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WORK GROUP III Group Leader: Dr. Neil Anderson Identification Technology Group This group will define and seek solutions to unresolved issues pertaining to modern identification technology that have, in the past or may in the future, stand in the say of widespread use of these systems in the livestock industry. Such issues may include FDA approval of transponder implants, standardizations, universal coding, federal regulatory requirements, etc.
Work Group III Report* By Dr. Neil Anderson * Recorded by audiotape. Some portions inaudible. Our group was to define and seek solutions to unresolved issues pertaining to modern ID technology that had, in the past or may in the future stand in the way of widespread use of these systems in the livestock industry. Several issues were cited. I will refer to them in a moment but I wanted to tell you how we organized and what we did. First of all, we sort of went into a free wheeling mode and listed a number of concerns that we thought related to technology and we had a wide range of representation so that I felt we were able to bring everyone to the table. Personally I had fairly modest expectations for this as follows. First of all I was hoping that we could say something that wasn’t said in 1988. Whether we succeeded in that I don’t know. I have great concern that we mouth the same phrases and say the same things. To the credit of the group that I was associated with, I found people willing to deal out on to the table and maybe we haven’t yet identified those common areas that we can work together on. But, I can tell you I was much encouraged by the willingness of those who have proprietary information that for the continuance of their company, they have to keep something on the inside pocket but at least they were willing to go as far as they possibly could to advance this whole matter. Then, one of our modest expectations was to avoid saying the obvious and that is saying a lot for me. I have made an academic career out of saying the obvious and I think many of us have as well. Number three, we very simply wanted to avoid fisticuffs. So we ended up with a simpler view of the world than these excellent retorts that we have presently heard. For better or worse, we organized it in the following manner. We felt that the producers and their potential economic advantage was likely to be a greater driving force than regulatory concerns. That we are different from the European community in which the experience is that there is enough political will and a social organization that permits, for instance in the dairy industry, and in a country the size of Holland for example or Denmark and I am just using these as examples, so that a top down system can be put in place that is centrally planned, workable and acceptable. In this country, a somewhat larger country, we have a more diverse country, a history of doing things in a somewhat different way. It is our sense that while legislation on the books to protect the public, which is what generates all of the regulatory concern and properly so, that is, at least in our midrange view, not likely to be the primary driving force. As evidence of that, in a number of meetings that I have been at, APHIS is clearly stating that they won’t buy interrogators until they know that one interrogator will do everything that comes through the plant. That clearly states to me their position. I don’t criticize them for it, I am glad they are up front about it. Then we know where things are insofar as they are concerned. We must remember from the standpoint of regulation that they have a long history of working up systems that work for them in terms of a variety of ways of identifying visually as back tags. So, what we came down to is that if there is to be a driving force, the rest of this century and into the early years of the next century, it will be found where there is an economic advantage that can be identified by the producer that will make it desirable to buy products that we sell in our trade show here. Once again, I would like to give credit to those that both operated the trade show for our benefit, those of us who aren’t in that end of the industry and attended the session that I was in. So we make our principal point that in terms of the utilization of this technology, the economic advantage of producers of livestock would be characterized as follows: That they can identify something that is value based and here I see us coming to some extent, to a point where we must persuade the processing, the packers and the distributors, that they can gain something from this as well. I don’t know if that is going to be easy because they have a value based system. They know the value of the products that they produce. If we send them two steers that differ by $230, that is where they carve out some of their profit. If the producer wants to play in that game and be able to provide a uniform product, whether that is done by an individual producer or more likely through a common gathering point like a feed lot, then we are taking some of the action away from them. Whether to leave them enthusiastic about participating in this and sending information back to us, the producer, remains to be seen. There must be a marketing edge for the producer then, in utilizing this technology. It must be user friendly if producers are asked if they would like to have this information available to anyone who wants it, they are likely to say no. So the matter of confidentiality has to be dealt with. There have been stated through the two previous reports, that there is great species variance in regard to application. Either application during the life of the animal or the way in which technology can be applied to the advantage of that species producer. For example, the sheer distance through which the signal can be detected is no small matter. Dr. Spahr showed examples of a cow going through a doorway. That is one system. Another system is holding something up to the ear and the difference between two inches and four inches and two feet or three feet is a big issue that has to be dealt with. Then we talked about whether the ISO standard frequencies are going to permit us to have that latitude in terms of interrogation. We agreed that a number of these issues are going to have to continue under some sort of a working group and perhaps that can be part of our outcome here. It also had to be to the economic advantage of the producers or distributors, the sellers of devices. If there isn’t something in it for them, then we are not likely to see much interest on the part of entrepreneurs to have this available for producers. So, reading distance was of importance. Now, here I am saying something that I know was said in 1988, unique, unalterable and permanent, that is fine insofar as it goes. I think we finally came down with the idea that using this technology to keep people honest is probably more than the technology can deliver in that those who are evil will always be able, in specific instances, to find ways to cheat those who are good. And so, the prevention of theft of animals by the use of these devices probably isn’t going to happen. Preventing misrepresenting animals in the show ring is also of some question, but I think if we focus on the major issues, those can be dealt with in due time. Insofar as the people who make and sell devices, the ISO standards were of considerable interest and importance to them. It is a guide to their industry. I think each one of those people would say that they chafe under some of the outcomes that are expected from the meeting that Dr. Spahr cited to us. Once again, they want to present something that is user friendly. Finally, under regulatory concerns, the first point of application in the marketing stream is very likely to be different for different species and different in terms of age depending on the end use of that species. Finally, while traceback is so important for food safety whether it involves microbial agents or residues and we acknowledge that as being of importance, we doubt that it will soon result in the application of electronic ID to resolve those issues or to deal with those issues at the regulatory level. I think we see them doing it with systems that they already have in place and that they are not so likely to be major players in terms of bringing those on line. With respect specifically to FDA, and Dr. Mitchell was kind enough to attend our session he reviewed the issue of disposal and reiterated that the primary concern of the agency is: how the presence of this device will likely impact human food safety or public safety. It was of secondary concern as to how or whether this product, this device or a residue of it might appear in the feed stuff stream that goes back to a particular species. So there is a distinction between who is most important, the people are most important. With respect to the sheep industry and the voluntary scrapie certification program, FDA is already on record as approving that for use within that program. So that indicates some movement and over time it may be possible to, for instance, make that acceptable for the whole meat industry and then potentially for others. |