A diverse group of livestock organizations, The Cattle Identification Group, sent a letter this week to Agriculture Secretary Tom Vilsack asking for an extension of the public-comment period on USDA’s proposed framework for animal-disease traceability. Following is the text of the letter.
Dear Mr. Secretary:
The Cattle Identification Group (CIDG) was formed a couple of years ago to provide input into the U.S. Department of Agriculture’s (USDA) development of an Animal Disease Traceability (ADT) framework and plan for the identification and traceability of cattle moving interstate. The participating members of the CIDG represent all classes of cattle and segments of the cattle industry with membership spanning the length and breadth of this country.
As development of USDA’s ADT program proceeded over time, the CIDG as well as its individual industry organizations have been active participants in the various meetings and discussions that USDA has held around the country throughout the development of the program. In that regard, we very much appreciate USDA’s efforts to develop the ADT program with transparency, openness and an evident desire to have the cattle industry’s input on a regulatory program that is sure to have a huge impact on every livestock operation in the United States
The proposed ADT rule (Docket No. APHIS-2009-0091) was published in the Federal Register August 11 with a 90-day comment period, ending November 9. Within weeks of the proposed ADT rule, the CIDG met to begin our discussions on the various aspects of the proposal and what, if any, remaining concerns and/or questions we have respective to the ADT program as established in the proposed rule. It was obvious from the very beginning of our initial discussion on the ADT proposed rule that there remains a great deal of work yet to be done by the CIDG and our individual organizations in assessing all the numerous repercussions, connotations, and consequences of the many different aspects of the proposed rule. It also looks likely that we will need to do some additional work on assessing the cost to industry stakeholders in complying with the ADT rule, particularly once all cattle are required to be identified. In addition, numerous questions are being raised about various elements of the proposal that will need clarification by USDA staff in order for us to responsibly inform and respond to the membership of our organizations in the short time that remains of the current comment period.