The Texas Animal Health Commission has posted its agenda for next Tuesday's meeting.  Item 12 on the agenda is consideration and possible adoption of a list of proposed regulations, including the proposed regulation to require every dairy cow to be identified with an "official identification device."
 
If you own a dairy cow, this may be your last chance to tell the Commissioners what you think about the proposal.  If you know dairy farmers, please tell them about the meeting so that they have the opportunity to comment!
 
Last week's action alert on this topic, with more details, is included below. The meeting begins at 8:30 am, and we estimate that they will get to the proposed regulation mid-morning, although we do not have a definite time.
 
Here's the meeting information on TAHC's website: http://www.tahc.state.tx.us/agency/meetings/agendas/Agenda_364thTAHCCommMtg.pdf
 
 
Earlier this summer, the Texas Animal Health Commission (TAHC) proposed a new regulation that would require all dairy cattle being transported within Texas to be identified with an "official identification device or identification device approved by the Commission."  FARFA sent out an action alert urging everyone to submit comments on the proposed regulation, and a lot of people wrote the agency. Thank you!
 
The TAHC's next meeting is on Tuesday, September 18.  The agenda has not been posted yet, but the agency will most likely consider the proposed regulations as part of the meeting.  If you are concerned about the proposed regulation, this is your chance to tell the Commissioners in person.  This is especially important if you own a dairy cow and will be directly impacted by the regulation.
 
WHERE: TAHC's central office, 2105 Kramer Lane, Austin, Texas.
WHEN: Tuesday, September 18th, 2007.  Meeting begins at 8:30 a.m.
WHAT: Opportunity for public comment on proposed regulations
 
We will send out an update when the TAHC posts the agenda for the meeting.
 
Some background on the proposed regulation is below. You can read the proposed tagging regulation, as well as other proposed regulations, at  http://www.sos.state.tx.us/texreg/archive/June82007/PROPOSED/4.AGRICULTURE.html.
 
Read the previous alert: http://farmandranchfreedom.org/content/action-7-16-07.
 
Read FARFA's comments on the proposed regulation: http://farmandranchfreedom.org/content/files/7.18.07%20Comments%20on%20proposed%20TB%20regs.pdf
 
Read TAHC's meeting minutes: http://www.tahc.state.tx.us/news/meetings/Synopsis_CommMtg_May2007.pdf.  The discussion of the proposed TB regulation starts on page 3.

Background

The stated reason for the proposed regulation is the risk of tuberculosis (TB) exposure from untested dairy cattle.   But according to TAHC, the risk of tuberculosis infection is coming from out of state.  So the agency should be focused on entry requirements and testing out of state cattle coming in to Texas, not burdening in-state producers.
 
The proposed regulation also opens the door for the agency to require RFID tagging and NAIS premises registration requirements for dairy cattle.  The proposed regulation limits the identification to a "device," which may or may not include traditional forms of identification such as tattoos and brands.  We've already seen a similar approach in Michigan.  The Michigan Department of Agriculture made a "policy decision" that the only form of acceptable identification under its tuberculosis program was NAIS-compliant RFID tags, complete with premises registration!
 
The proposed Texas regulation by itself won't force dairy cattle owners to register and use electronic tags.  But it would be very easy for the agency to take that next step, with no additional regulations or notice.  Even if the agency has no intention of imposing electronic identification at this time, the language of the regulation would allow them to do it next year, or the year after, or whenever they want to.
 
As always, if you have any questions, contact us at info@farmandranchfreedom.org or call 866-687-6452.

Working together, we can make our voices heard.
 
Sincerely,
 

Judith McGeary
Farm and Ranch Freedom Alliance
www.farmandranchfreedom.org
866-687-6452