The concept of animal ID is not new, in the United States or abroad. For decades, American producers have kept records on, and used ID methods for, livestock animals for both commercial and regulatory purposes. Specifically, several USDA and state animal disease eradication programs—such as programs for tuberculosis (TB) in cattle, pseudorabies in swine, and scrapie in sheep and goats—include animal ID requirements. Certain species and classes of animals require officially recognized ID devices for interstate commerce, and all live animals imported into, or exported from, the United States require official ID. Thus, many livestock animals are already identified in the United States by ear tags, branding, tattoos, or other devices. However, the use of ID devices varies by breed, species, and state, and, until NAIS, no attempt had been made to create a uniform animal ID system of national scope and across multiple species using a universal numbering system and central data repository. Due to serious concerns about the United States’ ability to safeguard its livestock from the harmful effects of disease, in 2002, the National Institute of Animal Agriculture—an organization of producers, veterinarians, scientists, government representatives, and allied industries—initiated a state-USDA-industry task force of approximately 70 representatives to create a national animal ID system. In 2003, USDA expanded upon this work and established a development team consisting of more than 70 industry associations, organizations, and government agencies. That team ultimately produced the United States Animal Identification Plan in December 2003, which provided the foundation for NAIS. Although early versions of the plan focused on food animals only, other livestock species were later incorporated. The plan was being finalized when the nation’s first case of BSE was confirmed on December 25, 2003. Five days later, the Secretary of Agriculture announced measures to guard against BSE and indicated that USDA would expedite the implementation of a national animal ID system. Since 2004, USDA has solicited public comments on draft NAIS policy documents, held public listening sessions, and met with industry groups and others in its efforts to design and implement NAIS. In addition, USDA has received input from 10 working groups comprising producers, academics, and others representing the various livestock species and industry sectors currently included in NAIS. These working groups make recommendations to the NAIS Subcommittee, a group of state and industry stakeholders established by USDA in September 2004 to provide regular, formal input to the USDA Secretary’s Advisory Committee on Foreign Animal and Poultry Diseases (full committee) about how NAIS should progress. The NAIS Subcommittee is also responsible for receiving input from the National Institute of Animal Agriculture; the United States Animal Health Association, an organization representing state veterinarians and allied industry groups; and other organizations and individuals. The full committee is a federal advisory group of state, academic, and industry experts selected by the Secretary, which meets once a year or as deemed necessary by the Secretary. While the NAIS Subcommittee meets periodically, the full committee has met only twice— in September 2004 and September 2006—since the creation of NAIS. USDA is not obligated to take action on the NAIS Subcommittee’s, full committee’s, or others’ recommendations. For the premises registration component of NAIS, states and tribes are responsible for submitting premises information—given to them by producers and others—to a central, Web-based USDA premises database. In turn, USDA allocates a unique, 7-digit, alphanumeric, premises ID number (e.g., A123B45). The premises then receives confirmation online or by mail from the relevant state or tribe with its unique premises ID number. For the animal ID component, USDA published an interim rule, effective in November 2004, recognizing the Animal Identification Number as a new, official numbering system for individual animals in interstate commerce. Producers and other NAIS participants can order ID devices from USDA- approved managers that are imprinted with a unique, 15-digit Animal Identification Number for use on animals that move through the production process as individuals, as is typical in the cattle, sheep, and goat industries. Figure 1 shows a calf that is identified with tags in both ears, with the calf’s left ear bearing an electronic tag and its right ear bearing a visual tag. Both tags have the Animal Identification Number for official ID purposes, and the visual tag also has a number used for the producer’s herd management purposes. For animals of the same species that typically move through the production chain as a group, such as commercial poultry and swine, producers can instead identify the animals with a group/lot ID number. Group/Lot ID numbers are self-generated by the premises (not assigned by USDA) and are maintained at the premises in management records. Lastly, for the animal tracking component, USDA has developed the Animal Trace Processing System to allow state and federal animal health officials to request information, in the event of an animal health investigation, from multiple private and state animal tracking databases containing animal location and movement records. Producers and others are responsible for reporting certain animal movements, such as when a change of ownership occurs or when animals commingle with other herds or flocks. Events that would enable state and federal animal health officials to request information from this network of databases include an indication or a confirmed positive test of a foreign animal disease, an animal disease emergency as determined by the Secretary of Agriculture or state departments of agriculture, or a need to conduct a trace to determine the origin of infection for a domestic disease of concern. (See app. II for a list of domestic and foreign animal diseases of concern identified by USDA.) USDA has steadily increased the number of livestock premises registered in the nation and has taken some steps to address stakeholder concerns in implementing NAIS. However, the agency has not effectively addressed a number of key issues identified by livestock industry groups, market operators, state animal health officials, and others that, if not ultimately resolved, could undermine the program’s goal of rapid and effective traceback, thus hindering its success. USDA’s decision to implement NAIS as a voluntary program without benchmarks to measure progress may affect the agency’s ability to attract the necessary levels of participation to quickly and efficiently locate all animals potentially exposed to a disease. In addition, USDA has not prioritized the implementation of NAIS by species or other criteria. Furthermore, USDA has not developed a plan for integrating NAIS with other USDA and state animal ID requirements, nor has it established a robust process for selecting, standardizing, and testing ID and tracking technologies. The agency also does not clearly define the time frame for rapid traceback. Finally, USDA does not require potentially critical information for efficient traceback to be recorded in NAIS databases. During the first 2 years of the program’s implementation, USDA stated several times that participation in NAIS would initially be voluntary but would eventually become mandatory to achieve full participation and, thus, the goal of rapid and effective traceback. One of USDA’s first major NAIS policy documents, the Draft Strategic Plan 2005-2009, released in April 2005, stated that during initial implementation, participation would be voluntary so that stakeholders could have the opportunity to obtain experience with the program and provide feedback as successful and practical solutions evolved. The plan also provided a timeline for implementation, with premises registration and animal ID to be required by January 2008 and the reporting of defined animal movements to be required by January 2009, under what would become an entirely mandatory program. The plan stated that this phased-in approach was “to support the transition from voluntary to mandatory as full implementation is achieved.” In addition, the plan also stated that, “While market forces may eventually create more inclusiveness, the clear stakeholder support for transitioning to a mandatory program and the urgency of achieving the goal, suggest that setting a date for that transition would benefit the program.” Later, the April 2006 Strategies for the Implementation of NAIS set benchmarks that were intended to gauge progress in attaining full participation. These benchmarks called for gradually increasing the percentages of premises registered, animals identified, and animals tracked from January 2007 through January 2009. Specifically, for premises registration, USDA aimed for 25 percent participation by January 2007, 70 percent by January 2008, and 100 percent by January 2009. In addition, the implementation plan called for 40 percent of animals being identified by January 2008, 100 percent of “new” animals less than 1 year of age being identified by January 2009, and 60 percent of new animals having complete tracking data by January 2009. USDA stated that it would evaluate whether participation levels were increasing at rates that would achieve full participation by 2009, and that, if this were not the case, USDA would develop federal regulations to require industry to identify their premises and animals. In May 2006, in an announcement for NAIS cooperative agreements, USDA stated that it anticipated promulgating regulations by early 2008 to require participation in all three components of the program. Furthermore, in a document supporting its fiscal year 2007 budget submission to OMB, USDA stated that the intrinsic value of its investment in NAIS was based on the assumption that there would be sufficient animal ID and movement data available to support the program’s traceback goal. USDA also said that if participation fell below expectations, traceback would periodically fail because of the lack of animal tracking information from nonparticipants. However, in August 2006, reporting that 20 percent of the nation’s premises had been registered, USDA decided that NAIS would permanently remain a voluntary program. USDA officials told us that due to opposition from some industry groups, it is imperative that industry advance the program, rather than government regulations, to encourage participation. Some industry groups believe that NAIS could succeed as a voluntary program or that USDA first needs to resolve several key implementation issues before making participation mandatory.