Browsing Posts tagged health

The Effect of Political Correctness on Politics

By Warren Beatty

The late Charlton Heston once said, “Political correctness is tyranny with manners.”

The rationale of political correctness (PC) is to prevent supposed minorities from being offended (the manners) — to compel people (the tyranny) to avoid using words or behavior that may upset homosexuals, women, non-whites, the crippled, the stupid, the fat, the ugly, or any other minority group identified by those who define PC.  Its primary method is the redefinition or replacement of words and behavior in order to avoid offense, to be sensitive to the feelings of minorities.

Before we can examine PC and its effect on politics, we must first understand PC’s origin and purpose.

The concept of PC was developed at the Institute for Social Research, in Frankfurt, Germany, in the early 1920s.  The institute considered why communism in Russia was not spreading westward.  The conclusion was that Western civilization, with its belief that the individual could develop valid ideas, was the problem.  At the root of communism was the theory that all valid ideas came from the state, that the individual is nothing.  The institute believed that the only way for communism to advance and spread was to help Western civilization destroy itself, or else force it to.

The institute said that by undercutting Western civilization’s foundations by weakening the rights of individuals through the change of speech and thought patterns, by spreading the idea that vocalizing beliefs was disrespectful to others and had to be avoided to make up for past inequities and injustice, Western civilization could be destroyed.  The institute wanted to call its method something that sounded positive — thus “political correctness.”

Another communist, Chairman Mao Zedong, in China in the 1930s, wrote an article on the “correct” handling of contradictions among the Chinese people, thus giving us the PC concept of “sensitivity training.”

Today we can add socialism to communism.  Does the addition of that economic philosophy alter the original intent of PC in any way?

Here are two specific examples of PC and of not being sensitive.

First, a famous PC incident occurred in Washington, D.C. in 1999.  David Howard, a white aide to Anthony A. Williams, the black mayor of Washington, D.C., correctly used the word “niggardly” in reference to a particularly small budget item.  This reference upset one of his black colleagues, who interpreted it as a racial slur and lodged a complaint.  The use of the word “niggardly” was not PC due to its phonetic similarity to the racial slur “nigger,” despite the fact that the two words are etymologically unrelated.  Howard was not “sensitive” or PC. He actually resigned his job, but was reinstated after a national outcry over the conflation of unrelated terms.

The cited incident (and others like it) raise the question, “Are we now to abandon the use of certain useful words in the English language in the name of sensitivity and PC?”

We can now examine how PC specifically affects politics.

PC particularly serves mediocre politicians and the bureaucrats they appoint.  It is used to hold on to jobs, silencing critics and threatening anyone who questions their abilities.  If the offended party can strike back with accusation of racism, discrimination, prejudice, and hatred, then PC has done its job.  PC is a way of covering up incompetence and corruption.  It has worked well in the U.S. for decades: attack the accuser.  Benjamin Jealous, president of the NAACP, wrote, “Let me tell you something about political correctness: when politicians start overdoing it with PC, rest assured they’re either hopeless at what they do or have screwed everything up big time.”

The current uproar about the Health and Human Services (HHS) edict on birth control is a good example of the PC problem.  The HHS edict said it wanted to expand “health care preventive services.”  But that PC phrase included some services that were contrary to the First-Amendment guarantee of freedom of religion.  PC tends to eliminate any possibility of the discussion of the rightness and wrongness of a particular action through the restraint of free speech.

As a final example of PC run amok, consider this: Why have “swamps” been replaced by “wetlands”?  Why have “rainforests” replaced “jungles”?  Are they not the same things?  A government that wants to spend taxpayer money on conservation needs to avoid the negative connotations involving parasites and disease, so it redefines/replaces words in order to be more PC.  The preservation of wetlands is a much more noble cause than preserving a mosquito-infested swamp.

The continuing necessity for PC and sensitivity indicates that the ideal of societal equality (as defined by the PC-definers) has not yet been realized.

Where, ultimately, can PC take us?  One forecast was published in 1949 by George Orwell.  In his book 1984, Orwell, characterizing “newspeak,” wrote, “The destruction of words is a beautiful thing.”  Big Brother, the personification of the power of the state, through newspeak “simplified” words (gave them definitions he determined) to better control society.  With the simplification of words, the younger generations knew only Big Brother’s version of reality.  Is PC today’s newspeak?

Dr. Beatty earned a Ph.D. in quantitative management and statistics from Florida State University.  He was a (very conservative) professor of quantitative management specializing in using statistics to assist/support decision-making.  He has been a consultant to many small businesses and is now retired.  Dr. Beatty is a veteran who served in the U.S. Army for 22 years.  He blogs at rwno.limewebs.com.

Read more: http://www.americanthinker.com/2012/02/the_effect_of_political_correctness_on_politics.html#ixzz2IoYPHH8c
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R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 23, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

10 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part X of X-Part Series

Billings, Mont. – Today’s news release is the final installment of the 10-day series in which R-CALF USA provides a detailed explanation of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes it has brought to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part X:  APHIS’ Proposed Rule Is Based on False Information Regarding the U.S. Cattle Industry and Is an Affront to the Hard Working Men and Women in the U.S. Cattle Industry

  1. Additional Concerns Regarding APHIS’ Proposed Rule
  1. 1.      APHIS’ proposed rule is functionally deficient because it is silent on producer liability.

The proposed rule fails to address one of the most critical concerns raised by thousands of cattle producers during USDA’s NAIS listening sessions. That critical concern was producer liability. Under APHIS’ proposal, which is a book-end identification system, the person who applied the animal’s tag likely would be the primary suspect in any disease traceback, even if he/she sold the animal years earlier and the animal was later comingled with higher-risk Mexican cattle or trader cattle on multiple occasions. As a primary suspect, the original ear-tagger likely would bear the cost of testing and retesting his/her entire herd. This is unacceptable and APHIS has not even attempted to estimate the tremendous cost that U.S. cattle producers likely would bear as a result of APHIS’ proposed rule.

  1. 2.      APHIS’ proposed rule will significant disrupt interstate commerce by prohibiting the use of back tags on cattle destined for slaughter.

USDA’s proposed rule will significantly increase the cost of interstate movement by disallowing the use of expedient back-tags for cattle destined for slaughter. Back tags are a proven, effective, humane and expedient means of identifying cattle destined for slaughter and the elimination of this device will disrupt commerce, increase animal injuries, and add unnecessary cost to an industry incapable of passing additional costs to those that may benefit from USDA’s new imposition on cattle producers.

  1. 3.      APHIS justifies its proposed rule based on false cattle industry information and information that is too broad and ambiguous to meaningfully inform decision makers.

R-CALF USA remains concerned that APHIS continues to not only ignore the unique characteristics of the U.S. cattle industry, but also, it continually presents misleading information to the public. For example, APHIS’ supporting documents for the proposed rule states:

Although the total cattle inventory fell by 15 percent between 1979 and 2009, commercial beef production grew by 22 percent. The decline in cattle inventory has been offset by a 23 percent increase in the average dressed weight of federally inspected cattle.

APHIS, fails to inform the public that the 22 percent growth in beef production between 1979 and 2009 also was due to the influx of imported live cattle that were subsequently slaughtered in the U.S., with their resulting beef added to the United States’ commercial beef production. Live cattle imports from Mexico and Canada increased by 1,269,560 head between 1979 and 2009. Based on the average carcass weight in 2009 of 748 pounds, those imported cattle contributed about 950 million additional pounds to commercial beef production.  !

Commercial beef production increased from 21.262 billion pounds to 25.966 billion pounds between 2007 and 2009.  This represents about a 4.7 billion pound increase during that period. However, nearly one billion pounds (about 950 million pounds) of that increase was attributable to beef derived from imported cattle.  Therefore, the growth in commercial beef production attributable to increased dressed weights was less than 18 percent while the contribution of imports to that growth was 20 percent, i.e., beef from imported cattle accounted for approximately 20 percent of the growth in domestic beef production between 2007 and 2009.

Thus, APHIS’ assertion that the decline in cattle inventory has been offset by a 23 percent increase in the average dressed weight of federally inspected cattle is false. APHS would have been accurate to state, however, that 1.2 million head of the U.S. mother cow herd had been offset by the growth in imported cattle, which increased by 1.2 million head between 1979 and 2009.

Also, and as mentioned previously, APHIS describes the U.S. cattle industry as one in which the average number of cattle per cattle operation has increased to nearly 100 head for all cattle operations. This description fails to recognize, describe, or disclose the profound, segmented nature of the U.S. cattle industry. For example, in 2010 the average size of the U.S. beef cow herd was fewer than 42 head per herd; the average size of the U.S. dairy herd was 146 head; the average number of cattle in the 75,000 remaining farmer feedlots with capacities of less than 1,000 head was only 34 head per feedlot; and, the average number of cattle in the 2,140 commercial feedlots! with capacities of more than 1,000 head was 5,380 head per feedlot.

This information provides a far more accurate description of the U.S. cattle industry and provides far more valuable information to people making decisions that impact the U.S. cattle industry. R-CALF USA urges APHIS to be truthful and accurate when representing the U.S. cattle industry so as to avoid the propagation of erroneous information that invariably leads to bad public policy, such as APHIS’ proposed rule now under consideration.

  1. Conclusion.

There is absolutely no need for a federally mandated animal identification system. The 50 states already have animal health import and export rules that rely upon and reference existing official animal identification devices. If USDA wishes to assist the 50 states and the nation’s tribes to improve disease traceability, it should work in cooperation with the states, tribes and cattle producers to develop best practices guidelines for the import and export of cattle among and between the states and tribes and assist those states and tribes in developing specific programs that work best for them.

For all the foregoing reasons APHIS’ one-size-fits-all proposed rule is, at best, an absolute boondoggle and must be immediately withdrawn. If APHIS does not immediately withdraw the proposed rule, the U.S. cattle industry will suffer irreparable harm.

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 22, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days (Now 10) of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part IX of X-Part Series

Billings, Mont. – To minimize the size of the last scheduled news release in R-CALF USA’s 8-day series, R-CALF USA extended the series for two additional days. Each daily news release provides a detailed explanation of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part IX:  The Agency’s Disdain for Brands, Inclusion of Feeder Cattle, and Failure to Disclose Documented Reasons for Untimely Disease Tracebacks Demonstrate APHIS’ Insincerity 

  1. APHIS’ Proposed Rule Discriminates Against States that Require Brand Inspections and Brand Inspection Certificates as a Condition for Leaving a Brand Inspection Area and Discriminates Against Cattle Producers Within Those States that Pay for and Rely on Brands and Brand Certificates to Identify Their Cattle
  1. APHIS’ inexplicable failure to include hot-iron brands accompanied by a certificate from a recognized brand inspection authority as a group/lot identifier is unscientific.

APHIS has failed to recognize brands as an official means of providing group/lot identification, under any circumstance. This is more than just alarming because of the obvious fact that each animal in a group of branded cattle is traceable even in the event the group/lot identification number is lost or destroyed, or in the event the group of animals, or any member of the group of animals, is inadvertently separated. APHIS cannot make this claim for any other group/lot identification device it is proposing.

The ability to identify each individual member of the group as a member of the group is scientifically and practicably superior to any of the group/lot identification devices proposed by APHIS in the proposed rule. It is unconscionable that APHIS would reject the single most effective means of group/lot identification, and the only means that would enable a trace back of a group/lot that inadvertently becomes separated or for which the paperwork is lost or destroyed.

APHIS must universally recognize the hot-iron brand accompanied by a certificate from a recognized brand authority as an officially approved group/lot identification method. Further, U.S. cattle producers that move in interstate commerce a group/lot of branded cattle accompanied by a certificate from a recognized brand authority should have no further obligation to place any other type of animal identification on their cattle. When the group lot arrives at its destination, which may be another brand state wherein the cattle likely will be rebranded, the buyer or buyers of those cattle should be responsible for applying any type of identification that may be required by the receiving state if the group is to be separated. I! f the group is not separated, e.g., if the entire group is sold to a feedlot for finishing, than the owner or manager of those cattle in the receiving state should have no obligation to apply any other form of identification.

  1. Under no circumstances should APHIS include feeder cattle in any mandatory animal identification rule.

The U.S. all but eradicated diseases such as bovine TB and brucellosis by focusing on the identification of breeding cattle only. The principal culprits that have caused the resurgence of those diseases are imported cattle (primarily from Mexico, see supra) and wildlife reservoirs. APHIS has the authority, recourses and means to fully prevent the continual reintroduction of disease that are spread by imported cattle as well as to minimize disease reservoirs in wildlife, but it refuses to implement stricter import standards and effective wildlife mitigations. Instead, USDA wants to burden the owners! of our nation’s 31.4 million beef mother cows with its onerous, overreaching rule that effectively forces U.S. cattle producers to pay costs associated with other country’s disease problems and site-specific wildlife problems. This proposed rule is anything but a scientific, risk-based proposal.

APHIS has failed to explain how past disease programs were so “tremendously successful” without ever imposing mandatory identification on feeder cattle and why, suddenly, APHIS deems it necessary.

As stated above, the cost of ear tagging the 2010 calf crop, again using APHIS’ estimate that 3.1 million calves already bear official identification, would be between $554 million and $880 million. This cost would be expected to be incurred year after year if feeder cattle were subjected to the proposed rule. Even using APHIS’ grossly understated cost of $4.68 per head, the proposed rule would cost U.S. cattle producers $152.6 million annually.

For comparison purposes, APHIS estimates the annual cost to states and the federal government for bovine TB testing is $2.6 million. However, this cost does not come close to justifying the mandatory imposition of hundreds of millions of dollars in additional costs on U.S. cow/calf producers.

  1. APHIS has failed to disclose the full nature of the problem the proposed rule is intended to address or to explain how the proposed rule would be expected to correct the serious problems APHIS failed to disclose.

APHIS has failed to disclose significant problems that have been identified in its disease traceback operations and has failed to explain how the proposed rule would be expected to correct those problems. For example, APHIS attempts to justify its proposed rule on the basis that some bovine TB investigations exceed 150 days.  See supporting document, at 8.  APHIS, along with other proponents of the proposed rule’s precursor – NAIS – alleged that because of what they call an “outdated system of tracking outbreaks of animal diseases to their sources (EXHIBIT 26, p. 5);” and a “lack of any official identification” with which to determine the “specific origin of the subject animal . . .[and] without movement data (EXHIBIT 7, p. 3),”  disease traceback investigations have taken too long to conduct.  Both the American Veterinar! y Medical Association (AVMA) and APHIS cited the same statistics to su pport their allegations:  AVMA stated, “Investigators spent an average of 199 days tracing the sources of animals infected with bovine tuberculosis between October 2005 and August 2007 (EXHIBIT 26, p. 5).” APHIS stated, “The average time spent conducting a traceback involving 27 recent bovine tuberculosis investigations was 199 days (EXHIBIT 7, p. 4).”

However, the Office of Inspector General (OIG) conducted an audit of APHIS’ control over its bovine TB eradication program in September 2006. According to the audit, the OIG found that a lack of identification on individual animals was not the sole source of APHIS’ problem in conducting its bovine TB investigations. In fact, the OIG found that over half of the investigations that were closed with an outcome of “untraceable” were animals that were identified with eartags, but the eartags either were not collected at the time of slaughter, had been removed by the feedlot prior to slaughter, or were unable to be traced because there was no requirement to maintain records (EXHIBIT 27, p. 38).  Equally important, the OIG found that APHIS’ disease eradication efforts were hampered because the agency was not using its oversight tools in a timely manner, i.e., not timely reviewing and responding to the annual and monthly summaries of program results submitted by States nor was it properly reviewing States for program compliance (EXHIBIT 27, p. 5-9). The OIG also found that APHIS was not following Federal regulations for declaring affected bovine TB herds, which weakened the agency’s ability to contain and eradicate the disease and resulted in no additional controls being put in place for the majority of bovine TB cases detected in the past 5 years (EXHIBIT 27, p. 11-14). The agency was also cited for not timely downgrading the TB status of States after the agency knew that the disease was not isolated in one herd (EXHIBIT 27, p. 16-17); not having adequate controls to restrict the introduction of bovine TB in Mexican cattle (EXHIBIT 27, p. 19-21); not requiring slaughtering facilities to conduct surveillance at the recommended rate (EXHIBIT 27, p. ! 22-24); not monitoring high-risk herds and the corresponding on-farm testing that is required (EXHIBIT 27, p. 28-29); and not providing sufficient training to investigators so investigations could be completed in a timely manner (EXHIBIT 27, p. 22, 25, 28).

APHIS has failed to provide the livestock industry with sufficient data to identify all significant problems associated with current animal disease traceability systems and provide documentation to show how any new animal disease traceability system would be expected to resolve any such specific problems. The systemic problems described above are internal management problems that impede disease control and eradication as well as disease investigations and would not be solved by implementing the proposed rule.

Because the proposed rule fails to address how APHIS intends to address the systemic problems disclosed and discussed above, it is as likely as not that APHIS’ internal management problems would continually hamstring disease investigations and no measurable improvement would be made to the timeliness of the Agency’s disease investigation simply by imposing an outrageously expensive identification requirement on U.S. cattle producers.

 

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 21, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days (Now 10) of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part VIII of X-Part Series

Billings, Mont. – To minimize the size of the last scheduled news release in R-CALF USA’s 8-day series, R-CALF USA is extending the series for two more days. Each daily news release provides a detailed explanation of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part VIII:  APHIS’ Proposed Rule Is an Affront to the Cattle Industry’s Centuries-old Brand

 

  1. APHIS’ Proposed Rule Discriminates Against States that Require Brand Inspections and Brand Inspection Certificates as a Condition for Leaving a Brand Inspection Area and Discriminates Against Cattle Producers Within Those States that Pay for and Rely on Brands and Brand Certificates to Identify Their Cattle

 

  1. APHIS’s proposed rule ignores the historical effectiveness, functionality and permanence of the hot-iron brand as a means of identifying cattle and groups of cattle.

 

APHIS is acutely aware of the superior permanence of the hot-iron brand as compared to ear tags.  In its final rule to allow the importation of Canadian cattle 30 months of age or older (OTM rule), APHIS distinguishes brands as “permanent identification,” while separately requiring, in addition to permanent identification, an official ear tag to be placed in imported Canadian cattle (EXHIBIT 24, p. 53378 col. 1). In fact, ear tags are not even mentioned as acceptable means of permanent identification, with only freeze brands, hot-iron brands, and tattoos expressly listed among the acceptable, permanent means of identification (EXHIBIT 24, p. 53378 col. 1). In addition to permanent identification, the OTM rule also requires the individual identification with an official ear tag of the country of origin (EXHIBIT 24, p. 53378 co! l. 1).

 

APHIS’ purpose for requiring permanent brands on Canadian cattle along with ear tags is succinctly explained in the OTM rule. APHIS stated, “We recognize that animals can lose eartags at various points in the process. . . (EXHIBIT 24, p. 53340 col. 1).”

 

The foregoing discussion reveals that for disease traceback purposes, even for cattle originating in regions that APHIS has deemed a “minimal-risk” for disease, APHIS requires a three-prong traceback system:  1) it requires the permanent identification of the animal using a brand or tattoo; 2) it requires individual identification with an official ear tag; and, 3) it requires visible information on the animal to denote the animal’s origin (EXHIBIT 24, p. 53379 col. 1).

 

R-CALF USA agrees that this three-prong traceback system is a science-based means of achieving functional traceability on livestock that may be subject to a disease investigation.  The system has needed redundancy to address the inherent propensity for ear tags to be lost, and it provides visible information that enables any person to identify the origin of the animal.

 

APHIS’ proposed rule fails completely to explain why the three identification elements needed from minimal-risk regions are not needed to provide a science-based traceback system for U.S. cattle. Nor does APHIS explain which of the three elements are most important to ensure the ability to conduct tracebacks, e.g., is it more important to have permanent identification or are loss-prone ear tags equally functional for disease tracebacks? And, APHIS fails completely to explain why the ability to visibly identify the origin of the animal is not even necessary for domestic traceback purposes.

 

If the requirement contained in the OTM rule is science-based, than the proposed requirements in the proposed rule are not.  This is because the proposed rule incorporates only one of the three elements required in the OTM rule, and the one it has incorporated is not even recognized by APHIS as a permanent form of identification. The proposed rule depends exclusively on an official ear tag that bears a U.S. shield and a number:  it does not require permanent identification (indeed it expels permanent identification from its list of official animal identification devices), and it does not require ear tags to bear visible information to i! dentify even the state from which the animal originated. APHIS further fails to explain why privately-owned U.S. cattle must bear a U.S. shield for the privilege of moving across a state line. Such a shield is of no use to disease investigators and if a shield is to be required at all, it should be the shield of the state from which the animal originated, at least then a person could immediately initiate a disease investigation by calling the animal heath officials in the state of origin should an animal be detected with a disease. Better yet, the animal should bear the shield of the property’s owner – which is precisely what is accomplished with a registered hot-iron brand.

 

APHIS contends it cannot require all states to accept brands because all states do not have brand inspection programs. At the same time, however, APHIS’ proposed rule requires all states to accept ear tags that do not allow any visible means with which to ascertain the origin of an animal. For example, the APHIS approved 840 ear tag does not contain an identifier that denotes the state of origin.  Therefore, an animal health official without immediate access to an expensive, electronic wand or a national database has no means of initiating an immediate traceback of the animal. On the other hand, if an animal was transported to a state with a brand, then the animal health official could immediately narrow the animal’s potential origin to those states that have a ! recognized brand authority that issues brand certificates. APHIS is disingenuous in its claim that non-brand states cannot accept brands while it simultaneously requires non-wand states to accept 840 electronic tags.

 

APHIS’ proposed identification requirements for cattle lack any scientific justification. APHIS has thrown the proverbial baby out with the bath water by refusing to adopt even the core elements of current U.S. disease programs that APHIS itself acknowledges were “tremendously successful” in the agency’s efforts to eradicate brucellosis.. See 76 Fed. Reg. 50081, col. 3. The highly successful brucellosis program, not surprisingly, incorporated each of the three prongs APHIS requires of Canada:  1) the program recognized brands as official identification, which provided a high level of redundancy; 2) the program required an official ear tag! ; and, 3) the ear tag contained visible information with which to immediately identify the state of origin.

APHIS’ claim that its goal is to shorten the time necessary to conduct disease tracebacks is proved false by APHIS’ failure to adopt the historically proven, simple, and visible state identifier, such as two-digit numeric code that denotes the tag’s state of origin, on all of its approved ear tags.

 

The role of the permanent brand in contributing to the United States’ “tremendously successful” disease program is profound. In a March 9, 2010, article by James C. Clement, D.V.M., Cow-Calf Research & Consulting, Dr. Clement explains the profound contribution that brands and brand programs make to generating animal tracking data every day, along with describing how critical tracking data are compiled.  Dr. Clement states:

 

Animal tracking data is generated every day in Brand States and is the byproduct of routine record-keeping processes that involve cattle marketing businesses and SBIS [State Brand Inspection Systems]. SBIS create inspection certificates associated with the movement of 27,000,000 head of livestock (primarily cattle) on an annual basis (EXHIBIT 25).

 

APHIS cites no study, nor does it have any nationwide experience in conducting animal disease tracebacks without relying upon the animal tracking data generated by brand states. Indeed, APHIS has not cited any system in the world that can hold a candle to the brand states’ ongoing generation of animal tracking data for 27 million head of livestock, primarily cattle, which represents about one-third of the entire U.S. population of cattle and calves.

 

APHIS has no scientific basis for delisting the hot-iron brand accompanied by a certificate from a recognized brand authority from the list of official animal identification devices or methods, or in any way demoting the hot-iron brand to a level below any other form of animal identification.

 

Based on the hot-iron brand’s role in generating animal tacking data for tens of millions of livestock, APHIS’ proposed rule that delists the brand from the list of official animal identification devices will reduce the United State’s ability to timely trace disease suspects to the disease source.

 

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 20, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part VII of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA has launched an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part VII:  APHIS’ Proposed Rule Discriminates Against Brand Inspection States and Brands

  1. APHIS’ Proposed Rule Discriminates Against States that Require Brand Inspections and Brand Inspection Certificates as a Condition for Leaving a Brand Inspection Area and Discriminates Against Cattle Producers Within Those States that Pay for and Rely on Brands and Brand Certificates to Identify Their Cattle
  1. USDA-APHIS has deceived U.S. cattle producers by proposing to remove brands from the list of official animal identification devices or methods.

APHIS’ proposal in the proposed rule to delist the hot-iron brand accompanied by a certificate from a recognized brand authority as an official form of animal identification constitutes a broken promise made by USDA to U.S. cattle producers.  In February 2010, USDA stated in regard to its new animal disease traceability framework, which has materialized into the proposed rule:

USDA will maintain a list of official identification devices, which can be updated or expanded based on the needs of the States and Tribal Nations. There are many official identification options available, such as branding, metal tags, RFID, just to name a few (EXHIBIT 10). (Emphasis added.)

Cattle producers have been outright deceived by USDA due to APHIS’ proposal to remove brands from the list of official identification devices or methods. The construction of the above sentence, along with the usual and customary meaning attached to its words and phrases, unambiguously implies that brands will remain an official identification option on USDA’s list of official identification devices or methods. Only under a perverted interpretation of that sentence could it mean otherwise.

The consequence of APHIS’ action strips from the states and tribes the option to decide to continue relying upon the brand accompanied by a brand certificate from a recognized brand authority to identify livestock. This reduces flexibility for states and tribes to adopt a system that works best for them. In addition, it strips from individual producers within each state the flexibility to decide to continue their reliance on the brand, which flexibility each individual producer could influence by persuading their respective states’ elected officials.

Under the proposed rule, however, the decision to use brands must be made jointly by two or more states or tribes. Thus, any single state or tribe would be subject to decisions made outside their jurisdiction regarding their ability to use brands for identification. This is an affront on state sovereignty. Moreover, the rights of individual cattle producers in a brand state to continue relying upon their brands would be subject to the decisions made in other states, over which they would have no control.

And, the proposed rule would effectively discriminate against cattle producers in states with mandatory brand inspection programs, which are funded in whole or in part by producer fees, by not reimbursing the producers for the cost of brand inspection fees paid when those producers leave the jurisdiction of their brand inspection authority, which generally is the state’s border, when they are required by APHIS to apply a new form of animal identification.  If APHIS does not reimburse producers that are required by their respective state to obtain a brand inspection before leaving their state, and if APHIS nevertheless requires them to incur the cost of applyi! ng a second form of identification (i.e., requires them to apply an ear tag in addition to their preexisting brand), then APHIS would effectively financially disadvantage those producers in interstate commerce by the per head cost for their mandatory brand inspection.

At the very least, USDA-APHIS has an absolute moral and ethical obligation to treat U.S. cattle producers honestly and fairly. Stating one thing and doing another is dishonest and unfair. In this case, USDA-APHIS stated one thing and did another without providing any notice to the public that it had deviated from its official commitment. Regardless of any rationalization USDA-APHIS may espouse to defend its deviant action, it has acted dishonestly, unfairly, and deceptively. For this reason alone, USDA-APHIS must restore the brand’s rightful status as an official animal identification device and withdraw its proposed ru! le.

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

 

# # #

 

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

 

R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 17, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part IV of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA has launched an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part IV:  APHIS’ Cost Estimate for the Proposed Rule Robs Peter and Pays Paul

 

C. APHIS Grossly Understates the Economic Cost of the Proposed Rule that Will be Borne by U.S. Cattle Producers 

 

  1. 2.      APHIS likely relied on misinformation when it calculated its grossly understated cost estimate for the proposed rule.

 

APHIS commissioned a study in 2009 titled “Benefit-Cost Analysis of the National Animal Identification System” (EXHIBIT 13) (APHIS ID Study), which study APHIS heavily relied on to arrive at its grossly understated cost estimate for the proposed rule. The assumptions used in APHIS’ ID Study are erroneous and do not reflect actual costs by U.S. cattle producers for tagging cattle. For e! xample, the APHIS ID Study estimated the cost of working (i.e., tagging) cattle based on a 2005 NDSU Article by Dr. Ringwall and assumed it took only 66 seconds to work an animal in a squeeze chute that took 15 minutes to set up; and the chute cost per head was $1.00 (EXHIBIT 13, p. 16).  However, the article referenced by the APHIS ID Study that was used to calculate an artificially low cost to the cattle industry for tagging cattle explained that the cost estimates were based on the use of a state-of-the-art mobile cattle working system that likely is not availab! le to many, if not most, U.S. cattle producers:

The team utilized the For-Most portable hydraulic double alley with a 750 chute. The system, as described by For-Most, has a 14-foot adjustable double alley, adjustable overhead grill and a 4- foot funnel section to a 9-foot single alley behind the model 750 squeeze chute and scale.

Cattle were fed into the For-Most system through a portable Wilson Wheel Corral, a series of hinged panels that unfold from the travel position to a complete corral for 140 head of calves (600 pound) and can be set up by one person in seven minutes (as described by Wilson). The team found setup time was quick and easy, utilizing available hydraulics and skill and experience with fifth-wheel driving (EXHIBIT 14).

In addition, the setup and teardown time for the state-of-the-art equipment that enabled Dr. Ringwall’s team to work each animal in only 66 seconds actually took 56 minutes and 34 minutes, respectively (EXHIBIT 14), which is much longer than the 15-minute setup time used in the APHIS ID Study, and that APHIS used in its supporting document.

 

Further, while the APHIS ID Study estimated that the cost to beef cow operators for a bookend-type identification system, as manifested in the proposed rule, was only $3.919 per head (EXHIBIT 13, p. vii), and APHIS’ upper-end cost estimate was only $0.76 per head more, the articles by Dr. Ringwall actually relied on by the APHIS ID Study estimated the actual cost of working the cattle, excluding the cost of ear tags, using the state-of-the-art cattle working system wa! s a total of $7.27 per head, provided that 10,000 head of cattle were worked through the cattle working system on an annual basis (EXHIBIT 15).

 

This is but one glaring example of how the authors of the APHIS ID Study deceived the public and APHIS by misusing legitimate data for the purpose of generating an inaccurate and fictitious low estimate for the cost that typical U.S. cattle producers would incur under a bookend-type animal ID system, as is contemplated in the proposed rule. This example alone reveals that the APHIS ID Study manipulated data to underestimate the basic cost of working cattle by $3.35 per head, even when worked in a state-of-the-art cattle handling facility that is beyond the reach of many, if not most, U.S. cattle producers.

 

Another glaring example of data manipulation in the APHIS ID Study is its treatment of shrink.  For the cow/calf industry, the APHIS ID Study included only 25 percent of the expected shrink as a cost to the cow/calf producer (EXHIBIT 13, p. 18). The APHIS Study rationalized this deceptive ploy on the basis that the buyer of the shrunken cattle would realize a compensatory gain when ! the cattle were sold and subsequently afforded an opportunity to eat and drink (EXHIBIT 13, p.18). The practical effect of this misuse of data, of course, is that the true cost of shrink borne by U.S. cow/calf producers for tagging their cattle was understated by 75 percent. Based on the fact that APHIS used the APHIS ID Study’s shrink estimate, it too reduced the true cost of shrink that cow calf producers will realize when tagging cull cows and calves by 75 percent.

 

APHIS is dead wrong to assume that “the cattle industry” would realize only a 25 percent net loss because the buyer would benefit from a compensatory gain. This is because the cattle industry is a distinct and separate industry from the meatpacking industry and when a cattle industry participant sells cull cows to a meatpacking industry participant and APHIS assigns only 25 percent of the cattle industry participant’s cost to the cattle industry, then APHIS has affectively robbed 75 percent of the cost actually realized by the cattle industry and gifted the monetary value of that cost directly to the meatpacking industry. By slight-of-hand, APHIS silently attempted to rob Peter to pay Paul in its effort to artificially lower the true cost of its ridiculously expensive mandatory animal identification scheme.

 

It must be noted that despite APHIS’ intimation that that the U.S. cattle herd, as it measured by dividing the total cattle and calf inventory by the total number of U.S. cattle operations, “is now nearly 100 head” (see supporting document, at 12), the average size of the U.S. beef cow herd remains at less than 42 mother cows per herd (as measured by dividing the total number of beef cows by the total number of beef cow operations). It is those cow/calf producers, which collectively have an average herd size of less than 42 head, who will be directly burdened and financially disadvantaged by the proposed rule. And, many, if not most, of those cow/calf producers do not have access to the state-of-the-art cattle working system used in Dr. Ringwall’s study. Therefore, the actual costs borne by ! U.S. cow/calf producers would be expected to be higher than Dr. Ringwall projected.

For the foregoing reasons, APHIS’ reliance on the 2009 APHIS ID Study to estimate the cost of the proposed rule on U.S. cattle producers is unjustified, erroneous, and deceitful. As a result of APHIS’ direct reliance on the APHIS ID Study, APHIS’ cost estimates likewise are unjustified, erroneous and deceitful. Based on the realistic cost estimates generated by Dr. Ringwall’s study, the proposed rule’s start-up costs and annual costs, which would range from a low of $554 million to a high of $1.9 billion, are unfeasible. APHIS’ proposed rule is a financially unworkable albatross that will economically harm U.S. cow/calf producers who will not be afforded any opportunit! y to recoup their costs in the marketplace.

 

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

 

# # #

 

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit www.r-calfusa.com  or, call 406-252-2516.

R-CALF United Stockgrowers of America

 

“Fighting for the U.S. ! Cattle Producer”

 

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 16, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part III of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA has launched an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part III:  The Proposed Rule Would Cost the U.S. Cattle Industry Hundreds of Millions of Dollars

 

C. APHIS Grossly Understates the Economic Cost of the Proposed Rule that Will be Borne by U.S. Cattle Producers 

 

  1. 1.      A three-year study shows the proposed rule will cost U.S. cattle producers hundreds of millions of dollars, if not billons of dollars

 

USDA data show the 2010 U.S. calf crop was 35.685 million head and the U.S. commercially slaughtered 34.249 million cattle in 2010. (EXHIBIT 11, p. 19) Based on the assumption that all of those cattle had to be moved at least once in 2010 – from herd of origin to grass or backgrounder, or from herd of origin to feedlot and/or slau! ghter plant, respectively – there was a potential for all those cattle to be moved in interstate commerce and to be subject to the proposed rule’s requirements (it is noted the requirement for indentifying feeder cattle would be only temporarily delayed under the proposed rule). Thus, there was the potential in 2010 for nearly 70 million head of cattle to be required to be individually identified if the proposed rule were fully implemented.

 

A study presented to the U.S. International Trade Commission (USITC) in 2007 by Kris Ringwall, Ph.D., Director, Dickinson Research Center Extension and Livestock Specialist, North Dakota State University (NDSU), that involved the tagging of 14,432 calves during the three-year period 2004-2006, concluded that the cost working each calf, tag placement and documentation was $7.00 per calf. (EXHIBIT 12, p. 2) In addition, Dr. Ringwall’s three-year project determined tha! t the tagging of calves was costly to producers because of shrink, which he defined as “weight loss while handling calves.” (EXHIBIT 12, p. 2) Dr. Rinwall stated in his testimony:

 

When we’ve measured shrink in the cattle we have worked during the project, we estimate up to $10 to $20 in lost income potential per calf, regardless of the management activity applied. (EXHIBIT 12, p. 2)

 

Based on Dr. Ringwall’s findings, the cost of tagging and documenting calves, excluding the cost of the tag itself, and the cost of the income lost due to shrink, ranged from $17.00 per head to $27.00 per head in 2006 or 2007 dollars. Based on information and belief, that cost in 2010 dollars likely is as high as $30.00 per head, if not higher. However, applying Dr. Ringwall’s 2007 findings to all cattle – cows, bulls, and calves – the likely cost of the proposed rule to U.S. cattle producers ranges from $1,190,000,000 ($1.2 billion) to $1,890,000,000 ($1.9 billion) (70 million head of cattle multiplied by $17.00 per head and $27.00 per head, respectively).  Even if only the cattle moved to slaughter in 2010 were considered, the cost to U.S. cattle producers would be $924,723,000, or about $920 million (34.249 million head of commercial slaughter cattle multiplied by $27.00 per head).

 

Applying Dr. Ringwall’s findings to APHIS’ assertion that “[a]pproximately 20 percent of cattle are not currently eartagged as part of routine management practices” (see 76 Fed. Reg., 50097, col. 1) and based on the assumption that APHIS used the Jan. 1, 2011, U.S. cattle and calves inventory number of  92,582,400 head, it would cost U.S. cattle producers a high of nearly $500 million to tag the 20 percent of cattle not already tagged (20 percent of 92,582,400 cattle equals 18,516,480 cattle multiplied by $27 per head).

 

Using APHIS’ data relied on in its supporting document, only 3.1 million of the 35.685 million head annual calf crop is tagged with official identification.  Therefore, the cost of tagging the remaining 2010 calf crop would range from $554 million to $880 million.

 

Thus, based on an actual study of tagging actual cattle – not on a study of available literature upon which APHIS relies – the cost to U.S. cattle producers to comply with the proposed rule will likely be hundreds of millions of dollars, if not billions of dollars. APHIS’ upper cost estimate for the proposed rule of only $34.3 million (see 76 Fed. Reg., 50097, cols. 2, 3) is based on a complete lack of understanding of the U.S. cattle industry, and it grossly understates the cost that U.S. cattle producers actually will bear if USDA does not immediately withdraw the proposed r! ule.

 

 

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress. 

R-CALF United Stockgrowers of America

“Fighting for the U.S. ! Cattle Producer”

For Immediate Release                                                                         Contact: R-CALF USA CEO Bill Bullard

December 15, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part II of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA has launched an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part II:  By Deploying the Underhanded Tactic of “Bait-and-Switch,” APHIS Deceptively Scared the Livestock Industry, Congress, and the Public Into Falsely Believing that a Mandatory Animal Identification System was Absolutely Critical to Protect the U.S. from Foot-and-Mouth Disease

  1. APHIS’ Flip-Flop Regarding Its Principal Justification for a Mandatory Animal Identification System Demonstrates that APHIS has an Ulterior Motive for the Proposed Rule that Is Unrelated to the Prevention or Control of Animal Diseases

Remarkably, while APHIS touted the risk of FMD introduction and spread as the principal justification – indeed its “poster-child disease” – for a national animal identification system (NAIS) in the years, months and days leading up to its publication of the proposed rule, FMD is no longer included among the diseases APHIS identifies as justification for its proposed rule. In fact the voluminous, 28-page proposed rule does not even mention FMD, let alone reference it as a disease APHIS would expect to prevent or control should it finalize its proposed rule. Any mention of FMD is now relegated to a small, hypothetical and ambiguous section in APHIS’ supporting documents, in which APHIS provides the disclaimer that its hypothetical FMD discussion “does not specifically model conditions that may exist under the proposed rule;” and in whi! ch APHIS provides no explanation regarding how its proposed rule would, in any way, protect against a potential outbreak or spread of FMD.

It is abundantly clear that while APHIS has long assigned substantial weight to the potential to mitigate FMD introduction and spread in the United States in its historical and ongoing effort to impose a national animal identification system on the U.S. cattle industry, it has now completely abandoned its flagship disease.

In its 2008 risk evaluation of South Korea, APHIS described in detail South Korea’s evolving national animal identification system to highlight the system as a measure to effectively mitigate FMD spread following a FMD outbreak (EXHIBIT 6, pp. 24, 25). Similarly, in recent congressional testimony, APHIS testified that Japan had adopted a national animal identification system and that the need for such a unified national animal identification system had assumed greater urgency in the U.S. due to FMD (EXHIBIT 7). APHIS further claimed that a national animal identification system would be critical in mitigating the risks posed by potential FMD outbreaks, and vehemently argued that the costs of a national animal identification system must be compared with the estimated billions of dollars in losses th! e U.S. would be expected to suffer from a FMD outbreak (EXHIBIT 7). Recently, in APHIS’ risk analysis section of its risk evaluation for the agency’s proposed rule to regionalize a Brazilian state, APHIS describes Santa Catarina’s animal identification systems in significant detail and claims the systems would allow officials to trace the movement of cattle within Santa Catarina, presumably to mitigate the spread of a FMD outbreak in Santa Catarina (EXHIBIT 8, pp. 45-47). Then, within just days of publishing the proposed rule, APHIS published a notice of availability (notice) and request for comment that referenced its APHIS Evaluation of the Foot and Mouth Disease Status of Japan risk analysis as the basis for deciding whether to resume trade in FMD-susceptible products with Japan (see 76 Fed. Reg. 44503-504 (July 26, 2011)). APHIS stated in its notice: “The risk analysis will also serve as the basis for our determination whether to allow the resumption of the importation of whole cuts of boneless beef from Japan.” Id., 504, col 1. APHIS’ referenced risk analysis regarding the potential risk of FMD introduction from Japan stated, “Japan’s cattle identification system ensures adequate trace-back capability in the event of an [FMD] animal disease outbreak” (EXHIBIT 9, p. 17).

As demonstrated above, APHIS for many years concocted a virtual taxpayer-funded fervor, both publicly and within the entire U.S. livestock industry, to advance its goal to establish a mandatory animal identification system in the United States – which goal manifested into the proposed rule – principally, if not exclusively, by claiming a mandatory animal identification system is essential to prevent the introduction and/or spread of FMD in the United States. APHIS’ absolute silence regarding any potential for the proposed rule to mitigate the introduction or spread of FMD in the U.S. is inexplicable and provides compelling e! vidence that APHIS has an ulterior motive for proposing the proposed rule, which ulterior motive has absolutely nothing to do with prevention or control of animal diseases.

APHIS’ proposed rule is a complete scam. APHIS provides no support whatsoever for its proposed rule based on its multi-year, multi-million dollar (EXHIBIT 10, p. 1), taxpayer-funded public-relations and nationwide marketing campaign to hype a mandatory animal identification system as essential to protecting U.S. livestock from the most contagious disease known to cloven-hoofed animals – FMD; and, as will be discussed below, APHIS’ proposed rule directly contradicts APHIS’ claimed objective to carry out its statutory responsibilities using a scientific, risk-based approach.

APHIS’ inexplicable abandonment of the threat of an FMD introduction as its principal justification for a mandatory animal identification system as is clearly revealed in the proposed rule is akin to the hideous and unlawful scheme known as bait-and-switch in the retail industry.  Under a bait-and-switch scheme, retailers lure consumers into their establishment by advertising an item known to attract consumers; but, when the consumer arrives at the establishment, the item that lured them there is unavailable, and the retailer hopes the unsuspecting consumer will nevertheless purchase an alternative item. This deceptive tactic is precisely what APHIS has employed to coerce unsuspecting cattle producers to buy into the proposed rule – it aggressively advertised FMD as the principal disease ne! cessitating a mandatory identification system and when the proposed rule is published, FMD suddenly is abandoned as justification for the proposed rule, with only less contagious diseases remaining.

Like the victimized consumer duped by a retailer’s deceptive bait-and-switch scheme, cattle producers have no moral or ethical obligation to comply with APHIS’ equally deceptive bait-and-switch tactic deployed in the proposed rule, and they should have no legal obligation either.

If APHIS proceeds in any way other than to immediately withdraw the proposed rule, it must fully and comprehensively explain why APHIS abruptly abandoned FMD as a justification for the proposed rule. As part of that explanation, APHIS must describe in detail the specific role that a mandatory animal identification system played, if any, during the outbreaks of FMD that occurred very recently during this decade in the United Kingdom, South Korea, Japan, and Paraguay.  Specifically, APHIS must describe in detail the degree to which traceability in those nation! s reduced the spread of FMD or otherwise assisted in combating the disease.

Further, and in addition to the proposed rule’s failure to address APHIS’ historical insistence that a mandatory animal identification system is needed to address FMD, the proposed rule also fails to explain or describe what measures and operations APHIS will deploy to control or eradicate any specific diseases. APHIS’ authority to control or eradicate diseases (note that “control” and “eradicate” have very different meaning) is conferred by the AHPA’s authorization to carry out operations and measures for those purposes. (See 7 U.S.C. 8308 (a), (“The Secretary may carry out operations and measures to detect, control, or eradicate any pest or disease of livestock. . .”). However, the proposed rule is silent on any specific “operations and measures” the agency intends to carry out to eradicat! e or control any specific disease.

Due to this additional deficiency contained in the proposed rule, and if the agency proceeds in any way other than to immediately withdraw the proposed rule, the agency must explain and describe to the U.S. cattle industry:

  1. The specific diseases APHIS intends to “control” under the proposed rule.
  2. The specific nature of the “operations and measures” APHIS intends to use to “control” each of the specific diseases APHIS intends to “control” and a detailed description of the role of the traceability contemplated in the proposed rule in carrying out such “operations and measures.”
  3. The specific diseases APHIS intends to “eradicate” under the proposed rule.
  4. The specific nature of the “operations and measures” APHIS intends to use to “eradicate” each of the specific diseases APHIS intends to “eradicate” and a detailed description of the role of the traceability contemplated in the proposed rule in carrying out such “operations and measures.”

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress.

# # #

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit www.r-calfusa.com or, call 406-252-2516.

R-CALF United Stockgrowers of America

“Fighting for the U.S. Cattle Producer”

For Immediate Release Contact: R-CALF USA CEO Bill Bullard

August 9, 2011 Phone: 406-252-2516; r-calfusa@r-calfusa.com

USDA Spurns U.S. Cattle Industry: Issues Overreaching, Intrusive Mandatory Animal Identification Rule

Billings, Mont. — In direct defiance of fundamental recommendations to preserve branding as a means of official animal identification and to not include cattle less than 18 months of age in any national animal identification system made by R-CALF USA and several other U.S. livestock groups, the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) today released an early version of its proposed rule to implement a national animal identification system titled “Traceability for Livestock Moving Interstate” (proposed rule).

The proposed rule would remove the hot-iron brand from among the list of official identification devices that cattle producers could choose to comply with the new federal mandate. It also encompasses cattle less than 18 months of age that would be triggered at USDA’s discretion one-year after USDA determines that older-aged cattle are substantially identified.

“The proposed rule, expected to be published in tomorrow’s Federal Register, not only spurns the U.S. livestock industries key recommendations regarding the hot-iron brand and younger cattle, but also, it snubs the critical recommendation by Agriculture Secretary Tom Vilsack’s own Advisory Committee on Animal Health, which urged the Secretary to provide at least a 120-day public comment period for the proposed rule. Instead, Vilsack is only providing a 90-day public comment period,” said R-CALF USA CEO Bill Bullard.

Bullard said the 90-day comment period will run at a time when tens of thousands of livestock producers are battling perhaps the nation’s most widespread and devastating drought and coincides with the cattle industry’s busy calf-weaning and calf-shipping season.

According to Bullard, USDA’s rejection of its own advisory committee’s recommendation to give producers more time to respond to the 114-page proposed rule suggests it already has decided to force this unacceptable mandate on U.S. livestock producers.

“USDA is running roughshod over the U.S. livestock industry with its bureaucratic ‘we know better than the entire industry’ attitude,” said Bullard adding, “USDA officials have deceived livestock producers by pretending to seriously consider producer recommendations and then springing these unworkable and unacceptable mandates on us in its proposed rule.”

“It’s obvious that USDA did not listen to the multitude of U.S. livestock producers who participated in the agency’s nationwide NAIS (National Animal Identification System) listening sessions in 2009 and overwhelmingly opposed USDA’s efforts to force individual identification on younger cattle and any mandate that would limit a producer’s choice regarding how they identify their livestock,” said R-CALF USA President George Chambers.

Chambers said his group will be calling for new listening sessions to help USDA recall the serious concerns producers raised earlier but have since been either forgotten or ignored.

Chambers said the proposed rule severely restricts producer choices because it removes completely the option for a producer to unilaterally choose to continue using the hot-iron brand when shipping cattle across state lines.

“Under the proposed rule, individual producers cannot choose on their own to continue using the hot-iron brand to identify their cattle. Nor can an individual state on its own choose to identify the cattle leaving their state with a hot-iron brand. Only if two state governments mutually agree to use the now delisted hot-iron brand will that option be available to either U.S. cattle producers or individual states,” Chambers said.

He continued to explain, “USDA did not have to attack our industry’s hot-iron brand or add younger cattle to the proposed rule in order to improve animal disease traceability in the United States, but we believe it has chosen to do so to appease the World Trade Organization and other international tribunals.”

Chambers also explained that the proposed rule itself provides absolute proof that the hot-iron brand remains an effective means of identifying animals in interstate commerce:

The proposed rule expressly allows producers to use hot-iron brands on their horses when shipping across state lines. This provision completely obliterates USDA’s feeble argument that it cannot require the 36 non-brand program states to accept a registered brand originating in the 14 brand program states as an official identification device — that’s precisely what USDA is doing with horses. It’s clear USDA is misleading us to achieve some ulterior motive.

“This proposed rule reduces flexibility and reduces producer choices and we are urging U.S. livestock producers to aggressively oppose the proposed rule,” Chambers concluded.

The public can submit comments on the proposed rule by either of the following methods:

– Federal eRulemaking Portal: Go to

http://www.regulations.gov/#!documentDetail;D=APHIS-2009-0091-0001.

– Postal Mail/Commercial Delivery: Send your comment to Docket No. APHIS-2009-

0091, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River

Road Unit 118, Riverdale, MD 20737-1238.

# # #

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 46 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. For more information, visit www.r-calfusa.com or, call 406-252-2516.

Note: The Proposed Rule can be viewed at http://r-calfusa.com/animal%20id/110809USDAProposedRule.pdf

Note: To remove yourself from this list, reply to this e-mail and include the word “unsubscribe” in the subject line.

 

Editor’s Note: Abu Dhabi, the center of the United Arab Emirates, like all other countries is drinking the koolaid about animal ID from the World Ogranisation of Animal Health (OIE). They are told to ID every animal or they can not export — else all livestock value will be ended.

Abu Dhabi, unlike the USA proposed a compulsory AIRS (same as NAIS) that all animals be numbered for food health purposes. In Abu Dhabi the race horses aren’t numbered, but 105,087 camels are. Most won’t be eating camels, but who knows, maybe they have gonorrhea? The government is paying for the computer records and furnishing compliance officers to search the desert sands for every camel, goat, sheep, and cattle.

The fact Abu Dhabi imports over 90% of their milk and meat why do they listen to the OIE and concern themselves with export issues? It is the same sales pitch offered by the USDA, and the United Nations. Now, every one humped dromedary will have an ear chip, but the camel jockeys won’t have to pay for it.

Over 1 million livestock registered in Abu Dhabi

16 January 2011,

ABU DHABI — The Animal Identification and Registration System (AIRS) campaign registered and tagged over a million animals in the livestock category, the Abu Dhabi Food Control Authority (ADFCA) announced.

The authority allocated 55 teams of four each to implement and reach its target in Abu Dhabi city and the Eastern Region that includes Al Ain.

In Al Gharbia or the Western Region, work will be completed by the end of February.

In the last three months since the AIRS kicked off in Abu Dhabi and Al Ain, 7,878 farms were visited.

The authority also said the animals already registered include 105,087 camels, 25,748 cows and 1,050,087 sheep and goat heads.

“AIRS campaign is progressing extremely well and we are geared up to complete it on schedule. Farm owners and workers have fully understood the huge benefits AIRS can bring about for them, the consumers, the community, and are greatly supportive for field teams. This is indeed a decisive factor that is helping us to complete both Abu Dhabi and Al Ain Regions on time and we are very thankful for them,” said Mohamed Jalal Al Reyaysa, Director of Communication and Community Service, ADFCA. “As we embark on the Western Region AIRS campaign, we invite livestock owners in Abu Dhabi Region whose animals have not been identified yet to contact the AIRS help desk 800555, or other various existing communications channels to provide all required information such as farm area and number, GPS Location, livestock number per species and AIRS team will set a visit time,” he advised.

AIRS is compulsory and free of charge for livestock owners and it allows the traceability of animals and products of animal origin.

The programme aims to achieve many benefits for Abu Dhabi, livestock owners and consumers and the community such as national database for animals towards achieving food safety, better livestock management systems, as well as better diseases surveillance and control of humans and animals health emergencies.

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