The Latest News on Animal Identification

December 6:  Have you told USDA what you think about the proposed rule for animal ID? 
 
This Friday is the deadline!

Small farmers and urban poultry owners alike are threatened by the USDA's new proposal for animal identification.  The agency has proposed a rule that imposes costs and paperwork burdens on farmers, ranchers, backyard poultry owners, sale barns, vets, and state agencies in order to track animals that cross state lines.

The proposed rule is a solution in search of a problem.  The USDA has failed to identify the specific problem or disease of concern, and the real focus of the program is helping the export market for the benefit of a handful of large corporations.  The agency has also failed to account for the full cost to both private individuals and state governments, creating an unfunded mandate. The new rule 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.   

Family farmers and ranchers cannot afford additional paperwork and unnecessary expenses.  Please help protect our farms and our right to own animals by submitting your comments today -- the deadline is midnight on Friday, December 9!

Take Action

You can submit comments online at http://www.regulations.gov/#!submitComment;D=APHIS-2009-0091-0001  

 The government's online system can be difficult to navigate and there is a time limit.  We encourage you to write your comments and save them in a document on your computer, then copy and paste them into the online comment form.  Also, although only some of the information fields are marked as being "required," some people have experienced problems when they left fields blank.  So for the fields that are not required, you may wish to put "NA" (not applicable) in them to avoid potential problems. 

 DEADLINE:  Friday, December 9, 2011
 
 
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, followed by sample comments and more detailed information.
 
TALKING POINTS:
 
1)  The agency should withdraw the proposed rule.  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.
 
2)  The agency needs to identify the specific diseases of concern and analyze how to best address those diseases - including prevention measures -- rather than continuing to push a one-size-fits-all tracking program.
 
3)  At the very least, significant changes need to be made:

* Do not impose any new requirements for identifying chickens and other poultry.  Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.

* 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 brands and tattoos as official forms of identification.

 
SAMPLE COMMENTS:   Please personalize these sample comments rather than doing a form letter.  The personalization can be just a few sentences at the beginning of the comments, but it does make a significant difference.  And if you have time to write more detailed comments, that's even better!

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; 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.  For disease control, the agency needs to focus on preventative measures rather than after-the-fact tracking.
 
At the very least, significant changes need to be made:

* Do not impose any new requirements for identifying chickens and other poultry.  Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.

* 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 brands and tattoos as official forms of identification.

Sincerely,

 Name

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.  

We have asked USDA for data showing where the problems are in tracking animals currently.  Rather than provide that data, USDA hand-picked a few anecdotes, out of the millions of animals in this country.  But the agency's unsupported claims do not justify imposing broad new tracking requirements.  Small farms are not the source of most disease problems in this country, yet the proposed rule will burden them unfairly.

POULTRY: 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. 

Even if the definition of "group identification" were changed to cover small operations, the result would be new paperwork requirements on almost every person who owns chickens, turkeys, or other poultry.  The agency has entirely failed to justify imposing these burdens on poultry owners.

CATTLE: Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on calves and young cattle ("feeder cattle"), even though there's no evidence that such requirements will help disease control. In addition, veterinarians and sale barns will have to keep records for 5 years, even though many of these cattle will have been consumed years earlier, creating mountains of useless paperwork.

Producers will only be able to use brands or tattoos as identification if their States enter into special agreements. State agencies will have to build extensive database systems to handle all of the data, creating problems for States' budgets.
 
HORSES: The proposed rule also requires that horse owners identify their animals before crossing state lines.  Although most, if not all, horses that are shipped across state lines are already identified in some fashion, 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.

SHEEP, GOATS, and HOGS: 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 http://www.regulations.gov/#!documentDetail;D=APHIS-2009-0091-0001

October 28, 2011:  Download our new flyer on animal ID -- put it out at your local farmers market, feed store, sale barn, etc. 

September 2011: Take Action!  Check out our sample comments and submit your own to USDA.  All the details are here

August 26, 2011: Read our initial overview of the proposed Animal ID rule here.

August 25, 2011: FARFA and 48 other organizations urge USDA to extend the public comment period on proposed Animal ID rule.  Read our letter here

June 21, 2011: USDA and Corporate Agribusiness Continue to Push Animal ID Scheme - Read the press release here. 

March 7, 2011: USDA Secretary's Advisory Committee submits recommendations on Animal ID framework. 

February 18, 2011:  USDA plans to propose rules in April.  Read our comments on the current framework and learn more

December 17, 2010: Secretary's Advisory Committee on Animal Health announced.  Three of our nominees were selected!  Read more

August 31, 2010:  FARFA submits comments to USDA on Animal Traceability framework

July 1, 2010: Read about USDA's public meetings on Animal Traceability, and the current proposal, here

June 30, 2010: House Subcommittee cuts funding for NAIS:The House Agricultural Appropriations Subcommittee has cut all funding for animal ID in the 2011 Appropriations bill.  The Subcommittee rejected USDA’s request for $14.2 million for FY 2011.  Remember that this is just the first step in the appropriations process, and the funding could be re-instated later.

Learn more about the National Animal Identification System (NAIS), its history and the money trail behind it.  Click here

May 3, 2010: FARFA Provides Input to USDA on New Framework

FARFA drafted and sent a letter, signed by a dozen other organizations, to USDA and the State and Tribal members of the regulatory working group, asking for clarification on the new framework and providing input on issues of concern to animal owners.  Read the full letter here

March 9, 2010: Trial Court Victory!

The Wisconsin trial court has dismissed the case against Mr. Miller, an Amish farmer who refused to register his property on religious grounds. Read the court's decision here. FARFA and 22 other organizations filed an amicus brief in support of Mr. Miller, which you can read here.

February 5, 2010: USDA has announced that it is dropping NAIS!

This is a major victory for the grassroots!! Thank you to the thousands of people who called, wrote, organized meetings, and more. Dozens of organizations, from across the country and the full range of the political spectrum, worked together on this common cause. And we succeeded in making our voices heard.

USDA has stated that it is refocusing its efforts on “a new, flexible framework” that will apply only to animals moved in interstate commerce and encourage the use of “lower-cost” technology. During today’s conference call with USDA, I asked whether the agency would continue using federal funding to pressure states to adopt the program through cooperative agreements. In response, Secretary Vilsack stated that USDA has gotten a “failing grade” on NAIS and that he does NOT intend to try to implement it through the back door.

You can read more details from USDA at: http://www.aphis.usda.gov/publications/animal_health/printable_version/faq_traceability.pdf

We still have more work in front of us. As USDA develops its new framework, we must be involved and vocal, so that agribusiness does not develop yet another high-tech, big-industry boondoggle. We must be active at the state level to ensure that the state agencies do not implement unnecessary and burdensome rules. And we must work to roll back the unfair requirements that have already been implemented in Wisconsin and Michigan. Ultimately, it is up to us – as animal owners, homesteaders, farmers, ranchers, and consumers -- to build a positive vision for our farms and our food.

Read FARFA's Letter to Secretary Vilsack