Agricultural News
R-CALF USA Tells Producers Why They Should Oppose USDA's Animal ID Rule
Wed, 30 Nov 2011 16:25:34 CST
Earlier this month, the mail-in ballots from R-CALF USA's cattle-producing members located across the United States were counted and by a margin of 98.5 percent, R-CALF USA members voted to oppose the U.S. Department of Agriculture's (USDA's) new mandatory animal identification rule, commonly known as the Traceability for Livestock Moving I nterstate rule (rule).
With the Dec. 9, 2011, deadline for public comments looming, R-CALF USA issued the following Baker's Dozen list of why U.S. cattle producers should oppose USDA's new mandatory rule:
1. There is absolutely no need for a federally mandated animal identification rule. The 50 states already have animal health import and export rules. Rather than impose its one-size-fits-all command and control regime upon the states, USDA should develop best practices guidelines that states could voluntarily use to develop programs that work best for them.
2. USDA's rule to require persons that transport cattle across state lines to identify cattle is an ineffective and unscientific means of achieving disease traceability. USDA's rule completely ignores the science-based principle that disease outbreaks are most likely to originate at locations where livestock are comingled with livestock from other herds, particularly with livestock from foreign herds, and where livestock comingle with diseased wildlife. State borders do not constitute likely sources of disease outbreaks.
3. USDA's rule does not even require official ear tags to bear a state code that would at least enable health officials to immediately determine the animal's state-of-origin.
4. USDA's rule fails to address one of the most critical concerns raised by thousands of cattle producers during USDA's 2009 listening sessions. That critical concern was producer liability. Under USDA's book-end system, the person who applied an animal's tag would be the primary suspect in any disease traceback, even if the animal was sold months or years prior to disease detection. As a primary suspect, the original ear-tagger likely would bear the cost of testing and retesting his/her entire herd.
5. USDA's proposed rule requires all states to accept USDA's international 840 ear tags that are functionally incapable of revealing even the state from where the animal originated without the use of an electronic wand or access to a federal database. USDA is insincere to claim hot-iron brands cannot be used by non-brand states while it simultaneously requires non-wand states to accept 840 tags.
6.Under no circumstances should the hot-iron brand be delisted, or in any way demoted below any other form of animal identification, as an official animal identification device.
7. Under no circumstances should feeder cattle be included in any mandatory animal identification rule.
8. Under no circumstances should the federal government mandate that the private property owned by the citizens of the various 50 states be identified with an official USA shield. This is an unscientific requirement that has nothing to do with disease traceability. If a shield is needed at all, cattle identification devices should bear the shield of the state from where the cattle originated. At least with a state shield , health officials would know where to start a disease investigation.
9. USDA's proposed rule discriminates against and financially disadvantages cattle producers who reside in states that require mandatory brand inspection as a condition of leaving a brand inspection area. Not only will those producers continue to bear the cost of their state-mandated brand inspections, but now, those producers must also pay the added cost of applying additional identification devices and for recording those devices before participating in interstate commerce.
10. USDA's proposed rule will significantly increase the cost of interstate movement by disallowing the use of expedient back-tags for cattle destined for slaughter. Back tags are an effective and expedient means of identifying cattle destined for slaughter and the elimination of this device will disrupt commerce, increase injuries, and add unnecessary cost to an industry incapable of passing additional costs to anyone else in the supply chain.
11.The proposed rule will interfere with, if not altogether eliminate, market driven incentives and economic premiums presently paid to producers that source-verify cattle. If USDA mandates a national identification system, it will no doubt persuade beef exporting nations to recognize the new system as a government-sanctioned guarantee that all beef produced in U.S. slaughter facilities can be traced to its herd of origin. When this occurs, ec onomic premiums presently paid by packers for source information will evaporate.
12. The benefactors of the proposed rule are multinational meatpackers that will be gifted, at no cost to them, the right to advertise and promote their entire beef production as traceable to its source. Of course, individual producers and states and tribes will pay the entire cost of delivering this gift to the meatpackers free of charge. This is unacceptable and constitutes overreaching government interference in our free market system.
13. USDA has reneged on its promise to grant each state the flexibility to choose to continue using the registered hot-iron brand accompanied with a brand inspection certificate to identify cattle moved in interstate commerce. Under USDA's rule, an individual state cannot choose to use the registered brand and accompanying brand certificate unless it can first convince another state to also agree to their use. USDA also has disallowed the brand even for group/lot identification, which is a far superior means of identifying ani mal groups as each animal in the group would necessarily be individually identified with the brand.
To submit comments on USDA's rule no later than December 9:
By E-mail:
1) Go to regulations website.
2) Find the entry titled "Traceability for Livestock Moving Interstate" with a "posted date" of 08/11/2011.
3) Just to the right of the date "08/11/2011," click "Submit a Comment."
4) Follow the instructions for submitting your comments that can be written in the box provided.
By U.S. Mail:
Docket No. APHIS-2009-0091
Regulatory Analysis and Development, PPD
APHIS, Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238
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