(the following was prepared by Community Farm Alliance)
On August 11th, the Animal and Plant Health Inspection Service (APHIS) issued a proposed rule to improve the traceability of diseased animals. This is the long-awaited follow up to the agencies previous attempt identifying and tracking livestock and poultry that proved to be widely unpopular, the National Animal Identification System (NAIS).
In sum, the new traceability rule would require that all livestock and poultry moving interstate be required to have “an official identification device” (typically an ear tag, though it varies by species) and an interstate certificate of veterinary inspection (ICVI). The rule is designed to be low-tech and low or no-cost. APHIS will leave the design of the systems up to the states.
The Rule: An Overview:
The intent of the rule is “to establish minimum national official identification and documentation requirements for the traceability of livestock moving interstate.” The aim of traceability, as APHIS points out, is not to prevent disease, but to instead be able to locate diseased and at-risk animals and to know where they have been.
While the rule encompasses all poultry and livestock, the focus of the rule is mainly on cattle. The reason for the focus on cattle is because, in the past, APHIS was able to track a considerable amount of cattle through the brucellosis vaccination program, however, the number of calves that are officially identified through that program is down 70% from the late 1980′s due to the success of the program. Other species, such as sheep, are already sufficiently and efficiently tracked through the National Scrapie Eradication Program. Sheep can be tracked within minutes; with cattle, disease investigations for bovine tuberculosis, for example, frequently exceed 150 days.
In the preamble to the rule, APHIS describes the proposed rule as a departure from NAIS. APHIS admits that,
“although there was some support for NAIS, the vast majority of listening session participants and commenters were highly critical of the program and of USDA’s implementation efforts. Many commenters viewed the NAIS as a Government-imposed, ‘one-size-fits-all’ approach to animal traceability. Producers were concerned about various issues, including having their data maintained in a Federal database and the cost of the technology that would be necessary to achieve the 48-hour traceability goal. Overall, the feedback revealed that NAIS had become a barrier to achieving meaningful animal disease traceability in the United States in partnership with America’s producers.”
APHIS’s goal is to “have an adaptable approach that will help us find animals associated with a disease quickly, focus our efforts on those animals, and minimize harm to producers.”
As such, the rule affects only livestock moving interstate. This would seem to preclude any livestock and poultry from being subject to the requirements of the proposed rule that is raised and slaughtered in Kentucky for either personal consumption or direct-to-consumer sales. Livestock, however, that is moved to a custom slaughter facility out of state for personal consumption (and presumably direct market sale) would be exempt. It should be noted though, that poultry moved interstate to live bid markets would not be exempt.
The traceability requirements have two main elements:
1) all animals moved interstate would have to be officially identified. This would typically involve attaching an eartag with a unique official ID number and;
2) animals moved interstate must be accompanied by an interstate certificate of veterinary inspection (ICVI).
It is important to point out that it will be up to the states (and tribes) to develop the systems and methods used to trace animals that move interstate. Dr. Robert Stout, the State Veterinarian for Kentucky, has been tagging all cattle leaving the Blue Grass Stockyards since February of this year. Since then, tens of thousands of cows have been tagged.
The proposed rule would also require that veterinarians keep records on file for a minimum of 5 years regarding the distribution of official identification devices. Livestock facilities would also have to keep for 5 years ICVI documents. The reasons for the lengthy record-keeping time periods is that some animal diseases have a lengthy incubation period (e.g. tuberculosis, bovine spongiform encephalopathy). Such diseases may not manifest themselves until the animal reaches adulthood. The USDA is requesting comments on this aspect of the rule to determine if it is unduly burdensome to either veterinarians or livestock facility managers.
Finally, with regards to cattle, there is a phase in process.
upon the effective date determined by the publication of the final rule, all sexually intact cattle will immediately be subject to the requirements laid out previously. They are a priority because of their longer lifespans.
will begin at a later point in time when 70% of the cattle from the initial phase are tagged and identified, the requirements of the proposed rule would be applied to all classes of cattle moving interstate.
APHIS recognizes that if the second phase is not implemented properly, it could disrupt the management and marketing of cattle. On this second phase, APHIS plans to seek input from its advisory group following an assessment of the workability of the first phase.
- National Farmers Union called it “a step in the right direction for animal disease traceability… that creates a systematic approach to allow for swift response when there are issues.”
- The American Veterinary Medical Association “applauded the release of the proposed rule… affirming its support for a collaborative, transparent and flexible rule for establishing traceability to protect the health of our nation’s herds and flocks.”
- The National Cattleman’s Beef Association (NCBA) commended USDA in a brief statement for working with producers and industry groups on the development of the rule.
- Farm and Ranch Freedom Alliance: FARFA signed onto a joint press release along with R-CALF USA, Food and Water Watch, Western Organization of Resource Councils, and the Cornucopia Institute. In the release immediately following the announcement of the release of the proposed rule, the group writes that, “while the USDA already has traceability requirements as part of existing animal disease control programs, the proposed rule goes much further to require animal tagging and tracing without specific disease threats.” Bill Bullard, CEO or R-CALF, calls it a “one-size-fits-all approach that does not specifically aim at the control of livestock diseases.” Gilles Stockton from WORC stated that the “volume of animal the USDA proposes to track could overwhelm the capabilities of state agencies.” Judith McGreary (who it should be pointed out serves on an advisory board to APHIS) from FARFA stated that feeder cattle do not have to have their records kept for 5 years since they only live for 18-24 months and that this requirement would unnecessarily burden auctions and vets. Food and Water Watch stated that USDA needs to focus on food safety and animal health risks posed by industrialized meat production.
FARFA will be coming out with a more in-depth analysis of the rule by the end of the month.
- R-CALF USA came out with a separate release expressing their opposition to the proposed rule. Chief among their concerns were that brands are not recognized as an official identification. However, and they do admit, the USDA will allow to consenting states that already have pre-existing branding programs to develop a program that would allow them to accept either’s brand as a form of ID. Currently, only 14 states use brands, and APHIS felt that they could not force 36 other states to develop branding programs for the sake of those 14. R-CALF is also particularly incensed by the inclusion of feeder cattle less than 18 months old.
The American Farm Bureau Federation has been mum so far, though state affiliates are beginning to weigh in.