The Texas Animal Health Commission (TAHC) is proposing a new rule on cattle identification, and we need you to speak up for small producers!
Previously, the TAHC had adopted a requirement that all adult cattle be tagged upon change of ownership, with no exemptions. Due to the objections of many groups and the debate during the Texas legislative session, the agency agreed to repeal that rule and replace it with a rule that included a direct-to-slaughter exemption.
The TAHC has now done that … sort of. Under the new proposed rule, all adult cattle, except steers and spayed heifers, must be identified with an official eartag or other form of official permanent ID as approved by the agency when they change ownership. There is an exemption for cattle that are being taken to slaughter within seven days of the change of ownership — but only if they go to a state or federally approved slaughterhouse.
This is an improvement from TAHC’s previous rule, which did not include any slaughter exemption. But there still are serious flaws.
Problems with the new TAHC rule
First, there is the continuing underlying problem that the agency ignores the cost of tagging to small producers. The agency appears to assume that the costs of the tags will be paid for by the government, but this is far from guaranteed. And the agency is dismissive of the fact that the real costs lie not in the tag, but in the labor and equipment needed to attach the tag to a 1,000 lb cow. The agency uses its false assumptions to avoid the normal requirement for an economic impact statement to determine the impact on small and micro-businesses.
Second, the proposed rule shows the agency’s disregard for small producers by limiting the direct-to-slaughter exemption to inspected slaughterhouses and excluding custom slaughterhouses. At a TAHC meeting in January, FARFA specifically pointed out the fact that many small farmers do not have an inspected slaughterhouse that will accept their animals within a reasonable distance. The only option for these farmers is to use a custom slaughterhouse.
Since meat from a custom slaughterhouse cannot be sold and is only for personal consumption, these farmers are left with only one legal option: to sell the live animal to one or more consumers. The animal, now owned by the consumers, can be taken to the nearby custom slaughterhouse to be processed for the new owners’ benefit.
But under the proposed rule, the farmer would have to go to the expense and trouble of officially tagging the animal simply because it “changes ownership” before going to the custom slaughterhouse. This imposes unfair costs and burdens on small producers.
- MAIL: Carol Pivonka, TAHC, 2105 Kramer Lane, Austin, Texas 78758
- FAX: (512) 719-0721
- EMAIL: firstname.lastname@example.org
Below are sample comments. Please take a few minutes to personalize at least the first couple of sentences. You will have a much greater impact with a personalized letter!
Dear Ms. Pivonka,
I am a _____________ (small-scale cattle owner, consumer who buys beef locally, supporter of my local farms, etc.). I am concerned about the agency’s proposed rule for tagging cattle under Chapter 50.
First, the agency should have done an economic impact statement to determine the cost for small and micro-businesses. The statement that the identification tags are “available to producers” does not address the question of whether the government will continue to provide tags at no cost in the future. And the greater cost will come from the labor and equipment needed to do tagging, particularly for very small scale producers who do not have chutes and headgates, which can cost thousands of dollars. The agency assumes that there will be businesses offering tagging services “for a nominal fee,” but this has yet to happen.
Second, cattle that are being taken to slaughter at a custom slaughterhouse should be exempted, just like cattle being taken to slaughter at a state or federally inspected slaughterhouse. From a traceability perspective, there is no significant difference between an inspected and a custom slaughterhouse. Many small-scale producers do not have an inspected slaughterhouse nearby, and it is unfair to impose tagging requirements on them simply because of the inspection status of the facility.
You can read the proposed rule at: www.sos.state.tx.us/texreg/archive/October42013/Proposed%20Rules/4.AGRICULTURE.html#14