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Deal Breakers in USDA’s New Animal Disease Traceability Framework:  Delisting of Brands, Inclusion of Feeder Cattle, Unaddressed Imports of Diseased Cattle

 

March 15, 2011 Billings, Mont. – At the behest of its animal identification committee, R-CALF USA wrote to Agriculture Secretary Tom Vilsack specifically about two of its grave concerns that indicate the U.S. Department of Agriculture (USDA) “has reneged on the very principles you set forth to encourage our participation and support in the ADTF (Animal Disease Traceability Framework) process…and we implore you to exclude from any proposed rule a trigger mechanism to capture feeder cattle under the auspices of a new traceability system and a delisting of the brand as an official animal identification device…” 

R-CALF USA’s first grave concern involves the inclusion in the ADTF of a trigger mechanism that would require feeder cattle, as opposed to breeding cattle, to be subject to the proposed ADTF at some future point in time, after certain operational thresholds have been met in the identification of breeding cattle. 

“We have repeatedly expressed to your agency our willingness to support improvements to our nation’s disease traceback capabilities within our breeding herd,” wrote R-CALF USA CEO Bill Bullard. “In addition, we have expressed our willingness to consider whether there would be even a need to augment our current forms of identification of feeder cattle after improvement to USDA’s disease traceback capability is achieved in breeding cattle. USDA’s plan to include – in the initial proposed rule to implement the ADTF for breeding cattle – a trigger mechanism to include feeder cattle is unacceptable and would force us to work aggressively with all known stakeholders to undo what has so far been accomplished under USDA’s new ADTF.” 

The group’s second grave concern is intrinsically tied to the first, because while R-CALF USA has agreed in principle to augment the use of hot-iron brands on breeding cattle with another form of identification device (i.e., the low cost brucellosis-type ear tag) under certain circumstances, we strenuously oppose USDA’s proposal to delist the brand as an official animal identification device or method.  

“Because a trigger mechanism for feeder cattle is proposed in the ADTF, this delisting of the brand likewise would affect feeder cattle,” Bullard explained. “The delisting of the brand constitutes a broken promise and repudiates the core principles you outlined on Feb. 5, 2010, to encourage organizations like R-CALF USA to participate in the development of a new ADTF… 

“The effect of delisting brands from the current list of official identification devices is to reduce, not maximize, flexibility to producers, as it eliminates from official purview one of the longest standing and most effective means of identifying cattle,” the letter states. “Further, the effect of delisting brands is the opposite of updating or expanding the list of identification devices currently available, as it reduces the number and type of options a producer, State, or Tribal Nation might choose. And worse, delisting brands can be construed as a deliberate, broken promise to producers, as they were led by your agency to believe that brands will be maintained on the list of official identification devices. If this were not true, your agency would not have expressly listed ‘branding’ as among the options available to producers and others.       

“If USDA were to revoke the brand as an official animal identification device, it likely would trigger an immediate de-emphasis of brands throughout the nation and result in the defunding of State programs that currently oversee brand laws,” the letter continues. “Moreover, brands have been successfully and effectively used for decades in conjunction with USDA’s animal disease programs to eradicate and control disease outbreaks. It is not the reduction of branded cattle that USDA cites as justification for its desire to improve animal disease traceback, but rather, it is the reduction in the number of cattle participating in complementary identification systems (e.g., the brucellosis program). There is no justification for USDA’s attack on our nation’s oldest, most permanent, and most effective means of identifying the origin of cattle in interstate commerce.  

“USDA’s about-face on the foregoing two issues rekindles our concern that USDA’s entire effort to implement a new form of animal identification system is driven not by a genuine desire to prevent and control livestock disease outbreaks, but rather, by a desire to conform to international trade standards,” Bullard emphasizes.  

Evidence persists that this is the case. For example, while USDA claims bovine TB is a flagship disease that necessitates improved traceback capabilities for both breeding cattle and feeder cattle, USDA continually refuses to implement any meaningful border interdiction to prevent the continual reintroduction of bovine TB in imported Mexican cattle. USDA’s own data show that during the past seven years (2003 – 2009), an incredible 67 percent of all bovine TB cases detected at U.S. slaughter plants were found in cattle originating from foreign countries, primarily Mexico.             

“Until and unless USDA begins to demonstrate a sincere effort to prevent the continual reintroduction of dangerous livestock diseases like bovine TB from foreign countries by implementing appropriate border restrictions – an action USDA can readily accomplish at no expense to U.S. cattle producers, U.S. cattle producers – and R-CALF USA in particular – have no reason to trust that USDA’s loyalties lie anywhere but with international traders who want the U.S. cattle industry to shoulder the costs of foreign animal disease problems,” he concludes. 

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 46 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

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                            This page was last updated on Wednesday, October 12, 2011.