[This Action Alert is Over]

Your comments needed today!

Having dropped the plans for the National Animal Identification System (NAIS), USDA is back again for Round Two. The agency has proposed a rule that would require livestock producers, related businesses, and state livestock agencies to incur significant expense tracking animals that cross state lines—with few tangible benefits to farmers or their American customers.

Though less sweeping than the NAIS, the proposed animal traceability rule is still burdensome and a solution in search of a problem.

The USDA has again failed to identify the specific problem or disease of concern, and the real focus of the program is helping the export market—benefiting a handful of large agribusinesses, the costs and burdens will fall on individual farmers and ranchers, vets, sale barns and weigh stations, and already financially strapped states.

These new regulations will harm rural businesses while wasting taxpayer dollars that could be better spent on the real problems we face in controlling animal disease, food security, and food safety.

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 the small businesses of the nation.

TAKE ACTION

Please submit comments to USDA today! You can submit comments either 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 deadline for comments is FRIDAY, DECEMBER 9, 2011.
(Talking points and a sample letter can be found below.)

Please also send a copy of your comments to your Congressman and Senators. If you don’t know who represents you, you can find out at www.house.gov and www.senate.gov

Here are talking points you can use for your comments. A sample letter, which you can customize is at the end of this alert.

TALKING POINTS:

1) The agency should withdraw the proposed rule.

2) 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 offer economic premiums to livestock producers to encourage them to participate in a voluntary system.

3) 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.

4) 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.

5) At the very least, significant changes need to be made:

  • Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
  • Exempt all direct-to-slaughter cattle, both for custom and for retail sales. The proposed rule provides for a temporary exemption, but then phases these animals into the program except for personal use.
  • Recognize livestock brands as “official identification” among and between all states that currently have official state brand programs and “official supplementary identification” for all other states.
  • Do not impose any new requirement for identifying poultry. There has simply been no evidence that imposing new requirements on small-scale poultry operations is warranted, while they definitely will cause significant economic harm.
  • Provide that a physical description qualifies as an official identification method for horses without having to be approved by the health officials in the receiving State or Tribe.

MORE INFORMATION:

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.

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. 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.

READ USDA’S DOCUMENTS:

You can read the proposed rule at:
http://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

SAMPLE LETTER:

Please personalize these comments! Include a personal story at the beginning of your comments so that it is less likely to be viewed as a form letter. The personalization can be just a few sentences, but it does make a significant difference.

Dear USDA Secretary Vilsack:

I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.). I am very concerned that the proposed animal traceability rule 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.)

I urge the USDA to withdraw the proposed rule.

If the export market would benefit from the proposed rule, as the agency claims, then the meat packing companies that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.

The agency’s analysis does not address the full costs of the program, and this is a waste of money at a time when both private and government resources are already stretched thin. The proposed rule is an unfunded mandate on state agencies, private businesses, and individuals.

At the very least, significant changes need to be made:

  • Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
    Exempt all direct-to-slaughter cattle, both for custom and for retail sales.
  • Recognize the brand as “official identification” among and between all states that currently have official state brand programs and “official supplementary identification” for all other states.
  • Do not impose any new requirements for identifying poultry. There has simply been no showing that imposing new requirements on small-scale poultry operations is needed, while it will definitely cause significant harm.
  • Provide that a physical description qualifies as an official identification method for horses without having to be approved by the health officials in the receiving State or Tribe.

Sincerely,

Name
Address
City, State Zip

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