Liberty Ark Coalition
Liberty Ark Action Alert: USDA Announces Three More Public Meetings on Animal Identification:
More Opportunities to Tell The Agency What You Think About Animal ID!
Date: August 9, 2010
The USDA continues to hold public meetings to discuss its new framework for animal traceability. USDA has stated that this new framework will apply only to animals that cross interstate borders and will emphasize low-cost identification methods. But Big Ag and Big Tech are pushing for a more expansive and expensive -- federal program, while they also make plans to re-create NAIS at the state level. It also appears that some career bureaucrats who supported NAIS continue to agree with Big Ag and Big Tech's views.
The public meetings are an opportunity to have input before the agency writes its proposed rule. The next meetings are in August in Wisconsin, Georgia, and Washington.
TAKE ACTION
Come to the meeting and make your voice heard!
Wednesday, August 18
Crowne Plaza Madison
4402 East Washington Avenue
Madison, WI 53704
Friday, August 20
Doubletree Hotel Atlanta Airport
3400 Norman Berry Drive
Atlanta, GA 30344
Tuesday, August 24
Red Lion Hotel
2525 N 20th Avenue
Pasco, WA 99301
The meetings will take place between 8 am and 4 pm, and the USDA has more information posted at http://www.aphis.usda.gov/traceability/meetings/index.shtml
The morning will consist of presentations by government officials, followed by breakout sessions at tables based on species groups. After the small groups have reported back to the full audience, a USDA official will respond to written questions, and there may be an opportunity at the very end for oral questions or comments.
Below are a couple of suggestions to help you be effective:
1) Plan your written questions ahead of time. When the USDA official goes through the questions in the afternoon, if he doesnt actually answer your question, stand up and politely insist on an answer.
2) At the small group discussion, be prepared to be an advocate for your views and to politely disagree with the facilitator(s). If they claim that a consensus has been reached with an answer that you dont agree with, say so. At the end, one person from the table will report back to the full group. Let the spokesperson give his or her report, and then politely speak up to add any points that were covered by the group that were skipped.
MORE INFORMATION
The USDA has held five public meetings on its new animal traceability framework. Below is information drawn from people attending the previous meetings.
The USDAs new proposal was developed by a "Regulatory Working Group made up of five state vets and five tribal representatives. The proposal includes four performance standards, which set how quickly States and Tribes must be able to perform four activities:
1. The State where the animal is located must notify the State or Tribe where the animal of interest was originally identified: 95% within 1 business day
2. The State or Tribe where the animal of interest was officially identified must identify the "traceability unit" in which the animal was identified: 75% within 5 business days, with a later phase requiring 95% within 2 business days
3. The State where the animal is located must notify the State or Tribe from which the animal was last shipped: 95% within 7 business days, with a later phase requiring 95% within 3 business days
4. The State from which the animal was last shipped must identify the "traceability unit" from which the animal was shipped: 75% within 5 business days, with a later phase requiring 95% within 2 business days
Many concerns have already been raised at these earlier meetings:
What is the basis for the new proposal? The performance standards, like NAIS, lack a scientific basis. At one breakout table, a USDA vet stated that the performance standards were based on the experience of the state vets and regulatory officials. While experience is important, why is their experience prioritized over the experience of animal owners who deal with animal health every day? Before imposing any new requirements on animal owners, the agency needs to provide solid scientific and economic analyses to show why these steps are needed.
Are performance standards the right approach? Should USDA be setting standards when it is far from clear how the States would be able to achieve them?
There is still no analysis of where the real problem lies. Is it truly an animal identification problem? Or are the problems with traceability due to bureaucratic inefficiencies, lack of enforcement of existing regulations, or other issues? On the issue of animal health, where exactly are the gaps?
There is a continued assumption that electronic ID is the best approach. While USDA has committed to using low-tech methods for the framework, there are repeated references to progress over time, and every government speaker emphasized the benefits of RFID tags. Yet the advocates of electronic ID continue to fail to show that it is needed or cost-effective.
The proposal is confusing and unclear. For example, there is no written definition of traceability unit, and weve now heard three different definitions at three different public meetings. At the Colorado meeting, Colorado State Vet Dr. Roehr stated that it was a geographical unit and could be anything from the whole state to a set of counties to a county to an individual premises. At the Utah meeting, Montana State Vet Dr. Zaluski stated that the traceability unit was either a physical location or a group of animals. At the Texas meeting, Oklahoma State Vet Dr. Brewer stated that ultimately it is a premises. Three members of the Regulatory Working Group, with three different statements on what the term means!
How can the public provide input when the people who drafted the proposal cant even explain it clearly? How can we provide useful input without first getting answers about what the program is, how it will be implemented, its purposes and goals? The proposal is extremely ambiguous, but it appears to set the stage for traceability back to individual premises and ultimately RFID tagging of each animal. Is this USDAs intent? Or is it being driven by industry and the career bureaucrats who have spent more than a decade building NAIS? Right now, it's not clear.
Come to the meetings in Wisconsin, Georgia, and Washington, and make your voice heard!
Go to www.LibertyArk.net for more information.
Liberty Ark Coalition
www.LibertyArk.net
Email: [email protected]
http://www.aphis.usda.gov/traceability/meetings/index.shtml
Liberty Ark Action Alert: USDA Announces Three More Public Meetings on Animal Identification:
More Opportunities to Tell The Agency What You Think About Animal ID!
Date: August 9, 2010
The USDA continues to hold public meetings to discuss its new framework for animal traceability. USDA has stated that this new framework will apply only to animals that cross interstate borders and will emphasize low-cost identification methods. But Big Ag and Big Tech are pushing for a more expansive and expensive -- federal program, while they also make plans to re-create NAIS at the state level. It also appears that some career bureaucrats who supported NAIS continue to agree with Big Ag and Big Tech's views.
The public meetings are an opportunity to have input before the agency writes its proposed rule. The next meetings are in August in Wisconsin, Georgia, and Washington.
TAKE ACTION
Come to the meeting and make your voice heard!
Wednesday, August 18
Crowne Plaza Madison
4402 East Washington Avenue
Madison, WI 53704
Friday, August 20
Doubletree Hotel Atlanta Airport
3400 Norman Berry Drive
Atlanta, GA 30344
Tuesday, August 24
Red Lion Hotel
2525 N 20th Avenue
Pasco, WA 99301
The meetings will take place between 8 am and 4 pm, and the USDA has more information posted at http://www.aphis.usda.gov/traceability/meetings/index.shtml
The morning will consist of presentations by government officials, followed by breakout sessions at tables based on species groups. After the small groups have reported back to the full audience, a USDA official will respond to written questions, and there may be an opportunity at the very end for oral questions or comments.
Below are a couple of suggestions to help you be effective:
1) Plan your written questions ahead of time. When the USDA official goes through the questions in the afternoon, if he doesnt actually answer your question, stand up and politely insist on an answer.
2) At the small group discussion, be prepared to be an advocate for your views and to politely disagree with the facilitator(s). If they claim that a consensus has been reached with an answer that you dont agree with, say so. At the end, one person from the table will report back to the full group. Let the spokesperson give his or her report, and then politely speak up to add any points that were covered by the group that were skipped.
MORE INFORMATION
The USDA has held five public meetings on its new animal traceability framework. Below is information drawn from people attending the previous meetings.
The USDAs new proposal was developed by a "Regulatory Working Group made up of five state vets and five tribal representatives. The proposal includes four performance standards, which set how quickly States and Tribes must be able to perform four activities:
1. The State where the animal is located must notify the State or Tribe where the animal of interest was originally identified: 95% within 1 business day
2. The State or Tribe where the animal of interest was officially identified must identify the "traceability unit" in which the animal was identified: 75% within 5 business days, with a later phase requiring 95% within 2 business days
3. The State where the animal is located must notify the State or Tribe from which the animal was last shipped: 95% within 7 business days, with a later phase requiring 95% within 3 business days
4. The State from which the animal was last shipped must identify the "traceability unit" from which the animal was shipped: 75% within 5 business days, with a later phase requiring 95% within 2 business days
Many concerns have already been raised at these earlier meetings:
What is the basis for the new proposal? The performance standards, like NAIS, lack a scientific basis. At one breakout table, a USDA vet stated that the performance standards were based on the experience of the state vets and regulatory officials. While experience is important, why is their experience prioritized over the experience of animal owners who deal with animal health every day? Before imposing any new requirements on animal owners, the agency needs to provide solid scientific and economic analyses to show why these steps are needed.
Are performance standards the right approach? Should USDA be setting standards when it is far from clear how the States would be able to achieve them?
There is still no analysis of where the real problem lies. Is it truly an animal identification problem? Or are the problems with traceability due to bureaucratic inefficiencies, lack of enforcement of existing regulations, or other issues? On the issue of animal health, where exactly are the gaps?
There is a continued assumption that electronic ID is the best approach. While USDA has committed to using low-tech methods for the framework, there are repeated references to progress over time, and every government speaker emphasized the benefits of RFID tags. Yet the advocates of electronic ID continue to fail to show that it is needed or cost-effective.
The proposal is confusing and unclear. For example, there is no written definition of traceability unit, and weve now heard three different definitions at three different public meetings. At the Colorado meeting, Colorado State Vet Dr. Roehr stated that it was a geographical unit and could be anything from the whole state to a set of counties to a county to an individual premises. At the Utah meeting, Montana State Vet Dr. Zaluski stated that the traceability unit was either a physical location or a group of animals. At the Texas meeting, Oklahoma State Vet Dr. Brewer stated that ultimately it is a premises. Three members of the Regulatory Working Group, with three different statements on what the term means!
How can the public provide input when the people who drafted the proposal cant even explain it clearly? How can we provide useful input without first getting answers about what the program is, how it will be implemented, its purposes and goals? The proposal is extremely ambiguous, but it appears to set the stage for traceability back to individual premises and ultimately RFID tagging of each animal. Is this USDAs intent? Or is it being driven by industry and the career bureaucrats who have spent more than a decade building NAIS? Right now, it's not clear.
Come to the meetings in Wisconsin, Georgia, and Washington, and make your voice heard!
Go to www.LibertyArk.net for more information.
Liberty Ark Coalition
www.LibertyArk.net
Email: [email protected]
http://www.aphis.usda.gov/traceability/meetings/index.shtml