SDSGA & Guy E. Ham Beef Industry Scholarships
Last updated:
08/13/2008
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God Bless America!
U.S. Congress and USDA
Washington, D.C. 20510
Dear U. S. Senators, U.S. Representatives and USDA Secretary Veneman,
The undersigned organizations share serious concerns about the proposed U.S. Animal Identification Plan (USAIP). We are also troubled by federal legislative and regulatory proposals to accelerate USAIP implementation without first resolving critical problems. Many of our members are farmers and ranchers dedicated to providing safe food, and all of our members are consumers who wish access to safe, healthy food.
We agree it is imperative to maintain consumer confidence in the safety and quality of the U.S. food supply. However, sustaining the economic viability of independent family farmers and ranchers must also be an essential component of any new food safety program. Therefore, we respectfully request you address the following issues prior to implementation of any animal identification system:
1. Any animal identification system must include imported animals and meat products, and provide country of origin labeling for consumers. It must prevent diseased livestock and meat from entering the U.S. food supply. The same identification standards required of our domestic industry must also be required of our trading partners. Livestock should be permanently marked by country of origin before entering the U.S, and any trace-back system must track imported livestock and meat throughout the whole process, up to end users.
The USAIP, however, does not prevent further introduction of BSE in imported meat, nor foreign animal disease to the U.S. food supply. Additionally, the USAIP does not identify foreign animals already in this country.
2. Any animal identification system must coordinate and enhance current animal health and ownership brand identification programs, rather than duplicating and complicating them. While no single comprehensive U.S. animal identification system is presently in place, there are numerous state-run systems overseen by APHIS. They facilitate tracing of individual animals, and could be combined into one system.
The USAIP plan threatens to create an entirely new bureaucracy which would take more time to implement than modifying extant programs. It could pose a major expense for taxpayers, family farmers and ranchers.
3. Additional costs imposed by an animal identification system should not burden family farmers and ranchers, but be financed through the federal government.
The electronic chip system included in the USAIP carries an estimated price tag of nearly $400 million over a five year period. That figure doesn’t include administrative costs, which would be significant.
4. An animal identification system must be carefully managed and implemented by federal agencies in full partnership with state animal health agencies and tribal governments, and should not be an opportunity for profiteering. Food safety is the goal, not funding for special interests.
The USAIP would unsuitably allow livestock commodity organizations and for-profit entities to manage or subcontract animal identification implementation. Commodity groups are scrambling for new funding opportunities because their current check-off dollars are in jeopardy. Many of these groups have a poor record of representing family farmers and ranchers and should not be provided a new money-generating procedure through animal identification.
5. Information collected under any animal identification program should be available only to public health officials for the purposes of tracing an outbreak. Access to this data must be limited to those with a legitimate, food-safety use for the information; and the system must be designed to prevent potential abuse. Privacy firewalls are an essential animal identification program component
The USAIP would collect proprietary information about production practices that could be misused if not strictly controlled. While government agencies must have access to producer-related data regarding livestock, meatpackers and commodity groups need to be screened from access to proprietary information which could be used discriminatorily and would increase corporate control over producers.
6. Livestock producers should not be liable for claims other than those made by agencies authorized to access data in cases of animal health emergencies through an animal identification system.
The USAIP could expose family farmers and ranchers to unwarranted liability. Legal responsibility for food contamination incidents must not be unfairly shifted from packers, processors, and feed and feed supplement suppliers back to farmers and ranchers.
7. No animal identification plan should be imposed before it can be reasonably and cost-effectively implemented with safeguards for both consumers and producers.
An animal identification system must not be rushed.
If the USAIP program as currently designed is implemented, its intricacies and flaws could create a logistical and financial disaster.
In closing, we ask you to design and implement a national animal identification system that maximizes safety for consumers while preventing undue economic burden to family farmers and ranchers. The plan should not expand packers’ ability to unfairly discriminate against farmers, nor shift liability from packers and feed and feed supplement suppliers to producers. The program must also include identification and labeling of imported meats.
We urge you to take the time necessary to insure that both consumers’ and producers’ rights are upheld through this process. Thank you for your attention.
Sincerely,
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