There are a number
of serious flaws affecting the ISO 11784/85 standard.
This paper will discuss three issues which make it unsuitable for
national companion animal registration programs and endangered species
identification:
(1) Inability to ensure unique ID codes
(2) Lack of manufacturers’ accountability
(3) The problem of transponder performance
(1) Inability to ensure
unique ID codes
One of the biggest
problems affecting ISO 11784/85 compliant transponders is that the
manufacturer cannot guarantee unique ID codes beyond his own manufacturing
facility. In fact, quite the contrary is true. ISO11784/85 compliant
read-only transponders (those that are programmed by the manufacturer
in the factory), one-time-programmable transponders (those that come
blank and are programmed upon implementation) and write-many-read-many
transponders (those that come blank and can be reprogrammed repeatedly)
are currently being offered by a number of manufacturers. All of these
are compatible with ISO 11784 and 11785 and could be programmed to
read any number the customer desires, including ID code duplicates.
Why is the lack of unique
ID codes a problem?
It is only a
problem in certain applications, namely, those that require unique identification
in open-loop systems, such as national recovery databases, breed registries
and the like. Why has no national bank ever published an “open standard”
for printing paper money, so that anyone may print its currency? Publishing
specifications for paper, ink and printing plates to use to print money
is the functional equivalent of putting the protocol and IC coding for
transponders in the public domain. Like a $100 bill, which costs only
a few cents to make, a transponder, when put in a champion Pekinese
or a champion racehorse, assumes an intrinsic value many times higher
than its cost. Duplicating the ID number allows someone wishing to “game
the system,” to clone the animal, at least as far as the database or
registry is concerned.
Using ISO11784/85 compliant
OTP transponders, an animal from Latvia (for example) can be made
to look like one that came from Germany, or, vice versa. Dog owners
can keep several cocker spaniels, for example, while registering only
one: if ISO 11784/85 transponders are used to identify them, all of
the others can be chipped with the same transponder ID number. A parrot
poached from the Amazon rainforest can be made to look like one hatched
in the Tampa Zoo, thereby circumventing CITES trade restrictions designed
to protect endangered species from extinction. An animal owner can
claim insurance coverage for several animals while only taking out
a policy for one. By using a WMRM transponder, the same animal can
even change identities throughout its life.
How does the “open standards”
approach create this problem?
The premise
behind the International Standards Organisation (ISO) is to create
so-called “open standards.” Generic solutions. An ISO standard is
designed to be a sort of “cook book recipe” that any manufacturer
may follow to create a product that complies with the standard. ISO
does not police compliance. Compliance is entirely voluntary. This
approach to standardization works extremely well for modem protocols
and paper sizes, and it is also suitable for identification of dairy
cows in closed loop systems and the like, but it is flawed if the
premise is to generate unique ID numbers for use in open loop systems.
Because there are no legal "teeth" behind the ISO standard, there is
no means to interdict the production of unsanctioned transponders or
to prevent their being applied and the animals chipped with them from
being shipped around the world. The ISO "open standard" by its nature
depends upon an honour code. It is susceptible to compromise by manufacturers,
whose cooperation cannot be enforced.
Even obtaining transponders
from pre-approved, “vetted” manufacturers and filtering all these
ISO-conforming transponders through a single hub will not prevent
ISO 11784/85-conforming transponders with duplicate ID numbers from
entering the market.
(2) The problem of manufacturers'
accountability
A related problem
of all "open standards" and generic products is how to hold individual
manufacturers accountable. An implantable, glass-encapsulated transponder
of one brand can be visually indistinguishable from other brands.
Obviously, once the transponder is implanted, you cannot even visually
inspect the transponder.
Because all ISO FDX-B transponders
are functional clones, the operating protocol also will not help distinguish
the product (in the way a reader can distinguish between a Trovan
128 KHz transponder and an AVID encrypted transponder, for example).
A Rome-based institute called
ICAR has agreed to assign so-called “manufacturer’s codes” to different
suppliers of ISO 11784/85 transponders, who pay for the privilege.
The idea is to give the user a means of distinguishing among different
transponder brands. In this way, so the thinking went, it would be
possible for the user to identify inferior product, or manufacturers
who didn't strictly control their numbering schemes, and avoid the
offending manufacturer's product in the future. It must be noted,
however, that the published ISO 11784 and ISO 11785 standards do not
assign this role to ICAR. Also, unfortunately, ICAR cannot guarantee
that a given manufacturer's three-digit ID number appearing in a transponder’s
ID code ensures that this manufacturer in fact made the transponder.
(3) The problem of transponder
performance
Neither ISO 11784
nor ISO 11785 stipulates any minimum transponder performance requirements
for microtransponders (the size of transponder that is suitable for
use in companion animals, exotics etc.) Therefore, a transponder reading
at "touch" reading distance (a matter of 1 cm or less) could be fully
ISO-standards compliant. A transponder reading at “touch” reading
distance, would yield a “no read” in a turtle, a Pekinese or a Persian
cat, because the animal’s carapace/coat itself is well over 1 cm thick.
The transponder is out of range of the reader. ISO 11784/85-compliance
is therefore no quality guarantee or guarantee of suitability for
a given application. It also offers no guarantee to the veterinary
that a given RFID product will actually work when implanted into the
animal. What is more, ISO-compatible transponders programmed with
a given manufacturer’s code could merely be code clones that do not
meet that particular manufacturer’s product or quality standards.
Hasn’t ISO/TC23/SC19/WG3
already moved to address the problem?
In response
to the well-known problems with code security in the current ISO 11784/85
standard, the responsible working group, WG3, has set itself the task
of developing a new standard, ISO 14223. ISO 14223 describes a so-called
“advanced” transponder, and attempts to frustrate the duplication
of the ID code through increased technical complexity and encryption
of the integrated circuit (IC). This approach would merely raise the
hurdle slightly: the product specifications would still be published
and conform to all the ISO usage and accessibility guidelines, but
the resulting product would be more costly than transponders in the
market today and the size of the IC would be larger, precluding its
use in so-called “microtransponders” (the small, glass-encapsulated
transponders that are the preferred embodiment for companion animal
and endangered species).
Conclusion
There are a number of legitimate, very worthwhile potential uses
for ISO 11784/85 transponders, however national animal registration
databases relying on postive and unique identification is not one
of them. For a comprehensive discussion please see: http://www.rfidnews.com/iso_11784.html
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