Browsing Posts tagged inspection

Downsize Government

Memo ~~ USDA knows 18% of the beef consumed in the USA was imported
in 2011 because the nation does not produce enough product to feed
it’s people, yet more costly rulemaking is assessed upon producers
by bureaucrats. This document is vague and impossible to determine
the teeth, however, be assured, the devil is in the details. Once
Hammerschmidt gets this approved and mandatory he will personally
add the teath. There will be no more listening sessions or public
comments — the federales will have their way, regardless of the
majoritie’s oppositon.

Yesterday, USDA submitted it Animal Disease Traceability Rule to the
White House Office of Management and Budget for final review. See
Below.
This is one obstinate agency.

 

AGENCY: USDA-APHIS RIN: 0579-AD24TITLE: Animal Disease Traceability
Neil HammerschmidtSTAGE: Final Rule ECONOMICALLY SIGNIFICANT: No
** RECEIVED DATE: 04/25/2012 LEGAL DEADLINE: None
RIN Data
USDA/APHIS RIN: 0579-AD24 Publication ID: Fall 2011
Title: Animal Disease Traceability

Abstract: This rulemaking would establish a new part
in the Code of Federal Regulations containing minimum
national identification and documentation requirements
for livestock moving interstate. The proposed regulations
specify approved forms of official identification for each
species covered under this rulemaking but would allow such
livestock to be moved interstate with another form of
identification, as agreed upon by animal health officials
in the shipping and receiving States or tribes. The purpose
of the new regulations is to improve our ability to
trace livestock in the event that disease is found.

Agency: Department of Agriculture(USDA)
Priority: Other Significant
RIN Status: Previously published in the Unified Agenda Agenda Stage
of Rulemaking: Final Rule Stage
Major: No Unfunded Mandates: No
CFR Citation: 9 CFR 90
Legal Authority: 7 USC 8305
Legal Deadline: None

Statement of Need: Preventing and controlling animal disease is the
cornerstone of protecting American animal agriculture. While ranchers
and farmers work hard to protect their animals and their livelihoods,
there is never a guarantee that their animals will be spared from
disease. To support their efforts, USDA has enacted regulations to
prevent, control, and eradicate disease, and to increase foreign and
domestic confidence in the safety of animals and animal products.
Traceability helps give that reassurance. Traceability does not prevent
disease, but knowing where diseased and at-risk animals are, where they
have been, and when, is indispensable in emergency response and in
ongoing disease programs. The primary objective of these proposed
regulations is to improve our ability to trace livestock in the event
that disease is found in a manner that continues to ensure the smooth
flow of livestock in interstate commerce.

Summary of the Legal Basis: Under the Animal Health Protection Act (7
U.S.C. 8301 et seq.), the Secretary of Agriculture may prohibit or
restrict the interstate movement of any animal to prevent the
introduction or dissemination of any pest or disease of livestock, and
may carry out operations and measures to detect, control, or eradicate
any pest or disease of livestock. The Secretary may promulgate such
regulations as may be necessary to carry out the Act.

Alternatives: As part of its ongoing efforts to safeguard animal
health, APHIS initiated implementation of the National Animal
Identification System (NAIS) in 2004. More recently, the Agency launched
an effort to assess the level of acceptance of NAIS through meetings
with the Secretary, listening sessions in 14 cities, and public
comments. Although there was some support for NAIS, the vast majority of
participants were highly critical of the program and of USDA's
implementation efforts. The feedback revealed that NAIS has become a
barrier to achieving meaningful animal disease traceability in the
United States in partnership with America's producers. The option we are
proposing pertains strictly to interstate movement and gives States and
tribes the flexibility to identify and implement the traceability
approaches that work best for them.

Anticipated Costs and Benefits: A workable and effective animal
traceability system would enhance animal health programs, leading to
more secure market access and other societal gains. Traceability can
reduce the cost of disease outbreaks, minimizing losses to producers and
industries by enabling current and previous locations of potentially
exposed animals to be readily identified. Trade benefits can include
increased competitiveness in global markets generally, and when
outbreaks do occur, the mitigation of export market losses through
regionalization. Markets benefit through more efficient and timely
epidemiological investigation of animal health issues. Other societal
benefits include improved animal welfare during natural disasters. The
main economic effect of the rule is expected to be on the beef and
cattle industry. For other species such as horses and other equine
species, poultry, sheep and goats, swine, and captive cervids, APHIS
would largely maintain and build on the identification requirements of
existing disease program regulations. Costs of an animal traceability
system would include those for tags and interstate certificates of
veterinary inspection (ICVIs) or other movement documentation, for
animals moved interstate. Incremental costs incurred are expected to
vary depending upon a number of factors, including whether an enterprise
does or does not already use eartags to identify individual cattle. For
many operators, costs of official animal identification and ICVIs would
be similar, respectively, to costs associated with current animal
identification practices and the in-shipment documentation currently
required by individual States. To the extent that official animal
identification and ICVIs would simply replace current requirements, the
incremental costs of the rule for private enterprises would be minimal.

Risks: This rulemaking is being undertaken to address the animal health
risks posed by gaps in the existing regulations concerning
identification of livestock being moved interstate. The current lack of
a comprehensive animal traceability program is impairing our ability to
trace animals that may be infected with disease.

Timetable:
Action Date FR Cite
NPRM 08/11/2011 76 FR 50082
NPRM Comment Period End 11/09/2011
Final Rule 08/00/2012

Additional Information: Additional information about APHIS and its
programs is available on the Internet at http://www.aphis.usda.gov.
Regulatory Flexibility Analysis Required: No Government Levels

Affected: State, Tribal
Small Entities Affected: Businesses Federalism: No
Included in the Regulatory Plan: Yes
RIN Data Printed in the FR: No

Agency Contact: Neil Hammerschmidt
Program Manager, Animal Disease Traceability, VS

Department of Agriculture
Animal and Plant Health Inspection Service
4700 River Road, Unit 46,
Riverdale, MD 20737-1231
Phone:301 734-5571
______________________________________________________________________

 

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. 

An electronic animal ID system has been the passion of USDA for over 18 years. Recently, Secretary of Agriculture Tom Vilsack announced that hot iron branding was an acceptable form of future animal ID.

History completely agrees with the secretary’s findings.

Branding History

The western cowboy did not invent hot iron branding. The documented history of branding goes back for thousands of years. Scenes of oxen being branded on hieroglyphics are depicted on Egyptian tombs as early as 2,700 BC.

Hot Iron BrandingHot iron branding animal ID, for proof of title, has not changed for over 5,000 years. The book of Zechariah records this process in chapter 3 verse 2, “a brand plucked out of the fire.”

On a darker side of history, the use of a hot iron as proof of ownership went beyond cattle to an area people today prefer not to think about, the ID branding of human beings. From days of the ancient Greeks, Arabians, Romans and Egyptians, slaves were often marked as property with a small brand by their owner. The practice has continued in slave owning countries around the world. More recently branding has been used on prisoners and self branding which is termed “art branding” or “scarification.”

Hernando Cortez is credited with bringing the first branding irons to the Americas in 1541. His personal holding brand was three crosses.

Branding became common in the US after the Civil War. Eventually, in Canada, the second session of the Northwest Territories government on August 1, 1878 established a law requiring all livestock to be branded.

Brands of every shape and design were visible on every Longhorn that came out of Texas during the great trail drives. Spanish brands are often artistically designed with cursive, complicated circular characters. The western American ranchers chose simpler block and open shapes, which proved harder to alter and easier to read.

Designing a Personal Brand

Designs and names of brands are as colorful as the people who use them. The traditions and pride of ownership attached to brands is a volume in itself.

Selecting a brand can be a simple thing or as detailed and historically meaningful as the owner desires. Most brands are based on the owner’s or the ranch’s initials. They may be a symbol, letter, number, character or combinations of connected or separate figures. A brand symbol, for example, may be a hat, fish, pitch fork, shovel, hook, bell, spur, staple, horse shoe, or wine glass. The list goes on.

Brands are read like books from top to bottom and from left to right. Without a doubt, it is a historical, respected, language all it’s own.

A branding iron should be of quarter-inch clean iron made to the desired shape. Small cattle should be branded with irons about 3″ tall and larger adult stock can be about 4.”

A horse iron can be as small as 2″.

The handle should be about thirty inches long with an end grip holding device. When applied to stock, separate letters should be at least one inch apart so as not to appear attached.

Notches or “breaks” are necessary on all irons where the bars join or intersect, about 1/4″ to 3/8″ wide. This prevents blotching in the corners. Letters like the top point of an A are particularly prone to blotch and always should be left open. Letters like L, C, U, I, J, S and open shapes yield themselves to clean readable brands.

Holding Brand Registration

No ownership holding brand should be applied until legally registered. Registration is done in most states through the Dept. of Agriculture. A brand design is submitted for approval and recorded for a set fee, and only the recorded owner of that design can legally use it on their livestock.

No two brands will be registered that are, or appear to be, the same design. In the eastern U.S. many states only have a few hundred registered brands, so it is easy to acquire a simple, clean brand.

Colorado, on the other hand, has registered over 60,000 brands making it difficult to get a new brand with less than 4 letters. Texas, not to be outdone, claims over 230,000 registered brands on the books.

Code Brand Records

Simple brand codes may reveal to the owner information like pedigrees, year of birth, or ranch division where born. In order to keep the brand process simple and requiring minimal time to apply, fewer letters are always better.

A single number indicating the year of birth is quite often used. The current year 2010 would be “0”. At a glance the owner can easily know the year of birth. The year code can be part of the regular numbering system, over, under, in front of, or beyond the animal ID brand number. Brands are simple and can be recorded on a paper tablet providing a permanent record that lives well beyond the life of the animal. The numbering process is practiced by most ranches providing a non duplicate ID for every animal traceable through the records of USDA through the state brand registration system.

Confinement

Successfully applying a clear distinct ID brand requires the recipient to be still. In the open range, cattle were roped and laid on the ground for branding. Some of the best clear brands are done this way.

The same process can be used in a small herd where the critter is physically laid down, not on the open range, but in a back yard corral. This is recommended for young calves, and not adults.

When adult cattle are branded, a metal squeeze chute is safe and efficient. The side squeeze chutes eliminate the head catch and restrain the critter better from head swinging. This provides safer name tagging, vapor tagging, and OCV tattoos. Plus, the side swing confinements are always the safest for releasing an animal from either side. A general purpose chute sells for $1250 to $2500.

Animal Safety/Care

All processes in cattle care should be bloodless. Although tags and pins are numerous, each tag entry can puncture arteries, hide, muscles and pierce major ear cartilage, which always bleeds. With bleeding can come infection, insect attraction, irritation, or partial loss of hearing and ear function.

The searing process of branding should never draw blood and is self sealing. It becomes a permanent ID in seconds and no medication should be needed in the future.

State Brand Laws

Secretary Vilsack has wisely acknowledged the State Brand Inspection Systems (SBIS) are good animal ID. From the Mississippi west every state has brand laws and inspection procedures, with some dating well over a hundred years old — well tested by time. Branding is economical and a system currently in use by nearly every major cattle raiser. It doesn’t require more fees, expanded USDA staff, computer education, high tech equipment purchases (not proven to perform under range conditions) or pernicious enforcement fines. The old brand laws work for all the right reasons. Last year SBIS visually inspected and documented 27,000,000 cattle according to James Clement, DVM. (See Animal ID, Another View)

Heating the Irons

More irons have been heated with wood than any other way. A hot wood fire serves the purpose well. Today most people are in a hurry and use either electric irons or heat with propane. A small propane bottle will heat a lot of irons and may be transported easily without the limitations of an electric cord.

The iron, when heated properly, should appear a light ash color. An iron heated in a flame will first accumulate carbon and appear very black. A black iron is too cold. It may be hot enough to burn or singe the hair, but not hot enough to penetrate the roots of the hair follicles, essential for a permanent mark.

Red hot, yellow, or white irons should be cooled before use. A red hot iron may brand too fast. The beauty of clear clean brands comes with experience.

Applying the Brand

It is impossible to make a rule for the length of time the iron should be held to the hide, because the condition of the hair and the temperature vary.

To apply the brand, move the handle in a slow, rocking motion which will vary the pressure. A critter is not a flat surface so a flat iron may not clearly mark at all corners. It is better to remove the iron after a couple of seconds, check the mark and reapply the iron to the parts not adequately branded. Always error on the light side rather than over doing the time and pressure.

With the first brand effort, test the result. Hand rub the brand and briskly remove the charred hair. If the animal has been properly branded, a clear outline mark of the complete brand will have a saddle leather light rust color to it.

On the other hand, if the iron was not hot enough, only the hair will be burned and short partially branded hair will be in the brand design. Re-heat and place the iron exactly on the same spot and allow additional time.

RFID ID Tags in Europe

In Europe numerous ear tag computer methods are used. Year by year more electronic ear devices become mandatory, attached at birth. (calf already has 4 tags - required by law)

When branding is complete, a generous rub with bacon grease using a paint mitten will promptly soothe and lubricate the hide.

An adult steer has hide 10 times thicker than a human. A good brand only enters about one tenth into the total thickness of the hide. Penetration of the skin’s epidermis outer layer is the goal of a correct brand. Correct placement is below the hair and above the dermis tissue.

What is the Real Reason?

Proof of title is the historic reason for a brand. It has worked for over 5,000 years. It is the best permanent ID for an owner’s records. Permanent fire brand ID not only works on a live animal, but continues to be a valid ID on the hide after processing. Unfortunately, there are always unscrupulous people who want to steal or “rustle” livestock. In the fifth century BC, I Chronicles 7-21 records that the whole family of Ephraim was killed for “trying” to rustle cattle.

Modern cattle rustlers, which are numerous, truly love the current highly promoted electronic ID. Any cattle rustler can easily remove, replace, change tags and electronic pins. To speed up the process rustlers order a Tag-Sav-R Ear Tag Remover from Nasco for $25.75. Nasco Tag-Sav_RThis jiffy Safety Tag Knifetool was developed to back-out the pin arrow and allow a person to replace it into another animal. It only takes a couple seconds on most pins. If $25.75 cost too much, Nasco has a more affordable Safety Tag Knife for $3.95, cut those unsightly tags out and throw them away.

To think the 840 pins are legal ID or even correct source verification is absurd.

When a rustler is in a hurry to haul-out, it only takes a second to cut the whole ear tip off. That is not a permanent animal ID — ask any successful cattle rustler.

Special TSCRA Ranger Scott Williamson, who is working on several rustling cases in Texas says, “It is a great deal easier in court when stolen animals are fire branded. Prosecutors prefer to try cases where the animals have been branded. If you can prove to the prosecutor that he’s going to be able to absolutely identify an animal in court, he knows he’s not sticking his neck out to take the case.”

No type of animal ear ID has ever held up in court for a conviction, yet hot iron brands have.

Every major cattle producing nation on earth used fire brands. The permanence and stability of a fire brand is superior to all other ID methods including the old “brite” USDA tags that are being newly promoted for ADT.

So, after the smoke and the dust are settled, and all the government bureaucrats have put up their crayolas, trust your neighbors — but fire brand your cattle!

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