FARFA, joined by a dozen organizations, sent a letter to USDA and the State and Tribal members of the Regulatory Working Group about the new animal ID framework. The letter raises fundamental questions about the new framework, as well as specific points of concern. Below are some excerpts:
"Before moving forward with any framework, the undersigned organizations would like USDA to clearly identify which animals beingmoved in commerce are not already traceable, the flaws in the current traceability programs, and the specific problems they hope to solve through a traceability program." ...
"The greatest animal health and public health risks come from consolidated production and processing, and any program that increases consolidation would be counter-productive. We urge USDA to consider the ramifications on competition in animal agriculture when developing policies, both on animal identification and beyond." ...
"Below are a few specific points of concern.
1. Transport across state lines without change of ownership a. Transport for slaughter: Many family farmers and ranchers raise livestock entirely within one state, but cross state lines in order to reach a slaughterhouse because of the difficulty in finding slaughterhouses that will process single or small groups of animals. These livestock do not change ownership when they cross state lines, and their owners should not be encumbered with any additional identification requirements on top of those already required under current regulations. ...
2. Impact on intrastate and intratribe programs: The USDA has clearly stated that the new program is intended to track animals that cross state or tribal lines back to the state or tribe of origin, and we support this limited purpose. Depending on what the program requires, however, it could potentially create pressures on intrastate, intratribe, or even private programs to adopt specific requirements or technologies through a “trickle-down effect.” We do not ask USDA to take responsibility for the truly independent decisions of others, but we urge the agency to consider all of the ramifications of the proposed program, including the influence it will bring to bear on state and tribal authorities and market programs.
3. Shipping of poultry: It is common practice for hobbyists, homesteaders, and family farmers to order day-old poultry through the mail. There are only a few hatcheries left that provide poultry to individuals outside of vertically integrated corporate-controlled operations, so the chicks are commonly shipped across state lines. The poultry frequently do not cross state lines again during their relatively brief lives. Requiring poultry to be identified when shipped across state lines as chicks would be unduly burdensome
4. The use of a national database: If the premises registration (now location identifier) and 840 tags continue to be available to states and individuals, how will those databases be maintained? What information will be stored? How can individuals be removed from the databases if they no longer wish to be involved or if they were originally entered without their consent?"
We encourage everyone to raise these questions, along with any additional questions or suggestions you have, in the upcoming meetings on animal identification. See below for dates and locations of the meetings.
The letter was signed by: American Grassfed Association, Carolina Farm Stewardship Association, The Cornucopia Institute, Empire State Family Farm Alliance, Farm and Ranch Freedom Alliance, Innovative Farmers of Ohio, Massachusetts SmallHolders Alliance, Missouri Rural Crisis Center, Nebraska Sustainable Agriculture Society, Northeast Organic Farming Association -- Massachusetts, R-CALF USA, South Dakota Stockgrowers Association, and Western Organization of Resource Councils .
The full letter is available at http://farmandranchfreedom.org/sff/Ltr-animal-traceability-100503.pdf
USDA Public Meetings on Animal ID
USDA is holding three public meetings on Animal Identification in Missouri, Maryland, and Colorado between May 11 and May 17:
• Tuesday, May 11, 2010 Holiday Inn Kansas City – SE Waterpark, 9103 East 39th Street, Kansas City, MO 64133
• Thursday, May 13, 2010 USDA Center at Riverside , 4700 River Road, Riverdale, MD 20737
• Monday, May 17, 2010 Crowne Plaza – Denver International Airport , 15500 East 40th Avenue, Denver, CO 80239
In response to our question about the purpose of the meeting, USDA stated that it plans to take specific input and suggestions on traceabilty performance measures. Members of the regulatory working group will be at the meetings. If you are within traveling distance of these meetings, please come and speak up!
USDA has stated that there will be other opportunities for input. So if you can't go to one of the meetings, stay tuned for information on how to submit written comments. More information is posted at: http://www.aphis.usda.gov/traceability/meetings/index.shtml