| Subject: Comments needed on USDA mandating NAIS |
Author:
Matt Lhamon
[Edit]
|
Date Posted: 11:46:20 02/08/09 Sun
Comments needed on USDA mandating NAIS
by Karin on Sun Feb 08, 2009 10:41 am
In a rush to implement rules before there was a new administration, USDA published a notice of rulemaking that makes NAIS mandatory for four disease programs. Before you say, "hey this isn't me" realize that if they do it for cattle, goats, sheep, and swine, then poultry (as in NPIP) aren't far behind. It's true they're not talking about microchipping chickens (now) but they have come up with hair-brained ideas like hanging id tags off metal loops threaded through the neck skin of day-old birds. No I am *not* kidding! That was a USDA vet!
It is important to comment on this rule. below is information on how to do that, why, and some sample comments.
Permission to cross-post, forward, print up as flyers and distribute, etc., as written.
consider supporting organizations that really support local independent agriculture: Farm and Ranch Freedom Alliance, Farm to Consumer Defense Fund, and Liberty Ark.
Cheers,
Karin
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Animal owners, consumers and taxpayers:
NAIS ALERT!
Protect your right to farm and the food supply!
The USDA has proposed a rule to mandate premises registration under the National
Animal Identification System (NAIS) for existing disease control programs. The draft rule
covers programs for cattle, sheep, goats, and swine, but it sets the stage for the entire
NAIS program to be mandated for everyone.
It is critical that the USDA and Congress hear from the hundreds of thousands of people
who will be adversely affected by the NAIS program. This includes anyone who owns even
one livestock animal (including a single chicken or a horse), as well as consumers who
care about local and sustainable foods, taxpayers who object to wasteful government
programs, and advocates for a safer food system.
STEP 1: Submit comments to USDA online or by mail. The comments must be received by
USDA by March 16, 2009.
You can submit comments online by going to: http://www.regulations.gov/fdmspublic/c ... l&d=APHIS-
2007-0096.
Click on the yellow balloon under "add comments."
Or mail two copies of your comments to USDA.
Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Clearly state that your comments refer to Docket No. APHIS-2007-0096.
(Sample comments are at the end of this alert.)
STEP 2: Send a copy of your comments to your Congressman and Senators.
You can find who represents you, and their contact information by clicking here
Background
The U.S. Department of Agriculture (USDA) has been working for over five years to force a
National Animal Identification System (NAIS) onto American animal owners. NAIS is
designed to identify and track each and every individual livestock and poultry animal
owned by family farmers, hobby farmers, homesteaders, and pet owners across the
country.
USDA claims that NAIS is a disease tracking program, but has refused to provide any
support for its claims. In reality, NAIS will:
Usurp states' existing, well-functioning disease response and brand inspection programs;
Impose high costs and government surveillance on every farmer and animal owner for no
significant benefits.
NAIS does nothing to improve food safety for consumers or prevent animal diseases. This
program is a one-size-fits-all program developed by and for big Agribusiness. NAIS will
increase consolidation of our food supply in the hands of a few large companies and put
the brakes on the growing movement toward regional food systems.
Despite promises to the contrary, the USDA's new proposed rule would make portions of
the NAIS mandatory for thousands of people in every state. This draft rule would mandate
the first step – premises registration – for anyone who is involved in a federal disease
control program. That includes tuberculosis, brucellosis, scrapie, Johne's and more. The
NAIS Premises Identification Number (PIN) will become the only form of premises
identification acceptable for official USDA purposes, with no opt-out provision.
The proposed rule would also limit official Animal Identification Numbers to the NAIS-
compliant 840-numbering system, laying the groundwork for future regulations that
would limit people's options on the types of tags they could use.
The proposed rule is not final yet. You can help stop it by visiting the Federal Registry and
making a comment, and click on the yellow balloon under "add comments." Be sure to
send a copy of your comments to your elected officials, letting them know how you feel
about NAIS.
The grassroots movement has already successfully stalled USDA's plans for NAIS, which
originally called for the entire program - premises registration, animal identification, and
tracking - to be mandatory by January 2009. The proposed rule is an opportunity to get
thousands of objections in the formal record, and have an even greater impact. It is
imperative that people speak up to protect our right to farm and our food supply!
Sample Comments
Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Mail two copies to the address above, or submit comments online by clicking here.
Date: __________
Re: Docket No. APHIS–2007–0096
I urge the USDA to withdraw its proposed rule to implement portions of the National
Animal Identification System (NAIS), Docket No. APHIS-2007-0096.
I am a __________________________________________________________
(State who you are - farmer, consumer, animal owner - and why this issue matters to you.)
The proposed rule mandates the NAIS Premises Identification Number (PIN) as the sole
means of identifying properties for official USDA purposes. The proposed rule also
mandates the use of the NAIS numbering system (i.e. the "840 numbering system") for
eartags using official animal identification numbers. Tags using other numbering systems
would be required to be linked to a NAIS PIN.
The draft rule is seriously flawed for multiple reasons:
Does not substantiate the alleged benefits to animal health. USDA makes general claims
about the benefits of identifying locations where animals are kept, but the agency does
not address the capacity of existing programs to meet this purpose, nor how the proposed
rule actually improves on the current ability to identify locations.
Ignores the costs and burdens. The proposed rule would substantially increase costs, and
add intrusive governmental burdens, to the industry and the taxpayer. The costs include
the development and maintenance of a massive database; the purchase of 840-numbered
tags by animal owners; state agencies having to implement changes to existing programs;
and increased federal government intrusion into the lives and daily activities of farmers
and other animal owners.
Violation of individuals' religious beliefs. Amish, Mennonite, and some other individuals
have religious objections to the universal numbering system under NAIS.
Creates disincentives for people to seek veterinary care for their animals and participate in
existing disease control programs. The proposed rule lists four animal disease programs -
tuberculosis, brucellosis, scrapie, and Johne's - and will impact others. These programs
include provisions for veterinary care through vaccinations and testing. Animal owners
who object to NAIS, may avoid participating in these programs, thereby increasing health
risks to the public and farm operations.
Adds to the confusion. This rule is the latest in a series of ambiguous and often
contradictory documents that the USDA has issued on NAIS. This has created enormous
confusion over the intent of the USDA and problems for both animal owners and state
agencies.
The proposed rule is a significant step towards implementing the entire NAIS program.
Thus, the agency should address the fundamental question of whether it should be
implementing NAIS at all. In addition to the problems with the draft rule listed above, there
are many additional objectionsto the entire NAIS propgram:
No significant benefits: USDA's assertions that NAIS will provide benefits for animal health
are not supported, and actually contradict basic scientific principles.
High costs for animal owners and taxpayers: These costs include: (1) the development,
maintenance, and update of massive databases; (2) the costs of tags, most of which will
contain microchips; (3) the labor burdens for tagging every animal; (4) the paperwork
burdens of reporting routine movements; and (5) the costs of enforcement on millions of
individuals.
Impracticality: The databases to register the properties, identify each animal, and record
billions of "events" will dwarf any system currently in existence.
Waste of money: The USDA has already spent over $130 million on NAIS implementation,
but has yet to develop a workable plan for the program.
Diverts resources from more critical needs such as disease testing, disease prevention
through vaccination and improved animal husbandry practices, and disease detection in
currently uninspected livestock imports.
Damage to food safety efforts: NAIS will not prevent foodborne illnesses, such as e. coli or
salmonella contamination, because the tracking ends at the time of slaughter. Food safety
is better served by focusing on programs such as increased testing for bovine spongiform
encephalopathy (BSE or "Mad Cow"), improved oversight of slaughterhouses and food
processing facilities, and increased inspections of imported food. Programs such as NAIS
that burden small, sustainable farmers will hurt efforts to develop safer, decentralized
local food systems.
Discourages involvement in farming or animal husbandry: Because of the costs and
government intrusion, some people will choose not to stay in farming or go into farming.
This will result in less competition, greater reliance in foreign imports, and poor quality at
higher prices.
I urge the USDA to withdraw the proposed rule to implement portions of the National
Animal Identification System, Docket No. APHIS-2007-0096.
Sincerely,
Name: ___________________________
Address: __________________________
City, State Zip: __________________________
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