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).

Trovan, Ltd. Sues Pfizer for Trademark Infringement

February 12, 1998

Santa Barbara, CA--
Electronic Identification Devices, Ltd., the North American distributor for Trovan, Ltd., and Trovan, Ltd., a UK corporation, have initiated legal action against Pfizer Inc. for trademark infringement.

Trovan, Ltd., which owns the TROVAN trademark, is a worldwide supplier of products to electronic and pharmaceutical applications marketed under its registered trademark TROVAN since 1989.

Pfizer Inc. has obtained FDA approval in December of 1997 and has begun marketing its new oral and intravenous broad-spectrum quinolone antibiotic trovafloxacin under the TROVAN trademark. According to Pfizer, the U.S. New Drug Application filed for this antibiotic was the largest ever filed by Pfizer with the FDA. Trovan, Ltd. has taken legal action to prevent unlicensed use of the TROVAN trademark by Pfizer.

Trovan, Ltd. has obtained marketing rights for a new technology which enables delivery of antibiotics and other pharmaceutica into animals or human bodies without the use of a syringe. The TROVAN delivery device, which consists of a tiny container shaped like a bullet, can be used for implanting electronic transponders for remote animal identification. The space inside the device contains a small dose of antibiotic paste, in addition to the transponder, to ward off any possible infection of the implantation site. The TROVAN delivery device can be inserted very easily simply by pressing it, sharp point first, into the animal's skin with the thumb. No tools are necessary. The implanted container will dissolve completely in the animal's tissue within three hours of insertion.

"To the uninitiated," said Mr. Dieter Salomon of Trovan, Ltd., "this device may look like it is made of a very hard, clear plastic, but the "plastic" is actually a soluble material made of a molecular compound contained in the muscle tissue of humans and animals."

The TROVAN delivery device does not make an incision, or cut, in the skin as a syringe would. Rather it pierces the skin, allowing for rapid closure of the opening after penetration, thereby minimising tissue damage and trauma.

TROVAN passive transponders are FDA approved, and have been in use for animal identification and medical tracking applications for years. The Captive Breeding Specialist Group (C.B.S.G.), an umbrella organisation for zoos and wildlife parks worldwide, has endorsed the TROVAN product in 1991 based on its unmatched performance, its small size and its low cost to the end-user. As a consequence, the Convention on International Trade of Endangered Species (C.I.T.E.S.) has voted to align itself with the C.B.S.G. recommendations in 1992, specifying that endangered fauna crossing national boundaries be identified "in accordance with the advice received from the IUCN/SCC Captive Breeding Specialist Group." Use of the TROVAN passive transponder is mandated by government agencies in a number of countries.

For additional information in the United States please contact:
Electronic Identification Devices, Ltd.
Barbara Masin
telephone: 805-565-1288
fax: 805-565-1127