A year ago, USDA announced that it was dropping its plans for the National Animal Identification System (NAIS), and that it would instead develop a new framework for tracking animals that move across state lines. At the same time, the USDA also announced that it would form a new “Secretary’s Advisory Committee on Animal Health.”
Last fall, FARFA joined with a coalition of organizations to nominate a slate of producers to the Committee. After a long delay, the Committee was finally named in December. Three of the coalition’s nominees were selected: Judith McGeary of the Farm and Ranch Freedom Alliance, Gilles Stockton of the Western Organization of Resource Councils, and Genell Pridgen of Carolina Farm Stewardship Association. Judith McGeary was also named Vice-Chair of the Committee, with Dr. Don Hoenig (the State Vet of Maine) named as the Chair.
The Committee, made up of a total of 20 people, met for the first time on January 20-21, 2011. At that meeting, the USDA officials stated that a proposed rule has already been written and is going through the administrative process prior to publication, which is scheduled for mid-April. So the Committee’s initial work has been limited to highlighting “show stoppers” in the framework. You can review all of documents presented to the Committee at www.aphis.usda.gov/animal_health/acah.
On March 4, the Advisory Committee held a teleconference to discuss the issues different stakeholders had raised as potential show stoppers. The Committee discussed a range of issues, from the inclusion of feeder cattle to the role of brands and confidentiality concerns. There was no consensus to recommend changes to the framework on most issues, but the majority of the Committee did agree on two recommendations:
1. On the issue of cost: The proposed rule should incorporate concrete provisions to ensure it will not result in an unfunded mandate. The proposed rule should provide that the regulatory requirements will be suspended if, at any point, there is insufficient funding, specifically for the costs to producers for identification devices; costs to States for necessary personnel and technology; and the costs to other impacted individuals (such as veterinarians, sales facilities, and other market facilitators) for any mandated practices and technology.
2. The public comment period on the proposed rule should be extended to 120 days, instead of the standard 60 days, to allow people more time to learn about the proposal, review it, and comment.
These recommendations were submitted to the Secretary on April 7.
The Committee process does not in any way limit what FARFA or its members can and will say about the proposed rule as an organization or individuals. Please be ready to speak up during the public comment period! The USDA’s decision to withdraw the NAIS plans shows that the grassroots can be successful, and we will need each of you reading this to be involved to ensure that any new regulations do not create unfair burdens for our producers.
Still Asking for the Data
From the beginning of the fight over the National Animal Identification System, FARFA has repeatedly asked: “Where’s the data?” What is the alleged problem? What facts support the government’s and industry’s claims that a program like NAIS would do anything to improve animal health? Repeatedly, we’ve been met with silence or the response that we should just “trust the experts.” But we won’t stop asking.
Below is what we requested from USDA in January of this year. The USDA staff has stated that a “white paper” will be published along with the proposed rule, setting out the underlying data and analysis in response to this request.
Request for information from USDA regarding animal traceability:
1) Data relating to traceability under existing programs
a. What is the total number of tracing events in the last 5 years?
b. How many failed? How many were successful?
i. How is “failure” defined? How far back was the animal able to be traced? Was the event defined as a failure based on an inability to trace the animal of interest, its cohorts, and/or its offspring?
ii. For each event, how many producers were affected?
iii. For each event, how many head of animals were affected?
c. What animal health consequences resulted from the failed traces?
d. What are the costs for successful traces? Failed traces?
i. Estimated employee hours, divided between federal and state employees?
ii. Costs of quarantines to federal and state agencies? To livestock owners?
iii. What were the costs for the additional testing, euthanasia, or other steps taken to federal and state agencies? To livestock owners?
e. Looking at just traces of sheep, what are these numbers?
f. What were the numbers of failed versus successful traces for cattle 20 years ago?
g. Has any data been collected yet from the recent outbreaks of FMD in other countries, to look at what (if any) difference their traceability programs made?
2) Analysis of the failures
a. What analysis has been done to determine why some traces fail and some succeed?
b. What percentage of failed traces involve a gap in existing regulations (i.e. the failure occurred because the animal was not required to be identified) as opposed to a failure to comply with existing regulations (i.e. the animal should have been identified, but the ID was illegally removed or failed to be removed at slaughter)? Failures to comply with existing regulations also include such failures on the part of animal health officials or private veterinarians to report and maintain required records.
c. What role does the IT infrastructure at the state and federal agencies play, i.e. what improvements can be made by using electronic technology within the agencies without requiring electronic technology to be used by producers and veterinarians?
3) Analysis of the goals and costs
a. The USDA has set various performance goals, ranging from being able to notify the State where the animal was identified 95% of the time within 1 business day, to identifying the state where the animal was last shipped from 95% of the time within 7 business days. Yet there has been no explanation of why these numbers were selected as goals. What analysis has been done to estimate the differences in outcome based on different traceability times?
b. Based on the presentation to the Committee, a key part of the program from USDA’s perspective is moving CVIs from paper-based systems to electronic-based systems. One way to do this is through electronic CVIs, but those would pose significant burdens for many livestock veterinarians and the producers they serve. The other way to achieve this goal, as noted by USDA, is to accept paper CVIs from veterinarians and establish a data entry system within the state agencies to place key pieces of data in searchable form. What are the estimated costs of the latter approach?
c. Has any modeling been done to compare the likely success rate of traces under different options? For example, a comparison of the likely success rates of traces with feeder cattle included versus excluded?
d. What will the program, as currently proposed by USDA, cost to the federal government, state government, and animal owners? What financial contributions does USDA plan to make to the program?
4) Analysis of the role of traceability within animal health as a whole
a. The analysis should also address the role of traceability as one part of animal health, rather than a goal in and of itself. Preventative measures, such as preventing high-risk imports and promoting healthy animal management, may be more effective (and cost-effective) than increasing levels of tracking.