Browsing Posts tagged traceability

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 18, 2011                                                                                          Phone: 406-252-2516; r-calfusa@r-calfusa.com

 

8 Days of Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part V 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 V:  Marketplace Premiums for Traceable Cattle Will Evaporate Under the Proposed Rule

 

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

 

  1. 3.      APHIS’s cost estimates completely overlook and ignore the market value of the information intrinsic to an individually identified animal and the effect of APHIS’ proposed rule will be to steal that value from U.S. cattle producers and gift it to the U.S. meatpacking industry.

 

APHIS asserts the primary benefit of the proposed rule would be to minimize losses and quickly reestablish foreign and domestic markets. See 76 Fed. Reg. 50097, col. 3.  But, APHIS completely overlooks and ignores the fact that foreign markets already have assigned a market value to information that would enable traceability to the herd of origin. Primary export markets such as Japan, South Korea, and Hong Kong already require beef exported to them to be from animals that are traceable. Japan requires beef to be derived from cattle t! hat are individually identified and traceable back to ranch records (EXHIBIT 16). South Korea requires beef to be derived from cattle that are of U.S. origin or fed in the U.S. for at least 100 days if they originate from Mexico or Canada, which requirement necessitates individual animal identification (EXHIBIT 17). Hong Kong requires beef from cattle that are traceable to the last location and to the herd of origin in the event of a BSE outbreak (EXHIBIT 18).

 

The fact that the above mentioned export markets each require some form of traceability of cattle from which the exported beef is derived indicates they each have assigned a market value for traceability and are willing to pay for that additional value in the price they pay for U.S. beef. This market driven incentive to provide traceability as a product attribute for foreign markets has already been embraced by many R-CALF USA members. Anecdotal information from R-CALF USA members indicates that the marketplace has assigned economic premiums ranging from $30 to $60 per head for producers who are voluntarily providing traceable livestock for use in the beef export market.

Dr. Kris Ringwall’s 2007 testimony to the U.S. ITC succinctly explained that traceability has a market value:

 

Steve Holcombe, founder and chief executive officer of Pardalis, Inc. (which is a third-party data storage company that values and treats data the same as money) noted: “The challenge is to effectuate regulations that are inclusive of small producers, and that recognize that there now are two distinct products being produced along agricultural supply chains today: (1) the traditional livestock product (the calf) and (2) an informational product that describes the ‘pedigree’ of the traditional product.”

 

This is important to understand. Today’s producer markets a calf but also markets the information about that calf, a process that is still struggling in the pens and alleyways of the cattle business. The free marketplace determines calf value, but the value of the information associated with the calf has not been determined. But one point is becoming very clear; the actual information contains the keys to unlock the various doors needed to enter the more complex market place, not only domestically but also internationally (EXHIBIT 12, p. 1).

 

The proposed rule is void of any economic analysis regarding the potential loss of all or part of the economic premiums that export-oriented cattle producers are presently receiving by choosing to add information to their cattle that describes the pedigree of their cattle. The proposed rule would interfere with the free market system by forcing all cattle producers to pay the cost of providing traceability and then gifting any and all of the market value associated with traceable cattle directly to the nation’s meatpackers, which, of course, are in the business of selling beef, not cattle. APHIS’ failure to analyze the loss of economic premiums, specifically the portion of the economic premium assigned to basic traceability, is fatal as the effect of its proposed rule would be to transfer wealth from U.S! . cattle producers to the purveyors of the commodity beef – the U.S. meatpacking industry.

 

Based on APHIS’ estimate that 3.1 million calves were officially identified in 2010 (see supporting document, at 8), and assuming that those cattle are receiving market-driven premiums in the range of $30 to $60 per head, the proposed rule would financially damage those producers in a range of between $93 million and $186 million. This would be in addition to the proposed rule’s costs addressed in Section C. 2. supra. This loss would be realized by U.S. cattle producers because, once the rule is implemented, those producers who already officially identify their cattle will no longer be able to differentiate their cattle based on all or part of the valuable “pedigree” information they are now “selling” in the marketplace.

 

R-CALF USA is concerned that APHIS intends to persuade export countries to abandon, in whole or in part, their current requirements for cattle traceability as specified in the USDA Export Verification (EV) program as soon as APHIS can demonstrate that all or most cattle in the U.S. are traceable under APHIS’ mandatory identification scheme. When this inevitability occurs, U.S. cattle producers will be deprived of the income discussed above that they can now earn by voluntarily participating in currently available EV programs.

 

R-CALF USA’s concern is not mere conjecture. In the June 3, 2005, Declaration of John R. Clifford, D.V.M., then deputy Administrator, APHIS, Veterinary Services, which included exhibits, Dr. Clifford stated that he did not believe the voluntary Export Verification Program was needed:

 

The program, called the Beef Export Verification program, will set forth policies, procedures and requirements for an independent process verification of participants.

 

It is a voluntary, user-fee service available to suppliers of beef and beef products derived from cattle slaughtered in the United States.

 

The USDA Agricultural Marketing Service will conduct process verification audits of suppliers, program documentation and procedures with regard to the Beef Export Verification program requirements.

 

Details of this program are being shared with the industry and will be posted on the USDA website starting today. It will be operational on or before September 1st.

 

As I said before, we do not believe such a program is necessary (EXHIBIT 1, pp. 2,3; EXHIBIT 19). (Emphasis added.)

 

Based on Dr. Clifford’s representation that APHIS was opposed to the very inception of the Beef Export Verification program, it is R-CALF USA’s belief that it is more likely than not that Dr. Clifford and APHIS will work aggressively to dismantle this voluntary, market-driven program as soon as the proposed rule is implemented.

 

If R-CALF USA’s concern materializes, APHIS’ proposed rule would effectively steal the market value associated with “pedigree” information that enables livestock traceability (estimated at between $93 million and $186 million in 2010 alone) away from U.S. cattle producers and gift it to the U.S. meatpacking industry, even though it is the cattle producers who will continually bear the cost of providing such valuable market information.

 

As explained above, APHIS’ proposed rule directly interferes with the United States’ free market system and if the losses estimated for 2010 were calculated on the basis of the cattle industry’s lost future income potential, those losses would compound astronomically and result in an acceleration of the already contracting U.S. cattle industry. For this reason, the proposed rule must be immediately withdrawn.

 

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.

 

The Denver Post

As USDA turns to ear tags over brands, cattle ranchers fear end of tradition

Ordway rancher John Reid holds some of the irons he uses to brand livestock on his ranch, the Reid Cattle Co. The USDA is expected to release new interstate rules requiring individual cattle to be identified by a number stamped on an ear tag. (Aaron Ontiveroz, The Denver Post )

The future of the hot-iron brand, an icon of Western heritage, is at the center of a nearly decade-long battle over cattle identification and traceability.

“It’s the latest hot lightning rod,” said John Reid, an Ordway rancher who is past president of the Colorado Independent Cattle Growers Association.

The U.S. Department of Agriculture is expected soon to release a draft of new regulations, which will remove the hot-iron brand from its list of official identification for cattle sold or shipped across state lines.

The new rules will require each animal to be identified by a number stamped on a removable ear tag.

States would still be able to use brands as official IDs within their boundaries.

Individual agreements between states can be reached to allow brands as official IDs for interstate movement — more complications.

Critics fear this is the beginning of the end for America’s centuries-old branding tradition.

“The federal government’s action sends a signal to the entire industry that the ear tag is a superior means of identification,” said Bill Bullard, chief executive of the Ranchers-Cattlemen Action Legal Fund.

Ranchers argue that ear tags can fall off or be stolen by thieves, so are not a good form of official ID.

State brand commissioner Rick Wahlert said nothing will change for the state’s cattle producers.

However, the new system is a critical element of participation in the interstate beef market, he said.

Negative reaction to the new rules, he said, “is really about change, and a fear of the government being in your business.”

Gerald Schreiber, a third-generation rancher in northeastern Colorado, already uses ear tags for identification within the herd but bristles at the new regulations.

“It sounds good on the surface, but anytime you get the Big Brother approach, I don’t trust it,” he said. “The brand has worked for 1000 years, I don’t know why they want to disregard it. In the West, branding is more than just a tradition; it’s our identity as ranches.”

First proposed in 2002, the National Animal Identification System (NAIS) was rolled out in 2004, but flatly rejected in USDA listening sessions by over 90% of the cattle producers.

Producers across the country are skeptical about the new program, which would require radio-frequency ear tags that would let cattle be tracked from slaughterhouse to birth.

Their concerns ranged from potential costs to confidentiality of information, including fears that animal-rights advocates would be able to gain information on ranchers through the use of the federal Freedom of Information Act.

“It got pretty ugly,” said Ordway rancher Reid.

From 2004 to 2009, the USDA spent $142 million on NAIS, according to a Congressional Research Service report to Congress. Because it was a voluntary program, less than 30 percent of cattle producers participated.

In February 2010, the USDA announced it was abandoning NAIS due to mass rejection by livestock producers. Now a new name and a new program has evolved called Animal Disease Traceability.

Loss of tradition

The draft of the proposed USDA rule was due in April but has been delayed. It is now expected to be released within weeks, followed by a 60- to 90-day period of public comment. It will take an additional 12 to 15 months before the final rule is released.

“Americans want two things,” Rohr said. “They want to know their food is safe, and they have an interest in knowing where their food comes from.”

Still, the plan to remove the hot-iron brand as an official method of ID across state lines has angered Westerners, who worry about a loss of tradition and the addition of more red tape to their businesses.

“The piece of the deal that is awfully hard for producers to understand is that most disease comes from meat processing plants more than individual cattle or cattle herds.” Reid said.

The brand is the oldest and more permanent form of herd identification, while ear tags, with their unique numbers, can easily fall off in brush and trucks where cattle frequent.

“So the question is,” said Reid, “do we need individual ID or is herd ID enough?”

USDA and Corporate Agribusiness Continue to Push Animal ID Scheme

Consumers and Independent Producers Lose if Big Ag Wins on Animal Traceability

Source: The Cornucopia Institute, Mark Kastel – June 21, 2011

WASHINGTON, DC — The U.S. Department of Agriculture (USDA) is expected to issue its new proposed rule for mandatory animal traceability very shortly. While USDA already has traceability requirements as part of existing animal disease control programs, the proposed framework goes much further to require animal tagging and tracing even absent any active disease threat. The framework has raised significant concerns among family farm and ranch advocates, who criticize the agency for failing to provide a coherent, factual explanation for the new program’s necessity.

“USDA brags about the success of past programs, but has abandoned the principles that made them successful,” argued Bill Bullard of R-CALF USA. “Past programs were based on sound science and were developed in response to the transmission, treatment, and elimination of specific identified diseases. USDA’s new approach is a one-size-fits-all approach that does not specifically aim at the control of livestock diseases.”

The USDA has presented its traceability scheme as an animal health program, but it has also reiterated the importance of the export market to the United States in promoting its new plan. The powerful meatpacking lobby has continued to push for such mandated traceability requirements in order to develop international standards for exports. Critics have suggested this is not in the American public’s best interest, however, since the U.S. is a net importer of beef and cattle and the profits from the export market go to a small handful of massive meatpacking companies.

“Factory farms can easily absorb the added economic burdens, and the meatpacking industry stands to benefit from a marketing standpoint,” asserted Judith McGeary, a livestock farmer and executive director of the Farm and Ranch Freedom Alliance. “However, the extra expenses and labor will fall disproportionately on family farmers and ranchers, accelerating the loss of independent businesses to corporate industrial-scale producers.”

“Consumers need the USDA to start focusing on the animal health and food safety risks posed by industrialized meat production,” said Patty Lovera of Food & Water Watch. “If USDA devoted as much energy to preventing animal diseases as it has to promoting animal tracking, our food system would be in much better shape.”

Many cattle organizations agree that tracing breeding-age cattle may be appropriate for efficient disease control, but USDA’s proposal goes far beyond that by calling for the identification of every cow that crosses state lines, including feeder cattle that are processed at a young age. Because of the sheer numbers of feeder cattle, this requirement could unduly burden small ranchers and sales barns and further erode competition in the marketplace.

“The large volume of the animals that USDA proposes to track could overwhelm the capabilities of state agencies, making it impossible to retrieve useful data if there is in fact a disease outbreak,” stated Gilles Stockton, a Montana rancher and member of the Western Organization of Resource Councils.

Additionally, the centuries-old tradition of hot-iron branding cattle would be demoted from an official identification device. “The brand is a part of our ranching heritage and a long accepted method of animal identification,” stated Rep. Denny Rehberg, R-Mont, in a letter to USDA Secretary Tom Vilsack.

A coalition of farm, ranch and consumer groups urges citizens to contact their Congressional representatives and the USDA with their concern that mandatory animal traceability helps only a few giant corporations, at the expense of American family farmers and consumers.

“If Americans don’t want their food supply to cave like the banking and housing industries, it’s time to take action,” stated Mark Kastel of The Cornucopia Institute.- 30-

MORE

Additional contact information:

Judith McGeary, Farm and Ranch Freedom Alliance, 512-484-8821

Bill Bullard, R-CALF USA, 406-252-2516

Patty Lovera, Food & Water Watch, 202-683-2465

Gilles Stockton, Western Organization of Resource Councils, 406-366-4463

The Cornucopia Institute PO Box 126 Cornucopia, WI 54827 www.cornucopia.org

ID Scheme

Note:Sec Vilsack knows that 16% of the US 2010 consumed beef was imported. He knows that for the last 21 years the USA has not produced enough beef to feed the nation. Why then, pray tell, does he think it is important to export beef to China, much of which has to be purchased outside the USA? Why would the marble halls of USDA contain people so far removed from the real world to assume it commercially feasable to force mandatory electronic ear tags on nearly a hundred million US cattle just to sell a few ocean containers of beef to China? Who comes up with this math? The cattle ID enforcement brain-child is not about exporting! It is not about livestock disease!

–Editor

Inside U.S. Trade

Daily News

Vilsack Indicates New Traceability Rule Will Help Exports, But Exact Impact Unclear

Posted: May 23, 2011

A soon-to-be-released proposed rule from the U.S. Department of Agriculture (USDA) imposing a mandatory animal traceability system will help win more market access for U.S. meat producers by enhancing the ability of the U.S. government to respond to an animal disease outbreak, Agriculture Secretary Tom Vilsack said at a May 12 House Agriculture Committee hearing.

“One of the concerns that we often hear from our trading partners is [about] the capacity to basically trace back at least to the state of origin any problem with animal health, which is why this traceability system is important,” Vilsack said.

Only about 30 percent of cattle producers participate in the current, voluntary traceability system, Vilsack said, and the current system does not “provide us the certainty and the guarantee” that the new system will. “So we think we’re going to get much more acceptance from this effort, and that should reassure our trading partners,” he said.

One meat packing industry source agreed that a comprehensive traceability system is important to expanding exports of beef to the European Union, which has so many information requirements for imports that traceability while not expressly required is necessary nevertheless. A mandatory system could enable more companies to ship there, he said.

Japan, which currently restricts access to its market to U.S. beef exports from cattle younger than 20 months, may be more willing to further open its beef market in light of a new, mandatory traceability system, this source said, because the United States could argue it is better equipped to deal with any animal health problem.

While the new system is intended to be comprehensive and mandatory, it is unclear whether it would meet the demands of all U.S. trade partners.

For instance, China has demanded that the United States implement a system that allows cattle to be traced back not only to their state of origin, but to the farm where they were born. China has said the United States must meet this condition before it will accept beef imports from the United States (Inside U.S. Trade,Nov. 12).

A spokeswoman for USDA’s Animal and Plant Health Inspection Service (APHIS) would not comment on whether the new proposal would be able to meet that requirement. She also would not give a more firm timeline for the proposal’s release than the one offered by Vilsack, who said it would be published by “late spring or early summer.”

But there are signs that the program would not go as far on traceability as China has demanded.

While mandatory, the new program will only apply to animals moving interstate, as these animals pose the biggest risk for spreading disease nationwide, according to a March USDA report giving the initial outlines of the proposal.

Before cattle are moved and sold across state lines, they will be affixed with a tag that bears a code indicating the state or American Indian tribe of origin and a unique numeric identifier. The state or tribe where the animal originated will then be responsible for maintaining detailed information of the animal’s origin.

This means that, in the case of a disease outbreak, it could be traced back tothe farm from which it came.

But Bill Bullard, CEO of the Ranchers-Cattlemen Action Legal Fund (R-CALF), said in an interview that while the system strengthens the government’s current ability to conduct trace-backs, it will likely not enable the government to trace back all cattle to their place of birth.

For example, if a cow changed hands several times within a state before being moved across state lines, state records would reflect only the farm where the cow was held last. That said, authorities could rely upon brands or other records kept by ranchers to trace the animal back to its farm of origin in these instances, Bullard said.

In the case of a cow that was raised and slaughtered in the same state and never moved to another, it is possible that no records would be kept under the new system. So-called “slick cows,” those with no brands and no ear tag, could also cause potential identification problems if record-keeping was not detailed, Bullard acknowledged.

So could a cow whose ear tag had fallen off, he added one reason his organization is pushing USDA to maintain the hot-iron brand as a recognized form of official identification.

The focus of the program is cattle, although it will also include changes to the way horses and poultry are tracked; regulations on swine, along with sheep and goats, will not be affected, according to the USDA report.

According to a spokeswoman for USDA’s Animal and Plant Health Inspection Service (APHIS), the new rule will be announced on the APHIS homepage and posted on Regulations.gov for a 60-day comment period.

“Once the comment period has closed, no comments will be accepted,” the spokeswoman said. “Consideration and response [to] all submitted comments will appear in the final rule 12 to 15 months after the close of the comment period.”

Bullard said the forthcoming proposal addresses the primary criticisms of the failed National Animal Identification System program (NAIS): that a traceability system would violate ranchers’ confidentiality and leave them unfairly exposed to liability suits in cases of food poisoning. They had also worried about the cost of the program.

The new proposal solves these issues by storing information in databases at the state level or with tribes, rather than at the federal level, where it could potentially be subject to freedom of information requests, Bullard said.

Ranchers worried that kind of producer data could be used by meat packers to gain leverage in negotiating prices, or by people who became sick after eating bad meat and wanted to sue everyone in the supply chain, he explained.

Allowing the use of cheap, metal ear tags instead of the more costly electronic tags proposed under NAIS also largely solves the problem of cost, Bullard said.

Bob Stallman, president of the American Farm Bureau Federation, said he was not familiar with the upcoming proposal but emphasized that his group has favored a voluntary approach in the past.

“Our policy has supported voluntary traceability programs,” Stallman told reporters at a May 17 press lunch, adding that some of the group’s members are involved in animal identification for more premium markets.

“There’s some involved in that,” he said. “So they’re not [all] opposed to the idea of traceability. What they’ve been opposed to is who has the information and how much is it going to cost, and how’s the information going to be used,” he said, echoing similar worries to those expressed by Bullard.

But Bullard called other parts of the forthcoming proposal a “broken promise” to his members because USDA had assured them that hot-iron brands would still be considered official identifiers under the new system, and that cattle under 18 months old would not be covered.

Bullard said the latest draft of the proposal recognizes only metal or electronic ear tags as official identifiers and would begin to cover cattle of all ages once 70 percent of cattle older than 18 months roughly the breeding age have been registered in the tracing system.

This version of the proposal has been submitted to the Office of Management and Budget and should be released soon, he added, but R-CALF is urging USDA not to publish it until those provisions are changed.

His group wants branding to be recognized as a universal identifier because ear tags can easily fall off, or be replaced by thieves. Under the proposal, brands could only be recognized through special state-to-state agreements. In the interview, Bullard also said that including younger “feeder” cattle in the system is unnecessarily burdensome.

“Our position is, there has been no demonstrated need to identify these younger animals,” Bullard said.

“We have been highly successful in eradicating diseases by focusing only on the breeding herd. And so we want to focus on the breeding herd, and when that is accomplished, we want to do a needs assessment to determine if the additional cost and burden upon the industry outweigh the benefits of the program.”

“We believe that these feeder cattle are already sufficiently traceable during their relatively short lifespans,” he added, “[and] that there is no need to mandate their identification at this time.”

USDA wanting to end Fire Branding as means of ID

We should have known this would happen! Now USDA is planning to de list the hot-iron brand from the list of “official animal identification devices.” As all cattle producers know, the hot iron ID and holding brand system is the basis of historic permanent ID. If the federales oppose hot iron branding it could easily be assumed that PETA and other animal rights wackos will grab on the coat tails of USDA. A day could come that only the NAIS digital ear tags would be allowed. As with other idiot federal enforcements in the last two years, they can eventually smell egg on their own faces, and to protect their bureaucratic gravy-trains, crawfish backwards and renege their plan.

In the last few years trusted farm and cattle organizations have prostrated with USDA’s pitiful ideas. When they could have opposed bad judgement, they allowed costly enforcements to be enacted and cattle producers pay the price.

Most do not know what USDA is now planning. This is a USDA conspiratorial step to resurrect the flawed-thought of the hated NAIS. You have not been warned about this in the cattle media as they also understand the profitable nature of a passive attitude toward their consistent advertiser, USDA.

Only one organization is on their toes, alert and ready to defend the US cattle producers — R-CALF USA. The attached letter gives the position (not passive) of R-CALF. Each cattle producer should support R-CALF in their efforts to defend producers from USDA’s cumbersome-costly and ominous regulations, like delisting hot iron branding. Every professional producer understands the value of fire branding for permanent ID and prevention of cattle thefts.

If you are a USA citizen and cattle producer, it is very profitable to join and support R-CALF. Attached is a membership application.

Why R-CALF USA Opposes USDA Proposal to Delist Brands

The hot-iron brand is part-and-parcel to the culture and heritage of the U.S. cattle industry. In addition, the U.S. Department of Agriculture (USDA) has long recognized the importance of the brand as a permanent means of identifying livestock, not only for determining ownership, but also for conducting disease investigations. USDA regulations concerning interstate transportation of animals include the registered brand, when accompanied by a certificate of inspection (certificate) from a recognized brand authority, as an official identification device or method for use in existing disease programs. USDA regulations at 9 CFR 71.1 state:

Official identification device or method. A means of officially identifying an animal or group of animals using devices or methods approved by the Administrator, including, but not limited to, official tags, tattoos, and registered brands when accompanied by a certificate of inspection from a recognized brand inspection authority (emphasis added).

Under USDA’s earlier proposed Animal Disease Traceability Framework (ADTF), breeding-aged cattle would bear an ear tag containing a number identifier (such as the low-cost metal “Brite” tag) as a condition for interstate transportation. This proposal would restore traceability to levels previously achieved when breeding females were ear tagged under the brucellosis program. Like the brucellosis tag, the new tag would augment other official devices such as brands or tattoos. This augmentation enhances traceability because while ear tags are prone to loss, brands remain permanent. Brands have facilitated disease investigations throughout history.

Under this breeding-age-cattle-only proposal, interstate transportation of branded feeder cattle accompanied with a certificate would continue as it has for decades. States that identify a disease suspect in branded feeder cattle, regardless of whether the states have their own brand programs, could continue to use the brand and certificates to contact the state where the certificates were issued to identify the herd of origin – just as they have for decades.

But, USDA has now changed its position and plans to delist the brand as an official animal identification device and include feeder cattle in the ADTF. This would discredit the hot-iron brand as a means of identifying cattle in interstate transportation. Here’s why:
1) The brand and accompanying certificates would forever be delisted as an official animal identification device.
2) USDA may well be precluded from requiring permanent brands on imported cattle after brands are delisted.
3) When the trigger for feeder cattle is reached, the brand and accompanying certificates will be delisted, so USDA would need to carve out a special brand exception to allow states to continue using brands to identify cattle, causing the brand to be relegated to a secondary position in relation to USDA’s ear tag.
4) No longer will the numerical ear tag be an augmentation to the more permanent brand, but instead, the ear tag will be deemed a substitute for brands, providing justification for brand opponents such as meat packers that believe hide values would increase, and tag companies that believe sale revenues would increase, without brands.
5) USDA’s act of delisting brands will send an erroneous signal to the industry that brands are of limited use for disease traceback and likely will trigger a de-emphasis for brand programs operating in many states.
6) USDA’s act of delisting brands would be the first step toward the eventual elimination of hot-iron branding in the United States.

Please Download R-CALF Application and send it in. http://www.texaslonghorn.com/emails/R-CALF_Membership_Application.pdf

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