Billings, Mont. – Overkill: an excess of what is required or suitable, as because of zeal or misjudgment.
On Monday, R-CALF USA submitted its formal comments on the U.S. Department of Agriculture’s (USDA’s) interim rule on the use of 840 animal identification numbers (840 tags) for U.S.-born animals only (Docket No. APHIS-2008-0077).
“If imported cattle were to be removed from the J-List and permanently branded with their country of origin, 840 tags would become unnecessary,” said R-CALF USA Animal Identification Committee Chair Kenny Fox. “We believe each imported animal should be permanently marked with a brand denoting the animal’s origin as a condition of entry into the United States. That way, if a tag or other ID device gets lost, imported animals can still easily be identified because of a permanent mark on their hides.”
Of particular concern to R-CALF USA members was USDA’s language in the rule that states: “…as we progress toward full implementation of the NAIS…”
“We have suspected all along that USDA was working to turn the NAIS (National Animal Identification System) into a mandatory program rather than a voluntary one, and language like this leads us to suspect that was the agency’s goal all along,” Fox pointed out. “In fact, just last week we called into question an USDA memo requiring producers who engage in interstate commerce and participate in any of USDA’s regulated disease programs be required to register their premises under NAIS. This particular memo unlawfully mandates only the premises-based number system and allows no others.”
Also of specific concern was USDA’s attempt in this rule to tie NAIS with the law for country-of-origin labeling (COOL), which specifically prohibits the use of animal identification programs for the purposes of establishing an animal’s country of origin.
“USDA continues to strong-arm producers into participating in a national registry of personal property, and if USDA were genuinely interested in making COOL more convenient for livestock producers, it would inform meatpackers they can initiate an origin claim by visually inspecting each animal for foreign markets and instruct those packers to initiate a USA origin claim for all livestock that do not bear a foreign marking,” said R-CALF USA COOL Committee Chair Mike Schultz. “NAIS is overkill for COOL implementation, and USDA is being disingenuous by attempting to coerce hard-working U.S. livestock producers into believing that NAIS is the most convenient method for verifying origins of livestock pursuant to COOL.”
For years, R-CALF USA has pointed out to USDA that existing animal disease programs can be improved and enhanced for the purposes of traceback in the event of a disease outbreak.
“Producer records and records produced in the normal course of business for such programs contain adequate information to contact producers in the event of a disease outbreak, and although USDA claims there will be no significant economic expense to producers, the agency has not adequately evaluated the cost of NAIS on the U.S. cattle industry,” emphasized R-CALF USA President/Region VI Director Max Thornsberry, who also chairs the group’s animal health committee.
“We request that USDA cease all actions regarding the promotion and implementation of the NAIS, and, instead, allow local and state animal health authorities to determine how best to achieve traceback of animals that may become diseased after they exit their respective states,” Thornsberry concluded in the formal comments.