More Thoughts on NAIS from Texas folks....

[Carol Nelson]

This is what local ranchers are saying about the NAIS plan of recording, identifying, and controlling all livestock on all ranches and farms in the country.

"Things like this should tell folks what this NAIS plan is really about..........our money! They've picked on the wrong people! Lots of common sense!

FYI. Here at the Bastrop Texas Extension Service Meeting . A person asked the A&M doctor about the wild hog problem, what were they going to do about them, how were they going to tag them. We have lots of wild hogs.
The Vet replied that wild animals really did not pose a problem because they did not generally mix with domestic livestock. He was just about laughed out of the sales barn.

Wild hogs will come up in your yard and root. I have seen hogs grazing with cattle. A buddy of mine that raises hogs over in Seguin know of instances where wild boars jumped over the hog pen fences and bred the show sows! Can you imagine their faces when a show duroc sow litters and delivers little black wild piglets !

Seems the main disease vector is cash. If they can collect tax monies from owners then they are problem but if they are wild and belong to the state they don't propagate disease. Funny how free-range chickens are a danger but free-range hogs aren't!"

[Jane Hurl]

I'm assuming your NAIS is the same as our CCIP (Canadian Cattle Identification Program) and our CSIP (Canadian Sheep Identification Program), programs in which we MUST participate if any of our cattle or sheep are going to leave our farm ... dead or alive.

It is not a program designed to take money from farmers. It is a program designed to keep disease out of the human food chain, pure and simple.

The reason Canada has been so good at being able to track BSE (aka "Mad Cow Disease") is because CCIP has been in effect for a number of years now. It is not so in the US. When a Mad Cow shows up at a slaughter house down there, it could have lived in half a dozen herds prior to going to slaughter ... so where do you start tracking it to find others that might be infected? And further, because you don't have a decent tracking system (heck, you don't have any tracking system!) it would appear that a blind eye has been turned to cattle with BSE in the last number of years. How safe is that for your food chain? BSE causes something similar in people. It's called Kreitzfeld-Jacob's Disease. Essentially, it eats holes in your brain until, like cattle with BSE, you can't even walk! Steak, anyone?

We now have CSIP for sheep. Why? Because there is an argument to be made that BSE originated in a transfer from sheep infected with the ovine disease called "Scrapie". These sheep were (inadvertently) ground up and used in the protein supplements given to cattle to hurry their growth along. (Don't even get me started on the morality of feeding sheep to cattle! It makes me mental.)

I suspect that we will eventually have a system for pigs and horses being as they, too, enter the human food chain. Frankly, I don't know what we'll do about chickens. I'm sure it's in the works. I've just not heard about it.

You Americans are finally getting on board, and that's a good thing. I think you're doing it more logically than we too. I think we could have done nicely with one system that covered all edible critters, as you are setting up now. I suspect our multiple systems are less cost efficient.

[Mellifluous]

Here is an interesting letter that a lawyer has written about the program - brings up some valid points:

MARY-LOUISE ZANONI
P.O. Box 501
Canton, New York 13617
315-386-3199

Docket No. 05-015-1
Regulatory Analysis and Development
PPD
APHIS
Station 3C71
4700 River Road, Unit 118
Riverdale, MD 20737-1238



Re: Agency Docket Number: 05-015-1

Docket ID: APHIS-2005-0044


Comments on NAIS "Draft Program Standards" and "Draft Strategic Plan"


June 29, 2005


Introduction

I practice law in St. Lawrence County, a leading dairy-producing region of
New York State. I am also the Executive Director of Farm for Life, a
nonprofit group supporting small-scale and sustainable farmers, and
citizens who raise livestock and crops for their own food. (We refer to
this last category as "home farmers.")


I have carefully examined the Draft Program Standards (Standards) and Draft
Strategic Plan (Plan) issued by the USDA (the Department) on April 25,
2005, in furtherance of the Department's proposed National Animal
Identification System (NAIS). Many aspects of the Standards and Plan appear
to create insurmountable legal, fiscal, and logistical problems. The
comments below address five categories of problems: (1) constitutional
infirmities of the proposed program; (2) an enormous economic cost to
animal owners, the States, the Department, and, ultimately, to American
taxpayers and consumers for a program likely to be ineffectual; (3)
weaknesses in the stated rationales for the program; (4) a lack of
consideration of alternative, far cheaper and more easily administered
measures which would more effectively protect animal health and food
security; and (5) a lack of notice and an opportunity to be heard for
medium-scale, small-scale, and home farmers, and for other citizens owning
livestock solely for their own use or pleasure, in the Department's process
thus far.


1. The Standards and Plan Violate Many Provisions of the Constitution.

First Amendment Violations. Many Christians (as well as persons of other
religious beliefs) cannot comply with the Department's proposed program
because it violates their First Amendment right to free exercise. For
example, the Old Order Amish believe they are prohibited from registering
their farms or animals in the proposed program due to, inter alia,
Scriptural prohibitions. The way of life of these devout Christians
requires them to use horses for transportation, support themselves by
simple methods of dairy farming (most ship milk to cheese producers, since
their faith prohibits the use of the technologies required for modern fluid
milk production), and raise animals for the family's own food. The proposed
NAIS would place the Amish and other people of faith in an untenable
position of violating one or another requirement of their most important
beliefs. Further, it is not unlikely that enactment of the NAIS as
presently proposed would force the Amish and other devout people to seek
migration to another nation. It would greatly injure the status of our
country among the community of nations if the Department's actions were to
result in the forced migration of such simple, devout, and peaceful people.


Fourth Amendment Violations. The Department proposes surveillance of every
property where even a single animal of any livestock species is kept; and
to require, at a minimum, the radio-frequency identification tagging of
every animal. (Standards, pp. 3-4, 6, 17-
18.) Perhaps the Department had in mind as its model large commercial
facilities where thousands, or in many cases tens of thousands, of animals
are housed or processed. However, aside from large livestock businesses,
there are also tens of millions of individual American citizens who own a
pet horse, keep a half-dozen laying hens, or raise one steer, pig, or lamb
for their own food. In these instances, the "premises" that the Department
plans to subject to GPS satellite surveillance (Standards, p. 10) and
distance radio-frequency reading (Standards, p. 27) are the homes of these
tens of millions of citizens. The government is not permitted to use
sense-enhancing technologies to invade the privacy of citizens' homes.
Kyllo v. United States, 533 U.S. 27 (2001). The sanctity of the home is
entitled to privacy protection in circumstances where an industrial complex
is not. See Dow Chemical v. United States, 476 U.S. 227, 238 (1986).
Therefore, the Department should abandon its present proposals, insofar as
they entail enormously intrusive surveillance against unsuspecting innocent
citizens who have done nothing more than to own an animal (a common form of
personal property under the American system of law).



Fifth and Fourteenth Amendment Violations. The proposed NAIS is the first
attempt by the federal government at forced registration in a huge,
permanent federal database of individual citizens' real property (the homes
and farms where animals are kept) and personal property (the animals
themselves). (Standards, pp. 8-13; Plan, pp. 8, 12-13.) Indeed, the only
general systems of permanent registration of personal property in the
United States are systems administered by the individual states for two
items that are highly dangerous if misused: motor vehicles and guns. It is
difficult to imagine any acceptable basis for the Department to subject the
owner of a chicken to more intrusive surveillance than the owner of a gun.
For example, whereas the owner of a long gun generally can take the gun and
go hunting beyond the confines of his or her own property without notifying
the government, the Department proposes that the chicken owner, under pain
of unspecified "enforcement," must report within 24 hours any instance of a
chicken leaving or returning to the registered property. (Standards, pp.
13, 18-19, 21; Plan, p. 17.)


Even more important than the trammeling of basic property rights under the
program is the insult to fundamental human rights which must remain free
from government interference. See Lawrence v. Texas, 539 U.S. 558, 565
(2003). These fundamental human rights include decisions about nutrition
and bodily integrity. Cruzan v. Director, Missouri Dept. of Health, 497
U.S. 261 (1990); Rochin v. California, 342 U.S. 165 (1952). Surely it is
overreaching for the Department to propose, as it has, the constant
surveillance of one's home and animals when the citizen is only attempting
to raise food for the household or for a limited local area, and there is
no intention of distributing the food on a wider scale.



The foregoing numerous constitutional infirmities are bound to enmesh the
Department and state governments in extremely costly litigation for years
to come. Therefore, please reconsider the Department's plans to institute a
program so at odds with fundamental American values.


2. Practical and Cost Impediments to Enforcement.

As discussed more fully below (see no. 5, Lack of Notice), most owners of a
small number of livestock are not even aware of the USDA's proposals at
present (see, e.g., "Helping to Head Off A Livestock I.D. Crisis,"
Lancaster Farming, May 28, 2005, p. A38, discussing difficulties of
informing all farmers of the NAIS requirements). The Department does not
plan to issue "alerts" to inform livestock owners of the requirements until
April 2007, only eight months prior to the date when it will be mandatory
to submit the GPS coordinates of one's home and the RFID of one's animal to
the USDA database. The final rule governing mandatory home and animal
surveillance will not be published until "fall 2007" (Plan, p. 10), leaving
only a couple of months, at best, for notification and compliance before
January 2008. The citizens apt to own small numbers of livestock are rural
dwellers who have chosen their way of life partly as a means of escaping
excessive corporate and government bureaucracy. These factors suggest the
likelihood of a noncompliance problem of heroic proportions. In addition,
the proposals call for an animal owner to report, within 24 hours, any
missing animal, any missing tag, the sale of an animal, the death of an
animal, the slaughter of an animal, the purchase of an animal, the movement
of an animal off the farm or homestead, the movement of an animal onto the
farm or homestead. (Standards, pp. 13, 18-19, 21.) The Department plans to
demand the following actions by all animal owners according to the stated
timeline: "January 2008: All premises registered with enforcement
(regardless of livestock movements). . . . January 2008: Animal
identification required with enforcement. . . . January 2009: Enforcement
for the reporting of animal movements." (Plan, p. 17; emphasis added.)
Moreover, the NAIS will "prohibit any person" from removing an I.D. device,
causing the removal of an I.D. device, applying a second I.D. device,
altering an I.D. device to change its number, altering an I.D. device to
make its number unreadable, selling or providing an unauthorized I.D.
device, and "manufacturing, selling, or providing an identification device
that so closely resembles an approved device that it is likely to be
mistaken for official identification." (Standards, p. 7.)



Thousands of enforcement agents would have to be employed to find the
potentially tens of millions of unregistered premises and violations of the
animal identification and animal tracking requirements. Indeed, beyond the
expense, the spectre of these government agents entering onto citizens'
property to find possible unregistered homes and animals brings to mind the
actions of a frightening police state, not the actions of a government
agency whose mission should be to assist rural people, not to hunt them
down.



The proposed NAIS makes clear that animal owners will have to pay the costs
of registration and surveillance of their homes, farms, and livestock.
("[T]here will be costs to producers," Plan, p. 11; "private funding will
be required. . . . Producers will identify their animals and provide
necessary records to the databases. . . . All groups will need to provide
labor . . .", Plan, p. 14.) In fact, the financial and labor requirements
for animal owners would be huge. Livestock owners, even the owner of one
pet horse who takes rides off the property, would have to invest in RFID
reading devices and software to report information. The Standards and Plan
do not enlighten us about the amount of these costs. Many rural people do
not have (and do not want) computers at home and even those who have them
often cannot get high-speed connections. Even if some system of written or
manual reporting were allowed as an alternative, this would only greatly
increase the labor required for citizens who elected it. Indeed, with or
without access to technology, the labor requirement would be huge.



Consider a small-to-moderate size dairy, milking 160 head. A total of about
150 cattle (75 bull calves, 50 cull cows, and 25 excess heifers) would
leave such a farm each year. The farmer would be required to report each
tagging of an animal and each event of an animal shipped off the farm (300
reportable events). Plus let's assume that the farmer has 50 growing
heifers outside during pasture season, and, as heifers are prone to do,
they breach the fence and go off into the neighbor's fields twice during
the season, and the farmer has to herd them back. This results in an
additional 250 reportable events 50 instances of heifers having to be
tagged (strictly speaking, the rules would require tagging before they
leave the farm -- Plan, p. 8 -- one hopes the enforcement agents might
overlook the technical violation of the farmer perhaps not being able to
tag them until they are herded back), plus 100 instances of individual
heifers leaving the farm, and 100 instances of individual heifers returning
to the farm. The farmer now has at least 550 total reportable events, or an
average of over 1.5 times per day, 365 days per year, that the farmer must
interrupt his or her other work and submit data on premises identification,
animal identification, and an event code to the USDA's database. Further,
the animals shipped from this farm would generate at least an additional
600 reportable events per year for other stakeholders (i.e., 75 bull calves
into and out of the auction house, then onto a veal farm, off the veal
farm, and to a slaughter facility (375 events); 50 cull cows into and out
of the auction house, then to a slaughter facility (150 events); and 25
heifers into and out of the auction house, then onto new farms (75 events).
Thus, only one modest-sized farm would generate well over a thousand events
per year requiring recordkeeping and reporting.



Indeed, the only economic advantage of the NAIS is an advantage to the
corporations that manufacture high-tech tags, ID equipment, and the vast
amount of hardware and software required for the system. This "advantage"
is totally outweighed by the economic costs to both large and small
segments of the livestock industry and the social and civil-rights costs to
small producers, home farmers, and non-farming animal owners. The
Department's mission should be to protect and foster agriculture, not to
protect and foster manufacturers of tagging and computing equipment.



3. Infirmities in Supposed Justifications.

The primary justifications given by the Department for the NAIS are animal
health issues, specifically, foot-and-mouth disease (FMD) and bovine
spongiform encephalopathy (BSE). (Plan, p. 1.)



There has been no FMD in the United States for over 70 years and the
possibility of its reintroduction is speculative. Of course, FMD is a viral
disease exclusively of cloven-hoofed animals and does not infect humans.
Moreover, FMD is primarily an economic disease. Animals may become
temporarily lame or refuse to eat because of the lesions caused by the
virus, but nearly all animals recover within a few weeks. Thus, the primary
effects are a setback in weight gain for animals produced for meat, reduced
lactation in dairy animals, and restrictions on exports for countries where
FMD is present. NAIS proponents need to carefully consider whether a
disease of no risk to humans, not present in the United States, and only of
temporary effect to animals, can possibly justify a gravely flawed system
such as the proposed NAIS.



There have been only two known cases of BSE in the United States. There
have been no cases of humans contracting, while within the United States,
the related condition of variant Creutzfeldt-Jakob disease. The Department
has put into place all necessary safeguards and assures that the American
beef supply is safe and that transmission of BSE prions to humans cannot
now occur in the United States. After the banning of meat and bone meal
from ruminant feeds in 1997, any possible instances of BSE would now occur
only in relatively old cattle. Obviously, the number of such cattle
diminishes yearly and even assuming the longest potential lifespan of
cattle, any slight possibility of BSE in the U.S. cattle herd will
disappear in about 12 to 15 years. Thus, BSE is a very low-incidence,
self-limiting, rapidly disappearing disease in the United States. BSE has
not resulted in transmission of a single case of human disease in the
United States. BSE is, rather than a health threat, primarily an economic
problem affecting exports and imports of cattle and beef. It is apparent
that the Department's position that sufficient controls are in place is
correct. Thus, as with FMD, BSE cannot justify the creation of a huge,
permanent, expensive, and intrusive NAIS.



A further asserted justification is the risk of "an intentional
introduction of an animal disease." (Plan, p. 7.) Far from preventing
deliberate interference with the livestock industry or food supply, the
proposed plan creates numerous new opportunities for mayhem. The
Department's own proposals suggest that the counterfeiting and theft of
tags will quickly become a problem. (Standards, p. 7.) Application of
counterfeit tags could easily mask the introduction of a sick animal into a
facility containing thousands or tens of thousands of other animals.
Consider also the scenario in which someone brings a sick animal to a
slaughter facility and falsely reports its farm of origin as a large
operation with tens of thousands of animals in production. The resulting
baseless scare has the potential to create a huge disruption of food
supplies and the profitability of animal agriculture, regardless of whether
the hoax might ultimately be discovered.



4. Lack of Consideration of Alternate Methods.


As discussed above, the NAIS is a violation of civil rights, extremely
expensive and burdensome, likely to be ineffective, and not justified by
human health, animal health, or food safety considerations. Given these
numerous and probably insurmountable flaws, the Department should carefully
consider alternative methods that would be much more successful in
accomplishing the stated objectives.


The security of America's food supply and the resilience of livestock in
the face of diseases are best served by the decentralization and dispersal
of food production and processing, and of the breeding and maintaining of
livestock. If more citizens could depend on food raised and processed
within, say, 100 miles of their homes, the danger of large-scale
disruptions would be minimized, the costs of transport would be less
affected by volatile fuel prices, and any food-borne diseases that might
occur would be contained by the natural geographic limits of the system.
Similarly, if animals, such as cattle, for example, are kept in small herds
of, say, ten to a hundred animals, infectious diseases will have much more
difficulty in spreading beyond a discrete geographical area. In this
regard, the NAIS would actually be counterproductive, since it would tend
to drive more small producers and small processors out of business. Thus,
the Department should consider an approach and programs to support and
promote smaller, local herds and local food processing.


Smaller herds would also entail the possibility of many more closed herds
than our agricultural model supports at present. Especially in dairy
operations, where artificial insemination is the norm, only modest
government incentives would be necessary to encourage small and medium
sized producers to maintain closed herds. In the case of beef cattle, and
of other species not commonly using AI, a state-
level program requiring vet checks and recordkeeping for new animals
introduced to herds would be obviously far simpler, as well as more
effective, than the proposed NAIS.


Another contribution the Department could make to food safety and animal
health at low cost would be the encouragement of integrated
producer/processor operations. Despite economic and marketing forces that
are stacked against them, many small producers throughout the United States
still process and market their own dairy products, or raise meat that is
processed on site or at small local slaughterhouses and distributed
directly to consumers or to local retail outlets. Consumers love not only
the high quality of such products, but also the assurance that comes from
actually knowing the farmers who, for example, finish their steers on grass
and have the butchering done at a local small business. Very modest
programs of financial incentives and encouragements to the streamlining of
federal and state permitting procedures would help this hopeful segment of
our nation's agriculture to flourish.



Many recent developments in the agricultural sciences have demonstrated
time and again that the least-cost and least intrusive method is the most
effective and protective of health. For example, leading-edge research now
rejects the routine deworming of all cattle and sheep, in favor of
eliminating parasite-susceptible individuals as breeding stock. The
once-heralded approach of routine deworming, it turns out, only resulted in
resistant super-parasites and perpetuation in the gene pool of animal
families naturally subject to the largest infestations. Similarly, in
recent years our thinking has done an about-face on the subject of routine
use of antibiotics in the feed of beef steers and dairy heifers, and in
udder infusions for dry dairy cows who exhibit no clinical mastitis. Once
heralded as a means of increasing weight gain and providing extra insurance
against fresh-cow mastitis, those routine uses of antibiotics in healthy
animals are now rejected because they are known to produce resistant
super-bacteria that may cause not only animal infections, but human
infections. Unfortunately, it takes years for knowledge gained in the
latest research to reach the farmer, and the inappropriate overuse of
anthelmintics and antibiotics is still very common. Thus, another low-
cost and simple initiative the Department could undertake would be an
intensive educational initiative to end the inappropriate use of drugs in
animal agriculture.


The foregoing are just a few of the many possible more effective
animal-health and food-safety initiatives to which the Department could
devote its finite resources. It is appropriate for the Department to study
fully these alternatives before concluding that a bloated NAIS bureaucracy
is our only alternative.


5. Lack of Notice and an Opportunity to be Heard for Small Farmers and
Animal Owners.


The original impetus for a nationwide animal I.D. program came from a
private membership group, the National Institute for Animal Agriculture
(NIAA). (Plan, pp. 1, 4.) The members of the NIAA include such well-known
industry entities as Cargill Meat Solutions, Monsanto Company,
Schering-Plough, and the National Pork Producers Council. Further, of those
NIAA members listed as "National Associations and Commercial
Organizations," nearly 25% appear to be manufacturers and marketers of
identification technology systems. (animalagriculture.org/aboutNIAA/members/

memberdirectory.asp). In April 2002, the NIAA "initiated meetings that led
to the development of" the NAIS. (Plan, p. 1.) The NIAA "established a task
force to provide leadership in creating an animal identification plan."
(Plan, p. 4.) The NIAA already had been promoting animal I.D. for months
before the Department, through APHIS, became involved in the effort.
Moreover, the Department says that "[t]he development of [the Draft Program
Standards] was facilitated by significant industry feedback." (Standards,
p. 1.) Essentially, a private group has dominated animal I.D. thinking and
has dictated the NAIS plan now being proposed by the Department.



Moreover, the Department asserts a "broad support for NAIS" (Plan, p. 1)
when there is no such support. The Department says that it conducted
"listening sessions" for six months (June-November 2004) on NAIS. However,
only 60 comments were apparently made during these six months of sessions.
If the Department had made a truly widespread attempt to determine
citizens' views on animal I.D., surely it would have received far more than
60 comments on an issue that affects tens of millions of Americans.


The Department relies upon the NIAA's survey of itself as supposed evidence
of public support. (Plan, p. 7.) The Department quotes responses from the
survey and cites animalagriculture.org/survey/NAIS.htm as its source. (Id.)
However, when one visits that page, one finds a statement by the NIAA that
the survey is not scientific, that the survey's results are intended for
use by NIAA members only, and that any reproduction of the survey is
prohibited. Thus, the Department is presenting as "evidence" a private,
unscientific report that the public is forbidden to quote in opposition. To
correct this gross violation of normal agency procedure, the Department
must immediately publish this entire NIAA survey in the docket and issue a
press release specifying that the public is permitted to use the survey
freely in studying the relationship of the NIAA to the genesis of the NAIS.
This is not only a spurious example of "public support" but an
affirmatively misleading rationale for a mandatory NAIS. It tells us
nothing about truly public support to say that the NIAA, an organization of
the largest livestock businesses and manufacturers of identification
equipment, considers mandatory I.D. to be good for its own private
interests.


One further troubling instance of the failure to consider the needs of the
larger public deserves mention. The NIAA lists as public institutional
members some state departments of agriculture and animal health
commissions. These include representatives of several states with
significant populations of members of plain faiths, e.g., Pennsylvania, New
York, Ohio, Indiana, Michigan, Wisconsin, Missouri, Iowa. Yet it appears no
consideration whatsoever was given to the fact that the NAIS as proposed
would violate the right of these citizens to practice their religion
without government hindrance. Thus, the NAIS is not the result of any true
consensus or concern for the welfare of the citizenry as a whole. Rather,
the NAIS is the predictable result of allowing a small coterie of
financially-
interested "stakeholders" to create the agenda for animal identification.



Conclusion


The NAIS proposals as embodied in the Standards and Plan are unworkable
because of economic costs, the huge burdens of reporting, and enormous and
needless complexity. Their justifications based on animal diseases and food
safety would not be served but in fact would be harmed by the NAIS. The
Department has failed to consider numerous alternative methods that might
actually further animal health and food security without the vast problems
of the proposed NAIS. The Department has limited any input on the NAIS
chiefly to a small group of parties with a preexisting bias toward
mandatory animal ID; the Department did not make its plans known to small
farming interest groups and did not seek any input from such groups. Last,
and first, the most fatal flaw of the proposed NAIS is its disregard for
fundamental human rights enshrined in our Constitution: the right to
religious freedom, the right of property ownership, the right of privacy.



Not since Prohibition has any government agency attempted to enshrine in
law a system which so thoroughly stigmatizes and burdens common, everyday
behavior and is so certain to meet with huge resistance from the citizens
it unjustly targets. Therefore, the Department should: (1) withdraw the
present Standards and Plan as failing to embody a fair or workable system;
(2) reconsider whether, particularly in light of the present effective
measures against BSE, any animal I.D. scheme is warranted at present; (3)
consider implementing the low cost and easily undertaken measures that
would more effectively protect animal health, human health, and the food
supply; (4) review its procedures for development of programs such as NAIS
to correct the limitation of input to self-selected groups and the failure
to notify the vast majority of affected parties; and (5) institute
procedures to assure that, in the future, proposed programs will not be
permitted to threaten the constitutional rights of citizens.


Very truly yours,


Mary-Louise Zanoni

[Jane Hurl]

I didn't even read to the end of the first item (constitutional).

You know, in every law class somebody has to graduate at the bottom of the class. It is obvious to me that this person was that individual in her class.

To suggest that tracking animals that are classified as livestock is the same as putting unneccessary surveillance into the homes of law abiding farmers is plain ridiculous. First off ... what are those people doing ... keeping their livestock in the house? *eyes rolling*

Prior to that bit of stupidity, that lawyer (and I use the term loosely here) commented on how this would put the Amish in an untenable position with respect to their religion ... and stating that they only raise food for themselves and for people in their immediate area ... not the nation at large. So just how far from the farm do you have to live before getting Kreitzveld-Jacob Disease counts?

And finally, I skipped ahead and read what she had to say about BSE ... that it's a "disappearing disease". Well, that may or may not be so ... because there are people out there who are feeding chicken feed to their cattle! (No, don't ask me why. It makes no sense to me, but one of the BSE cattle found up here was due to that very thing.) And further, does this idiot lawyer think that BSE is the only disease that cattle can or will in the future get that could threaten your nation's people ... or the people of the world if you're exporting?

Jeez, Louise! No, make that "Jeez, Mary-Louise"! *eyes rolling*

Now that I've ranted, I think I'll go back and read the rest of her epistle ... though I don't think I'll be very impressed with it, considering those parts that I've read already.

[Jane Hurl]

Okay ... read the whole durn thing.

Only one comment: Pfft! She's a powder puff who is blowing the "invasion of privacy" think waaaay out of proportion and is blatantly overstating the inconvenience and cost to the producers.

Actually, she's blowing everything out of proportion and most of what she proposes doesn't make any sense whatsoever ... especially the bit about proposing smaller farms and ranches rather than larger conglomerates. First off, that just ain't gonna happen! The price of your beef would go through the roof ... and secondly, it would make your food safety less secure than ever! That is what government meat inspectors are for -- and they don't grow on trees! You can't have one at every little Mom and Pop abbatoir!

But that's more than just one comment, eh? *grin*

In closing, I think that you will find yourselves not welcome on the international food trading field if you don't have some way of tracking your critters. (The only reason you allowed us to reintroduce Canadian beef to the US was because of our superior ability to a. track cattle and b. discover BSE before it hit the food chain -- and we could not have done that without CCIP!)

[Cindy]

To suggest that tracking animals that are classified as livestock is the same as putting unneccessary surveillance into the homes of law abiding farmers is plain ridiculous. First off ... what are those people doing ... keeping their livestock in the house? *eyes rolling

Actually, yes, these regulations would pertain not only to animals raised for food but all animals in the categories that are included. For example, if you have a pet bird, you will be subject to the same regulations for that bird as a chicken farm is for it's birds. It does in fact boil down to money as they could find much better ways to track animals that are raised for food than what they have come up with which will affect pretty much everyone who owns an animal that is not a dog or a cat. And that will most likely be the next step.

I do agree with some of her points being somewhat ridiculous though. But the proposal as it stands is ridiculous also.

[Mellifluous]

Here is an angle that I had not considered - is it a little to "conspiracy theory" for you guys!

I am having fun reading all of the comments about this program from assorted sites.

Last night as I was going over the figures I pulled from the Horse Council site, the light suddenly went on in my old, damaged brain as to why equines were included in this stupid Plan.

Look at the overall numbers involved in the US. Guess who's going to pay the bill for the whole shebang. Not the cattle industry who get's to have "herd" id's instead of individuals id's unless your a little guy. Horse owners are going to be the one's footing the bills.

Here are the numbers involved by activity in the US

Racing 844,531
Showing 2,718,954
Recreation 3,806,923
Other 1,752,429

Say it's $15 to register your property, $15 for each horse registered, $15 for each id "tag", $150 for the reader, $50 for the software, $40 farm call from the vet plus $5 for each horse he "tags" - like me, you own 23 - $1,060. Put's a dent in the horse budget for most people.

9.2 million horses in the US - $138 miillion just for the horses being registered. Easy money.

Since they have not given us much in the way of information, my figures are just approximates. You guys that already have this in place in your home state do the math and let us know what you come up with please.

This whole Plan was supposed to be designed to keep the US food chain safe, which is a good thing. We don't eat horses in this country - or camels or llamas or donkeys or mules.............but they sure know where to get the funding from.

If we don't get off our collective butts, we are screwed and have no one to blame but ourselves.

[Jane Hurl]

Yep, a little too "conspiracy theory" for me ... but then I'm Canadian and we don't (for the most part) run around looking for conspiracies!

The bottom line is: horses ARE eaten in the US of A. Not by many, but they ARE eaten. (Remember the big Samoan that CarolU spoke of? The guy going around the countryside looking to buy a horse ... any horse?) And they are sold to foreign countries for eating as well.

As for pet parakeets: only two words -- avian flu.

It is not a conspiracy, people! It is a plan to try to keep you and your critters safe -- pure and simple! Sheesh! (You have no idea how fanatical the American gun-under-every-pillow-and-conspiracy-behind-every-door thing sounds to the rest of the world!)

Now, having said that, I don't know the particulars of your NAIS plan. Maybe it IS flawed ... but the IDEA of the plan is not.

[CarolU]

You know I have real mixed feelings about this law. I do agree that trying to say any of it damages a Constitutional "right" is pushing it... :roll: Every farm already is catalogued, registered with the County Clerk, taxed, as are the 'livestock' on the farm. Even the Amish have to pay taxes.

The costs in Mel's second post are scary...it is not JUST the initial cost of getting all the animals microchipped, it is paying for all the readers everywhere and then the 'fees' to have your horse read in/out of every activity. The person is right, according to the law as proposed, you can register groups (herds, flocks, coops, pens) of mass-produced animals. The big guys WON'T pay a lot for this. The little mom/pop guys will. Most of them already tag their cattle...they just don't track them which WILL cost plenty.

I am sure those "FEES" are looming large in a lot of governments thinking they can MAKE money on this law.

Then there is the plus side. If a horse came down with something contagious at a show - even say Strangles - it would be VERY easy to track down all the animals that were there and quarenteen them. The plus side could save a lot of other animals and their owners.

It is not an easy delima, one way or the other...

Yep Jane...the Tongans and Somoans both eat ponies and horses here all the time. They passed a law though, they can't eat dogs and cats anymore.

[Moniece Dickerson]

I am with Carol U on this.Very mixed feelings about it.Moniece

[Jane Hurl]

Admittedly, I know nothing of the system that is being set up down there ... but I'm well aware of the one up here. That knowledge leads me to ask: why will every Mom and Pop farm have to purchase an expensive tag reader and software? To me, that sounds like a scare tactic. Why won't they be able to simply write down the tag numbers of their animals (as we do) and keep a written log of what leaves the ranch and what comes (new critters) to the ranch?

And, as to the "surveillance", it's not like there's a camera in the tag! Big Brother can't see what you're doing in your house or on your property! The GPS thing is something that isn't up here (yet?), but there are chip readers. Ranchers don't own them though. They have no need for them. They already know the numbers on their critters. Slaughter houses use them, as do auction rings and veterinarians etc.[/i]

[Jasfino]

I like what the law is trying to accomplish.. tracking the animals so our food chain will be protected. I am not sure I like the system.

The little guys always pay the price.. while the government in turn takes care of the big guys. Speaking of chickens, the government cant even keep track of the illegal workers the big corporations bring in in order to keep their profits high. This sort of thing is overlooked though for awhile, until another terrorist sneaks in with a biological disease that wipes out more than our food chain. It is a widespread problem that the government needs to be addressing better. Maybe this is the start of their plan of hightened security. We need to start with our borders.

[Tami Pinell]

If you go back to basic thinking and sift through all the legal jargon.... it boils down to money. If our governement came out and said "hey, I'm going to charge each and every person X amount of dollar to cover stuff we have done and then give a cut to a good friend of mine that has Y company." ; we would go ape.... what better way to get most people to "willingly" give money.... tell them it is for their own good. Show them some overly simple way that it may remotely help and let them fight each other over it. The masses of people in this country are not in Ag, they do not live on farms, and they buy EVERYTHING out of a store...... now if we go to vote, who do you think will win?
I bet if we could get every person with an animal in the US to put this little tag on the critter, it would create a million jobs and we could charge them 250% of the cost......
Not much different from - I bet we could change our clocks twice a year and mess up everyones time and get them to do it just cause we say they will not have school kids run over in the dark......
If you stop to think about WHO is REALLY going to benefit from this you will find that it will not be YOU (unless you work for the department that is pushing this or you own stock in the chip company).... I would like for someone to tell me HOW am I going to benefit from this program when I am raising a rabbit from birth to death and stuffing that guy in my oven? I also want you to tell me WHO is going to benefit and HOW by me tagging that same dead bunny. I like parts of the "idea" but to me it is still an "idea".... it needs a LOT of tweeking..... like the part where I read a cattle ranch could be exempt from indiviual tagging due to the "volume"..... well, hello - that is the one that needs to look and ID EACH cow.... they raise them as "food" - the Dexter pet next door will never see the kitchen stove in anyway.....

[Mellifluous]

If you go back to basic thinking and sift through all the legal jargon.... it boils down to money. If our governement came out and said "hey, I'm going to charge each and every person X amount of dollar to cover stuff we have done and then give a cut to a good friend of mine that has Y company." ; we would go ape.... what better way to get most people to "willingly" give money.... tell them it is for their own good. Show them some overly simple way that it may remotely help and let them fight each other over it. The masses of people in this country are not in Ag, they do not live on farms, and they buy EVERYTHING out of a store...... now if we go to vote, who do you think will win?
I bet if we could get every person with an animal in the US to put this little tag on the critter, it would create a million jobs and we could charge them 250% of the cost......
Not much different from - I bet we could change our clocks twice a year and mess up everyones time and get them to do it just cause we say they will not have school kids run over in the dark......
If you stop to think about WHO is REALLY going to benefit from this you will find that it will not be YOU (unless you work for the department that is pushing this or you own stock in the chip company).... I would like for someone to tell me HOW am I going to benefit from this program when I am raising a rabbit from birth to death and stuffing that guy in my oven? I also want you to tell me WHO is going to benefit and HOW by me tagging that same dead bunny. I like parts of the "idea" but to me it is still an "idea".... it needs a LOT of tweeking..... like the part where I read a cattle ranch could be exempt from indiviual tagging due to the "volume"..... well, hello - that is the one that needs to look and ID EACH cow.... they raise them as "food" - the Dexter pet next door will never see the kitchen stove in anyway.....

Ditto.


I think folks need to band together and get this plan fixed before it is too late to turn back.

[jmtw]

My thoughts are its a control thing. Control = power.
Not to mention the money factor.
The United States does not include Canada, contrary to popular belief. Or vice-versa. :smile:
Our government likes to overdo stuff, due to good intentions, I'm sure. :smile:


You may laugh, :smile: , but eventually we will all live in controlled societies, do what we're told, eat what we're told, breed like we're told, and live like we're told.
We'll wear communicators with GPS, of course, to make our life easier.
Money will be on a card, cash will be obsolete.
We'll own what we're allowed to own.
Drive what we're allowed to drive.
Live where we're told to live.
All for 'our own good', of course.
They'll breed out the 'bad' genes, and only the best will be breeders.
We do it with our animals now, why not humans?
They can breed out diseases, mental problems, anyone who doesn't 'conform' to their way, etc etc etc.
We'll all live longer, of course, and life will be easier.
Disease will be non-existant. Crime will be unheard of.
And life, in general, will be just *beep* dandy.
But this is only if you wish to live in the 'best' places.
There will be the 'third world' places where a person can still be an individual. They won't have the benefits, but they'll still be human.

Sound like science fiction? Fact follows fiction (which is a proven fact).
Conspiracy theory? Possible. Just as anything is possible.
Paranoid? maybe. The best way to control is if the one you're controling thinks it's for their own good.
Assuming, we don't kill ourselves first, of course. :D

[Carol Nelson]

AMEN...to everything Lexi, Tami and jmtw said!!

I guess that's why Texans are so fierce in protecting their freedoms...they still remember the ALAMO!!

[Jane Hurl]

I'm going to answer Tami's questions from the perspective of someone who is living with an animal ID system now. My sincere hope is that you don't see me as "the enemy". I am merely trying to bring to light things that some of you have not considered, and some eventualities that are real, not imaginings.

If you stop to think about WHO is REALLY going to benefit from this you will find that it will not be YOU (unless you work for the department that is pushing this or you own stock in the chip company).... [quote]

But it IS you who will benefit, Tami. You will benefit because any disease that is transmittable to humans (or to other critters) will be traceable, and can therefore be dealt with at the herd level ... something that it is NOT (in your country) now. To see the benefit, just look across the Atlantic. They had no way of tracking BSE in Britain when there was that awful outbreak. Now there are people dying of the human form of BSE. Further, because they had no way of tracking BSE, they had to slaughter and bury almost the ENTIRE cattle population of the country. It was a HUGE economic disaster. And then, the cattle breeders were either going out of business by the thousands, or they were committing suicide because they had no other way of earning a living and nobody in Britain would eat beef for YEARS and YEARS. Now fast forward to Canada. We had a couple of BSE cows show up but, having learned from the Brits, we had our ID system in place and could track the animals quickly and efficiently. OUR cattle business is still intact. Our ranchers are still alive and working. They had a hard go of it for a while, but that was mostly due to a group of American ranchers ("R-CALF") who lobbied (successfully at first) to keep Canadian beef out of your country.

I would like for someone to tell me HOW am I going to benefit from this program when I am raising a rabbit from birth to death and stuffing that guy in my oven?

Assuming your system works as ours does (and I can't imagine why it would be much different), you won't have to chip a rabbit that you raise from birth to death and stuff in your oven. Assuming he was born there, you ONLY have to chip him if he's leaving your ranch. If you sell him to someone else, THEN you have to chip him because THEN he has the potential to threaten the lives of others. Up here, we don't HAVE to chip. We can ear tag instead. It's nothing to slip an ear tag on a lamb just as we're heading out the gate on the way to the abbatoir.

I also want you to tell me WHO is going to benefit and HOW by me tagging that same dead bunny.

Again assuming that your system will be like ours, if he's born on your place and dies on your place, no chip. The theory is that if he gets sick on your place and dies ... and a bunch of other bunnies there die as well ... you're going to contact your veterinarian to find out WHY they all died and an epidemic would be stopped right there ... BEFORE ANYTHING LEFT YOUR PLACE. Same deal, if you got sick from eating him. The authorities would know that you got sick from one of your own bunnies and would know where to find the source of the infection.

But, you see, if that bunny gets sick and makes you sick, and in the MEANTIME, you've sold a bunch of his siblings (we all know about rabbits, right? *wink*) and you DID NOT tag them ... well, now how in the world are we going to find all the contaminated bunnies before they make other people sick ... or are used to breed that sickness into another entire flock of bunnies. (Are bunnies called a "flock"? A "warren"?) THAT is the biggest reason for the tagging.

I like parts of the "idea" but to me it is still an "idea".... it needs a LOT of tweeking..... like the part where I read a cattle ranch could be exempt from indiviual tagging due to the "volume"..... well, hello - that is the one that needs to look and ID EACH cow.... they raise them as "food" - the Dexter pet next door will never see the kitchen stove in anyway.....

The reason the large cattle ranches would be exempt on a volume basis, is that those "batches" that leave the ranch are heading for the slaughter house. In that case (assuming your system will work the way ours does up here) the "batch" would have an ID number. That way, if there's something wrong with even ONE of the cattle in that "batch", they can follow the trail back to the ranch.

Let's say that rancher (the one who is exempt from each cow being tagged) is selling ONE bull to someone else as a breeding bull. THAT animal would have to be tagged. Same deal if said rancher was selling a breeding cow, or a heifer, to someone looking to improve their bloodlines.

The whole idea is to be able to trace the animal's movement around your country ... and north, if it is coming into Canada. Our cattle industries are so closely intertwined that animals cross the border all the time. It is because of our tracking system that when the first cow with BSE was found in the US, it was possible to track it back to its EXACT HERD of origin (here in Alberta) and the herd was euthanized. (Turns out the entire herd didn't NEED to be euthanized, but that's another story entirely. We did it to appease the USA.)

the Dexter pet next door will never see the kitchen stove in anyway.....

No, the Dexter pet next door may never see the kitchen stove ... but what happens if the owners of those Dexters die? (One assumes it is not a lone Dexter. It would be a very unhappy pet that way.) Where do those Dexters go? If they go into a breeding program in Utah, don't you think the entire country would want to know where the BSE came FROM, if it came in with that pet Dexter? And wouldn't YOU want to know where his herd-mates went? The human form of BSE is an ugly, ugly disease with no cure. Again, as long as that Dexter doesn't leave the place, he doesn't need to be tagged. But you cannot take him to any abbatoir for processing without a tag.

Okay, so now I've done my best to educate and to dispel the paranoia (as I see it) over this. Have I done a decent job of it ... or have I ticked you all off? *grin*

[Mellifluous]

Ok - From the FAQ page of the USDA site - straight from the horse's mouth.

OUCH
How Much Will the Program Cost?
A. It is difficult to quantify the cost of a fully operational system since all of the needed components have not yet been fully defined. During fiscal year (FY) 2004, USDA has invested $18.8 million into the NAIS, and the President's FY 2005 Budget requests an additional $33 million.


Q. Who Will Pay for the Identification System?
A. The size and scope of this undertaking demand that it be a cooperative effort. Because it is being developed as an industry-government partnership, it is expected that industry and the government will share the cost of the necessary elements.

Q. Who Will be Responsible for Applying Identification to Animals?
A. During the phase-in period, animals will need to be identified as they leave whatever premises they are on regardless of where they were born. After the first few years of the program, identifying animals will be the responsibility of the "premises of birth" animal owners. For animal owners who lack equipment for individual identification, "tagging stations" will be available.

Q. What is a Tagging Station and Where Will Such Stations be Located?
A.A tagging station is an entity operating from a fixed location that has been officially approved by APHIS to apply identification devices to animals that are required to be identified.

USDA recognizes that not all animal owners will have facilities to individually tag animals before they leave their premises of origin. Therefore, animal owners who are required to individually tag animals that leave the premises of origin can elect to transport animals to an approved tagging station. They would pay the operator of the tagging station a fee to apply individual animal identification devices and report the identification information to a central information repository. Such tagging stations may include, but not be limited to, an existing livestock marketing facility, a veterinary clinic, a fairgrounds, or a facility specifically dedicated to performing tagging services.


Q. If a Person Raises Animals for His or Her Own Use and the Animals Never Leave the Owner's Property, Do They Need to be Identified?
A. Under the current plan, animals that never leave a premises do not need to be identified. However, animal owners are encouraged to identify their animals and their premises, regardless of the number of animals present, since many animal diseases may be spread whether an animal leaves its home premises or not. Examples of such diseases include West Nile virus, foot-and-mouth disease, vesicular stomatitus, and equine infectious anemia.

Q. If a Person Only Shows Animals or Only Takes Them to Trail Rides, Do They Need to be Identified?
A. When people show or commingle their animals with animals from multiple premises, the possibility of spreading disease becomes a factor. Those animals will need to be identified.
Return

Q. What Species Will be Included in the NAIS?
A. The NAIS is being developed for all animals that will benefit from having a system to facilitate rapid traceback/traceout in the event of disease concern. Currently, working groups are developing plans for aquaculture, camelids (llamas and alpacas), cattle/bison, cervids (deer and elk), equine, goats, poultry, sheep, and swine.


This is the website for the program.
http://animalid.aphis.usda.gov/nais/index.shtml

[Mellifluous]

Here is the equine working group membership list: Looks like CJ is our rep.

Also, here is a place to send comments.


Equine Identification Working Group Members
Mr. Alan Balch
American Saddlebred Horse Association

Dr. G. Marvin Beeman
Trustee American Horse Council

Mr. Remi Bellocq
The National H.B.P. A., Inc.

Mr. Doug Burge
California Thoroughbred Breeders Assn.

Ms. Cindy Chilton
Palomino Horse Breeders of America

Dr. Tim Cordes
Senior Staff Veterinarian
USDA/APHIS/VS/NAHP

Dr. Douglas Corey
Professional Rodeo Cowboys Assn

Mr. Paul Estok
Harness Tracks of America

Ms. J. Amelita Facchiano
Global VetLink, LC

Mr. Dan Fick
The Jockey Club

Dr. L. B. Fleming
American Endurance Ride Conference

Mr. Alan Foreman
Thoroughbred Horsemen's Association, Inc.

Ms. Debbie Fuentes
Arabian Horse Association

Dr. Mary Giddens
NA/WPN

Mr. Jim Gowen
Thoroughbred Racing Protective Bureau

Dr. Nancy Halpern
New Jersey Department of Agriculture
Div. Of Animal Industry

Dr. Steve Halstead
Michigan Dept. of Agriculture
Animal Industry Division

Mr. Neil Hammerschmidt
Animal Identification Coordinator
USDA/APHIS/VS

Dr. James Heird
Colorado State University
College of Agricultural Sciences

Ms. Peggy Hendershot
National Thoroughbred Racing Association

Mr. Jay Hickey, Jr.
President American Horse Council

Mr. Alan Hill
Back Country Horsemen of America

Mr. Jeff Hooper
National Cutting Horse Association

Mr. Charles Hulsey
Tennessee Walking Horse Breeders' & Exhibitors' Association

Ms. Bonnie Jenkins
U.S. Equestrian Team

Mr. Jim Kelley
American Paint Horse Association

Dr. Mack Lea, Jr.
Louisiana State Veterinarian
Louisiana Dept. of Agriculture
Office of Animal Health Services

Mr. Bob Luehrman
U.S. Trotting Association

Ms. Amy Mann
Director, Health and Regulatory Affairs
American Horse Council

Mr. C.J. Marcello, Jr.
Paso Fino Horse Association

Mr. Dan Metzger
Thoroughbred Owners & Breeders Association

Dr. Jim Morehead
American Association of Equine Practitioners

Mr. Joe Santarelli, Sr.
Mersant International Ltd

Ms. Cindy Schonholtz
Professional Rodeo Cowboys Assn

Mr. Ward Stutz
American Quarter Horse Association

Mr. David Switzer
Kentucky Thoroughbred Association

Dr. Peter Timoney
University of Kentucky

Mr. Dan Wall
National Reining Horse Association
Continued grassroots input is critical to the success of the NAIS. Accordingly, USDA and its State and industry partners have established NAIS working groups to provide recommendations and input as we move forward with the system.

To provide input to USDA, please send an email to animalidcomments@aphis.usda.gov. We'll share your comments with the NAIS Subcommittee and the Equine Identification Working Group as appropriate.

Equine Work Group
Chair: Ms. Amy Mann
Director, Health and Regulatory Affairs
American Horse Council

[Jane Hurl]

The only thing I see that's different there than here is the application of tags. Obviously, you can't use external tags like our ear tags. But, it seems to me I saw something about chipping being the next step up here because ear tags can and do get ripped out from time to time.

All in all, it sounds to me like you're developing a better system than our present one, if only for the fact that it sounds like yours MUST be a chip. Frankly, if my horses have to be identified, I'd rather have a chip than an ugly old ear tag anyway!

As far as my "livestock" goes, we only tag when they're ready to leave. When lambs are going to market, we load 'em, and then go in the trailer with tags and an applicator. It's done in about 10 minutes. Then they go to the abbatoir and, once killed, the tags are removed and kept until the meat has been inspected. Then, I think, the tags are sent to the government ... but I don't know that last part for sure.

[Jane Hurl]

Pfft! Just went back and looked at my post to answer Tami. Somehow I got the quote/unquote thingies wrong. Hope I didn't confuse the issue!

[Barbwire]

Tammi, you eat bunnies? http://homepage.mac.com/oatmeal/MAF/maxes/sadsadmax.png

[Jane Hurl]

I have a Newfie hired hand who eats bunnies all the time. I tried it. Liked it (tastes like chicken) ... then found out that they catch and kill them by using a wire snare. BLAGH! All I could think about after that was a poor little bunny squirming on the end of a wire snare.

Won't eat bunny no mo'.