Follow That Beef!

Photo by pseudoplacebo. Some rights reserved.

Late last week the USDA’s Animal and Plant Health Inspection Service (APHIS) announced an extension of the comment period for the proposed rule on animal disease traceability.

What proposed rule on animal disease traceability, you might ask?

The USDA press release explains it so:

Under the proposed rule, unless specifically exempted, livestock moved interstate would have to be officially identified and accompanied by an interstate certificate of veterinary inspection or other documentation, such as owner-shipper statements or brand certificates.  The proposed rule encourages the use of low-cost technology and specifies approved forms of official identification for each species, such as metal eartags for cattle.

Animal disease traceability, or knowing where diseased and at-risk animals are, where they’ve been, and when, is very important to ensure there can be a rapid response when animal disease events take place.  An efficient and accurate animal disease traceability system helps reduce the number of animals involved in an investigation, reduces the time needed to respond, and decreases the cost to producers and the government.

The comment period was extended to “allow interested persons additional time to prepare and submit comments.” However, the earlier comment deadline didn’t stop many interested persons from submitting feedback. On regulations.gov there are already 425 comments on the proposed rule.

Most are from farmers, like Lisa D’Alia, who share a similar sentiment:

“This id tracking regulation for livestock is unnecessary and puts an extreme burden of regulatory intrusion onto the farmer, especially in tour [sic] economic environment today.”

A handwritten and colorful note from Kerry Byme, the owner and operator of Hat Butte Ranch can be almost be deciphered to read:

“Please note that this proposed rule completely disregards U.S. livestock industry input and interests […] Your Gestapo tactics remove choice from our business and is [sic] highly reprehensible.”

At least one (self-identified) “private citizen,” Margaret Boyd, finds the regulation unnecessary:

“It is not needed as proved recently by the outbreak in the Cutting Horse world was traced easily and a country wide voluntary quarantine was handled by private citizens. It worked well as the spread was stopped.”

Another – at first glance – worries how the cost of compliance will affect her grocery bill:

“I am a local foods consumer. I am very concerned that the proposed rule will impose costs on my farmers that will then be passed on to me.”

However, the specifics of her demands suggest she does more than just shop for meat:

“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 the brand as “official identification” among and between all states that currently have official state brand programs and “official supplementary identification” for all other states. Do not impose any new requirements for identifying poultry. There has simply been no showing that imposing new requirements on small-scale poultry operations is needed, while it will definitely cause significant harm. Provide that a physical description qualifies as an official identification method for horses without having to be approved by the health officials in the receiving State or Tribe.”

Funny that another “Local foods consumer,” Jennifer Hascall, had the exact same suggestions. In fact, a search in the comments for the exact (and ostensibly unique) phrase “Provide that a physical description qualifies as an official identification method” returns 81 distinct comments. Comment padding, anyone?

Should you like to offer some truly unique feedback, you now have until December 9, 2011, to do so.

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