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:
- 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.
- 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.
- Violates individuals' religious beliefs. Amish, Mennonite, and some other individuals have religious objections to the universal numbering system under NAIS.
- 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.
- 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:
- No significant benefits: USDA's assertions that NAIS will provide benefits for animal health are not supported, and actually contradict basic scientific principles.
- 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.
- Impracticality: The databases to register the properties, identify each animal, and record billions of "events" will dwarf any system currently in existence.
- 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.
- 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.
- 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
- 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.