TALKING POINTS :
1) The agency should withdraw the proposed rule.
2) If the export market would benefit from the proposed rule, as the agency claims, then the agribusinesses that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.
3) The agency needs to identify the specific diseases of concern and analyze how to best address those diseases, rather than continuing to push a one-size-fits-all generalized tracking program.
4) The agency's analysis does not address the full costs of the program-- this is a waste of money at a time when both private and government resources are already stretched thin. This is an unfunded mandate on both state governments and private businesses.
5) At the very least, significant changes need to be made:
- Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
- Exempt all direct-to-slaughter cattle, both for custom and for retail sales. The proposed rule provides for a temporary exemption, but then phases these animals into the program except for personal use.
- Recognize livestock brands as "official identification" among and between all states that currently have official state brand programs and "official supplementary identification" for all other states.
- Do not impose any new requirement for identifying poultry. There has simply been no evidence that imposing new requirements on small-scale poultry operations is warranted, while they definitely will cause significant economic harm.
- Provide that a physical description qualifies as an official identification method for horses without having to be approved by the health officials in the receiving State or Tribe.
MORE INFORMATION :
The program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness' export markets.
Some of the specific requirements for cattle pose particular problems. Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on non-breeding feeder cattle, despite the lack of evidence that such requirements will help disease control. In addition, anyone issuing official ID tags will have to keep records of the tags for five years , and sales barns will have to keep copies of paperwork for five years , even though many of these cattle will have been consumed years earlier.
State agencies will have to build compliant programs, database storage, and management and retrieval systems in order to handle all of the data, creating problems for many states' budgets. The proposed rule doesn't address what will be the consequences if states' systems don't meet the federal government's goals. The sending and receiving states can agree to use alternative identification methods, such as brands and tattoos, but otherwise the brand and tattoo will no longer qualify as an official identification method.
Small-scale, pastured, and backyard poultry will be particularly hard hit by the proposed rule . While the large confinement operations will be able to use "group identification," the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.
Under the proposed rule, horses will have to be identified when they cross state lines. Official identification includes a physical description, digital photograph, or electronic identification. Although most, if not all, horses that are shipped across state lines are already identified in one of these ways, the language of the proposed rule creates a new complication. Whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.
The draft rule also covers sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.
READ USDA'S DOCUMENTS :
You can read the proposed rule at:
http://www.aphis.usda.gov/traceability/downloads/2011/Proposed%20Rule.pdf
You can read the USDA's regulatory analysis, which includes its analysis of the costs of the program and the alleged benefits to the export market, at: http://www.aphis.usda.gov/traceability/downloads/2011/Regulatory%20Impact%20Analysis.pdf
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