In the wake of seven-day-long meetings across the country last year to assess and receive comments on its current Animal Disease Traceability (ADT) regulation, USDA’s Animal and Plant Health Inspection Service (APHIS) received strong pushback over the veracity of its summary of that feedback.
Calling the report “factually inaccurate, unreliable and biased,” the Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF USA) filed a complaint, asking for an agency information correction.
The group noted its request for a correction was based on the fact the report fails to meet minimum quality standards as required by the Data Quality Act. It directed its request for a correction to Secretary of Agriculture Sonny Perdue; USDA Inspector General Phyllis Fong; APHIS Administrator Kevin Shea; and USDA Quality of Information Officer Connie Williams.
Traceability Concerns. The summary out of the APHIS meetings noted four general concerns with the current ADT program. These include: confidentiality and security of information obtained through ADT; producer liability tied to tracing an animal back to its original premises; cost of identification and the need to distribute cost fairly throughout the industry, especially with regards to electronic identification (EID) methods; and the fact that for small producers, costs of the program are proportionally higher. In some direct-sales venues, such as organic sales, it was emphasized custom slaughter facilities are used, and animals are already traceable. Therefore, producers contend, they do not need to be part of a larger, national registry.
As it currently stands, ADT requirements impact beef cattle over 18 months of age and all dairy cattle moved interstate. The meetings addressed how to move beyond the basic traceability framework in place now and close traceability gaps within the industry.
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What is inaccurate about the summary report? The R-CALF USA letter, dated Sept. 27, takes issue with the use of the word “consensus” throughout the report. The group stresses there is no way APHIS can claim comments are a consensus and notes, “the record shows that USDA APHIS obtained no such consensus on the question of whether younger cattle should ever be included under a mandatory animal identification requirement, let alone be included among cattle that must be identified with electronic identification devices”.
Thirty-nine signatories in addition to R-CALF USA submitted comments to USDA APHIS under the Federal Register notice asking to comment on the ADT program earlier in the summer. The groups urged USDA “not to take any steps to adopt new requirements related to animal traceability.” That is part of the basis for questioning a consensus with regards to the report.
R-CALF USA CEO Bill Bullard insists the cross-country meetings were a precursor to APHIS expanding its current ADT rule, moving to “Phase 2, which would include feeder cattle and would require use of EID tags as the only recognized means of identification.”
In addressing APHIS’s reference to gaps in the traceability system, Bullard says those gaps will always exist regardless of the system. “One of the huge gaps we aren’t talking about is the fact that we don’t require imported animals meet the same health standards as our own animals. So, there are always going to be gaps, and that is a disingenuous argument,” he stresses.
EID Premiums. Bullard says he is not against the use of EIDs, and many of R-CALF USA’s 5,000 members use them to obtain market premiums. But, he believes imposing the use of EIDs on the entire industry means, “those tags will no longer have any additional value, and any premium producers are receiving will evaporate.”
The APHIS summary notes cost of EIDs is a concern but adds, “commentators noted that other sectors [aside from cow/calf] would contribute significantly to the cost of the infrastructure for EID, and, as a result, the cost to implement EID would not be borne by the cow/calf sector alone.”
Bullard, when asked if R-CALF USA had received a response to its request for a correction of the summary report, notes it received an acknowledgement the complaint had been received and processed.
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