USDA proposal to mandate animal ID slammed

On Friday, R-CALF USA commented on the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service's (APHIS') proposed rule titled Traceability for Livestock Moving Interstate (proposed rule). In its 41-page comment supported by 27 exhibits, R-CALF USA urged USDA-APHIS (APHIS) to immediately withdraw the proposed rule and to, instead, proceed in a cooperative effort with states, tribes and individual livestock producers to develop best practices guidelines. The group states that states and tribes could voluntarily adopt best practices guidelines, in whole or in part, to improve their existing import and export regulations that already address livestock movements into and from their respective jurisdictions.

R-CALF USA described the proposed rule as a “one-size-fits-all solution to an ill-defined problem.” In its rigorous opposition to the mandatory nature of the proposed rule, the group charged APHIS with shirking its responsibilities under the U.S. Animal Health Protection Act, which compels the agency to prevent the introduction and spread of foreign animal diseases.

R-CALF USA contends that because APHIS is not fulfilling its statutory responsibility to impose stricter import standards to prevent the known and continual introduction of foreign animal diseases, “APHIS is a leading cause, if not the leading cause, of livestock disease problems experienced in the United States.”

In support of its allegation, the group listed five instances supported by accompanying exhibits that show, for example, that nearly 72 percent of all bovine tuberculosis (TB) cases detected at U.S. slaughter plants from 2001 through February 2009 were traced to Mexico, and because Mexican cattle infected with TB were found in 12 states, they are a principle source of ongoing TB spread in U.S. livestock.

“APHIS could not be more disingenuous in its claim that the proposed rule is intended to support U.S. cattle producers in their effort to protect their cattle herds from disease when APHIS itself is actively facilitating the introduction of dangerous foreign animal diseases,” the comments state.

R-CALF USA also accuses APHIS of engaging in a deceitful “bait-and-switch” strategy to gain support for its proposed rule.

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

R-CALF USA also attacked APHIS’ cost estimates for the proposed rule and provided evidence to show that APHIS understated the cost of tagging cattle by using a cost estimate generated from a study that involved a state-of-the-art mobile cattle handling facility, which R-CALF USA stated was not typically available to many, if not most, U.S. cattle producers. APHIS’ cost estimate for shrink – weight loss caused by handling cattle – was also refuted on the basis that APHIS allocated only one-fourth of the actual cost of shrink to the cow-calf producers who would bear 100 percent of the cost of shrink.

Using cost data R-CALF USA claims is more accurate than that used by APHIS, the group states the estimated total cost of the proposed rule to U.S. cattle producers ranges from $1.2 billion to $1.9 billion; if only cattle moved to slaughter are considered, R-CALF USA’s cost estimate for the proposed rule is about $920 million; and, if only the 2010 calf crop is considered, the group's cost estimate ranges from $554 million to $880 million.

“There is absolutely no need for a federally mandated animal identification rule,” said R-CALF USA Animal Identification Committee Chair Kenny Fox, adding, “We are extremely disappointed in USDA’s tactic to win support of its ill-conceived proposed rule by using millions of taxpayer dollars to literally wear down industry participants. The industry has told USDA for many years that a government-mandated animal identification system is not appropriate in our United States’ free-market system, but the agency apparently believes it knows better than all the hard working men and women within the industry.

“Because of the horrendous impact this proposed rule would have on U.S. cattle producers, and because all producers need to know the level to which USDA is improperly promoting its proposed rule, R-CALF USA will issue its 41-page comments in separate parts over the next several days. We hope the distribution of our comments in easily readable portions will create a new awareness for the disservice USDA is attempting to cause to our U.S. cattle industry,” Fox concluded.