National Cattlemen's Beef Association
APHISNonrulemakingAPHIS-2009-0027

National Animal Identification System; Public Meetings

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National Cattlemen's Beef Association filings
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National Cattlemen's Beef Association filed 1 comment on this docket between Aug 6, 2009 and Aug 6, 2009. 0 other organizations filed here. The comment window closed 6203d ago.

What National Cattlemen's Beef Association filed (1)

Aug 6, 2009· Comment from Gary Voogt, National Cattlemen's Beef Association· APHIS-2009-0027-0593

NCBA Statement on the National Animal Identification System As the oldest and largest national association for cattle producers, we represent 230,000 cattle farmers and ranchers through our membership and the membership of our state and breed affiliates. NCBA policy is generated at the grassroots level, is debated by producers, and is voted on by all NCBA members before it is finalized. NCBA recognizes and supports the need for a National Animal Identification System for the purpose of enabling state and federal animal health officials to respond rapidly and effectively to animal health emergencies, such as foreign animal disease outbreaks or emerging domestic diseases. We also support the use of animal identification systems for genetic improvement and marketing arrangements. In fact, albeit recognizing the need for continued refinements to be developed, NCBA policy supports the adoption of the NAIS as the national animal identification program. NCBA has encouraged our members to participate in animal identification systems, and has produced and implemented a media campaign to get producers to register their premises. Many of our members already participate voluntarily in numerous animal identification programs as one of many tools to improve their herds, monitor disease, and better market their cattle. The private sector plays a tremendous role in the administration of these voluntary programs, and NCBA believes that private sector involvement and the resulting competitive market forces benefit producers while maintaining the objectives of the NAIS. However, our members continue to have concerns with NAIS, which is why NCBA's policy supports a voluntary – rather than a mandatory – system. The first concern is that private producers' confidential information would be housed in a USDA-maintained database. The federal government does not have a strong track record of preventing the leak of private information. Furthermore, USDA has not been able to guarantee us that the information in a mandatory system would be protected from release under a Freedom of Information (FOIA) request. USDA's own Office of General Counsel has told us and the House Agriculture Committee that protection is different between a voluntary and mandatory system. Another concern is the need for a system that will move at the speed of commerce. The working, processing, and marketing of cattle cannot slow down in order to be scanned and entered into the system. Finally, we want to make it very clear that animal ID is NOT a food safety tool. There are many firewalls and inspection procedures in place to keep our beef supply safe. The NAIS will not serve to enhance food safety, nor was it intended to. Additionally, animal ID does not prevent animal disease; it is merely a tool to respond to an animal health emergency. In short, NCBA encourages USDA to develop an efficient system that meets the needs of the country's beef producers by: •minimizing additional costs to the beef industry •maintaining the confidentiality of producer, animal, and premises information •operating at the speed of commerce •integrating private-sector databases •ensuring that the system is phased-in within and between species •providing that any animal tracking database should be user friendly to producers of all sizes •ensuring that current or future business plans include significantly more details to allow producers to understand day to day impacts of the plan, prior to the final rule-making process NCBA is committed to working with USDA in working towards these, and other continued refinements to NAIS, and we look forward to these discussions in the further development of a workable system.

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