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Friday, December 15, 2006

An editorial Part I

This was posted on a sheep owner forum and e-mailed to me.
I do have permission to print it from the owner. This is a
very well thought out opinion on what the New User Guide
{NAIS} means to us.

You all know that I am against NAIS and there
are a wholelot of reasons to dislike NAIS
besides those that I have pointed out in the
past. Basically they fall into 4 categories.
1. Constitutional Reasons, 2. Economic Cost
(including time) 3. Global Reasons
4. Religious Reasons But I would like only like to point
out those things that I have personally
researched and feel I can be covered here.
Neither can I cover any of these 4 reasons
with the expertise that can be found on
other websites. I would recommend that you go to
one of the major sites such as (which will lead you to
all the other sites out there against NAIS)
Stop Animal

I would also recommend that you go
to the USDA's website on
NAIS (I have it bookmarked)
and read everything there
Don't depend on any ones
word on what the program will be like
(even my local USDA/NRCS
people knew less about NAIS than I did
and didn't even know what
I was talking about when I first
asked about it, the first part
of the year. Of course they were
like that the first time I asked
about the wool program, scrapie
program and lamb retention program.
Most of the information that I am
going to point out (including
estimated cost) can be verified on
the USDA's site. Either in the
User guide, field trial projects,
and other documents published by USDA.

NAIS and the Scrapie Eradication
program have MAJOR differences.
NAIS adds and changes requirements
in Scrapie Program. If you are
like me you will no longer be
recognized as just a sheep operation but
a multi-species reporting operation.

1. There is a difference between the
premise identification and farm ID
numbers. Farm ID numbers applies to
your flock and goes with you if you
move your farm to another location.
Also Farm ID only refers to sheep/goat
premises. A premise identification
number is attached to the land and stays
with the land - (GPS located) and
applies to all reportable species.
If you move your farm/operation
(lock, stock and barrel) you leave behind
your old premise ID and get a new
premise ID (or assume the already assigned
premise ID) for your farm/operation.
You will have to file several reports
to the individual data bases when you
move you animals to your new location.
which leads me to the next

2. These reports are on each Animal
Identification Number (AIN) one animal
-one number - one report. You don't
report your farm moving animals, you
report each AIN movement. Because
each animal has it's own record in what
ever data base it is in. (example:
you move 4 cows, 10 sheep, 20 chicken,
10 geese, 4 horses and 2 pigs.
(each of these animals will need an AIN
assigned to it and they are leaving
their premise of origin) you will
send 4 reports to the data base that
covers cows; 10 reports to the sheep
data base, 30 reports to the poultry
data base, 4 reports to the horse
data base and 2 reports to the pig
data base) and do this within 24-48
hrs of the animals actual movement.
This applies to almost all animal
movements (AINs) off of the premise
of record. (need to check each species
group on which movements need reporting
- though there is presently only
a preliminary list at the NAIS site).
There are the standard reportable
movements in each species but there
are also differences for each type of
animal (i.e. Horses have different
types of reportable movements that
poultry wouldn't even need)

3. But what about Group/Lot Identification
Numbers (GIN) as an alternate
to AIN's. User guide says this "However,
group/lot identification may be
an option for other species when they move
through the production chain
as a group." (note the word MAY) Most
small operations do not do an
'all-in all-out' separation of animals.
(my chickens are raised in one
house and while I sell small groups of
them to different people, I do not
and would not be able separate and maintain
groups of chickens according
to when they would be leaving my premise of

4. Small farmers/operations will be the
ones that provide the main
financial support to maintain NAIS (talking
millions of dollars). GIN
are mainly used by the poultry and pork
industry (big operations under
contract with major food industries that
have brand names in the
supermarkets, I won't mention names)
These same companies are pushing
for NAIS but they are not going to be
included in NAIS requirements or
provide financial support to do the other
2 parts of NAIS (tagging and
tracking). Because GIN are created or
'self-generated' on the premise
(not assigned by USDA) and maintained
on the premises (check User Guide).
Large operations don't have to buy the
tags nor file reports to a national
data base, they only need to get and
maintain a premise ID.

5. USDA says small non-commercial
producers are exempt from NAIS.
This is the USDA's definition -
"Individuals whose animals are not
moved to auction barns or from their
location to those of commercial
producers. And Individuals whose
animal movements are limited to
those moved directly to custom
slaughter; movements within a single
producer's premises; local fairs
and local 4-H events, " (local is
within your county or parish)
also from the user guide "Animals that
do not leave their birth premises
for reportable movements and that
die and are buried at the birth
place would not be identified
(animals that die on the premises and
are taken to a rendering plant
need to identified...)" These
is a very narrow exemption guideline.
Very few small operations even operate
this way since most people don't
breed all of the species of animals
they raise.

6. What is the financial cost? Here
USDA has had plenty of years to do a
cost analysis but as refused to do one
(or atleast publish an all inclusive
cost of materials and labor.) User
Guide mentions tags alone costing $1-$3.
It has done some recent field trails
but cautions that the cost are not
reliable and do not apply across the
board to all species that needs
reporting. But they have posted some
estimates in the past at some of
the townhall meetings ($8-$16 per animal
for the first year) and recently
in some of the field trials ($5-$20 per
animal). Most of these estimates
applied to large livestock and not to
Neither does these estimates include the
cost of the tagging and tracking
reports, nor the total tag failure rates
(30% as reported in Australia)
The Australian Beef Association did a cost
analysis that included all parts
of the whole program and reported a $40
per animal
per year (this is ausy dollars not sure
what the exchange rate is)
Australia's cattle has been in a mandatory
NLIS program for a couple of years.
Australia beef

While raising sheep/goats is different
from cattle the tagging and tracking
cost will be basically the same. Though
the handling cost may increase for
sheep/goat operations since many might
find they will need squeeze chutes
to use the scanners/wands in reporting
commerce movements.
my sheep operation alone would hopefully
be only $800 the first year)

All of us need to answer how many animals
would I need to sell to pay
for NAIS on our farm. I can assure anyone
that my profits from my sheep
will not increase by $800 just because
I have a different tag and I report
movements. Neither will my chickens and
eggs produce enough cash to pay
to maintain them in NAIS.


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