USDA has announced two more public meeting on its animal traceability framework:
Thursday, June 24 Sheraton Salt Lake City Hotel , 150 West 500 South , Salt Lake City, UT 84101
Thursday, July 1 Holiday Inn DFW Airport South , 14320 Center Station Drive, Ft. Worth, TX 76155
The meetings will take place between 8 am and 4 pm, and more information is posted at: http://www.aphis.usda.gov/traceability/meetings/index.shtml
Come to the meetings and speak up!
USDA has stated that there will be additional meetings scheduled, but the locations and dates are not yet posted.
More information
USDA provided the first glimpses into its “new framework” at the public meetings held last month in Kansas City, Riverdale, and Denver. Approximately 60 people attended each meeting, and Judith McGeary represented FARFA at the Denver meeting.
The presentation by the USDA official at the meetings essentially tracked the USDA statements since February 5: The new framework is intended to track animals that actually cross state lines, and encourage the use of low-cost technology such as metal tags. Producers who wish to use electronic forms of identification will be able to do so, but RFID tagging will not be required.
Unfortunately, the other presentations were not entirely consistent with that limited, low-tech approach. Dr. Breitmeyer, the California State Vet, presented the same powerpoint that he used at the National Institute for Animal Agriculture’s (NIAA’s) annual meeting. Dr. Breitmeyer is a proponent of RFID tagging for cattle, and his presentation focused on the dairy industry in California – without acknowledging that this is a highly consolidated industry, with huge herds of confined cattle that are handled two-three times per day, and extensive trading across both international and state borders. This is significantly different from the majority of livestock operations around the country.
The real issue is the presentation by the Regulatory Working Group, which was established by USDA with 5 state vets and 5 tribal authorities. Their initial proposal for discussion is posted at: http://www.aphis.usda.gov/traceability/downloads/performance_standards_handout.pdf
In brief, the Working Group proposes to set performance standards for four “action items” for animals that are moved interstate:
1) The State/Tribe where an “animal of interest” is located must be able to notify the State where the animal was originally identified. This is basically a bookend approach.
2) The State in which the animal was originally identified must be able to identify the “traceability unit” in which the animal was identified. The Working Group has not defined the term “traceability unit."
3) The State/Tribe where an “animal of interest" is located must also be able to notify the State from which the animal was last shipped. This may or may not be the same as action #1, depending on whether the animal has been moved interstate more than once.
4) The State from which the animal was last shipped must be able to identify the “traceability unit” from which the animal was shipped.
The Regulatory Working Group has developed proposed standards for each of these actions (such as being able to accomplish Action #1 within 1 business day 95% of the time).
There are several major issues:
1) What is the problem to be solved? Other than saying that “we can’t trace cattle well enough right now,” the Regulatory Working Group is not addressing the question of what level of traceability is actually necessary for animal health purposes. We need a real analysis of how traceability fits into the bigger picture of animal health issues, so that we can determine how to best use the limited resources of both animal owners and the government.
2) The Regulatory Working Group's proposal includes federal standards for intrastate tracking (Actions 2 and 4). While it would not dictate specific methods for intrastate tracking, this goes beyond the USDA’s statement that the new framework will address only interstate movements.
3) The Regulatory Working Group's proposal includes a standard for how quickly a state must be able to trace an animal back to a “traceability unit,” but does not define that term. In the presentations, Dr. Roehr stated that a “traceability unit” could be the entire state, a region, multiple counties, one county, or a single livestock premise. It makes no sense to set a standard on an undefined term.
We urge USDA to take steps to address these issues. Stay tuned for more information.
