AML Appaloosas

  (Thoreau, New Mexico)
[ Member listing ]

NAIS and your right to Farm

Animal owners, consumers and taxpayers:
NAIS ALERT!
Protect your right to farm and the food supply!

The USDA has proposed a rule to mandate premises registration under the National Animal Identification System (NAIS) for existing disease control programs. The draft rule covers programs for cattle, sheep, goats, and swine, but it sets the stage for the entire NAIS program to be mandated for everyone.

It is critical that the USDA and Congress hear from the hundreds of thousands of people who will be adversely affected by the NAIS program. This includes anyone who owns even one livestock animal (including a single chicken or a horse), as well as consumers who care about local and sustainable foods, taxpayers who object to wasteful government programs, and advocates for a safer food system.

STEP 1: Submit comments to USDA online or by mail. The comments must be received by USDA by March 16, 2009.

You can submit comments online by clicking here. Click on the yellow balloon under “add comments.”

Or mail two copies of your comments to USDA.

Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Clearly state that your comments refer to Docket No. APHIS-2007-0096.

(Sample comments are at the end of this alert.)

STEP 2: Send a copy of your comments to your Congressman and Senators.

You can find who represents you, and their contact information by clicking here

Background

The U.S. Department of Agriculture (USDA) has been working for over five years to force a National Animal Identification System (NAIS) onto American animal owners. NAIS is designed to identify and track each and every individual livestock and poultry animal owned by family farmers, hobby farmers, homesteaders, and pet owners across the country.

USDA claims that NAIS is a disease tracking program, but has refused to provide any support for its claims. In reality, NAIS will:

  • Usurp states’ existing, well-functioning disease response and brand inspection programs;
  • Impose high costs and government surveillance on every farmer and animal owner for no significant benefits.

NAIS does nothing to improve food safety for consumers or prevent animal diseases. This program is a one-size-fits-all program developed by and for big Agribusiness. NAIS will increase consolidation of our food supply in the hands of a few large companies and put the brakes on the growing movement toward regional food systems.

Despite promises to the contrary, the USDA’s new proposed rule would make portions of the NAIS mandatory for thousands of people in every state. This draft rule would mandate the first step – premises registration – for anyone who is involved in a federal disease control program. That includes tuberculosis, brucellosis, scrapie, Johne’s and more. The NAIS Premises Identification Number (PIN) will become the only form of premises identification acceptable for official USDA purposes, with no opt-out provision.

The proposed rule would also limit official Animal Identification Numbers to the NAIS-compliant 840-numbering system, laying the groundwork for future regulations that would limit people’s options on the types of tags they could use.

The proposed rule is not final yet. You can help stop it by visiting the Federal Registry and making a comment, and click on the yellow balloon under “add comments.” Be sure to send a copy of your comments to your elected officials, letting them know how you feel about NAIS.

The grassroots movement has already successfully stalled USDA’s plans for NAIS, which originally called for the entire program - premises registration, animal identification, and tracking - to be mandatory by January 2009. The proposed rule is an opportunity to get thousands of objections in the formal record, and have an even greater impact. It is imperative that people speak up to protect our right to farm and our food supply!

Sample Comments

Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Mail two copies to the address above, or submit comments online by clicking here.

Date: __________

Re: Docket No. APHIS–2007–0096

I urge the USDA to withdraw its proposed rule to implement portions of the National Animal Identification System (NAIS), Docket No. APHIS-2007-0096.

I am a ___________________________________________________________
(State who you are - farmer, consumer, animal owner - and why this issue matters to you.)

The proposed rule mandates the NAIS Premises Identification Number (PIN) as the sole means of identifying properties for official USDA purposes. The proposed rule also mandates the use of the NAIS numbering system (i.e. the “840 numbering system”) for eartags using official animal identification numbers. Tags using other numbering systems would be required to be linked to a NAIS PIN.

The draft rule is seriously flawed for multiple reasons:

  1. Does not substantiate the alleged benefits to animal health. USDA makes general claims about the benefits of identifying locations where animals are kept, but the agency does not address the capacity of existing programs to meet this purpose, nor how the proposed rule actually improves on the current ability to identify locations.
  2. Ignores the costs and burdens. The proposed rule would substantially increase costs, and add intrusive governmental burdens, to the industry and the taxpayer. The costs include the development and maintenance of a massive database; the purchase of 840-numbered tags by animal owners; state agencies having to implement changes to existing programs; and increased federal government intrusion into the lives and daily activities of farmers and other animal owners.
  3. Violation of individuals’ religious beliefs. Amish, Mennonite, and some other individuals have religious objections to the universal numbering system under NAIS.
  4. Creates disincentives for people to seek veterinary care for their animals and participate in existing disease control programs. The proposed rule lists four animal disease programs - tuberculosis, brucellosis, scrapie, and Johne’s - and will impact others. These programs include provisions for veterinary care through vaccinations and testing. Animal owners who object to NAIS, may avoid participating in these programs, thereby increasing health risks to the public and farm operations.
  5. Adds to the confusion. This rule is the latest in a series of ambiguous and often contradictory documents that the USDA has issued on NAIS. This has created enormous confusion over the intent of the USDA and problems for both animal owners and state agencies.

The proposed rule is a significant step towards implementing the entire NAIS program. Thus, the agency should address the fundamental question of whether it should be implementing NAIS at all. In addition to the problems with the draft rule listed above, there are many additional objectionsto the entire NAIS propgram:

  1. No significant benefits: USDA’s assertions that NAIS will provide benefits for animal health are not supported, and actually contradict basic scientific principles.
  2. High costs for animal owners and taxpayers: These costs include: (1) the development, maintenance, and update of massive databases; (2) the costs of tags, most of which will contain microchips; (3) the labor burdens for tagging every animal; (4) the paperwork burdens of reporting routine movements; and (5) the costs of enforcement on millions of individuals.
  3. Impracticality: The databases to register the properties, identify each animal, and record billions of “events” will dwarf any system currently in existence.
  4. Waste of money: The USDA has already spent over $130 million on NAIS implementation, but has yet to develop a workable plan for the program.
  5. Diverts resources from more critical needs such as disease testing, disease prevention through vaccination and improved animal husbandry practices, and disease detection in currently uninspected livestock imports.
  6. Damage to food safety efforts: NAIS will not prevent foodborne illnesses, such as e. coli or salmonella contamination, because the tracking ends at the time of slaughter. Food safety is better served by focusing on programs such as increased testing for bovine spongiform encephalopathy (BSE or “Mad Cow”), improved oversight of slaughterhouses and food processing facilities, and increased inspections of imported food. Programs such as NAIS that burden small, sustainable farmers will hurt efforts to develop safer, decentralized local food systems.
  7. Discourages involvement in farming or animal husbandry: Because of the costs and government intrusion, some people will choose not to stay in farming or go into farming. This will result in less competition, greater reliance in foreign imports, and poor quality at higher prices.

I urge the USDA to withdraw the proposed rule to implement portions of the National Animal Identification System, Docket No. APHIS-2007-0096.

Sincerely,

Name: ___________________________

Address: __________________________

City, State Zip: __________________________

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