on the industry.

 Evaluate and implement appropriate enforcement procedures for private sales, 

internet sales, production sales, herd dispersals, etc.

 Work with transportation agencies to perform spot-checks on highways and at 

transport nodes to monitor compliance with the ADT regulations during 

movement of animals. 

 Cooperate with States that have resources in the field that could help document 

and report noncompliance situations to the local VS office and APHIS IES 

personnel.

 Encourage States of destination to inform States of origin of ADT or other 

violations.

 Survey State and Federal officials to establish a comprehensive listing of 

compliance oversight methods used across the country.

 Obtain specific proposals from participants attending the NIAA Traceability 

Forum.

 Share recommended practices and enforcement methods nationally and 

encourage local APHIS officials to work collaboratively with State animal health 

officials to implement appropriate actions.

 Activities of cattle dealers, online auctions and others involved in commercial 

buying/selling of cattle should be enforced by the State when dealer licensing 
21

regulations apply.

 Collaborate with FSIS to ensure collection of ID by slaughter facility personnel

and correlation with the animal and its carcass through final inspection. (For 

more on this topic, please see proposal 7.)

7. COLLECTION OF ID AND ITS CORRELATION TO THE CARCASS AT SLAUGHTER PLANTS

Successful traceability relies on maintaining the animal’s identity at slaughter plants through 

final carcass inspection. Under 9 CFR Parts 86 and 310.2, all ID devices affixed to covered 

livestock unloaded at slaughter plants must be collected and correlated with the animal and 

its carcass through final inspection or condemnation by means approved by the FSIS. ID 

devices must also be packaged with any diagnostic samples from the animal. Success at 

meeting these requirements is inconsistent across the industry, due to factors such as lack of 

training and personnel turnover, as well as safety and efficiency concerns related to the 

collection of ID at the speed of the line. Failure to properly correlate ID to the correct 

carcass hampers traceability efforts and diminishes the value of the official ID.

Proposal 

APHIS should continue the efforts of the State/Federal Slaughter Plant Working Group to 

improve the rates of ID collection and correlation at slaughter including:

 Development of training and outreach materials on the requirements for new 

plant, FSIS, and APHIS personnel.

 Monitoring of diagnostic submissions collected to ensure slaughter plants 

sufficiently apply correlation practices.

 Maintaining constant communication and collaboration with FSIS to assist 

slaughter plants with correction of failed collection and/or correlation practices. 

8. PUBLIC/PRIVATE INFORMATION SYSTEM 

Confidentiality and security of data remains a significant concern by many cattle producers 

and must be resolved to strengthen industry buy-in and support for advancing traceability. 

Private information systems that support various marketing programs, including AMS PVP, 

branded products, etc. include traceability data that could assist in achieving ADT 

objectives.

Proposal

APHIS and States need to establish a partnership with industry that would enable utilization 

of private information systems for disease surveillance and response events. Ideally, 

establish a communication protocol between the private systems and an animal disease 

traceability portal that would allow producer data to be maintained in the private systems

and made available to animal health officials only when needed for animal disease control 

and response. Producers would have the choice to maintain their data in a private or public 

system. APHIS and the States would continue to protect producer data held in their systems 

and use it only for disease response. The basic concept of the communication protocol 

should account for:

 Defining data elements and standards for traceability information to which 

private systems would adhere (primarily official ID numbering formats and 

premises data).
22

 Developing a communication protocol that would allow a government portal to 

message the private system when a search for animal numbers or premises is 

necessary to respond to an animal disease event. 

 Limited access – only State and Federal animal health officials would have 

access to the portal.

9. EXEMPTIONS FOR OFFICIAL IDENTIFICATION REQUIREMENTS

Stakeholders broadly acknowledged that the exemptions for official ID create confusion and 

challenges to enforce ADT requirements uniformly. The working group reviewed each 

official ID exemption provided in 9 CFR Part 86.4. The direct to slaughter movements – in 

particular, those through one approved facility – are of the most concern; however, 

providing a simple revision to resolve this issue is challenging and needs additional input 

from the industry. 

Referenced below are the exemptions to the current official ID regulations with 

corresponding proposals. (See Appendix III for complete regulatory text for the official ID

exemptions.)

Proposal 

Commuter herd agreements

APHIS should remove the exemption for official ID. The requirement for individually 

listing the animals’ ID number on the movement document should allow for a range of 

numbers when a high majority of the animals covered under the agreement has official ID 

numbers within that range, or as agreed upon by the State animal health officials.

Movements directly from a location in one State through another State to a second location 

in the original State

The working group maintains the current position that APHIS should not require official ID

for these movements.

Tagging sites

APHIS and States should maintain the option to move cattle to a tagging site where they are 

tagged on behalf of the owner or person responsible.

Official identification options as agreed on by shipping and receiving State 

APHIS should remove this exemption allowing alternative methods of ID.

Direct to slaughter movements

The working group recommends APHIS: 

 Continue to allow cattle to move from the farm/ranch direct to slaughter on an 

approved USDA backtag in lieu of the official ID eartag, and retain the 

stipulation that requires official ID of cattle moved from the slaughter plant.

 Remove the exemptions for cattle moving to slaughter through one approved 

livestock facility, unless industry, State, and Federal officials collaborate to 

administer specific control protocols to ensure that these animals move direct to 

slaughter from the approved facility. 

 Consider phasing out the official ID exemptions for direct to slaughter 

movements, based on the EID implementation timeline, to ensure all cattle 

covered in the regulation arrive at the slaughter plant with the same technology 
23

tag. 

10. ICVI EXEMPTIONS AND MOVEMENT DOCUMENTS 

The working group reviewed the importance of ICVIs and the challenges they present. As 

noted in the section on electronic records, the working group believes continued emphasis 

on electronic ICVIs and other electronic movement records are a high priority. While the 

working group is not offering a specific change to the ICVI requirements, they provided 

the following proposals.

Proposal

Obtaining the key components of traceability – accurate and complete records of official 

ID numbers and the ship from and ship to locations – is critical to ADT program success. 

In anticipation of technology changes (specifically EID) and acknowledgement of regional 

differences in the availability of accredited veterinarians, States should consider use of 

movement documents, such as import permits or other documents that States have used 

successfully, as alternatives to ICVIs. Stakeholders support consistent requirements; 

however, the State of destination should be responsible for determining the documents 

appropriate for collection and compliance of key traceability components for livestock 

arriving to that State. 

The working group provided further proposals regarding ICVI exemptions below:

 Direct to slaughter, including through one approved facility: The ICVI exemption 

for direct to slaughter cattle is appropriate and should remain. The current 

exemption for slaughter movements through one market must be restricted to one 

market movement regardless if it is an interstate or intrastate shipment.

 Direct to an approved facility with an owner-shipper statement: There is concern 

about the exemption for interstate movements to an approved facility when the 

cattle move from the approved facility to a premises other than a slaughter plant. 

The current regulation allows for the exemption unless the cattle move interstate 

from the market. Removing this exemption and changing the regulation to cover 

change of ownership would address this issue.

 The ability for cattle to move under commuter herd agreement documents as 

agreed upon by the State animal health officials should remain. As noted in the 

official ID exemptions, the State authorities involved will determine if the listing 

of individual numbers is required or range of numbers is acceptable on 

movement documents for commuter herds.

11. UNIFORMITY OF STATE IMPORT REGULATIONS

The working group reviewed the stakeholder feedback pertaining to the confusion and 

difficulties that result from variations in State import regulations. The working group 

suggests limiting the exemptions to 9 CFR Part 86 to clarify and improve the uniformity of 

the federal requirements across States. For example, eliminating the option for the shipping 

and receiving States to agree on other forms of official ID would help standardize the 

official ID requirements. 

The working group also noted the need to review official ID requirements separately from 

those associated with testing and other health issues. For example, many of the health 

requirements established by States are those that industries within their State have 
24

requested to protect the health of their cattle operations and such issues are often specific 

to certain regions. The working group did not support expanding health requirements to 

achieve uniformity, as it would actually lead to more import regulations across the country 

and would be unwarranted from an animal disease control perspective.

Proposal

9 CFR Part 86 should provide the national standards for official ID and movement 

documentation. APHIS should continue revision of the regulations to increase 

standardization considering that eliminating various exemptions will lessen confusion and 

State differences. 

 The promotion of the website InterstateLivestock.com should expand to 

encourage increased use by accredited veterinarians, producers, livestock 

markets and others who need information on State import regulations. 

 It is essential that States maintain the ability to establish more stringent import 

requirements. 

 Uniformity of State regulations is important to increase the understanding of and 

compliance with import regulations. However, because disease issues are unique 

to certain areas of the United States, States should regionalize animal health 

import requirements as appropriate.

12. UNIFORM OFFICIAL IDENTIFICATION EARTAGS

There are differing views on allowing numerous tag types (size, shape, color, etc.), using 

bangle-like official eartags for both management and official ID purposes, or using one 

distinct standard tag for official ID. Some producers prefer the same tag for both 

management and official ID purposes, as it makes the tagging process more efficient. 

Others indicate a preference for a standard tag for official ID since many producers prefer 

to remove tags with existing herd management numbers when buying replacements from 

other dairies and ranches. Comments from stakeholders suggest that one standard tag 

would increase recognition of official ID and as a result, decrease the accidental removal 

of official tags. Additionally, there is support for AMS and APHIS to achieve uniformity 

of devices for both programs. Manufacturers of official ID eartags also indicate that a 

standard tag would improve manufacturing efficiencies and lower the cost of the official 

tags.

Proposal

The working group feels there is value in considering a standard, or uniform, official eartag 

to increase awareness and understanding that it is unlawful to remove the tag. APHIS 

should conduct a study to determine the potential advantages and disadvantages of having 

one national ID eartag for cattle. The study should examine the merit a standardized tag 

might bring to ease of recognizing official tags and its effect on compliance. The study 

should also include cost comparisons of the use of numerous tag styles, sizes, etc. versus 

one standard, uniform tag. APHIS should review this information and, if having one 

uniform tag has significant advantages, publish the one tag concept for public comment 

through the Federal Register. The actual change, if pursued, would require rulemaking. 

13. OFFICIAL EID TAG FOR IMPORTED CATTLE 

The definition of official eartags in 9 CFR Part 86.4 stipulates that the application of 
25

animal ID number (AIN) tags (commonly referred to as “840 tags”) is limited to livestock 

born in the United States. As a result, there is no official EID tag with LF technology 

available to retag imported animals. This has created some challenges in the marketplace. 

For example, regulations prohibit dairies that use 840 AIN LF tags for herd management, 

including parlors with integrated daily milk recording systems, from retagging a Canadian 

import with an 840 eartag. Since there is no official LF EID device, the producer is limited 

to retagging with a visual or UHF NUES tag and neither tag is compatible with their 

electronic herd management system. Conflicts with cattle shows that require AIN LF 

eartags are also becoming more common. This issue will become a more significant 

challenge if the United States moves to official EID in the future.

Proposal

The ability to maintain the identity of imported cattle is essential. As such, the working 

group recommends that APHIS allow the retagging of such animals with an official EID 

tag by revising the traceability regulation to define an “Import Tag” (with a specific range 

of AINs and tag color). For example, APHIS could reserve a range of 840 numbers starting 

with “8409” for use on these tags. To help distinguish “Import Tags” that have a panel 

component, the panel piece of the tag should include the text “Import”. This ID option 

would clearly identify animals tagged with an 840 Import Tag after importation to the 

United States; provide producers the option to use compatible EID technologies as 

preferred; and allows for re-tagging visual only tagged imported cattle with an 840 EID 

Import Tag (even if the visual only official tag of the exporting country is in the ear). 

Producers using UHF technology could use USDA approved UHF 840 tags or the USDA 

approved UHF NUES tags when the State Animal Health Official authorizes this option. 

The recordkeeping requirements for tagging imported animals would remain the same as 

currently written in 9 CFR Part 86 for retagging and adding a second official tag. The 

working group recommends that APHIS prohibit the use of visual only 840 tags in 

imported animals.

14. OFFICIAL IDENTIFICATION OF BEEF FEEDERS 

The inclusion of beef feeder cattle in the traceability regulations is an essential component 

of an effective traceability system in the long term. However, addressing other 

fundamental gaps in the traceability framework must occur first. The working group values 

the feedback from stakeholders regarding the official ID of beef feeder cattle under 18 

months of age, and agrees with these points provided by stakeholders: 

 Extensive collaboration with industry stakeholders potentially affected by the ID

of beef feeders is critical, and official ID of this sector would require separate 

rulemaking to ensure appropriate review. 

 Tagging large numbers of beef feeder cattle is not practical or feasible at 

livestock markets during peak periods of feeder sales. Therefore, alternative 

processes need to be established.

 Consider the timely development of a plan for the inclusion of beef feeders in the 

official ID requirement. This proactive approach will ensure well-defined 

processes are in place in the event their inclusion is necessary in response to a 

worst-case scenario animal disease event with minimal advance notice, such as 

an outbreak of FMD. 
26

 Consider incremental steps for the official ID of beef feeders, particularly 

policies that allow official ID to the birth premises. Recording of official ID

numbers for movement should be implemented over time as technology is highly 

proven to work at the speed of commerce. 

 Providing the option of tagging beef feeder cattle at the next location upon 

transfer of ownership, including auctions, feedlots and other locations that 

receive these cattle is essential. 

 The USDA should conduct studies to document the level of traceability 

necessary for this sector and its cost/benefit. 

The working group agrees with these statements above and reaffirms that APHIS should 

address the official ID of beef feeder cattle under 18 months of age through separate 

rulemaking.
27

Appendix 

Appendix I – List of Acronyms

ADT Animal Disease Traceability

AIMS Animal Identification Management System

AIN Animal Identification Number

AMS Agriculture Marketing Service

APHIS Animal and Plant Health Inspection Service

CFR Code of Federal Regulations

EID Electronic Identification 

EMRS Emergency Management Response System

FMD Foot and mouth disease

FSIS Food Safety Inspection Service

ICVI Interstate Certificate of Veterinary Inspection 

ID Identification

IES Investigative and Enforcement Services

IT Information Technology

LF Low Frequency

NIAA National Institute for Animal Agriculture

NUES National Uniform Eartagging System

OSS Owner-Shipper Statement

PVP Process Verification Program

RFID Radio Frequency Identification

SCS Surveillance Collaboration Services

TB Tuberculosis

TPM Trace Performance Measure

UHF Ultra-High Frequency 

USAHA United States Animal Health Association

USDA United States Department of Agriculture

VS Veterinary Services

VSPS Veterinary Services Process Streamlining
28

Appendix II – Working Group on Slaughter Plant ID Collection & 

Correlation

On November 9, 2016, APHIS established a working group to address traceability issues and short 

falls noted in the ADT assessment report.

Objective: Improve the rates of ID collection and correlation to the carcass at slaughter plants, to 

maximize ADT efforts related to disease programs and surveillance efforts. 

Specific goals for the working group include:

1. Review ID collection and correlation processes obtained from the top 40 adult and top 22 

fed cattle plants to determine best practices for application to all plants, especially those with

demonstrated difficulty in proper ID collection and correlation.

2. Develop and implement a plan for routine DNA matching on non-histocompatible VS Form 

6-35 submissions to closely monitor proper correlation of ID to the carcass.

3. Develop a protocol for outreach to plants regarding cases where DNA microsatellite test 

results indicated that tissue/hair associated with ID did not match the lesioned tissue 

submitted or matching was not possible because no tissue was submitted with the ID.

4. Develop elements for training State/VS field personnel on inspection of ID collection and 

correlation systems within slaughter plants.

5. Collaborate with FSIS to develop and implement training for FSIS Public Health 

Veterinarians and Inspectors on oversight of ID collection and correlation systems within 

slaughter plants.

6. In instances requiring additional information for a lot of cattle that contained diseased 

animals (from which samples were taken and submitted for diagnostic testing), there is often 

no data available from many adult-kill plants to assist with reconstructing correlation in 

retrospect since brucellosis blood sampling ceased. Evaluate the capability of adult-kill 

slaughter plants to reconstruct correlation of man-made ID to carcasses within a lot that 

contained diseased cattle for one (1) week after slaughter of such diseased cattle, and

develop a plan to address this lack of capability where it exists. 

7. Develop a guidance document with FSIS for ensuring the issuance of compliance actions for 

slaughter plants that fail to properly collect man made ID and correlate it to the appropriate 

carcass.

8. Update the FSIS ADT MOU.
29

The working group listed below meet monthly via conference call. 

Name Affiliation

Pat Basu Chief Public Health Veterinarian - FSIS, OPHS

Brian Bohl TAHC Veterinarian, TX

Debbie Cox VS Cattle Health Staff FSIS Liaison

Sunny Geiser-Novotny VS Cattle Health Staff/ ADT Veterinarian

Neil Hammerschmidt VS Traceability Program Staff

Robert Kerschen VS EC, CO

Bob Meyer Assistant State Veterinarian, WY

Kent Munden VS Animal Identification Coordinator, TX

Barry Pittman State Veterinarian, UT

Mark Schoenbaum VS Cattle Health Staff Epidemiologist

Rob Southall VS Assistant Director, KY

Dawn Sprouls District Manager, OFO

Debbie Sumpter VS Animal Identification Coordinator, CA

Beth Wittenbrader VS Animal Health Technician, PA
30

Appendix III – Official Identification and ICVI Exemptions

Regulation text from 9CFR Part 86.

§ 86.4 Official identification.

(b) Official identification requirementsforinterstatemovement—

(1)Cattle and bison. (i) All cattle and bison listed in paragraphs(b)(1)(iii)(A) through (b)(1)(iii)(D) ofthissection

must be officially identified prior to the interstate movement, using an official identification device or method

listed in paragraph (a)(1) of this section unless:

(A)The cattle and bison are moved as a commuter herd with a copy of the commuter herd agreement or other

documents as agreed to by the shipping and receiving States or Tribes. If any of the cattle or bison are shipped

to a State or Tribe not included in the commuter herd agreement or other documentation, then these cattle or

bison must be officially identified and documented to the original State of origin.

(B)The cattle and bison are moved directly from a location in one State through another State to a second location

in the original State.

(C)The cattle and bison are moved interstate directly to an approved tagging site and are officially identified

before commingling with cattle and bison from other premises or identified by the use of backtags or other

methods that will ensure that the identity of the animal is accurately maintained until tagging so that the

official eartag can be correlated to the person responsible for shipping the animal to the approved taggingsite.

(D)The cattle and bison are moved between shipping and receiving States or Tribes with another form of

identification, as agreed upon by animal health officials in the shipping and receiving States or Tribes.

(ii) Cattle and bison may also be moved interstate without official identification if they are moved directly to a

recognized slaughtering establishment or directly to no more than one approved livestock facility and then

directly to a recognized slaughtering establishment, where they are harvested within 3 days of arrival; and

(A)They are moved interstate with a USDA-approved backtag; or

(B)AUSDA-approvedbacktagis applied to the cattle or bison at the recognized slaughtering establishment

or federally approved livestock facility.

(C)If a determination to hold the cattle or bison for more than 3 days is made after the animals arrive at the

slaughter establishment, the animals must be officially identified in accordance with §86.4(d)(4)(ii).

§ 86.5 Documentation requirements for interstate movement of covered livestock.

(c) Cattle and bison. Cattle and bison moved interstate must be accompanied by an ICVI unless:

(1) They are moved directly to a recognized slaughtering establishment, or directly to an approved livestock

facility and then directly to a recognized slaughtering establishment, and they are accompanied by an 

owner-shipper statement.

(2) They are moved directly to an approved livestock facility with an owner-shipper statement and do not

move interstate from the facility unless accompanied by an ICVI.

(3) They are moved from the farm of origin for veterinary medical examination or treatment and returned to

the farm of origin without change in ownership.

(4) They are moved directly from one State through another State and back to the original State.

(5) They are moved as a commuter herd with a copy of the commuter herd agreement or other document as

agreed to by the States or Tribes involved in the movement.

(6) Additionally, cattle and bison may be moved between shipping and receiving States or Tribes with

documentation other than an ICVI, e.g., a brand inspection certificate, as agreed upon by animal health 

officials in the shipping and receiving States or Tribes.

(7) The official identification number of cattle or bison must be recorded on the ICVI or alternate

documentation unless:

i. The cattle or bison are moved from an approved livestock facility directly to a recognized slaughtering

establishment; or

ii. The cattle and bison are sexually intact cattle or bison under 18 months of age or steers or spayed

heifers; Except that: This exception does not apply to sexually intact dairy cattle of any age or to cattle

or bison used for rodeo, exhibition, or recreational purposes.