by Heather Smith Thomas  http://www.equinechronicle.com/Features/Thomas/thomas_B1006.html

Horse owners have a lot of questions about the National Animal Identification System (NAIS) plan that USDA wants us to comply with (premises registration, individual identification of our horses, and reporting the movements of horses). We wonder whether we’ll all have to ID our horses and what kind of ID we’ll have to use. Many horsemen already have their horses identified in some way, either for their breed registration and/or theft or loss recovery or proof of ownership—with freeze brands, hot brands, lip tattoos, descriptions of identifying markings on registration papers, DNA parentage, or microchips. Will we have to use an additional ID?
The NAIS plan (which is primarily geared toward farm animals, but includes horses because horses are considered livestock) calls for radio frequency identification devices—such as ear tags with microchips (for cattle, sheep, pigs, etc.) or microchips implanted directly into the animal (for horses). Microchips can be inserted into the middle third of the nuchal ligament (the long, strong ligament that runs from poll to withers) at the top of the horse’s neck. The NAIS plan also specifies a certain type of microchip: the ISO 11784/11785 134.2 kilohertz chip.

THE EQUINE SPECIES WORKING GROUP

When the NAIS plan took shape in 2002-2003, the USDA, in conjunction with the National Institute for American Agriculture (NIAA) created a task force—National Identification Development Team—representing 70 livestock industry groups and government agencies. This team decided they needed to create working groups within each species to represent to USDA what is unique about identification in their species. The American Horse Council had already put together its own task force to look into the NAIS plan, so this group became the Equine Species Working Group—the official liaison between USDA and the horse industry. Its purpose is to evaluate the NAIS plan, recommend ways the horse industry can fit into the NAIS, and develop standards for equine ID that will mesh with the NAIS if it becomes mandatory.
There were originally 35 members on this group, volunteers from various breeds and interests within the horse industry, and people from USDA and a few state departments of agriculture. The ESWG started out with enthusiastic efforts to identify goals and create a working plan for the horse industry, but members have not always been in agreement and membership has kept changing. A smaller number have continued to participate, and there’s been a small core group of members who have determined its direction.
Early on this core group of people, for various reasons, decided it was best to go along with the USDA’s plan—and try to make recommendations that would fit the horse industry a little better than if we wait and have the government tell us what we have to do. As part of that “fitting in”, they decided that microchips would be the best means of individual identification for horses, and that a certain type of microchip (being pushed by USDA for the livestock industry) would also be the best one for horses. Their recommendation to horse owners to use this chip is stated in their 20 page booklet “National Animal Identification System and Horses” published in May, 2006 (available on the American Horse Council website and the ESWG website).
Jim Morehead, DVM (representing the American Association of Equine Practitioners, on the ESWG) has taken an active role in the ESWG and was instrumental in its formation and organization. He says, “We’re probably looking at microchips for future ID for our horses. It’s the most practical, at this point, with current technology. The ESWG wants horsemen to use the 134.2 kHz (kilohertz) chip. The particulars on that chip merely say that it has 15 digits (the first 3 being a country code).
“Thus far, this is the only requirement for our horses’ microchips. There is a lot of talk about using bio-thermal chips that also have capability of transmitting the temperature of the horse, rather than just having a number on it. This would probably be more expensive, however, and we don’t yet know how well those chips work. At this point, what’s important to the ESWG is that the chip have a number, and it has to be an ISO (International Standards Organization) number,” says Morehead.
This particular issue, however, has created a great deal of controversy within and outside the ESWG. The ISO system is a foreign system that the U.S. has never used, up until now. The chips in this system operate at a different frequency than those being used in this country. Many people are wondering why the USDA, and especially the horse industry, suddenly decided to change to this system when we have been using a different microchip system in this country for the past 15 years. At this point in time, there are already more than 800,000 horses and millions of pets microchipped (for permanent and secure ID that enables them to be traced back to their owners if lost or stolen), yet the USDA and ESWG want to throw out this system and start over.

THE “AMERICAN” SYSTEM

Horsemen and pet owners have been using RFID (radio frequency identification device) microchips for a long time—for theft prevention, lost animal and disaster recovery, regulatory needs, etc. Owner contact information (to recover lost or stolen animals, for instance) is kept in a private database and released only upon owner request. This has been a very rapidly growing voluntary system for horse owners, with more than 100,000 scanners currently in place throughout the country. The microchip system in this country operates at a radio frequency of 125 kHz.
The state of Louisiana uses these microchips in efforts to control Equine Infectious Anemia. In order to get their annual Coggins test, horses must have permanent individual ID. It can be a tattoo, freeze brand, microchip—anything unique to that horse— but most owners have chosen microchips. Louisiana made it their official system in 1995. The state veterinarian’s office purchases chips from Destron and distributes them to vets around the state. About 90 percent of horses in Louisiana (more than 200,000 horses) are chipped. This was very helpful after Hurricane Katrina left hundreds of animals homeless. After Katrina, 364 horses were gathered up, and owners were located for all but one, largely because of these microchips. If any of those horses had ISO 134.2 frequency chips, however, no scanners could have “read” them.
According to Dr. John Wade, a Louisiana veterinarian who has been in private practice since 1980 and has been microchipping horses since 1988 (and head of AVID equine division, a company that makes chips for horses), says that AVID, Destron and other makers of 125 kHz chips are sending out more scanners every day. “Every dog that’s picked up, every horse that’s found, can be identified if it has a 125 kHz microchip. If you call the sheriff’s department or your local pound/shelter, they will scan the animal and tell you who it belongs to within a few minutes,” says Wade.
If a stolen horse might end up at a slaughterhouse, the plants that slaughter horses can be alerted. Federally inspected packing plants that kill horses have scanners and will scan upon request. If there’s report of a theft, they can be asked to look for a bay mare, for instance, and will oblige by scanning any horse that fits that description. If they find that chip number, they’ll hold that horse and not kill it, explains Wade. “The Texas Rangers, brand inspectors and other law enforcement agencies use scanners to identify recovered equines and return them to owners,” he says.
Though his company makes several kinds of chips, including a 134.2 kHz ISO chip (selling those to countries that use it), he doesn’t want to see the U.S. change to this type of chip because it is not a “secure” chip for proof of ownership or animal tracing. “AVID has 10 years of hands-on experience with this foreign microchip system and the problems that accompany it,” says Wade.

THE ISO SYSTEM

An RFID system used by some countries operates at 134.2 kHz frequency. The International Standards Organization is a group that creates standards for various things marketed in the European community. Since there are many different countries in a relatively small geographic area (similar to the various states in the U.S.) and many companies manufacturing similar products, there needed to be standards between countries and companies. The ISO is made up of representatives from the participating countries and the industries within them; the working groups within the ISO structure are composed of company representatives (technical people).
The next level up are the SC groups, with national delegates from the different national standards organizations that sit on these groups. Countries can opt into different SC groups, where they vote on various standards. At this point there are more than 17,000 ISO standards, on everything from tractor parts to paper sizes. The particular ISO standard in question for RFID equipment (radio frequency chips and readers) is ISO 11784/11785.
Barbara Masin is part of a company (Electronic Identification Devices, Ltd. and Trovan, Ltd, a British company) that has supplied electronic animal ID products for more than 15 years. Their technology is the most widely used today in the field of RFID and has supplied 100s of millions of transponders (microchips) to more than 100 countries, for use in pets, endangered species, fish and many types of animals. The company markets ISO chips as well as “American” chips with other frequencies. As a representative of this company, Masin sits on the board in charge of developing the ISO 11784/85 standard, as a U.S. delegate representing United States interests. She has serious concerns about the use of this particular RFID system in a national animal identification program because of its shortcomings for this type of application (providing unique identification).
The ISO 11784/85 committee has been involved in addressing the problems that have arisen over the past several years due to use of these chips for animal ID, since numbers on these chips can be easily duplicated. This particular chip system was originally developed in Russia to microchip tractor parts. It came from the need to accurately identify machinery parts for an international community. A scanner in France or Germany, for instance, could read the microchip and tell you what the part was. So the ISO accepted this system, which is a low frequency 134.2 kHz chip. One reason they chose it was because it was a smaller chip and had no proprietary attachments to it (no ownership, no patents) and was free to be used by anyone, anytime, anywhere.
“This standard was originally developed for agricultural equipment, commodities and closed-loop application in livestock, such as individual animal ID in dairy herds,” says Masin. “A farmer could utilize it to monitor the performance of individual animals.” A dairyman using automatic feeding in individual stanchions, for instance, might want to know which cow was which, and which part of the lactation cycle the animal is in, so the feed could be adjusted accordingly.
“In this situation it really doesn’t matter whether or not these chip numbers can be duplicated or reprogrammed, because the farmer is in a closed-loop operation and in control of what’s happening. And with tractor parts, you are merely updating things like maintenance information—like when this item was in for inspection the last time,” explains Masin.
“When this system was developed, the concept was for it to be an open standard. All the ISO standards are published, and any company that is interested can then conform with the published standard. It works very well if you are using it for commodities like copier paper, to make sure the products are the same and will work in various copiers. Then it doesn’t matter if you buy your paper from Xerox or Weyerhauser; if you put it in your photocopy machine it will fit. The same with modem protocols; no matter where I buy them, they can talk to each other. They all conform to the same standard and talk the same language,” she says.
But within the ISO standard there are reprogrammable chips and some can be reprogrammed multiple times. In the beginning, the ISO concept was for unique ID codes for farm animals (one number, unique for life). But ear tags (containing the chips) in cattle, sheep, etc. are often lost. In 2001, the ISO group responsible for standard 11784/85 decided that the solution to this problem would be to allow for retagging the animal with a new tag carrying the same ID number as the lost one. But a farmer can’t wait six months to get a “duplicate” tag from the manufacturer (who can’t stop production to make just a few transponders with duplicate numbers) so ISO allowed for OTP (one time programmable) “blank” microchips that could be programmed with the number of the lost tag.
For retagging with identical numbers ISO allowed for “uniquely identifying up to 7 retaggings of an animal”. Then reprogrammable tags were also allowed. In a May 31, 2001 ISO document describing their recommendations for replacing lost animal transponders, they stated it would be disastrous if OTPs fall into the wrong hands; “they should be transported in a secure way to issuing stations and must be safely kept. It is a national responsibility that the procedure is followed properly.” Instead of trying to preserve the integrity of the system, they essentially said, “You can duplicate and reprogram these chips, but we are not responsible.”
As Masin points out, problems arise when we begin using this technology for something it was not designed for—such as an open loop approach where there are lots of different animals. “Chipped animals may be part of a national system being used to control compliance (to make sure people are actually doing what they say they are doing, pertaining to animal health, for instance) or to make sure that an animal is indeed the individual with that number when it crosses a state line or goes somewhere else,” says Masin. USDA is not being realistic in thinking we can use this system for dependable animal trace-back to farm of origin, in case of a disease outbreak.
“The problem with using a published open standard like ISO 11784/85 for something that’s needed to provide unique or secure ID is that it won’t work. It would be like our government publishing the standard for dollar bills, telling people what paper to use, what color ink, etc. so anyone could do it,” explains Masin.

THE PROBLEM OF DUPLICATE NUMBERS AND EASE OF COUNTERFEITING AND DUPLICATING ISO CHIPS

The drawback in using this type of chip in a national system for purposes of disease trace-back, bio-security or unique ID for proof of ownership or theft prevention/loss recovery is that there is no guarantee of uniqueness of ID codes. There are several ways ID codes can be undermined in any open system. Chips can be ordered factory-programmed, with desired numbers. Some manufacturers also sell reprogrammable chips which are programmable by the user in the field, and indistinguishable from factory programmed chips. Some can be reprogrammed as many times as the user desires, even after being implanted in an animal. Thus anyone can change the ID numbers in an open system.
Since this is an open standard, even if the NAIS gets its chips from selected manufacturers and distributes them through a single entity, this would not prevent ISO chips with duplicate ID numbers from entering the market, since ISO does not enforce compliance with its standards. Three companies have already announced that they will make ID codes to order when the ISO standard is put into place in this country—without going through the Brussels bureaucracy to have the numbers assigned.
In the ISO system, corruption of the ID numbering system is practically built-in. And even for manufacturers who adhere to the ISO honor code, ID numbers can be recycled every 33 years. This is no problem for cattle or pigs but might be a problem for longer lived animals such as horses. The ISO system also stipulates a two year “transition” period (for any changes), which was adequate for the original purpose such as food animals that were marketed within 2 years of life and cycled out of the system in that period of time. But this doesn’t begin to address the ID needs for other animals such as horses or companion animals.
This spring Barbara Masin attended a USDA/APHIS hearing on microchips for pets—the purpose of which was looking at changing the present ID system (the 125 kHz “American” chip already in use) to the ISO 134.2 kHz ISO system. After the meeting she gave a demonstration showing how it is easy to reprogram the ISO standard chip with any number you want.
“There were three people from the USDA and a number of speakers from the companion animal community (various interest groups that represent veterinary organizations, animal shelter organizations, local shelters), and one person from the American Horse Council— Amy Mann—who spoke on why she thought companion animals should have the same ISO chips as horses. I spoke there, and after everyone finished speaking, I gave the demo,” says Masin.
She showed that the ISO chips—whether programmed from the factory, or the OTP (one-time programmable chips that come blank and can be programmed once) or the reprogrammable ones where you can change the number after it’s in the animal—are visually indistinguishable; they look identical. You also can’t tell them apart with a scanner because they all read the same way.
“There are only two ways to tell the difference. You can dig it out of the animal and have it subjected to microscopic destructive analysis (which is very expensive). Or, if you happen to have the right kind of programmer and the chip doesn’t have a password on it, you can tell. I had several standard ISO chips made by various companies, preprogrammed. I also had reprogrammable chips. I shuffled them around and people could not tell the difference.”
She also had a couple of chips inserted in stuffed animals, and used a programmer (about the size of a deck of cards) to counterfeit (clone) one of the chips. “I scanned the chip in one animal, and the programmer stored the ID number. Then I passed the little programmer over the animal with the programmable chip and duplicated that number. So you don’t even have to key in the number; you just scan one chip and essentially put that number in the other one,” she explains. Anyone with a programmer could make other animals pass for the one with the original number.
The programmers are not expensive. Depending on where you get them, they can be purchased for as low as $160 to $200. “There are ads in various European publications and websites stating they can supply reprogrammable microchips and low-cost programmers. There are classified ads in newspapers offering low cost confidential provision for duplication of ID numbers,” says Masin.
An ad that appeared in the largest Swedish morning paper translates as follows: “We offer a new chip service. We will change the ID number of the Kennel type chip according to your wishes. Inexpensive. Easy. Fast. Total discretion. Also sale of ISO programming units.” A Spanish language ad in the veterinary publication VETECOM reads: “Specialists in animal accessories. Collars, muzzles...ISO reprogrammable transponders. You can encode all the ID numbers you require as often as you like. Can even be reprogrammed inside the animal. Conforms with ISO Standards 11784 and 11785. Compatible with all reader systems. Can be used in every kind of animal. Also readers for reprogramming.” Thus anyone who wanted to could use this ISO system to their own advantage, for various purposes.
The chips themselves are not very expensive. “If you buy them through a vet you might pay top dollar, but in an industrial market they are less than $5,” says Masin. “I could take a $5 chip and put it in a horse that looks like a valuable animal and, in essence, I’ve cloned the champion because my horse has its number. An animal from another country could be made to look like one that came from the U.S. or vice versa,” she says.
“A person could keep several look-alike animals and register only one, or claim health insurance coverage for 10 animals while taking out a policy on only one. Some jurisdictions require chips as proof of payment for horse vaccination requirements. With ISO 11784/85 chips, horse owners could have just one horse vaccinated while 9 others sport the same identity. By using a WORM (write many, read many) chip that can be reprogrammed as many times as desired, the same animal can change identities throughout its life. In jurisdictions with a ‘dangerous dog’ law that requires an animal to be put down after it bites three times, such a dog could easily have its identity changed by an unscrupulous owner,” says Masin.
Given enough time and money, people can duplicate anything, though it may take more effort to crack a secure system, depending on how high the hurdles are. “With the ISO standard, there is no hurdle. The standard itself allows duplication of a chip 8 times. There are many vendors, including us, that sell reprogrammable chips. The ISO standard stipulates this because if an ear tag falls off, livestock owners want to give that animal the same number again. If you are restricted to preprogrammed chips you’d be looking at having to go to a wafer fab plant, and they have lead times of six months or longer for computer chips,” she explains.
Another thing to consider, in choosing this system for the NAIS, is that by using the ISO microchip system, we are building in impending obsolescence. The ISO-based system is static and precludes the use of new technologies and advancements because the technical parameters of this chip are rigidly defined. The ISO standard 11784/85, as defined, leaves no room for innovation and improvement. If technological advancements become available, the USDA’s NAIS (and people who chip their horses with this system) will be confronted with a difficult choice. They can continue with out-moded technology or junk this standard and begin a new process of standardization (which took more than 5 years for the current ISO standard) for the new technology for a national system.
Jim Gowan, ESWG member representing the Thoroughbred Racing Protective Bureau, says the microchip issue was one of several things his group questioned about the ESWG’s recommendations to USDA and the horse industry. “Chips can be replaced, removed or changed. With today’s technology, how long will microchips be the system of choice? Maybe we don’t want to be locked into this, with chips in all our horses. If something better and more feasible comes along, then we’d have to switch systems and that could be very costly,” he says.
“I think ultimately the best means of ID will probably be instant DNA typing. You can’t tamper with that. If you have a horse entered in an event or race (or traveling across a state line) you would simply prick the horse, take the blood, put it in a scanner or reader, and it would instantly match that horse with its information,” he says. This could be a simpler, more foolproof system, and might alleviate some of the political behind-the-scenes push from vested interests who stand to gain from having all livestock producers and horse owners ID their animals.

THE FLAWS IN THE SYSTEM ARE RECOGNIZED IN EUROPE; WE NEED TO ALSO RECOGNIZE THEM HERE

This is not the “universal” international system that USDA and the ESWG are telling us it is. More than 60 countries besides the USA have not adopted the 134.2 kHz system, and some of the countries that use it are not happy with it.
When it became clear what some of the problems were with this system—especially for unique animal ID—and where the expansion in this market was heading, there was an official complaint by the Russian standards organization (Gosstandart). They made a formal motion requesting that IS0 11784/ll785 be repealed. According to Masin, the Russians said, “There’s a problem here. We don’t have unique ID. This standard is being sold as something that claims to provide unique ID, but it can’t. It’s two mutually incompatible technologies in one standard.” They submitted a long list of issues and said, “Based on these flaws with the standard, which we believe are substantial, this standard should be retracted and sent back to the working groups so it can be fixed.”
The Spanish Veterinary Association also filed a formal complaint with ISO, and the Australian Veterinary Association published an item in its official bulletin outlining problems with the standard. Their list of problems included read distance (which is shorter than other chips being used in Australia), ISO standards not taking into consideration longer life spans of horses and pets, uniqueness of numbers not guaranteed, etc. “There were so many complaints and formal objections that finally the highly unusual step was taken to put these standards to a vote,” says Masin.
The major flaws with the ISO 11784/85 system include the fact that this “standard” is actually two systems in one. The ISO process is based on the work of a committee, and almost always the result of compromise. With a committee involving manufacturers with high-stakes market interests this can be a lengthy political process, with results based on compromises rather than on things like performance, cost control or technical feasibility. At present there are two very different designs involved in the low frequency 134.2 kHz ISO standard chips. Even though only one company markets one type (every other company in the business markets some version of the other type), a political compromise stipulates that the ISO standard incorporate both technologies, which lowers the read speed performance and reliability of the readings. This makes the resulting readers less efficient and more costly than those designed to read a single type of technology.
Other flaws with the ISO 11784/85 standard are its inability to ensure unique ID codes. Being an open standard (in the public domain), it relies on an honor system—with all manufacturers agreeing on who manufactures which numbers, to prevent duplicates. But without legal teeth in the form of patents to thwart production of unsanctioned chips, the ISO standard is susceptible to compromise by manufacturers. There is no manufacturer accountability.
There is also the problem of transponder performance. Neither IS0 11784 or 11785 stipulates any minimum performance requirements for microchips suitable for use in animals. Thus a chip that can read at “touching” distance would be fully ISO compliant. Small animal veterinarians around the world have repeatedly expressed strong reservations about systems with such short reading distances and users in the livestock business (and horses) need even greater read range in order for microchips to be effective for them. Thus being ISO compliant is no guarantee of suitability for any given RFID product for use in animals.
So ultimately this was put to a vote in the SC group for that standard, says Masin. “It was a highly political process and very contentious. This group had their own problems with ‘hanging and dimpled chads’ in their vote. Only these were not chads; they were X’s on paper. But they had trouble seeing which columns the X’s were in! They did revotes and recounts. Each vote/recount yielded more votes against the standard, but the last count, which we still believe was incorrect, showed 50 percent of the nations for it and 50 percent against. It was a tie. The way the ISO system works, for an existing standard to go back to committee to be retracted, it has to be at least 50 percent plus 1 vote against the standard. So it was very close. We believe that the entities responsible for doing the counting were beneficiaries of one of the companies that was in favor of having the standard stay as it was,” says Masin.
“Essentially it was short by one vote of having the standard cancelled. So if people say it’s a great international standard, this is not true. In the ISO voting group, half the countries at the national standards level said this is a bad standard. They realize this system is open to fraud,” explains Masin.

WWHAT ABOUT U.S. HORSES TRAVELING TO OTHER COUNTRIES?

One of the arguments we hear as to why our horse industry should use the ISO 11784/85 chips is that this is necessary for international travel. This might be true if horses in the U.S. were considered food animals and were going to another country for human consumption, but the U.S. horses traveling internationally are doing so for sport or breeding purposes and by some definitions would fall into the classification of companion animals, says Masin.
Recent legislation passed in Europe (the “Pet Passport Law”) mentions the types of microchips that may be used. Airports in all European Union nations, including the UK, are required to have readers on hand that are capable of reading Trovan ID-100 chips and 125 kHz unencrypted chips. “Today there are laws in place in the European Union, Japan and Australia—the only jurisdictions that require microchips for companion animals—and all of them make provisions for 125 kHz chips (which is the U.S. basis for horses today) to be read. There is a 125 kHz encrypted chip which is not used in horses (but used in cats and dogs) that is not accommodated, but the ones used in horses (the unencrypted AVID 125 chip, Destron 125 chip, and 128 kHz Trovan chip) are all accommodated,” explains Masin. Basically, if the concern is being able to get your horse into one of these jurisdictions that require chips, there is no problem; they are accepted with the chips they already have.

WHY IS USDA PUSHING FOR THE ISO 11784/85 SYSTEM AND WHY IS THE ESWG GOING ALONG WITH THIS?

People who are aware of problems with the ISO system are wondering why the USDA is dictating the use of this particular kind of chip. “This chip is really not suitable,” says Masin. “When this was being discussed for livestock, our ISO board approached the USDA and attempted to communicate with everyone from Anne Venneman (Secretary of USDA at that time) on down, and we got no return calls. They were not interested in hearing this. I went to the USDA listening sessions and offered to show them the problem with duplication possibilities, but they didn’t want to see it. The situation is very political. There are certain people involved within the USDA who have very close ties to certain manufacturers. There is an underlying agenda, unfortunately, and this is not for the good of the country,” says Masin.
“The NAIS is being touted as an anti-bioterrorism measure, but it won’t cut the mustard, especially using these chips. If USDA or our livestock/horse industries tell people this is what they have to use, the first incidence of some serious disease outbreak after the NAIS is implemented will spawn litigation. We have put the USDA on notice, in writing, that this is a problem (so they are aware of it), and if they persist with their plans and use this type of ID anyway, it will be a field day for lawyers,” she says.
If horse owners and livestock producers are forced into a national ID system and then find out it’s not workable because of these flaws, there will be repercussions. There will also be more legal actions and suits by various microchip companies. As one member of the Equine Species Working Group recently stated, “the legal actions will make this thing implode, and then we all will have wasted our time and money working on this.”
The flaws have been well documented, as far back as 1995, says Masin. “It’s very unfortunate that when the discussion at USDA was happening for the livestock standard, it wasn’t an open discussion. Listening sessions were crowd control type; USDA didn’t want to see any information against the system and didn’t respond to efforts to show them what was actually going on in other countries,” she says. There are still many people who are not aware that this is a poor system and that other countries are unhappy with it.
The frustrating thing about this whole issue is that USDA (and even certain members of the ESWG) seem to want to ignore the fact there are problems, and want to press on with convincing everyone that this is the best system for livestock and horses in the U.S.