USDA’s animal traceability program is fundamentally flawed because it is not designed to address the real problems ranchers face, and it imposes burdens on producers for the benefit of Big Agribusiness.

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 paperwork for five years, even though many of these cattle will have been consumed years earlier.

State agencies would have to build compliant programs, database storage, and management and retrieval systems to handle all of the data, creating problems for many state budgets. The proposed rule doesn’t address what will be the consequences if states 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.

TAKE ACTION

Please submit comments to USDA today! You can submit comments either online or by mail.

SAMPLE COMMENTS

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.

Dear Secretary Vilsack:

I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.). I am very concerned that the proposed rule will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me, etc.)

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.

I urge you to make the following changes in the proposed rule to make it more workable for farmers and ranchers:

• Address and justify the full costs of the program.
• 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.

In closing, I urge you to extend the comment period on the proposed rule for sixty days. This is a busy time of the year for ranchers, and more time will help ensure those who are most affected by this proposed program are given the time they need to review it.

Sincerely,
Name
Address
City, State Zip

SEND COMMENTS ONLINE

Go to USDA website to comment online. 

SEND COMMENTS 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 December 9, 2011.

Please also send a copy of your comments to your Congressman and Senators. You can find their contact information at www.house.gov and www.senate.gov.

What you can say in your comments:

• Insist the agency address the full costs of the program so that this does not become an unfunded mandated a colossal waste of money at a time when both private and government resources are already stretched thin.
• 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.
• Recognize hot iron brands as “official identification among and between all states that currently recognize brands and “official supplementary identification” for all other states.
• Request specific assurances that information will be kept private and used only by agencies for disease tracking.

Read news release

READ USDA’S DOCUMENTS

You can read the proposed rule here.

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 here.