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
- 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
- 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.