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ACTION: Tell the USDA You Oppose the National Animal ID System

by: Jill Richardson

Mon Feb 23, 2009 at 06:00:00 AM PST


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A while back I promised to give you talking points against the National Animal ID System. We've got until March 16 to comment to the USDA on a rule proposed by the Bush administration in January. Well, here are the talking points (below), courtesy of the Farm and Ranch Freedom Alliance.

The proposed rules are complex and difficult to understand, but they basically come down to "Register for NAIS or you can't do business" if my understanding is right. Here is where you go to give the USDA your comments. You can also submit your comments via Organic Consumers Association here (just be sure to personalize the letter!!). See below for talking points.

Jill Richardson :: ACTION: Tell the USDA You Oppose the National Animal ID System
I urge the USDA to withdraw its proposed rule to implement portions of the National Animal Identification System (NAIS), Docket No. APHIS-2007-0096.  
I am a ___________________________________________________________________

_________________________________________________________________________
[State who you are - for instance, are you a farmer, consumer, or horse owner -- and why this issue matters to you]

The proposed rule mandates the NAIS Premises Identification Number (PIN) as the sole means of identifying properties for USDA animal health purposes.  The proposed rule also mandates the use of the NAIS numbering system (i.e. the "840 numbering system") for eartags using official animal identification numbers.  Tags using other numbering systems would be required to be linked to a NAIS PIN.
The draft rule is seriously flawed for multiple reasons:

  1. Does not substantiate the alleged benefits to animal health.  USDA makes general claims about the benefits of identifying locations where animals are kept, but the agency does not address the ability of existing programs to meet this purpose, nor how the proposed rule would improve the capability to identify locations.  

  2. Ignores the costs and burdens.   The proposed rule would substantially increase costs for livestock owners and taxpayers.  Costs include the development and maintenance of a massive database; purchase of 840-numbered tags by animal owners; changes by state agencies to make existing programs consistent with the rule; and increased federal government intrusion into the lives and daily activities of farmers and other animal owners.

  3. Violates individuals' religious beliefs.  Amish, Mennonite, and some other individuals have religious objections to the universal numbering system under NAIS.

  4. Creates disincentives for people to seek veterinary care for their animals and participate in existing disease control programs.  The proposed rule lists four animal disease programs-tuberculosis , brucellosis, scrapie, and Johne's - and will also impact others.  These programs include provisions for veterinary care through vaccinations and testing.  Animal owners who object to NAIS may avoid participating in these programs, thereby increasing health risks to the public and farm operations.

  5. Adds to the confusion.  This rule is the latest in a series of ambiguous and often contradictory documents that the USDA has issued on NAIS.  This has created enormous confusion over the intent of the USDA and problems for both animal owners and state agencies.

The proposed rule is a significant step towards implementing the entire NAIS program.  Thus, the agency should address the fundamental question of whether it should be implementing NAIS at all.  In addition to the problems with the draft rule listed above, there are many additional objections to the entire NAIS program:

  1. No significant benefits: USDA's assertions that NAIS will provide benefits for animal health are not supported, and actually contradict basic scientific principles.  

  2. High costs for animal owners and taxpayers:  These costs include: (1) the development, maintenance, and update of massive databases; (2) the costs of tags, most of which will contain microchips; (3) the labor burdens for tagging every animal; (4) the paperwork burdens of reporting routine movements; and (5) the costs of enforcement on millions of individuals.

  3. Impracticality:  The databases to register the properties, identify each animal, and record billions of "events" will dwarf any system currently in existence.  

  4. Waste of money:  The USDA has already spent over $130 million on NAIS implementation, but has yet to develop a workable plan for the program.  

  5. Diverts resources from more critical needs such as disease testing, disease prevention through vaccination and improved animal husbandry practices, and disease detection in currently uninspected livestock imports.

  6. Damage to food safety efforts:  NAIS will not prevent foodborne illnesses, such as e. coli or salmonella contamination, because the tracking ends at the time of slaughter.  Food safety is better served by focusing on programs such as increased testing for bovine spongiform encephalopathy (BSE or Mad Cow), improved oversight of slaughterhouses and food processing facilities, and increased inspections of imported foods.  Programs such as NAIS that burden small, sustainable farmers will hurt efforts to develop safer, decentralized local food systems

  7. Discourages involvement in farming or animal husbandry:  Because of costs and government intrusion, some people will choose not to stay in farming or go into farming.  This will result in less competition, greater reliance in foreign imports and poor quality at higher prices.

I urge the USDA to withdraw the proposed rule to implement portions of the National Animal Identification System, Docket No. APHIS-2007-0096.

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Regulation's Mangled Syntax - Written by a True Bushie (4.00 / 3)
I've tried to read the regulation, and it is difficult. What it appears to do is prohibit commonly done vaccinations and tests for several types of livestock - unless the producer enrolls in NAIS and purchases 840 RFID-tags, which of course is all "voluntary". The RFID-tags cost at least $2 - $3 each. This may not sound like much, but when a producer's profit margin is being squeezed between low prices and high costs, it all matters. The regulation also pushes the enforcement burden onto the veterinarian. Our USDA public servants' perception is that because producers no longer trust them or state animal health departments over NAIS, the local veterinarian is now responsible for selling/enforcing the program. Nice, huh?
(In order to help out the veterinarian the USDA did write a hand book on how to start conversations about NAIS).

One of the diseases targeted by the regulation is brucellosis. According to my bovine veterinarian the disease has almost been eradicated, and he has spent a career encouraging and educating producers to vaccinate. My normally cool and calm veterinarian was furious over the possibility of USDA actions causing this disease to make a come back. He is being put into the position of losing the trust of his customers - and their business.

Common sense tells us all that making vaccinations and tests more expensive and more bureaucratic is the height of stupidity. Common sense also tells us that destroying trust in the health system is dangerous.  That the USDA's chief veterinarian is willing to hold the safety of food-supply livestock hostage in order for agri-business to sell RFID chips and databases is irresponsible.  


Crazy... (4.00 / 2)
What it appears to do is prohibit commonly done vaccinations and tests for several types of livestock - unless the producer enrolls in NAIS and purchases 840 RFID-tags

Sounds like a familiar tactic - sort of like how they won't allow private producers to test for mad cow by refusing to sell them the necessary equipment...

One of the diseases targeted by the regulation is brucellosis. According to my bovine veterinarian the disease has almost been eradicated, and he has spent a career encouraging and educating producers to vaccinate. My normally cool and calm veterinarian was furious over the possibility of USDA actions causing this disease to make a come back.

What?!  Wow, imagine if they held up the polio vaccine 50 years ago by forcing everyone to buy into some Big PhRMA scheme first?


[ Parent ]
out of curiosity (4.00 / 2)
how hard would it be to do business without those vaccinations and tests that require NAIS registration? Is this basically a mandate for anyone whose animals are more than pets to register for NAIS?

"I can understand someone from Iowa promoting corn and soy, but we are not feeding the world, we are feeding animals and soft drink companies." - Jim Goodman

[ Parent ]
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