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in this section: TAKE ACTION, Background info, USDA Documents, Previous CFSA action on this subject, Links to more information
Sept. 26, 2011 UPDATE
Just Say ‘No’ to NAIS Lite
The USDA is back with another flawed animal tracking scheme that will hurt small farms and local food.
Two years ago the agency dropped plans for a National Animal Identification System (NAIS) in the face of huge public outcry from people like you. Now USDA has proposed a ‘lite’ version of NAIS that would impose major, unjustified costs on small-scale livestock producers and the businesses that support them, solely to protect the handful of giant companies that dominate the meatpacking industry.
Your voice is needed today to stop this unfair rule.
Animal-ID proponents claim a system is necessary to combat animal diseases, but the USDA’s proposed rule fails to identify any specific problem or disease of concern, and the real focus of the proposed program is helping the export market. So while the program will benefit a handful of large corporations, the costs and burdens will fall on producers, vets, sale barns and weigh stations. These new regulations will harm rural businesses while wasting taxpayer dollars.
At a time when farmers and ranchers are facing significant economic problems, the last thing we need is additional burdensome rules hindering the economic viability of these small businesses.
Submit your comments to USDA today and help stop this unfair rule. Please send your comments to USDA today! The deadline has been extended to DECEMBER 9, 2011. You can submit comments online or by mail.
***Please personalize these comments! Include a personal story at the beginning of your comments so that it’s not just a form letter. The personalization can be just a few sentences, but it does make a significant difference.
Here is the message to send:
Dear Secretary Vilsack:
I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.). I am very concerned that the proposed rule for tracking livestock moving between states will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me; make it prohibitively expensive for me to order baby chicks from out-of-state hatcheries; etc.).
1) The agency should withdraw the proposed rule. The program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness’ export markets.
2) Poultry should be excluded completely from any identification requirement. There has simply been no evidence that imposing new requirements on small-scale poultry operations is needed, while they definitely will cause significant harm.
3) If the export market would benefit from the proposed rule, as the agency claims, then the agribusinesses that export meat should pay the costs and pay premiums to livestock producers to encourage them to participate in a voluntary system.
4) The agency needs to identify the specific diseases of concern and analyze how to best address those diseases, rather than continuing to push a one-size-fits-all generalized tracking program.
5) The agency’s analysis does not address the full costs of the program. This is a waste of money at a time when both private and government resources are already stretched thin. This is an unfunded mandate on both state governments and private businesses.
6) All feeder cattle and direct-to-slaughter should be exempted completely from any identification requirements since there is no evidence that such requirements will help disease control.
7) USDA should not over-rule any of the existing state-based animal ownership registration programs and should recognize all of the “official identification” systems used among and between individual states.
Please send your comments to USDA today! The deadline is WEDNESDAY, NOVEMBER 9, 2011. You can submit comments online or by mail.
ONLINE:
http://www.regulations.gov/#!submitComment;D=APHIS-2009-0091-0001
BY 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
The USDA’s newly proposed animal identification program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness’ export markets.
Some of the specific requirements for cattle pose particular problems. Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on non-breeding feeder cattle, despite the lack of evidence that such requirements will help disease control. The proposed rule provides for a temporary exemption for cattle headed to slaughter, but then phases these animals into the program except for personal use only. In addition, anyone issuing official ID tags will have to keep records of the tags for five years, and sales barns will have to keep copies of paperwork for five years, even though many of these cattle will have been consumed years earlier.
State agencies will have to build compliant programs, database storage, and management and retrieval systems in order to handle all of the data, creating problems for many states’ budgets. The proposed rule doesn’t address what will be the consequences if states’ systems don’t meet the federal government’s goals. The sending and receiving states can agree to use alternative identification methods, such as brands and tattoos, but otherwise the brand and tattoo will no longer qualify as an official identification method.
Small-scale, pastured, and backyard poultry will be particularly hard hit by the proposed rule. While the large confinement operations will be able to use “group identification,” the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.
Under the proposed rule, horses will have to be identified when they cross state lines. Official identification includes a physical description, digital photograph, or electronic identification. Although most, if not all, horses that are shipped across state lines are already identified in one of these ways, the language of the proposed rule creates a new complication. Whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.
The draft rule also covers sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.
You can read the proposed rule at: www.aphis.usda.gov/traceability/downloads/2011/Proposed%20Rule.pdf
You can read the USDA’s regulatory analysis, which includes its analysis of the costs of the program and the alleged benefits to the export market, at: http://www.aphis.usda.gov/traceability/downloads/2011/Regulatory%20Impact%20Analysis.pdf
Aug. 30, 2011
The sustainable agriculture community won a huge victory in 2009 when we stopped NAIS, which was an industry-backed proposal to require the individual tracking of every livestock animal in the US—except animals on CAFOs. Thanks to a huge public outcry from ranchers and consumers alike, USDA eventually shelved the plan.
But the giant meat packers that dominate the livestock industry aren’t through with this issue, and they continue to seek mandated traceability requirements in order to develop international standards for exports. In response, the USDA has pressed on to develop a new traceability scheme, claiming it to be an animal health program, although admitting the importance of the export market to the United States.
The U.S is a net importer of meat. The profits from the export market go to a small handful of massive meatpackers. Factory farms can easily absorb the added economic burdens of a traceability scheme, while many family-scale farmers and ranchers would be forced out of business by the increased expenses and labor necessary to comply.
A range of cattle organizations agreed upon tracing breeder cattle as the basis for an efficient tracking system. However, the USDA’s initial draft of the new rule requires identification of every cow crossing state lines, including feeder cattle to be processed at a young age. Because of their sheer numbers, this requirement could wipe out small ranchers and sales barns and further erode competition in the marketplace, accelerating the loss of independent farmers to corporate industrial-scale producers.
The giant packers pressing for a new NAIS are the same ones that successfully stalled Country of Origin Labeling (COOL) for many years and that are now waging war against common-sense anti-trust rules for the Grain, Inspection, Packers and Stockyards Administration (GIPSA). The proposed GIPSA rule would end the discriminatory practices that have driven thousands of independent farmers and ranchers out of business. More than 65,000 people submitted comments on the GIPSA rule, almost all in support of strengthening it, yet the meatpackers are using their powerful influence in Congress to try to block its implementation. The corporations oppose any regulation of their own predatory practices, yet want to impose new requirements on family farmers and ranchers to boost their export profits.
CFSA member Genell Pridgen of Rainbow Meadow Farms served on the Secretary’s Advisory Committee on Animal Health that has previewed the USDA’s initial framework for a new animal traceability proposal. She as the handful of other sustainable ag advocates on the panel submitted comments to USDA citing problems with the agency’s proposal. To read those comments, click here:
For more background information about what USDA has released to date and the issues that have been raised so far, check out the following links:
USDA materials:
USDA implementation plan: http://www.aphis.usda.gov/traceability/downloads/report_implementation_plan.pdf
USDA statement on the role of brands:
http://www.aphis.usda.gov/traceability/downloads/clarification_regarding_use_of_brands.pdf
R-CALF’s letter to USDA that triggered this statement:
http://www.r-calfusa.com/animal%20id/110413RCALFLetterToVilsackReBrands.pdf
Secretary’s Advisory Committee materials:
In December 2010, USDA created a “Secretary’s Advisory Committee on Animal Health.” Three of our nominees from the sustainable ag community were included: Judith McGeary of the Farm and Ranch Freedom Alliance, Gilles Stockton of Western Organization of Resource Councils, and Genell Pridgen of Carolina Farm Stewardship Association. The Committee is composed of a total of twenty individuals. (http://www.aphis.usda.gov/animal_health/acah/)
The Committee’s ability to influence the proposed rule has been extremely limited because the proposal was already written and going through the agency approval process before the Committee even had its first meeting. As a result, the Committee members were asked only to identify “show stoppers” and the Committee ultimately made only two recommendations:
1) The proposed rule should incorporate concrete provisions to ensure it will not result in an unfunded mandate. The proposed rule should provide that the regulatory requirements will be suspended if, at any point, there is insufficient funding, specifically for the costs to producers for identification devices; costs to States for necessary personnel and technology; and the costs to other impacted individuals (such as veterinarians, sales facilities, and other market facilitators) for any mandated practices and technology.
2) The comment period for the proposed rule should be extended to120 days.
CFSA's Original Comments on the former NAIS Proposal
For even more background information on this issue and what CFSA did to fight these rules, click here.