Livestock Identification; Use of Alternative Numbering Systems

Harriet.A.Murphy@aphis.usda.gov 01/06/2005 10:02 AM To: Docket EPADC@EPA cc: Subject: Comment for APHIS-2004-0018 ----- Forwarded by Harriet A Murphy/MD/APHIS/USDA on 01/06/2005 10:01 AM ----- "Marissa Woodhull-Weiser"To:<regulations@aphis.usda.gov> <MarissaW@fb.org>cc: Subject: Docket No. 04-052-1 01/05/2005 09:16ID: 04-052-1 ( 2 ) AM January 4, 2004 U.S. Department of Agriculture Animal and Plant Health Inspection Service Regulatory Analysis and Development PPD, APHIS, Station 3C71 4700 River Road Unit 118 Riverdale, MD 20737&ndash;1238 Re: Docket No. 04&ndash;052&ndash;1 The American Farm Bureau Federation (AFBF) appreciates the opportunity to comment on the interim rule regarding the use of alternative numbering systems. AFBF strongly supports the establishment and implementation of a national animal identification system capable of providing support for animal disease control and eradication. Various forms of livestock identification have long been utilized by many of our members for production purposes, whether that is branding of cattle, ear-notching of swine, or tagging of a wide variety of species. Our livestock producers acknowledge and appreciate the vital importance of animal disease control. The concept of a uniform national system of animal identification has received increasing attention within our organization, and we look forward to working in partnership with USDA &ndash; through both informal feedback and official comments on specific issues such as these &ndash; as the National Animal Identification System (NAIS) is implemented. Background Since 2002, AFBF has been an active participant in the development of the U.S. Animal Identification Plan (USAIP). Along with more than 100 individuals representing over 70 industry groups as well as state and federal government representatives, we have compiled a working document that outlines information and concepts that could be used to rapidly implement a uniform national livestock identification system. We continue to provide input on the NAIS through the USAIP species working-group framework, and we appreciate the Department's inclusion of that framework in the feedback model for NAIS development. We encourage USDA to continue working closely with Farm Bureau and the livestock industry to ensure that grassroots solutions guide the implementation of the NAIS. USDA recognized very early that it was extremely important to develop the animal identification program via a public-private partnership. We strongly believe this is the best approach to enhance producer participation in a voluntary system and ultimately affect the success of the NAIS. Issues 1.Animal Identification Number (AIN) AFBF supports the use of alternative numbering systems for animal identification numbers. To increase efficiency and reduce cost, existing systems of livestock identification should be transitioned into the NAIS. Particularly in the initial stages of NAIS implementation, it is important to recognize and incorporate into the system those animals that are already identified through a government-mandated animal health or disease eradication program (such as tuberculosis control or scrapie eradication), as well as animals which bear a unique identification number for other purposes, without requiring producers to reapply a new device. State brand inspection systems and all brand laws must also be respected and incorporated into the NAIS. As soon as possible, a reasonable sunset date for identification numbers other than the standardized 15-digit AIN with 840 country code should be established and communicated with the industry. AFBF believes that the goal of this AIN implementation period should be to minimize labor for producers whose livestock are already identified and to increase the number of animals that can be easily recorded in the system, while at the same time transitioning all livestock to be identified using one uniform, standardized, and technology-neutral numberi…