The Controversial ISO 11784/85 standard

Periodic review vote on ISO 11784/85

November 2001 -- The year 2001 is the five-year anniversary for ISO 11784 and ISO 11785, bringing with it the automatic five-year periodic review prescribed by ISO. The voting was once again characterised by a number of interesting omissions and coincidences.

The documents ISO/TC23/SC19/N182 and ISO/TC23/SC19/N183 are the two forms issued by the SC19 Secretariat showing the votes of P-member nations on ISO 11784 and ISO 11785, respectively.

It is interesting that these two tabulation forms N182 and N183 are dated 12 September, 2001. Remarkably, when the WG3 meeting took place on the 15th, three days later, Mr. Skrandies , secretary of SC19, stated explicitly that there were no results of the votation as yet (see item 10 in the document WG3_V23_Paris). There were delegates of P-member voting nations present at the WG3 meeting who would undoubtedly have been interested in discussing the remarkable results of the vote, and the large number of member nations listed as non-responding, although their national working groups had met and determined the national positions on the matter of the review.

Exemptions to ISO 11784 and ISO 11785 currently under review in WG3

Suggestions involve explicitly permiting code duplication and to permit ISO 11784-incompatible coding

June 25, 2001 -- Two documents are being circulated by WG3 on the matter of proposed 'exemptions' to the ISO 11784 and ISO 11785 standards. Both involve a UK request to modify the standard to accommodate current visual tag standards within the scope of ISO 11784 and ISO 11785. The proposals will compound the problems with the standard that have been objected to by P-member nations in the past:

(1) incompatibility among various elements of the standard HDX, FDX-B and now "UK-coding" (for lack of a better term). Readers must be specially modified to read each of the three classes of transponders. (see "Recommendations for using the UK ending system for farm animals within the 11784 code structure," dated 18 June, 2001)

(2) official endorsement by WG3 for use of OTP technology (field-programmable transponders which can be coded with any ID number desired in the field) (see document ISO/TC23/SC19/WG3/TWG/193, dated 31 May, 2001 entitled "Recommendations for replacing lost animal transponders by specimen containing an identical national ID code." )

About the document "Recommendations for using the UK ending system for farm animals within the 11784 code structure."
Entities in the UK are advising WG3 that they want to use ISO 11784/85, but require a 'special' form of coding that doesn't fit within ISO 11784 as written. Instead of using ISO 11784 coding, they want to carry over their existing visual tag ID numbering scheme into electronic eartags. The author of the referenced paper "Recommendations for using the UK ending system for farm animals within the 11784 code structure," is proposing that WG3 bend over backward to accommodate this request.

As far as the technical aspect of the proposal is concerned, the UK's proposal is seriously incompatible with ISO 11784. Note the author's reference to making the check digit an 'information bit' in order to accommodate the UK's requirements - see point 4 under "Possible Solution." This means that transponders programmed in this way will be incompatible with the standard. The ID numbers of these transponders will not display correctly on ISO 11784- compliant readers already in use.

In other words, in addition to the FDX-B/HDX incompatibility that is already known, and that IDEA has pointed out, (see the warning issued by IDEA) we now have another incompatibility in the offing: a proposed 'accommodation' for a particular country. This sets a very bad precedent: When will the next incompatible special request be accommodated?

Note also the requirement for special species coding, location coding etc. Logistically, implementation of this proposal places a tremendous burden on the distribution systems to get the right transponder to the right end user, with no screw-ups anywhere along the line. It also presupposes that everyone is going to play by the rules and nobody will try to manipulate the system. (How likely will that be, human nature being what it is?) How will it be assured that the correct species code ends up in the correct animal? That transponders with a given regional ID code end up only in the designated counties? Mix-ups are inevitable, even assuming that there is no bad-faith attempt to manipulate the system.

Furthermore, the requesting entity has explained they would like ID codes for tags reported 'lost' to be duplicated. (see ). The author of the referenced document explains that it is logistically impossible to accommodate this request in a transponder production. (In other words, the requirement for custom code duplication precludes the use of factory pre-programmed transponders). As a solution he recommends use of OTP (one-time field-programmable) transponders, which would allow ID codes to be duplicated in the field.
It is becoming very apparent that this standard

(1) cannot ensure unique ID codes (contrary to what is claimed in ISO 11784)

(2) cannot ensure a single standard transmission protocol and a single standard programming scheme for transponders (i.e. Displays of a given transponder's ID number will differ depending upon the reader being used).

Transponder manufacturers promoting the standard (even those issued manufacturer codes by ICAR) have themselves contributed to the corruption of the standard by issuing transponders with custom codes in the country code field that have not been endorsed by ICAR (to Arowana fish breeders in Singapore), (Australian pet market), etc. and have volunteered to provide non-ISO compliant coding to entities issuing tenders for livestock ID. The proposed accommodation for the UK entity, as laid out in the enclosed two official WG3 documents, takes the corruption of the standard to a new and higher level. If even the supporters of the standard will not exercise the discipline required to conform to the rules they themselves have laid down for standards compliance, the ‘standard’ will quickly degenerate into a situation where ‘ISO 11784/85 transponders’ issued for various customers are not mutually readable, where customers buying cattle in a given market cannot be assured that the transponders in those cattle can be read by his or her reader... And we are back to where we started: various, mutually incompatible systems. However, there will be one key difference: the ID codes can be freely duplicated, in the field, by the end user, and, depending upon the situation, can even be changed and reprogrammed by the user, according to the requirements of the moment.

Reflections on the voting process in SC19


by Joseph V. Masin, long-time delegate to WG3, on behalf of Trovan, Ltd.

March 2000 -- In these last few months we have witnessed the amazing spectacle of 27 nations voting in the forum of ISO/TC23/SC19, those votes being counted three times, and a different tally resulting each time.

Furthermore, some votes that were returned to SC19 in a timely fashion could not be found for inclusion in the vote. (It is perhaps interesting to note that all of the missing votes favoured withdrawal of ISO 11784/85).

It may be instructive to briefly summarize the history of this vote: On 5 March, 1998, Russia submitted a formal petition for vote by member nations of SC19. The request called for revision and/or suspension of the ISO 11784 and ISO 11785 standards, and provided an explanation itemising five major flaws in the standard. When the voting ballots were sent out by the SC19 secretariat, it was three months later, 15 June. The final response date was given as 15 September. In many countries of the northern hemisphere, this period happens to coincide with annual summer holidays, meaning that regular meetings of working groups and regular business activity are suspended or put on hold. Coincidence?

When the votes were counted by the SC19 secretariat, the initial tally of 5 October showed an overwhelming majority rejecting Russia's request. According to the tally, twelve nations favoured retention of the standard, seven favoured suspension and three abstained. [Click here to see the official result of the first tally ]

There were problems, however. Brazil, Chile and New Zealand, all P-member nations of SC19 and entitled to vote, were not even mentioned anywhere on the page. As it turned out, two P-member nations were incorrectly listed as O-members. O-members have observer status only, and their votes are not counted. Interestingly, both affected nations had voted in favour of suspension of the standard.

After a number of SC19 member nations contacted the SC19 Secretariat to complain, the Secretary consented to count the votes again. Now the tally was 9 to 12, still rejecting Russia's request, but the majority favouring retention of the standard as-is had narrowed somewhat. The P-member nations New Zealand, Brazil and Chile were now listed as 'not replying.' [Click here to see the official result of the second tally. ]

More official complaints by P-member nations followed. Mr. Zens retallied the votes a third time. The third tally showed 12 in favour of suspension and 12 in favour of the status quo. [Click here to see the official result of the third tally.]

According to ISO regulations, there must be a simple majority favouring a proposal in order to proceed with it. After the third tally, SC19 advised all inquirers that the vote was a tie and that, having fallen short by one vote, the Russian proposal was rejected. SC19 informed all inquirers that it considered the matter closed. It even brushed off the request of Sweden, which requested its vote to be correctly counted.
[Click here to see Sweden's vote.]
[Click here to see Sweden's request to have its vote removed from the tally 'not supporting addition of the proposed new work item.']

Judge for yourself whether New Zealand wished to retain the standard as-is:
[Click here and here to see New Zealand's clarification of its intent]

Three tallies... Three results... and, still, in the end, a lack of due process.

No further action was taken by SC19 until the Technical Programme Manager of ISO, Mr. F. Abram, wrote to the Secretary of SC19 on 20 November, 1998:
"[...] Having taken note of the above, it remains that there is a clear majority of members of ISO/TC23/SC19 willing to undertake further discussion and/or study on the five issues raised in the GOST-R. [...] As a minimum, appropriate answers should be given on each question put forward." The letter went on to recommend "a study of the concerned issues and to report back to subcommittee ISO/TC23/SC19 providing advices and or propositions for possible improvements of the concerned standards," [Click here to see the full text of the letter]

Five months later, on 14 April, 1999, the Secretariat of SC19 issued document ISO/TC23/SC19 N139, punting the problem back to WG3. It began by asserting that "As the result of voting (N137 Rev.1) is unequivocal [...]" That is an interesting choice of words considering the actual voting result, the rather unusual history of the vote count and the unresolved situation concerning the Swedish vote, and went on to say with studied understatement, "as there obviously exists an enormous need of discussion, the WG3 is asked to elaborate corresponding solutions [...]" [Click here to see the full text of the letter]

The WG3 leadership was, to put it mildly, an unenthusiastic recipient of the ISO Central Secretariat's suggestion to 'discuss' revisions to the standard. By April 1999, the WG3 had been restructured in such a way that all substantive discussion of standards was shunted over to a new entity called TWG. TWG meets separately from the working group and participation is by invitation only. TWG is in fact comprised exclusively of a select group of manufacturers, all vocal supporters of ISO 11784 and 11785 in its current, unamended form. [See statement of manufacturers.] TWG explicitly excludes manufacturers known to favour revision of ISO 11784 and 11785, as well as all delegates from the SC19 member nations.

At the April, 1999, meeting of WG3 in Lugano, in response to the ISO Central Secretariat's suggestion which was handed down via SC19, and pressure from the delegates of voting nations present at the meeting, the leadership of WG3 was forced to put the issue of revision on the agenda. The chairman of WG3 responded to pressure by national delegates by forming an ad hoc committee for the ostensible purpose of discussing revisions to the standard. it consisted of seven delegates. Interestingly, six of the seven hailed from nations that opposed revision of the standard. Three of these hailed from a single nation: Holland.

By September 1999, when it was discontinued, the ad hoc committee had not even been convened a single time. When confronted about this rather remarkable omission during the WG3 meeting of September 1999, the Chairman of WG3 admitted that he had never even attempted to convene the ad hoc committee. He also admitted, he had never invited input from the SC19 member nations. When pressed for the reason, he offered an excuse: his father "had been ill." He proceeded, in almost the same breath, to reprimand efforts made by the single ad hoc committee who hailed from a nation favouring revision (Canada) to solicit input from the SC19 member nations. He concluded by stating that, since there was no input from SC19 member nations, the issue was closed.

TWG announced in the same meeting that it had determined conclusively, in its closed session, that there was no need to revise the standard. This was no surprise, considering the fact that the membership consisted of companies that opposed revision of the standard in the first place. When one of the national delegates moved from the floor that a vote be taken to determine the wishes of the working group, the chairman flatly refused. It was clear that the majority of delegates present in WG3 favoured revision. The leadership of WG3, with loud, vocal support from certain manufacturers, ruled that there would be no voting, and that the request for discussion by the ISO Central Secretariat had been concluded and that the matter of revision was now closed. When delegates from P-member nations protested, they were shouted down. In fact, the official minutes of the meeting did not document the repeated motions made by WG3 members attempting to put the matter to a vote and protesting the lack of due process by the leadership of WG3.

Considering the means by which this seriously flawed standard has been upheld, in both SC19 and WG3, the legitimacy of the standard is questionable, at best. The documented problems with the standard have not been addressed either by WG3 or SC19. Inspite of the documented will of the majority of SC19 members, there has been no calling to account.

Within the structure of ISO, the technical committees and working groups operate with great latitude and independence, and are not directly subordinated to th Central Secretariat of ISO, which does not have the means to call them to order, even in the event of gross violations of due process. The authorities in the Central Secretariat have only the power of persuasion at their disposal, and the ability to make suggestions. Ultimately, the leadership of technical committees is not answerable to any higher authority.

Under the circumstances, then, there appears to be no process by which the egregious violations of due process in TC23/SC19 can be corrected. There is no provision for ensuring that the will of the majority of the P-member nations in SC19 is acted upon. The majority of SC19 has spoken: the standards are not suitable for use as currently written, and must be fixed. What did WG3 do? Nothing. What did SC19 do about what happened in WG3? Nothing.

As officials of ISO never cease to point out, users implementing ISO standards are on their own: they implement ISO standards at their own risk and responsibility. The fact that ISO 11784 and ISO 11785 carry the 'ISO' label is no guarantee for their quality or suitability to the job they purport to do. In fact there are major documented problems with the standard. Users implement them at their own risk and responsibility. The moral of this story is: User Beware.

ISO 11784/85 Update - WG3 meeting in Wageningen

The meeting opened at 13:00h on 13 September, 1999, in Wageningen, Holland. At the Opening and Welcome the Swedish and Chilean delegates requested permission to record the meeting--on audio tape and video respectively. The requests were denied.

Subsequently, the Canadian delegate, Mr. John Vrolijk requested clarification of whether parliamentary proceedings would be used in the meeting, with items to be moved, seconded and voted on (as per Henderson's Parliamentary Guide) and made a motion to the effect that Henderson's Parliamentary procedure be used. The motion was not accepted by the Chairman. The Chairman questioned the need for parliamentary procedure, and after consultation with Mr. Zens (who was in attendance) and who indicated that there was no set procedure stating that some working groups were conducted according to parliamentary procedure while others were conducted on the basis of consensus. At that point, the Chair decided that WG3 works "on the basis of consensus." He stated that there would however be votes on issues if it was found that consensus was not possible. Throughout the meeting various issues were raised, some from the Chair, others from the floor. At no time was consensus sought or were any items voted on.

There was no democratic process regarding discussion of items on the agenda or new items brought forward from the floor. Motions from the floor were called out of order.When the Chairman tabled the agenda item "Approval of the draft agenda", the representative from Sweden requested that the discussion regarding the modification of ISO 11784/85 be dealt with right after approval of the minutes and before the TWG items because the TWG proposal is dependent on what modifications are made to ISO 11784/85. The Swedish delegate's request was accepted. When the Chairman tabled the agenda item "Approval of the minutes of the last meeting in Lugano" (doc. N219), the Russian delegate stated that the minutes of the Lugano meeting had to be corrected, specifically the item concerning implementation of ISO 11784 and 11785 around the world. Russia's report that ISO 11784'85 is not being implemented due to serious flaws was not recorded in the minutes.

Mr. Gary Burch of New Zealand stated that the outcome of the TC28 vote (joint Australian and New Zealand committe for animal RFID) was incorrectly recorded. The Australia-New Zealand joint committee had in fact rejected ISO 11784/85 in their May vote.

Mr. John Vrolijk of Canada stated that the deliberation that took place in Lugano regarding the suggestion that ISO 14223 be rolled into ISO 11784/85 in order to prevent confusion and to simplify implementation, a point raised by Ms. Emmeninger of Datamars, was not recorded in the minutes. Subsequently, Mr. Ingo Grotewahl, the Swedish delegate, requested that the count of nations on N139 (tally of votes on Gosstandard Motion) be revised. Sweden has previously advised Mr. Zens in writing that the Swedish vote is to be recorded as "Favouring revision of ISO 11784/85", and that consequently the tally should be 13:12 in favour of revision.

Mr. Burch of New Zealand pointed out that the New Zealand vote was fraught with difficulties because of the wording of Mr. Zens' request accompanying the ballot. New Zealand had previously advised Mr. Zens several times to correct the allocation of the New Zeland vote as "supporting the addition of the new item of work" and "prepared to participate in the development of the project." Mr. Burch requested that the New Zealand vote be deleted from the column of nations opposing the work item and counted as favouring the revision and willing to work on the standard. He stated that the resulting tally of nations is in fact 14 to 11 in favour of revision of ISO 11784/85 rather than 12:12.

Neither statement was challenged in the meeting. Mr. Zens, who was present, stated that he was unaware of the complaints and that he will not change the ballot.

Attendees from Slovakia, Czech Republic, Russia, Chile, Austria and Iceland were present, some for the first time; it appears that these nations are not adequately informed as to the workings of WG3 and therefore were not able to contribute as they may otherwise have done. Nor did they receive information relating to how WG3 worked nor were they ever advised of where minutes of past meetings would be available. The Czech delegate stated that he was concerned that delegates and national institutes from the Eastern European countries (i.e. Russia, Slovak Republic etc.) did not receive invitations and documentation for this meeting in time, or in fact at all.

When the document entitled "Draft report of the ad hoc committee" was presented by Mr. Mans Jansen, head of TWG, his treatment of Mr. Anisimov (the Russian delegate) during his presentation was acusatory and intimidating. Mr. Jansen intentionally distorted the proposal put forward by Gosstandard in its submission to WG3, particularly those concerning the requirement for code uniqueness in the standard in order to embarrass the delegate. Without requesting permission, he got up, walked across the room and positioned himself inches away from the Russian delegate thrusting papers in his face while speaking in a heated, accusatory tone. The chairman allowed this to continue at length and did not call Mr. Jansen to order.

Mr. Vrolijk, a member of the 7-member ad hoc committee, asked why the ad hoc committee was not consulted in the creation of the TWG document, as the proposal entitled "draft report of the ad hoc committee" was in fact prepared in its entirety by TWG. The chairman did not at any time have the ad hoc committee evalute and discuss the work item. The ad hoc committee was never convened and no discussion happened telephonically or by fax or by any other means of communication. The ad hoc committee was merely requested to "approve" (i.e. rubber stamp) the conclusions set out in the TWG report.

Mr. Vrolijk also pointed out that the report dismissed out of hand the proposals made by three countries that sent contributions, and did not reflect the concerns of those nations that were not given the opportunity to participate.

Mr. Burch of New Zealand made the point that TWG consists of manufacturers who have explicitly stated in writing that they are "not willing to continue to discuss" modification of ISO 11784 and ISO 11785. Mr. Burch referenced these companies' "Joint Statement of the Manufacturers" which was submitted to SC19 in March of 1998, and by which they have effectively disqualified themselves from further work on the standard.

The chairman stated that there were only two responses: from Italy and from Russia. John Vrolijk stated that there were actually three, since Brazil had also submitted a report. He also stated that insufficient time was given for a response by interested SC19 member nations. The time for submission of proposals was only one month from the date of the Lugano meeting, which is not enough time to develop a comprehensive response at the national level. The document entitled "Procedure to update ISO 11784 and 11785" was in fact only circulated by the chairman after the deadline for contributions had passed.

Mr. Vrolijk was chastised by the Chairman for taking it upon himself to invite participation of SC19 member nations who had stated on their ballots that they were prepared to participate in the work process. When it was pointed out that Mr. Vrolijk's invitations were in fact the only invitations ever sent out by anyone on the ad hoc committee, and when asked why he had not issued a formal invitation himself, as Chairman of the ad hoc committee, the Chairman stated that he didn't get around to it because of his father's illness.

The WG3 press release regarding ISO 11784 and ISO 11785 was presented in both a long and short version. It was pointed out that the long version of the press release clearly states that the standard ISO 11784/85 cannot guarantee ID code uniqueness. However, the proposed short version of the press release omits this crucial information. In fact, the word "unique" is prominent in the first sentence, thereby communicating that the uniqueness of coding is assured under ISO 11784/85. This incorrect short version was defended by its framers against objections made by a number of delegates, to the effect that it is O.K. not to tell the truth because it would help the industry, irrespective of the fact that it might be detrimental to users.

There was a brief discussion of ISO readers. The Chairman stated that only readers capable of reading FDX and HDX transponders (both types) are ISO-conforming. Only one reader was shown which could read both FDX and HDX transponders (a Destron product). However, the reader read a range of glass encapsulated transponders at a rather limited range, which is insufficient for most livestock applications.

Conclusions

The meeting was conducted in an undemocratic manner. The chairman
1 Would not allow any motions to be put forward
2 Would not allow voting of any kind
3 Never asked for or received a consensus on any of the issues presented at the meeting
4 Allowed very little discussion on any of the issues presented at the meeting.
5 Dissent on any issue was not allowed.

In fact, the individual agenda items were summarised on transparencies that were shown at the conclusion of each agenda item. These colour, computer-generated transparencies had been prepared in advance of the meeting, prior to the deliberation of said agenda items. It was clear that whoever prepared the transparencies already "knew" what the conclusions were to be prior to the meeting even taking place. At the end of the meeting several participants of the meeting have stated their objections to the way the meeting was conducted on the record and also objected on the record to the press release and the "Conclusion" on ISO 11784/85 which the Chairman proposes to forward to SC19.
• WG3 published a statement flatly contradicting the stated wishes of the majority of SC19 P-member nations, who had expressed their concerns with the unsuitability of the standard by voting to have it revised. The statement of purpose reads: "The approved ISO standards 11784 and 11785 as published are suitable for their intended applications and are the basis for additional standards for advanced transponders as they are in consideration in the new work item." The chairman proposed that an ad hoc committee be appointed to examine the proposals for revision that were to be submitted.
• The ad hoc committee was never convened and no discussion happened on the mandate to revise ISO 11784/85.
• The ad-hoc committee appointed by the chairman had 7 members: 6 were from nations that had voted against revision of the standard; only 1 member was from a nation in favour of revision.
• SC19 member nations were never advised by the chairman of WG3 that their input was desired.
• No action was ever taken by the chairman to advise anyone that proposals for revision of ISO 11784/85 were being solicited.
• The time for submission of proposals was one month from the date of the Lugano meeting: too short for any nation to develop a comprehensive response at the national level.
• The document "Procedure to Update ISO 11784/85" was circulated only after the deadline for submissions had passed. The only action taken by the chairman was to e-mail the TWG report to ad hoc committee members and asking ad hoc committee members to "approve" (ie.. rubber stamp) them.
• The TWG report dismissed all suggestions the three SC19 P-member nations submitted out of hand and recommended that ISO 11784 and 11785 be retained in their present form.
• There have been three counts of the P-member votes by SC19 and still there are discrepancies, as pointed out by the Swedish and New Zealand delegates. The vote in favour of revising ISO 11784 and 11785 is 14 to 11, and not 12 to 12, as stated in the back-dated document N139 rev.1.Some of the delegates travelled for over 36 hours to attend this meeting. They were made to listen to a minority group and a group of manufacturers dictate what the conclusions of WG3 were to be with no chance for input into the meeting. It is clear that interested parties are attempting to manipulate the meeting, and that the people controlling the proceedings are not concerned with having a standard that will work, only having a standard that can be used to market products under false pretences.
In order to ensure the integrity of the process on the revision of ISO 11784 and 11785, and to respect the expressed wishes of the majority of SC19 P-member nations, (1) The ad hoc committee must consist of delegates from nations that have stated they are in favour of revising ISO 11784/85 OR that they are prepared to participate in development of the project. (2) TWG must be excluded from the process. TWG has no legitimate role in the process as TWG's sole mandate is to discuss a new draft standard: ISO 14223. Furthermore, most TWG members are employees of manufacturers who have gone on the record to state that they do not want to discuss revising ISO 11784/85 See Manufacturers' Letter to SC19 There is a conflict of interest between TWG members are therefore contrary to those of the majority of SC19 P-member nations, and TWG has to be excluded on the basis of conflict of interest. (3) All those SC19 P-member nations stating that they are prepared to participate in development of the project must be given an opportunity to do so: sufficient time must be allowed for the nations to develop their responses; and formal invitations must be sent to all SC19 P-member nations that returned their ballots stating they "support the addition of the new work item to the programme of work" OR "are prepared to participate in the development of the project." (4) The responses of SC19 P-member participants should be reviewed by the ad hoc committee that was appointed to do the job. The responses should be given serious consideration and not be dismissed out of hand.

Errata

Mr. Hassan Sade stated his concern that in a discussion of the problems affecting ISO 11784/85, persons might conclude that the ID codes in Datamars transponders can be changed. Mr. Masin responded that, Datamars transponders conforming to ISO 11784/85, as long as they are read-only transponders, are not reprogrammable. The problem with ISO 11784/85 is that read-only, one-time-programmable (OTP) and write-many/read-many transponders (WMRM) are all encompassed by the standard. As a result, the code numbers of ISO 11784/85-compatible read-only transponders can be duplicated by other read-only, OTP and WMRM transponders. Also, the numbers in WMRM transponders can be changed at will. Databases allowing registration of ISO 11784/85 transponders are compromised, because there can be an unlimited number of transponders in the field "pointing" to a particular registration in the database. As far as the database is concerned, transponder number 762098100132313 is the ID number of a 3-year old German shepherd called "Hasso." The database can provide no assurance that a given German shepherd with that ID number is in fact the original "Hasso." Please click here for more information.

Source Documents to be referenced:
Manufacturers' Letter to SC19
Procedure to update ISO 11784 and 11785

ISO 11784/85 Update - WG3 meeting in Lugano

The meeting opened at 13:00h on 26 April, 1999, in Lugano, Switzerland. At the opening of the meeting, when the agenda item "Approval of the draft agenda" was formally raised by the Chairman of the WG3, Mr. Eradus, there was a call from the floor pointing out that a letter from Mr. Zens of SC19, returning ISO 11784/85 to WG3 for revision and correction, should have been received by Mr. Eradus. Since all the subsequent agenda points depended upon the continuance of ISO 11784/85 in their present form, Mr Zens' communication should be the first item addressed by the working group. The return of the standard for revision would obviously require changes in the entire meeting agenda. Thereupon Mr. Eradus acknowledged that he had in fact received the communication. However, since the communication had been faxed to him on the proceeding Friday morning (NB: that would have been 23 April, 3 days earlier), he stated that there had not been time to have it photocopied for the WG3 meeting. Consequently, he explained, he could not distribute it to the members of the working group at this time.

Mr. Eradus stated that he would arrange to have the copies made by the following day. An objection waas made that this would not provide sufficient time for working group members to review the documentation and for the group to develop an appropriate response. (When the copies of Mr. Zens' communication were distributed the following day, it was actually dated the 14th of April , 10 days prior.)

Mr Eradus paraphrased the letter by Mr. Zens aloud. WG3 was being asked to elaborate solutions according to the proposal of the ISO Central Secretariat, taking into account the items stated in the proposal submitted by the Russian Federation and the comments contained in document N137 and N137 rev.1

It was then stated for the record that it would be necessary for WG3 to accept the mandate to revise the standard, in compliance with the wishes of the 14 "P" member nations who had expressed concerns about the flaws in ISO 11784/85.

On the second day, Mr Eradus distributed Mr. Zens' communication to the members of WG3.

The communication included several documents:

Mr Zens subsequently announced that a subcommittee to study changes in ISO 11784/85 would be formed and that the committee members would be: Mr. Cees vant Klooster (Holland), Mr. Wim Eradus (Holland), Mr. Ronny Geers (Holland), Mr. Rudolf Artman (Germany), Mr. Torben Almedal (Denmark), Mr. George Tucker (U.S.A.) and Mr. John Volijk (Canada). The composition of the committee was determined upon unilaterally by the leadership of WG3. There was no vote and no deliberation permitted on the composition of the committee.

National delegates attending the session were asked about progress in implementing ISO 11784/85 in their various countries. The delegate for the Russian Federation stated that the Russian Federation had ISO 11784/85 in suspended condition because of the problems with ISO 11784/85. The Canadian delegate stated that there are serious issues with ISO 11784/85 that need to be discussed and resolved, and that there is a problem with duplicate ID codes, and that Canada believes these issues must be addressed by WG3. Fred Nind stated that the UK was proposing to eliminate quarantine requirements for imported animals with micro chips. Lionel Sheridan, an observer from New Zealand, stated that a joint committee from New Zealand and Australia had been formed, and that the vote approving ISO 11784/85 as the national standard in both New Zealand and Australia would close on Friday 30 April and that both countries would subsequently implement ISO 11784/85 as national standards for livestock and for pet identification. **

Manufacturers present in WG3 continued to insist that there were no problems with ISO 11784 and ISO 11785 and refused to recognise that ISO 11784 and ISO 11785 in their present form are in need of revision. The minutes of the meeting, as resolved upon by WG3 members in attendance, stated that WG3 maintains the "suitability of the standard for intended applications." However, it was requested that a dissent be put on the record, stating that it was apparent that the standard was not suitable for the intended applications, and that a majority of the "P" member nations had registered their objections to the standard and that the fact that the standard was back in WG3 for revision spoke for itself.

The minutes resolved upon by the WG3 members in attendance also specified that a committee was being formed to study proposals to improve the standard.

“Proposal
(a) can be for further research
(b) proposal for update.

Proposal
  • clear description of the problem
  • written text in two columns: today's text / proposed text

To be reviewed by:
  • Cees vant Klooster, Wim Eradus, Rudolf Artman, Ronny Geers, Torben Almedal, George Tucker, Mr. John Volijk
  • WG3."

**This was not quite correct. In fact, when the vote in IT28 closed Friday 30 April, ISO 11784/85 did not reach the requisite majority approval and, per the regulations of Standards Australia, will be returned to committee.

ISO 11784/85 Update - WG3 meeting in Edinburgh

Gosstandart of Russia, which is a permanent member of ISO/TC12/SC19, formally submitted a motion to that forum on April 20, 1998, as a New Work Item, requesting that ISO 11784/85 be returned to WG3 for review and revision.

The Gosstandart motion listed several major problems affecting the standard, all of which are generally recognized by most of the SC19 members as well as a great number of RF/ID user groups.

The SC19 Secretariat tallied the votes received on October 5, 1998, and released the results to coincide with the meeting of WG3 in Edinburgh, Scotland. The results of the vote announced by SC19 stated that 12 countries had voted in favour of the Gosstandart proposal and 7 countries voted against it, with two countries abstaining.

This tally did not however take into account the updated count of Permanent (P) SC19 member nations, Consequently the votes of some new SC19 members and of some former "O" members who had converted to "P" membership status were not counted.

Furthermore, several member nations have submitted a qualified vote recognizing the need for review of the standard, apparently incorrectly assuming that the request for "suspension" of the standard would cause immediate, automatic suspension of the standard, while the standard is being reviewed. Unfortunately, the proper procedural sequence, allaying the above concern, was identified by the SC19 Secretariat only in its German language cover letter.
Two member nations have requested a delay in vote tabulation for administrative reasons.

Based on the document submitted by SC19 to WG3 Edinburgh meeting, an announcement was developed by WG3 in acceptance of the ISO 11784/85 standard.
During the WG3 meeting, one of the major problems, lack of code security, has been discussed under the heading New Work Item Proposal, Advanced Transponder.

Among the participating manufacturers there was no dissent that the present standard does not provide any ID code security (i.e. no assurance can be given that the ID codes provided by the manufacturers are in fact unique). Recognition of this short-coming was well formulated by Mr. David Clemons of Destron/Fearing.
A solution currently under discussion in the working group proposes three levels of security to be implemented in years to come.

The proposal would introduce technological barriers to code duplication. This approach utilizes more complex technologies and therefore requires the use of larger ICs in complying transponders. These large ICs cannot be used in miniature implantable transponders, because of their large size, effectively precluding this strategy for "code security" in animal implantable transponders.

However, the degree of "security" this solution can offer is again only perceived, because there is in fact no way to legally enforce code uniqueness. One hypothetical solution discussed was to be limit access to ISO-compliant readers only to authorised personnel, and limit the number of readers in the field, on the grounds that anyone who has access to a reader would be a potential code cracker. This approach was immediately recognised as not workable. This "advanced transponder"-based standard would still have to be an open standard, allowing anybody to manufacture compliant product without any restrictions. Adding technical complexity does not provide legal protection. Patents, if any, must be made available to all comers on a nondiscriminatory basis under ISO patent policy rules . Consequently, there is once again no possibility to enforce the uniqueness of ID codes.

This proposed solution faces not only technical obstacles to implementation, but also would result in significantly higher costs which would make the product unappealing to the proposed target markets, which are highly cost sensitive. The product cost would increase commensurate to the degree of "security" to be implemented, with the third and highest security level being the most costly.

It is noteworthy that Mr. Kostas Aslanidis of Texas Instruments, expressed an opinion that one can expect that shortly there will be some manufacturers providing blank read/write ISO-compliant transponders to the market.

As a matter of fact, this type of technology may prove very useful in close-loop operations, for example, in dairy applications or in applications calling for the recycling of the transponders or where direct owner access without passing through an intermediary database is required (via a telephone number programmed into the transponder, for example).

Even the interim voting results publicized on 5 October show that substantial dissent exists and that "patch-on" solutions are perceived as being inadequate. The standard will at some point need to be returned to WG3 to be reworked. Regarding the Gosstandart motion to that end, the tally of votes needs to be adjusted for the reasons cited above. We expect that over the next few weeks, this issue will be addressed. Interested parties should keep themselves apprised of future developments.

Reflections on the SC19 meeting in Berlin

by Joseph V. Masin, delegate to WG3, on behalf of Trovan, Ltd.

It became very apparent that a number of nations will be submitting requests for major revisions of ISO 11784/85 in the near future. It is apparent that the standard in its present form is not acceptable to a large portion of the livestock producing nations. A significant number of WG3 members, including manufacturers, have in private conversations with myself admitted the deficiencies and major flaws of the standard, which largely coincide with the points made in the document entitled "A discussion of the ISO standard for RFID: its provenance, feasibility and limitations." They have however requested not to be quoted by name.

(1) The standard cannot ensure unique ID codes
(2) The standard is needlessly complex, combining two incompatible technologies: FDX and HDX.
(3) Legal issues continue to impact the standard
(4) Livestock and small animal identification have different requirements and require separate standards.

(1) The standard cannot ensure unique ID codes
ISO 11785 claims that ID codes of conforming transponders will be unique. In section 2, entitled "conformance," the standard states: "The unique individual identification codes transmitted by a transponder are in conformance with this International Standard provided they meet the requirements of clause 5." (emphasis added). The assumption of uniqueness is dangerous.

The idea has been put forward that manufacturers will police their own transponders. However, this would assume that every manufacturer will bother to apply for a manufacturers' code and that every manufacturer will program his transponders with only his manufacturers' code and nobody else's. Today, there is a great deal of confusion as to how the term "manufacturer" should even be defined (and consequently how "manufacturer responsibility for code uniqueness" should be assigned). Is it the manufacturer of the integrated circuit? Or is it the no-name manufacturer of transponder assemblies? Or is it the private label reseller of the transponder who is putting the transponder in the market under his brand name? Who bears the responsibility for ensuring manufacturer codes are used only by the designated manufacturer? (particularly in an environment where noone can be restrained from programming any code they want, or even reprogramming it, if they so choose). Companies may not restrict traffic in their goods between different geographical areas. (This principle has recently been reaffirmed by EEC court rulings and also impacts trade in transponders with pre-designated country codes).

Initially when the standard was first conceptualised in 1991, OTP (one-time-programmable) and WMRM (reprogrammable) transponders were not available. The standard is written in such a way that it makes no allowance for the introduction of these technologies. The standard actively misleads consumers into believing that the transponders provided under its aegis will be unique.

In fact, as stated by organisations that are operating registration databases, inclusion of ISO-standard compliant transponders in databases will make such databases unusable. The logical progression would be that, after an installed base of ISO-compatible readers were put into place, ISO-compatible transponders will be marketed as unprogrammed "blank" chips, with the number to be programmed once the transponder is implemented. The veterinarian or even the owner of the animal could add pertinent information such as the owner's telephone number. This approach, although a natural outgrowth of today's technological reality, would essentially make databases obsolete.

(2) The standard is needlessly complex, combining two incompatible technologies: FDX and HDX.
It is a fact that no commercially available reader today reads both FDX and HDX ISO-compliant transponders. Such a reader would be more complex to manufacture, inordinately costly to users and would compromise the performance of both the FDX and HDX systems, resulting in slower read speeds and potentially shorter read ranges.

To date, twelve companies (self-designated manufacturers) have announced their intent to sell ISO compliant transponders. Only one of these companies is manufacturing HDX transponders, which would be suitable for livestock ID. A tally of manufacturers clearly shows that the preferred technology, by an overwhelming margin, is FDX, for technical and operational reasons. There is no possibility, with the current state of the technology, to produce these HDX transponders in miniaturised form due to the need for a larger number of components. It is axiomatic in electronics that a larger number of components and connections results in a greater likelihood of system failure.

(3) Legal issues continue to impact the standard
At least one manufacturer alleges that it has patents impacting ISO 11784/85. For instance, AVID has clearly stated that it does not intend to comply with the ISO Patent Policy as stated in "Patents, N15".

The problems with the standard have become apparent over time. Many of the issues that concern user groups today were initially not recognised because no user input was formally solicited in the early stages of the process. The patent conflicts likewise arose at a fairly late date. A user requirements study, along the lines of what was done by AIM USA preliminary to beginning work on the U.S. companion animal identification standard, has never been conducted by WG3. Such a user requirements study would definitely show the need for a divided standard, guaranteed unique ID codes, for affordable readers and transponders that perform well enough that they can actually be read in their desired applications. It is incumbent upon us all, as responsible manufacturers, to address these issues before users discard the standard as being useless, thereby discrediting the industry that helped create the standard.

ISO 11784/85 Update - SC19 meeting in Berlin

The SC19 meeting in Berlin, which took place on March 12, 1998, dealt with a number of issues, including ISO 11784 and ISO 11785. Item no. 6 on the agenda was a report by the Chairman of WG3, Mr. Wim Wismans, on the current status of the standard. Mr. Wismans was also reporting on the next generation of the animal ID standard, giving a short overview of the recent work of WG3 and of future projects.

Several documents submitted by WG3 participants to SC19 were made available to attendees of the SC19 meeting. They included letters by AFNOR, Standard Australia, Standards New Zealand and Gosstandart of Russia, as well as ISO document N125 concerning the request for suspension of ISO 11784 and 11785.
After Mr. Wismans finished his report, the Chairman of SC19 stated that Standards New Zealand and Standards Australia had not submitted the previously announced request for suspension of the standards and return of the same to WG3 for review, for which reason no action was required for the time being. At this point, the representative from Gosstandart of Russia requested permission to address the meeting. The Gosstandart representative stated that, although New Zealand had not yet submitted its formal request, Russia had, and that Russia's request should be reviewed by SC19 at this time. Then the representative from Standards New Zealand stated that Standards New Zealand and Standards Australia had created a joint working group (IT28) to address the concerns previously announced by these two organisations to SC19 and the ISO. He stated that the topics were still under discussion and that, because of the short time between the WG3 meeting in Stockholm and the SC19 meeting in Berlin, the document could not be prepared for submission to SC19. He stated that nevertheless, the issues are still being formulated by IT28 and definitely will be provided to SC19 and the ISO.

At this point, Dr. Josef Schuermann of Texas Instruments intervened to question the credentials of the official representative of Standards New Zealand, and to question whether the latter was entitled to make any representations on behalf of Standards New Zealand and Standards Australia.
The representative of Standards New Zealand stated that he at no time has presumed to speak on behalf of Standards Australia. The Chairman of SC19 has called Dr. Schuermann to order.

The documents made available to members of SC19 were discussed at this point. Among these was
The Chairman of SC19 stated that the "Joint Statement" letter was submitted out of context. Nevertheless, he has allowed Dr. Schuermann to read aloud the document, in which the signing manufacturers (some of whom are currently selling ISO 11784/85 compliant transponders, and some of whom, while not yet doing so, are on record as intending to do so in the future) are announcing that they are not willing to work on improvement of the standard, as demanded by some national standard setting organisations and major user groups.
The representative of Standards New Zealand thereafter, in his capacity as participant in IT 28, expressed his grave concerns regarding ISO 11784/85 on behalf of IT28 (which includes representatives of numerous user groups in New Zealand and Australia which together represent some 220 to 240 million head of livestock). He forcefully expressed that these organisations had stated a desire to have a truly international standard that will work on a global basis, not merely a regional basis. He emphasized that even if a few national standards organisations state that they are entirely satisfied with the standards, the concerns of the other countries must be accommodated.

The representative of Polish Standards stated that his organisation's perception was that there were serious difficulties with the standard. He pointed out that major objections were the complexity of the standard (inclusion of both HDX and FDX in the standard); the uniqueness of code; the standard does not allow for backward compatibility with transponders presently being used in Poland in the target applications.

Thereafter, the representative of Swedish Standards has suggested that it may be appropriate to return the standard to WG3 for review, which idea was declined by the Chairman of SC19. The reason stated was that an official requirement to do so had not been submitted by Standards Australia or Standards New Zealand. The representative for Standards New Zealand announced that it was his understanding that the official request was to be submitted upon conclusion of deliberations by IT28, in which Standards Australia and Standards New Zealand are participating, and that, however, an official request had in fact been submitted by Gosstandart of Russia. He stated that IT28's meeting was scheduled for mid April.

The response to this was that the request has not been presented on the special ISO form for such requests and that the process for such submissions is known to the national standards organisations. At this point, after a spirited debate, the group could not determine if such a form could be made available during the meeting. The form was in fact produced later in the meeting.

After the ensuing break, the representatives of Standards New Zealand and Gosstandart each announced that they had made inquiries as to whether the form could be completed and submitted for a vote during the present SC19 meeting in Berlin. Mr. Francois Abram, Technical Programme Manager, Standards Department, ISO, apparently did not make a binding statement concerning the applicable voting procedure - whether only SC19 member nations would participate in the vote or whether all ISO member nations would be voting. However, it was determined that ISO, upon receipt of the request for the suspension of the standards on the correct form, will circulate a request for vote on the subject among its (members).

ISO 11784/85 Update - WG3 meeting in Stockholm

According to the agenda for the WG3 meeting in Stockholm, the Working Group was slated to review the current status of ISO standard 11784/85.

Mr. Wim Wissmans, the current Chairman, has taken it upon himself to declare the standard to be a success and fully accepted by all user communities.

The representative of Gosstandart, the Russian Standards Institut, Mr. Anisimov has stated in brief the problems facing Russian agriculture, and the need for RFID technology to track livestock that will be imported to upgrade the indigenous stock. According to the Russian representative, unique ID numbers are of paramount concern, in order to preclude fraud.

Gosstandart fully supports the idea of an international standard for RFID. However, the representative stated that the present ISO 11784/85 standard falls short of their national requirements, as ISO 11784/85 is a transponder-based, open standard. He stated that the country and manufacturer codes stipulated in the standard are of no use in ensuring unique ID codes and that ISO 11784/85 must be modified to ensure that ID codes are unique. He also stated that the presence of duplicate ID numbers in the market would jeopardize the integrity of any national database. He also expressed concern with the complexity of the standard, which encompasses the mutually incompatible FDX and HDX technologies, as this makes the readers unnecessarily expensive and limits their performance. He recommended that the standard stipulate either HDX or FDX, but not both. Similarly, he indicated that separate standards for livestock and companion animals would be appropriate.

The Russian delegate referred to a demonstration of ISO 11784/85 standard compliant transponders where duplicate code numbers had been programmed, which he termed "shocking."

Gosstandart registered a strong plea that ISO 11784/85 be returned to WG3 for speedy modification.

An offer was made by the Trovan representative to demonstrate the re-programming of ISO 11784/85-compatible transponders to WG3 members, either during or after the meeting. This offer was declined by the chairman, who stated that he had seen the technology demonstrated before. The transponders in question could be reprogrammed on the fly to different country code numbers and to any of the manufacturers' code numbers currently assigned by ICAR. This technology, which was not available at the inception of the standardisation process, is now commercially available.

Standards New Zealand representative Mr. Gary Burch, supported by a member of the Standards Australia working group IT28, questioned the ability of the standard to provide unique identification, which was deemed essential by both countries, especially in applications involving the international movement of animals, meat and animal products. The chairman responded that the ISO standard was never intended to deliver a guarantee of code uniqueness. A recent shipment of rams, which were previously embargoed, to Russia (also mentioned by the Russian delegate) was mentioned as a typical application. The country and/or manufacturer's codes stipulated in ISO 11784 were described as useless with respect to ensuring unique ID codes. Other top-priority issues for both countries' livestock industries were the reading speed and reading range of ISO 11784/85-compliant equipment; as well as backward compatibility.

Australia and New Zealand combined represent some 240,000,000 heads of livestock, approximately the same number as the EEC.

New Zealand moved to vote to have ISO 11784/85 returned to WG3 for modifications.

The chairman declared that he was not prepared to allow this motion by New Zealand, since WG3 has not been authorised by SC19 to review the standard.

The representative of Swedish Standards has repeatedly requested the group to deal with the request by Standards New Zealand to modify ISO 11784/85, referring to a communication by Mr. Abrams, Technical Director of ISO, advising that WG3 was to deal with this specific issue and to report back to SC19 on the outcome.

Mr. George Tucker, of the U.S. delegation, and Mr. Wissmans, the chairman, were of the opinion that the standard, once published, cannot be modified by WG3 without specific authorisation by SC19.

Nevertheless, the chairman decreed that he will not accept a verbal request from New Zealand and Russia to review the standard. However, he has agreed, upon the insistence of New Zealand and Russia, to accept written motions the next day, February 10. It was stated that such a motion, even if accepted, would not have any effect, since, according to the background presented by Mr. Tucker and Mr. Wissmans, a formal written request must be made by the organisation seeking a review of the standard prior to the meeting. Supposedly, the request by New Zealand was not expected by WG3, in spite of the letter by Mr. Abrams and the ISO Council ruling.

Accordingly, the next day on February 10, two motions were made, one each by New Zealand and Russia, and were rejected.

A poll of WG3 participants, some of which were not official national representatives, was taken to provide feedback on the success of ISO 11784/85 in these countries. The U.S. representative declared that there is no interest in the standard in the United States. The representative of the Spanish veterinary association, which by law represents all Spanish veterinarians, has submitted a letter to WG3 declaring that it has no desire to implement the standard in Spain. A visitor (private observer) from Brasil has mentioned a trial with 5,000 ea. ISO ear tags taking place in Brasil at this time. No activities were reported in Japan. Mr. Wissmans, for the Netherlands, has declared that the Dutch government has adopted the standard for all agricultural animals. Mr. Archie Sains, for the U.K., has informed the group that some other technologies may replace ISO 11784/85 if the issues of contention affecting the standard are not resolved promptly, and that the government's decision is expected shortly. Several other participants have declared that in their countries (Switzerland, Germany, Finland) the intention is to go with the standard. Nevertheless, 100 per cent, worldwide acceptance of ISO 11784/85 has been declared by the chairman.

Australia, New Zealand are reviewing ISO 11784/85 with respect to required modifications. When those modifications are clearly defined it is the intention to advise SC 19 of those changes. Russia has stated that it will submit its list of required modifications to ISO 11784/85 to SC 19, along with a request that the standard be adjusted accordingly.

International Standards Organisation returns RFID standard for animal use to working group for major revisions

On September 25, in response to demand by user groups and widespread complaints, the International Standards Organisation has returned two standards, ISO11784 and ISO11785, to SC19 Working Group 3 by vote of the ISO Council. The ISO Council is the executive body of the Geneva, Switzerland-based International Standards Organisation. ISO11784 and 11785 together comprise a standard for electronic identification (RFID) in agricultural machinery, livestock and other animals.

Based on the problems with ISO 11784 and 11785, it appears certain that the new standards which would emerge from WG3 will embody fundamental changes and major revisions of the present standard.

The ISO11784/85 standard has been beset with major problems even preceding its publication in August 15, 1996 and October 15, 1996 respectively. In particular, user groups have criticized the lack of unique identification codes. Because of the potential for intentional misuse, electronic identification devices (transponders) conforming to the above standard are unsuitable for use with national livestock tracking registries or companion animal registries. Registries of these types are a major proposed application for the standard.

The ISO 11784/85 standard also violates the International Standards Organisation's patent policy, as well as antitrust laws in several countries, due to the existence of three conflicting patents affecting ISO 11785. The revised standard must exclude technology claimed by patent holders as being subject to their patents.

There are also a number of other technical problems and conflicts.

Use of ISO 11784/85 compliant transponders, which operate at 134.2 Khz, would be subject to severe restrictions in Germany, due to a conflict with prior frequency assignations made by the German post office. It has been asserted that compliant equipment operating on this frequency may also interfere with the operation of life-supporting medical equipment (heart pacemakers). It will be necessary to change the frequency.

ISO 11784 and ISO 11785 embody two fundamentally incompatible approaches: the so-called full-duplex approach (FDX) and half-duplex approach (HDX), resulting in costly readers and compromised performance for both the FDX and the HDX elements of the standard. HDX is used exclusively in livestock applications, and has proven unsuitable for use in other applications. A number of national delegations have suggested that separate standards should be published for different applications.

ISO 11784 and ISO 11785 do not stipulate minimum transponder performance requirements for the types of transponders used in most applications. ISO compliance was therefore no guarantee to the user of suitability of a given RFID product for the intended application.

Recall of ISO 11784 and ISO 11785 will give the standard setting organisation an opportunity to address the problems concerning duplicate codes of transponders and specific performance guidelines, solution of which is indispensable to the user community. The requirements of different user groups cannot be accommodated within one standard, as it is today. The working group will also have the opportunity of developing separate standards for livestock and for companion animals, suitable to the specific requirements of the very different user communities. A reader-based standard solution will be proposed.

It is expected that systems built to the present standard's specifications will be incompatible with the revised standards specifications.

ISO 11784/85 compatible products have been primarily promoted in Europe by FECAVA, and by RFID distributors Rhone Merieux and Virbac, as well as manufacturers U.S.-based Destron-Fearing (Nasdaq: DFCO) and Datamars of Switzerland.

International Standards Organisation set to withdraw 11784/85 standard International Standards Organisation set to withdraw 11784/85 standard

The International Standards Organisation in Geneva, Switzerland has confirmed on July 30, 1997, that the proposal to withdraw two standards, ISO11784 and ISO11785, has been slated for the next ISO Council meeting. ISO11784 and 11785 together comprise a standard for electronic identification (RFID) in agricultural machinery, livestock and other animals. At present, this standard is being primarily promoted in Europe by FECAVA, and by RFID distributors Rhone Merieux and Virbac, as well as manufacturers U.S.-based Destron-Fearing and Datamars of Switzerland.

The ISO11784/85 standard has been beset with major problems even preceding its publication in August 15, 1996 and October 15, 1996 respectively. In particular, user groups have criticized the lack of unique identification codes, which, because of the potential for intentional misuse, makes ISO-conforming electronic identification devices (transponders) unsuitable for use with national livestock or companion animal registries, one of the major proposed application areas.

The ISO 11784/85 standard in its present form violates the International Standards Organisation's patent policy, as well as antitrust laws in several countries. The patent conflicts affecting ISO/DIS 11785 have not been resolved. However, even recall of ISO11784 and ISO11785 at this time may not absolve the International Standard Organisation from potential liability resulting from the standard's existence from the date of publication to the date of recall.

ISO 11784 and ISO 11785 do not stipulate minimum transponder performance requirements for the types of transponders used in most applications. ISO compliance is therefore no guarantee to the user of suitability of a given RFID product for the intended application.

The standard's 134.2 Khz operational frequency is incompatible with German regulatory requirements.

ISO 11784 and ISO 11785 embody two fundamentally incompatible approaches: the so-called full-duplex approach (FDX) and half-duplex approach (HDX), resulting in costly readers and compromised performance for both the FDX and the HDX elements of the standard.

Recall of ISO 11784 and ISO 11785 will give standard setting organisations an opportunity to address the problems concerning unique codes of transponders and performance guidelines, solution of which is indispensable to the user community, as well as developing standards suitable to the specific requirements of different user communities.

U.S. user groups favour reader-based standard: Why is a reader-based standard preferable for companion animals?

There are a number of factors which are driving the push to reader-based standards in a number of countries.

  • User Demand. User groups in the United States requested and obtained multi-system readers for use in animal shelters. The goal was to assure full coverage of all microchipped animals, irrespective of the source of the transponder. User groups had stated in surveys conducted by AIM (the Automatic ID Manufacturers' association) that their main objective in standardisation was a reader capable of reading all transponders in the U.S. market, in order to protect the installed base of companion animals.
  • Backward compatibility. Only a reader-based standard ensures backward compatibility for all animals already microchipped, whereas a transponder-based standard introduces an entirely new and incompatible transponder into the market. A reader-based standard ensures 100% coverage for all participating systems. Trovan, Ltd. has recognised and supported the requirements of veterinaries and animal shelters for a multi-system reader.
  • Accordingly, Trovan, Ltd. went on record as early as 1992 with its offer to cross-license its reader interface to qualified and interested manufacturers for $1. In February, Trovan's U.S. distributors EID, Ltd. and Infopet Identification Systems have achieved an agreement with Avid for cross-licensing of reader interfaces, which will make available a multi-system reader capable of reading Trovan, Avid and Destron microchips.
  • Multiple sources of product. The multi-system reader supports a number of manufacturer's product lines, allowing users to select the system which best suits their requirements while choosing from a range of vendors.
  • Technological evolution is supported. New innovations in transponder and/or reader technology are accommodated, because readers need only be equipped with the new read protocol, if needed.
  • Data integrity is assured. In a reader-based standard, individual numbering schemes cannot be compromised, since each manufacturer continues to manufacture their own transponders and control their own numbering scheme to ensure unique ID numbers. A reader-based standard precludes fraudulent duplication of code numbers and overlapping number series provided by different manufacturers.
  • Does not require costly, bureaucratic, nationalised administration and distribution schemes by individual countries.

User response has been overwhelmingly positive to the announcement by InfoPet Identification Systems, EID Ltd. and AVID regarding the agreement to provide multi-system readers to shelters.

Mr. Ed Sayres, Director of Animal Protection Division, American Humane Association:

"We applaud the U.S. manufacturers of microchip technology and their collaborative efforts. Through their generous offer to provide universal scanners to all animal shelters, a monumental step has been achieved for returning lost animals to their owners."

Mr. Coy Willis, President of the National Animal Control Association:

"The National Animal Control Association and animal shelters across the nation are very excited about the agreement for common readers between the microchip companies., We will be happy to be able to recommend a technology that will greatly enhance animal identification."

Mr. Sherbyn W. Ostrich, V.M.D., President of the American Veterinary Medical Association:

"The American Veterinary Medical Association is extremely pleased that the North American manufacturers of identification chips have agreed to have a universal scanner that will be distributed to animal shelters across North America. With this technology now being uniform, the benefits to the animal owners will be enhanced, and the likelihood of finding a stray or stolen animal will be very much increased. The American Veterinary Medical Association applauds the manufacturers for their spirit of cooperation in order to benefit animals, and stands ready to help in any way possible."

The implementation of multi-system readers in animal shelters will create a standard which will serve the needs of the veterinary profession and which is in keeping with its professional standards and its interests. The reader-based standard precludes duplication of code numbers, protects the installed base of microchipped companion animals, while allowing users access to multiple suppliers who compete solely on the merits of their products. A reader-based standard is the preferred solution, favoured over a transponder- based standard, for markets where integrity of ID codes is essential (companion animal ID, identification of endangered species etc.), and where compatibility with an installed base is desirable.