By the July deadline, USDA had received 730 comments on the draft plan, from consumers, producers, industry organizations, companies and veterinarians. The comments represent a broad range of opinions on different aspects of animal identification. Following are selected quotes directly from a few of the comments.
William O’Brian, Texas Beef: There is little rationale for two programs and there exists no structural problem for combining the two plans. The only difference between the two plans is NCBA’s broader view of the appli-cations of the data-store providing beef producers additional information on production processes and tracking the ownership chain.
Neither plan should move forward without first solving the governance issue. NCBA and USDA should negotiate and agree to representation and establish a governance board with composition to include stakeholders from business and government.
Patrick K. Goggins, president, Public Auction Yards, Billings, Mont.: This transfer of liability for the packing industry should not be allowed. When calves are born on the various farms and ranches, these folks cannot be expected to assume all the liability on that animal when it leaves their farm or ranch, as it moves through the various rungs and ladders of the industry finally ending up at the retail store.
John Crouch, executive vice president, American Angus Association: Producers want assurance that the data that is collected will only be used for animal-health tracing and that it is only accessible by authorized authorities. With that said, the AAA supports the implementation of a privately held database(s) for individual animal-identification information.
Glenn Slack, president and CEO, National Institute for Animal Agriculture: NIAA supports the development and implementation of a national animal-identification system as outlined in the U.S. Animal Identification Plan, and further refined through the National Animal Identification System with the understanding, as noted in the USAIP, that producer data required by the system be kept confidential and exempt from the Freedom of Information Act.
Bill Gray, president, Colorado Cattlemen’s Association: First and foremost, beef producers throughout Colorado appreciate the timeline-based approach in which the Draft Strategic Plan has been formatted. Goals, or in the case of this plan — milestones, are important for beef producers in planning for the future of their business.
The CCA supports a program that ultimately would become mandatory, contingent upon effective development of procedures through the voluntary phase.
Gary Wilson, cattle producer, Ohio: To maintain continuity of animal-disease programs and reporting animal-tracking data to the NAIS, I support the use of RFID technology in all livestock species as deemed effective and appropriate by the NAIS Species Working Groups.
I support entrepreneurial opportunities for establishing official tagging sites and/or mobile services. Both private individuals and livestock-auction managers should have the opportunity to provide these services. The open market will determine success.
Texas and Southwestern Cattle Raisers Association: From an animal-health-risk perspective, there is a more immediate need to record movements at some location scenarios than others. Therefore, we recommend the development of a process that identifies and categorizes movement-location scenarios and implements the system beginning with the most crucial categories, then progresses to the less crucial from a disease-surveillance-priority basis.
Wyoming Stock Growers Association: The need to make the system mandatory will be lessened to the extent that a voluntary program is user-friendly, cost-effective and meets the needs of the marketplace. WSGA recommends that APHIS refrain from announcing a mandatory program at this time while clearly emphasizing that failure to achieve a very high level of voluntary compliance with the program within a reasonable time period will result in the program becoming mandatory.
Bill Donald, president, Montana Stockgrowers Association: We fully realize that not all states have similar laws, but the industry in Montana accepts and recognizes the role brands and brand inspection plays, and we would like to see any national program recognize the hot-iron brand as a method of identification for individual states as they see fit.
Wendy’s International Inc.: We would strongly urge the agency to accelerate the rulemaking process to make animal identification and premises registration mandatory for cattle as soon as possible. The lack of a mandatory cattle-identification and traceability system will continue to be problematic for the United States as we try to regain our export markets, especially in light of the recently confirmed case of BSE in a native-born cow.
Tom Hansen, president, Nebraska Cattlemen: Nebraska Cattlemen believes strongly that disease surveillance is and should be the No. 1 priority of the NAIS. NC understands that producers should and will have a financial responsibility for the system, thus producers should also have the opportunity for economic returns by participating in the system.
Richard Bowman, Animal ID Committee chair, R-CALF USA: The NAIS draft timeline is too aggressive and unrealistic.
There should be no consideration given to the privatization of the public-service program proposed by USDA. If it is in the national interest that livestock be individually identified, then the program to accomplish this objective should remain in the public domain and funded by public funds.
The database should be exclusively managed by the federal government in coordination and cooperation with state animal-health departments, including state brand boards.
Jim McAdams, president, NCBA: NCBA is deeply concerned with the ability of USDA to truly provide confidentiality of information maintained within a database held by USDA or states.
This concern is the principal reason NCBA is in the final stages of development of a single/central national database that will allow appropriate access to animal-health officials while protecting producer information in a business setting that better respects confidential business information.
Industry timelines for reaching significant milestones are much shorter than those identified in the draft plan. The timeline established by the Department should be goal-focused, not date-oriented.
All comments are available to the public at http://animalid.aphis.usda.gov/ nais/index.shtml. Click on “Comments on eDockets.”