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Link to share: https://www.westonaprice.org/natl-alert-congress-must-stop-electronic-animal-id-mandate/#gsc.tab=0
Tell Your U.S. Representative to Protect Traditional Forms of Cattle ID
alert from Farm and Ranch Freedom Alliance
When it comes to the Farm Bill, the status quo is what the massive meatpacking corporations want on a lot of fronts, especially mandatory electronic Animal ID. If Congress does nothing, then USDA’s new rule mandating electronic ID for cattle will go into effect later this year – burdening small farmers and undermining our already stretched thin infrastructure of local sale barns and vets willing to work with those farmers.
Mandatory electronic animal identification DOES NOT address food safety or animal disease concerns, but instead, unreasonably burdens farmers and ranchers.
You may have heard that the last omnibus funding bill included electronic ID, which is unfortunately true … but it still hinges on the USDA rule going into effect. So we can still stop it if Congress takes action in the Farm Bill!
We have fought this Big Meatpacker-driven program since 2006 because of the loss of privacy, cost, inefficiency, and the burdens on small-scale farmers and ranchers. We’ve stopped it multiple times before, and we can do so again — with YOUR help!
We urge you to take immediate action and voice your opposition to the USDA’s electronic animal ID mandate.
ACTION TO TAKE
- Call your U.S. Representative: Urge them to include a provision in the Farm Bill that protects farmers’ ability to use traditional forms of ID on their cattle. Calls are most effective, so be sure to follow up by phone. See Talking Points below.
To find your U.S. Representative, enter your street address at https://www.congress.gov/members
- Spread the word: Share this information with your friends, family, and fellow farmers. Encourage them to also call their Congresspeople and voice their opposition to the mandate. Click here to view a video posted by FARFA opposing USDA’s proposed rule.
TALKING POINTS
- USDA has failed to show a need to impose more expensive requirements: Prior to imposing new regulations and costs, an agency should conduct an analysis to determine the need and whether the new requirements actually address that need. Despite numerous requests, the USDA has failed to conduct such an analysis for mandatory electronic animal ID.
- The proposed rule disproportionately harms small farmers and ranchers: Moving to a completely electronic ID system carries significant costs, not only from the cost of the tag itself but also associated infrastructure costs. This impacts not only farmers, but also sales barns and large-animal veterinarians. Large corporate-controlled operations will not only benefit from economies of scale, but could structure their operations to avoid individual ID requirements altogether.
Consider what happened when Michigan implemented mandatory electronic ID for cattle on an intrastate basis in 2007. Over the next five years, the number of very small cattle farms in Michigan declined by 3%, even though nationally the number of such farms increased. And the number of very large cattle farms in Michigan increased by 35%, even though the number of such operations decreased nationally. In other words, in the real-world example of the impact of mandatory electronic ID in this country, the results show that it hurts small farms and increases consolidation. [Note: This data is based on the USDA NASS Agricultural Census of 2007 and 2012.]
- The proposed rule will be ineffective improving animal traceability: Based on USDA’s own analysis, the agency estimates that it will impact only 11% of cattle in the country. Yet an earlier congressional analysis concluded that 18% was too low of a participation rate to make traceability programs effective. [see Summary, “Animal Identification and Traceability: Overview and Issues” (Nov 29, 2010), p. 2 – https://crsreports.congress.gov/product/pdf/R/R40832].
- Mandating electronic ID undermines the goal of promoting a resilient food system: If we want to build resilient, diversified supply chains, the federal government needs to take steps to avoid regulations and policies that are prejudiced against small- and mid-scale producers, such as mandatory electronic Animal ID. The solution is simple: Keep the 2013 Animal Disease Traceability Rule unchanged, allowing farmers and ranchers to identify their animal with traditional, low-tech forms of ID or electronic ID, depending on which works best for their operations.
WAPF will send out future alerts as events warrant.
LINKS
Find My Congress Members –
https://www.congress.gov/members
USDA proposed rule to mandate electronic ID for cattle and bison –
https://www.govinfo.gov/content/pkg/FR-2023-01-19/pdf/2023-00505.pdf
FARFA video opposing the proposed rule –
https://fb.watch/jgl1CweHyP/
“Animal Identification and Traceability: Overview and Issues” (congress.gov) –
https://crsreports.congress.gov/product/pdf/R/R40832
FARFA et al. (2023, April 19). Letter: “Comments on Use of Electronic Identification Eartags as Official Identification in Cattle and Bison”. https://farmandranchfreedom.org/wp-content/uploads/2023/04/Sign-on-letter-opposing-mandatory-electronic-ID-April-2023.pdf
This comes to us from the good folks from the Farm and Ranch Freedom Alliance:
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October 17, 2013
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Take Action of FDA’s Proposed Food Safety Regulations by November 15 Deadline
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| About Us |
FARFA is a national organization that supports independent family farmers and protects a healthy and productive food supply for American consumers. FARFA promotes common sense policies for local, diversified agricultural systems.
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Dear Lisa,
The FDA’s proposed food safety regulations pose significant problems for sustainable farmers, food producers, and food hubs across the country.
Under the proposed regulations, many farmers will be forced to comply with high-cost, industrial-scale regulations, and they will be unable to use traditional, sustainable growing practices. Food hubs and local food businesses will be forced to deal with costly and burdensome paperwork. Ultimately, consumers will face increased food prices and reduced availability of locally and sustainably produced foods.
Below is information on how YOU can help, with sample comments to the FDA and more! For more information on the specifics of the proposed regulations, scroll to the end of the alert or use the Quick Links on the left.
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 TAKE ACTION – Submit Comments to the FDA
Below is a sample letter on the FDA’s proposed rules. Comments must be received by the agency by Friday, November 15, 2013.
To submit comments by mail:
- Use the sample as a starter for your own comments; you can also view the text online (http://bit.ly/FSMA-sample-letter) or you can download a Word version for editing, from http://bit.ly/FSMA-sample-letter-download
- Sign your full name
- Mail to the address shown on the letter below
To submit comments online, go to:
Steps for submitting comments online:
- We recommend that you write your comment ahead of time and save it on your computer — there is a time limit when using the Federal Register System, and you may get timed out if you write your comment from scratch.
- If your comment is less than one page, you can copy and paste it into the comment box. If it is longer, you can instead write “see attached” and UPLOAD a separate document, such as a Word or PDF file, with your comments.
- Uncheck the box that says “I am submitting on behalf of a third party,” so that you do not have to enter an organization name.
- For category, select “individual consumer” or “private industry.”
- Click “continue.”
- Check the box that you have read and understood the statement, and be sure to click “submit comment.” You should be taken to a new screen with a confirmation number.
- Remember that the Tester-Hagan provision is found in both rules, so if you file comments online, be sure to submit them on both rules.
It is very important to personalize your comments! We’ve included some questions in italics in the Sample Letter below, to help you think about some of the comments you can make about the specific impact on you.
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Sample Letter
The italicized portions at the beginning are intended to help you personalize your comments. You don’t have to write a lot – even a couple of sentences can really increase the impact your comments will have!
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
Re: Preventive Controls Rule: FDA-2011-N-0920 and RIN 0910-AG36
Produce Standards Rule: FDA-2011-N-0921, and RIN 0910-AG35
I am a ______ [farmer, food producer, consumer, parent…]. I am deeply concerned about the impact that FDA’s proposed rules under FSMA would have on [my farm, my food business, the farms that I buy food from…].
For consumers, do you make an effort to buy from farms that use sustainable practices? Why do you care about these rules? Just a sentence or two is sufficient to explain.
If you are a farmer, explain your farm practices that would be impacted by the rule. Do you use manure, vermicompost, or compost teas? Do you use surface water or multiple different water sources? Do you do rotational grazing of your livestock with your crops, or use draft horses?
Do you have a CSA that involves more than one farm and would thus be required to do a HARPC plan? Do you do low-risk activities, such as bottling honey, grinding grains, or making jam? Do you have staff who could handle the HARPC paperwork or would you need to hire new people?
For food processors or food hubs, could you absorb the cost of writing a HARPC plan? Do you rely on supplies from farms that would be exempt under the Tester-Hagan provision?
I urge the FDA to address the following issues in the proposed FSMA rules:
Tester-Hagan “qualified exemption” in both the Produce Rule and the Preventive Controls Rule:
- The gross sales test to qualify for the Tester-Hagan provision should be based on sales of food that is subject to FSMA, whether the produce standards or the preventive controls rule. Sales of food that would not be regulated under FSMA should not be included.
- The FDA should not rush the process of revoking a producer’s Tester-Hagan exemption. The agency has other mechanisms it can use if there is an immediate threat of foodborne illness.
a) The FDA should be held to specific evidentiary standards before it can revoke a farmer’s or food facility’s Tester-Hagan exemption.
b) A farm or facility that is exempt under Tester-Hagan should be given at least 90 days to submit evidence and defend its exemption if FDA seeks to revoke it.
c) If the exemption is revoked, the farm or facility should have at least two years to come into compliance with the FSMA rules.
On-Farm Produce Standards Rule:
- The FDA’s approach to traditional farming methods, such as diversified livestock-crop farms, the use of working animals, and the use of biological soil amendments, is fundamentally flawed. The agency should not restrict these sustainable methods of farming without data showing an actual, verified increased rate of foodborne illness; the simple fact that these methods include diverse microbiological communities is not a sound scientific basis for restricting them.
- The waiting period between applying manure and harvesting the crop should be no more than 4 months, and there should be no waiting period between applying compost and harvesting the crop. The excellent track record for safety on organic farms shows that this standard is sufficient.
- Compost teas and other biological inoculants, including normal additives such as molasses, should be treated the same as compost.
- Water testing should not be required more often than once a month, and farmers should be able to test less frequently after establishing the safety of their water source through consecutive negative tests. In addition, farmers should be given the option to test for pathogens, rather than having to treat or stop using the water that tested positive for generic e. coli.
- The provisions on wildlife and domestic livestock need to be clarified to protect farmers who use biologically diverse farming from field inspectors using their discretion to require measures such as fencing or destruction of habitat.
Preventive Controls and HARPC Rule:
- “Very small facilities” should be defined as being under $1 million in total annual sales, adjusted for inflation. Imposing HARPC requirements on businesses smaller than that is unnecessary and overly burdensome.
- Any requirement for “supplier verification” should not prevent a facility from purchasing foods or ingredients from farms and facilities that are exempt from the regulations under the Tester-Hagan provision or other exemptions.
- Low-risk activities conducted by a farm using its own products, such as making jams, grinding grains, or dehydrating vegetables, should not be subject to these regulations.
- Low-risk activities, when conducted off-farm or by multiple farms working together, should not be subject to the same requirements as high-risk processing activities. The requirements should address both the scale of the operations and the level of risk of the activity.
Sincerely,
[Full Name]
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Take Action #2
It is vital that your elected officials know how you feel about your food!
- Find out who represents you by going to www.house.gov and www.senate.gov or by calling the Capitol Switchboard at 202-224-3121.
- Call and ask to speak to the staffer who handles agricultural issues. Explain that you’re a constituent and that high-quality food is very important to you. Ask your Congressman to contact FDA directly on behalf of you and other constituents.
- Get the staffer’s email address and follow up by sending them a copy of your comments to FDA.
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Exemption for Small-Scale Producers Under Threat
Congress included a very important provision in the Food Safety Modernization Act to exempt small-scale, direct-marketing producers. Specifically, under the Tester-Hagan amendment, farmers and food producers who sell less than $500,000 annually, and who sell more than half of their products directly to consumers or local restaurants and retailers, are exempt from the new regulations.
But the FDA’s proposed regulations don’t fulfill the intent of the provision. First, the FDA wants to judge farmers’ sales based on all their sales, not just the food that is subject to FDA regulation. This means that many diversified farmers will be unable to qualify for the exemption, even if they are raising only small amounts of food that is covered by the law.
Second, the FDA wants to be able to revoke farmers’ and producers’ exemptions without respecting basic principles of fairness and due process. As proposed, the regulations:
- Leave too much discretion in the hands of individual FDA officials;
- Do not give small farmers and local food producers enough opportunity to respond to a decision to end their exemption; and
- Do not give small farmers and local food producers enough time to comply with the rules if their exemption is revoked.
In essence, this means that any farmer or producer targeted by the FDA for revocation of its exemption will almost certainly go out of business. The number of producers targeted this way by the FDA is likely to be small, but it will be devastating for those affected. And the uncertainty of not knowing who might be the agency’s next target will have a chilling effect on many small producers.
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Proposed Rule #1: Regulations on How Farms Grow Produce
For farmers who don’t qualify for the Tester-Hagan exemption or whose exemption is revoked, the proposed produce safety regulations cover every aspect of growing and harvesting crops. Overall, the agency has taken a “guilty until proven innocent” approach to many traditional farming practices, forcing farmers to present scientific evidence in order to continue using farming methods that have been used for decades or even centuries.
Biological soil amendments are vital for farmers seeking to grow produce without synthetic chemicals, and they have an excellent track record for safety. But under the proposed regulations, a farmer would have to wait 6 weeks in between applying compost and harvesting the crop, making it much more difficult to use compost in many cases. A farmer using manure would be required to wait 9 months before harvest, effectively making it unusable for many farmers around the country.
FDA goes further and treats all of the following as if they were manure:
- Compost made without specific heating periods (“static compost”);
- Vermicompost or worm castings;
- Compost teas with any additives, even simple molasses or kelp meal;
- Any compost that does not meet the precise methods and testing requirements specified in the rule.
Applying any of these proven, valuable soil amendments would require the farmer to wait 9 months until harvest, essentially making them unusable. The practical effect of the proposed rule is to allow synthetic chemicals to be easily used, while making the use of many natural soil amendments difficult or even impossible for many farmers.
In contrast, the certified organic regulations have no waiting period in between applying compost and harvest, and only a 4-month waiting period between applying manure and harvest. Farmers have operated safely under the certified organic standards for over two decades, yet FDA’s proposed regulations would make it all but impossible for these farmers to continue farming as they have been.
Domestic Livestock and Wildlife
FDA’s proposed regulations also require farmers to take steps to prevent contamination by domestic livestock or wildlife, but they leave out the specifics of what is required to the discretion of the field inspectors. It would be difficult to comply with a strict interpretation of the proposed requirements without taking measures such as fencing animals out and destroying wildlife habitat – essentially a “scorched earth” approach.
The combination of the animal and soil amendment requirements poses significant problems for diversified farms that raise both vegetables and animals. Diversified farms are efficient, both biologically and economically, yet they would be hard-pressed to comply with the proposed rules. At the least, it would be very expensive; in many cases, the farmers simply could not comply without changing their entire approach to farming.
FDA’s proposed rule would require farmers to test their irrigation water every single week if they use a surface water source, such as a river or stock pond. If the water exceeds FDA’s standard for generic e. coli, the farmer would either have to treat it with chemicals or stop using it immediately. Yet generic e. coli is not a pathogen or disease causing organism. In other words, farmers will be forced to spend thousands of dollars testing for something that wouldn’t make a person sick, and then forced to either dump chemicals in the water or somehow find another water source based on these generic tests.
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Proposed Rule #2: Hazard Analysis Plans
FDA’s second rule, on Preventive Controls, deals with anyone who is handling or processing food. For producers who don’t qualify for the Tester-Hagan exemption or whose exemption is revoked, the Preventive Controls rule requires that any business that packs, holds, processes, or manufactures food creates a Hazard Analysis and Risk-based Preventive Control (HARPC) plan.
This encompasses a large number of low-risk activities that farms, food hubs, and cooperative produce distributors normally conduct. All of the following would be subject to the new requirements:
- A farm that dehydrates fruits, makes pickles, or mills grains;
- Two farms running a joint CSA and handling each other’s produce;
- A farm that stores food from any other farm or producer (even if they do no processing);
- All sorts of “food hubs” that distribute food from multiple local producers.
A producer subject to this rule must develop a HARPC plan. Developing such plans can cost thousands of dollars – up to $20,000 – for a small operation in the first year. The rule then requires annual “verification” that the plan is working, with records of this verification process and its findings, at continued significant expense.
The scope and complexity of the paperwork that will be required is daunting for both on-farm and off-farm processors. In the early 1990s, similar HACCP requirements led to many small- and mid-scale slaughterhouses having to shut their doors. The FDA’s proposed rule has the potential to put an end to many of the exciting innovations taking place right now with local food hubs, community processing facilities, and the other infrastructure so vital to re-establishing local food systems.
In addition, while not spelled out in the proposed rule, the references to “source verification” could easily lead to a requirement that all the producer’s sources be similarly regulated. In other words, a food hub or other regulated facility might not be able to purchase food or ingredients from farms and facilities that are exempt from some federal regulations — such as those protected by the Tester-Hagan exemption. The proposed regulation does not explicitly require this, but it does lay the foundation for such a step.
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Support Our Work
Please support FARFA and donate today!
Help us to continue to make sure that the voice of independent agriculture is heard loud and clear. We are very grateful for all that you do, and a donation of any amount will help make a difference.
Thank you!
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Working together, we can make our voices heard.
Sincerely,
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It always happens. I get the newsletter all “done”, send out the email announcements, and then someone sends me something that I think really should go into the newsletter!
So here is a very important email I got from the Farm & Ranch Freedom Alliance. I hope you will all take a moment to call your Representative. I just called Representative Defazio’s office at 800-944-9603 and left a message with the staff person. It only took one or two minutes.
Our Representative in this area (the 4th District) is:
Defazio, Peter – (D)
Washington, DC • 2134 Rayburn Office Building • Washington, DC • 20515 • p: 202.225.6416
Eugene • 405 East 8th Ave. #2030 • Eugene, OR 97401
p: 541.465.6732 • f: 541.465.6458 • Toll Free: 800.944.9603
Website: www.defazio.house.gov
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Call again to protect family farmers, ranchers, and poultry owners from burdensome new Animal ID regulation!
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| Quick Links |
| Find your U.S. RepresentativeMore information on Animal ID |
| About US |
FARFA is a national organization that supports independent family farmers and protects a healthy and productive food supply for American consumers. FARFA promotes common sense policies for local, diversified agricultural systems.
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| Dear Lisa,Please keep up the calls to your Representative to stop the looming animal ID rule! The Appropriations Committee is expected to take up the Agricultural Appropriations bill this Tuesday, June 19, so there’s no time to waste.We know that you get many emails, and we try not to overload you with alerts. With the Farm Bill being debated and the Animal ID regulation close to being issued, though, it’s a very busy time. We appreciate your patience with the multiple emails and, even more, your support of our farmers through your calls!The USDA is on track to issue a final rule on Animal ID this summer and has not indicated that any major changes have been made from the version it proposed last year. That rule as proposed by USDA would subject cattle and poultry owners — includingmany backyard poultry owners — to new tagging and paperwork requirements that could collectively cost millions of dollars, yet the agency has designated the final rule as “not economically significant.”
This animal ID rule is a solution in search of a problem. The USDA has failed to identify the specific problem or disease of concern. Instead, the real focus of the program is helping the export market for the benefit of a handful of large corporations.
The agency has also failed to account for the true cost to private individuals, businesses, and state and federal agencies, creating an unfunded mandate. The new rule will harm rural businesses while wasting taxpayer dollars that could be better spent on the real problems we face in controlling animal disease, food security, and food safety.
Please help protect our farms and our right to own animals by contacting your Representative today! |
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Take Action
Call your U.S. Representative and ask him or her to work to stop funding for the Animal ID rule until and unless the agency addresses the full costs of the proposal.If you don’t know who represents you, you can call the Capitol Switchboard at 202-224-3121 or find out online at www.house.govSAMPLE MESSAGE:Hi, my name is ____ and I am a constituent from (state). I urge Congressman ____ to work to eliminate funding for the USDA’s Animal Traceability rule. The agency has told the Office of Management and Budget (OMB) that the rule is not “economically significant,” but that is simply not true. The rule as proposed by USDA would impose significant costs on independent ranchers, family farmers, backyard poultry owners and livestock businesses.
In a time of economic hardship, it makes no sense to spend our tax dollars on this program when USDA hasn’t even properly evaluated the costs or identified specific, concrete benefits. Please work to eliminate the funding for this unnecessary and burdensome program in the Agricultural Appropriations bill. |
More Information
Although we don’t know for certain what is in the final rule that USDA has sent to the Office of Management and Budget (OMB) for final approval, we do know several things:1) The proposed rule had many problems (discussed more below).2) The USDA has not announced that it has made any major changes to the proposed rule. In fact, in informal statements, the USDA has indicated that the costly provisions for tagging feeder cattle are part of the final rule.3) The USDA has told OMB that the rule is “not economically significant,” putting it on the fast track for final approval without any serious evaluation of the true costs that it will impose.
Facts About the Proposed Rule
We have repeatedly asked USDA for data showing where the problems are in tracking animals currently. Rather than provide that data, USDA hand-picked a few anecdotes, out of the millions of animals in this country. But the agency’s unsupported claims do not justify imposing broad new tracking requirements. Small farms are not the source of most disease problems in this country, yet the proposed rule will burden them unfairly.
POULTRY: Small-scale, pastured, and backyard poultry would be particularly hard hit by the rule as proposed. While the large confinement operations will be able to use “group identification,” the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.
Even if the definition of “group identification” were changed to cover small operations, the result would be new paperwork requirements on almost every person who owns chickens, turkeys, or other poultry. The agency has entirely failed to justify imposing these burdens on poultry owners.
CATTLE: Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on calves and young cattle (“feeder cattle”), even though there’s no evidence that such requirements will help disease control. In addition, veterinarians and sale barns will have to keep records for 5 years, even though many of these cattle will have been consumed years earlier, creating mountains of useless paperwork.
Producers will only be able to use brands or tattoos as identification if their States enter into special agreements. State agencies will have to build extensive database systems to handle all of the data, creating problems for States’ budgets.
HORSES: The proposed rule also requires that horse owners identify their animals before crossing state lines. Although most, if not all, horses that are shipped across state lines are already identified in some fashion, the proposed rule creates a new complication: Whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.
SHEEP, GOATS, and HOG: The proposed rule also covered sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.
You can read the proposed rule at www.aphis.usda.gov/traceability/downloads/2011/Proposed%20Rule.pdf
FOR MORE INFORMATION, go to www.farmandranchfreedom.org/Animal-ID-2011 |
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Support Our Work 
Please support FARFA and donate now! This is a critical time for us to engage legislators and regulators to make sure that the voice of independent agriculture is heard loud and clear. We are very grateful for all that you do, and a donation of any amount will help make a difference.
You can donate online or download our membership form to mail. Thank you! |
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Working together, we can make our voices heard.
Sincerely,
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Judith McGeary
Farm and Ranch Freedom Alliance
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If you are not familiar with this issue please see more information on Animal ID. We have also covered this issue in the past. Please see: New Animal Identification Proposal
This comes to us from the Farm and Ranch Freedom Alliance (FARFA). I met Judith McGeary at the conference in Dallas. She worked tirelessly to stop the National Animal Identification System (NAIS), and continues to work to protect small family farms. Please take a few minutes to write a letter and support FARFA’s work to keep small-scale farms in business.
The deadline for comments is midnight on Friday, December 9!
Dear Lisa,
Small farmers and urban poultry owners alike are threatened by the USDA’s new proposal for animal identification. The agency has proposed a rule that imposes costs and paperwork burdens on farmers, ranchers, backyard poultry owners, sale barns, vets, and state agencies in order to track animals that cross state lines.
The proposed rule is a solution in search of a problem. The USDA has failed to identify the specific problem or disease of concern, and the real focus of the program is helping the export market for the benefit of a handful of large corporations. The agency has also failed to account for the full cost to both private individuals and state governments, creating an unfunded mandate. The new rule will harm rural businesses while wasting taxpayer dollars that could be better spent on the real problems we face in controlling animal disease, food security, and food safety.
Family farmers and ranchers cannot afford additional paperwork and unnecessary expenses. Please help protect our farms and our right to own animals by submitting your comments today — the deadline is midnight on Friday, December 9!
Take Action
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The government’s online system can be difficult to navigate and there is a time limit. We encourage you to write your comments and save them in a document on your computer, then copy and paste them into the online comment form. Also, although only some of the information fields are marked as being “required,” some people have experienced problems when they left fields blank. So for the fields that are not required, you may wish to put “NA” (not applicable) in them to avoid potential problems.
DEADLINE: Friday, December 9, 2011
Please also send a copy of your comments to your Congressman and Senators. If you don’t know who represents you, you can find out at www.house.gov and www.senate.gov
Here are talking points you can use for your comments, followed by sample comments and more detailed information.
TALKING POINTS:
1) The agency should withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the agribusinesses that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.
2) The agency needs to identify the specific diseases of concern and analyze how to best address those diseases – including prevention measures — rather than continuing to push a one-size-fits-all tracking program.
3) At the very least, significant changes need to be made:
* Do not impose any new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
* Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
* Exempt all direct-to-slaughter cattle, both for custom and for retail sales.
* Recognize brands and tattoos as official forms of identification.
SAMPLE COMMENTS: Please personalize these sample comments rather than doing a form letter. The personalization can be just a few sentences at the beginning of the comments, but it does make a significant difference. And if you have time to write more detailed comments, that’s even better!
I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.). I am very concerned that the proposed rule will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me; make it prohibitively expensive for me to order baby chicks from out-of-state hatcheries; etc.)
I urge the USDA to withdraw the proposed rule. If the export market would benefit from the proposed rule, as the agency claims, then the meat packing companies that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system. For disease control, the agency needs to focus on preventative measures rather than after-the-fact tracking.
At the very least, significant changes need to be made:
* Do not impose any new requirements for identifying chickens and other poultry. Small farmers and backyard poultry owners should not be burdened with identifying and tracking birds, and the agency has not shown any need to impose these new requirements.
* Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
* Exempt all direct-to-slaughter cattle, both for custom and for retail sales.
* Recognize brands and tattoos as official forms of identification.
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More Information
The program is fundamentally flawed because it is not designed to address the real problems we face, and it imposes burdens on producers for the benefit of Big Agribusiness’ export markets.
We have asked USDA for data showing where the problems are in tracking animals currently. Rather than provide that data, USDA hand-picked a few anecdotes, out of the millions of animals in this country. But the agency’s unsupported claims do not justify imposing broad new tracking requirements. Small farms are not the source of most disease problems in this country, yet the proposed rule will burden them unfairly.
POULTRY: Small-scale, pastured, and backyard poultry will be particularly hard hit by the proposed rule. While the large confinement operations will be able to use “group identification,” the definition of the term does not cover most independent operations. Since thousands of people order baby chicks from hatcheries in other states, these birds cross state lines the first day of their lives. Even if the farmer or backyard owner never takes the bird across state lines again, they will have to use individually sealed and numbered leg bands on each chicken, turkey, goose, or duck to comply with the language of the proposed rule.
Even if the definition of “group identification” were changed to cover small operations, the result would be new paperwork requirements on almost every person who owns chickens, turkeys, or other poultry. The agency has entirely failed to justify imposing these burdens on poultry owners.
CATTLE: Along with new identification requirements imposed on all breeding-age cattle, the proposed rule would require identification and paperwork on calves and young cattle (“feeder cattle”), even though there’s no evidence that such requirements will help disease control. In addition, veterinarians and sale barns will have to keep records for 5 years, even though many of these cattle will have been consumed years earlier, creating mountains of useless paperwork.
Producers will only be able to use brands or tattoos as identification if their States enter into special agreements. State agencies will have to build extensive database systems to handle all of the data, creating problems for States’ budgets.
HORSES: The proposed rule also requires that horse owners identify their animals before crossing state lines. Although most, if not all, horses that are shipped across state lines are already identified in some fashion, the proposed rule creates a new complication: Whether or not a physical description is sufficient identification will be determined by the health officials in the receiving state, leaving vets and horse owners struggling with significant uncertainty as they have to anticipate what will be allowed.
SHEEP, GOATS, and HOGS: The draft rule also covers sheep, goats, and hogs that cross state lines, essentially federalizing the existing programs which have been adopted state-by-state until now.
You can read the proposed rule at
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Working together, we can make our voices heard.
Sincerely,
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Judith McGeary
Farm and Ranch Freedom Alliance
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Thanks Judith!
Our Senators in Oregon are:
Merkley, Jeff – (D – OR) Class II
313 HART SENATE OFFICE BUILDING WASHINGTON DC 20510
(202) 224-3753
Web Form: www.merkley.senate.gov/contact/
Wyden, Ron – (D – OR) Class III
223 DIRKSEN SENATE OFFICE BUILDING WASHINGTON DC 20510
(202) 224-5244
Web Form: www.wyden.senate.gov/contact/
And our Representive in this area (the 4th District) is:
Defazio, Peter – (D)
Washington, DC • 2134 Rayburn Office Building • Washington, DC • 20515 • p: 202.225.6416
Eugene • 405 East 8th Ave. #2030 • Eugene, OR 97401 • p: 541.465.6732 • f: 541.465.6458 • Toll Free: 800.944.9603
Website: http://www.defazio.house.gov/
You are commenting on Proposed Rule: Traceability for Livestock Moving Interstate (Document ID APHIS-2009-0091-0001).
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