July 1, 2010

 Open Letter to the United States Cattle Industry

 Dear U.S. Cattle Producers and Other Rural Americans, 

            The most important day in the history of your U.S. cattle industry, and perhaps all of Rural America, is soon to arrive. Never in history have two presidential Cabinet members invited Rural Americans to meet with them in the center of the United States to show their support for restoring competition to the U.S. cattle industry. Never in history, that is, until now. 

            U.S. Attorney General Eric Holder and U.S. Agriculture Secretary Tom Vilsack have invited U.S. cattle producers and other Rural Americans to meet with them for one day on the campus of Colorado State University in Fort Collins, Colorado, beginning at 8:00 a.m. MDT on Friday, Aug. 27, 2010. 

            We must accept this unprecedented invitation! Every U.S. cattle producer, every main-street business owner who supports our cattle industry, and every consumer who wants USA beef produced by U.S. farmers and ranchers must be in Fort Collins on August 27 to show the U.S. Attorney General and U.S. Secretary of Agriculture that the No. 1 priority for Rural America must be to restore competition to the U.S. cattle market.

             Your attendance at this historic event, without saying a single word, will send a more powerful, compelling message to Washington, D.C., than could ever be achieved during several years’ worth of sending letters, making phone calls, or even flying to Washington, D.C., to visit with your elected representatives and agency officials. 

            This is the opportunity of a lifetime to genuinely make a positive impact on the future direction of your U.S. cattle industry and the future of Rural America. This opportunity is not only unprecedented, it is unique. It is unique because the invitation is not for the purpose of exploring whether there has been a loss of competition in the U.S. cattle industry. Indeed, the very reason the Attorney General and the Secretary of Agriculture have scheduled this unprecedented meeting in Fort Collins is because they do understand there is a serious problem in the U.S. cattle industry and it is affecting all of Rural America. The purpose of this meeting is to determine if it is the will of U.S. cattle producers and Rural Americans that immediate, aggressive action be taken to restore competition to the U.S. cattle industry.

            This is why your attendance is absolutely essential and why just being there will be so effective. When the U.S. Attorney General, U.S. Secretary of Agriculture, and all the media that follow these two gentlemen around look out at a crowd of 25,000 they will draw one, and only one, conclusion: U.S. cattle producers and Rural Americans want the federal government to put an immediate and permanent halt to the anticompetitive practices and antitrust activities that are rapidly causing the U.S. cattle industry to shrink, resulting in the hollowing out of rural communities all across the United States. 

            We encourage you to bring with you a simple, respectful sign that includes two critical pieces of information: 1) your message, which can be “Fix our Cattle Markets,” “Restore Competition,” or “Stop Anticompetitive Practices;” and, 2) the name of the state you are from.   

            When we all arrive with our simple, respectful sign on the Colorado State University Campus in Fort Collins, at 8:00 a.m. on Friday, August 27, we will make history. We will send Congress and the Administration a mandate they cannot ignore. We will mark the beginning of the reversal of the contraction of our U.S. cattle industry and we will preserve for ourselves and our children the opportunity to participate in the U.S. cattle industry as independent cattle producers who sell into a fully competitive market. This is our goal. This is our opportunity. And this is what is at stake. 

            Please do not underestimate the importance of this event. The concentrated beef packers and their supporting trade associations will be pulling out all the stops. They will hire economists to write glowing studies to show that producers and consumers benefit when beef packers control the cattle market. They also will initiate a media blitz to stop any efforts to limit their tremendous market control. Your attendance in Fort Collins will trump their self-serving efforts. When 25,000 people from all across the U.S. with an interest in preserving our U.S. cattle industry stand together in Fort Collins on August 27, we will indelibly imprint our message on the mind of each and every Washington, D.C., decision-maker, and all the money and self-serving efforts put forth by the powerful beef packers will be outshone. 

            Many of you have spent years helping us lay the foundation to change the course of our industry. But, to actually implement that change we need you, your family, and your neighbors to stand with us to make this historic event extraordinary. We look forward to your attendance on August 27 and welcome any assistance you can provide to encourage as many people from your area as possible to be there with you. Please call us for further assistance or information.           

This is the real deal! This is what we have all been working for! The time is now! Help us show the world that we are serious about preserving and strengthening Rural America – a feat that can only be accomplished by preserving and protecting our United States’ cattle-producing heritage. 

Sincerely,

R.M. (Max) Thornsberry, D.V.M.
R-CALF USA President of the Board

Bill Bullard
CEO

Click here for more information.

Billings, Mont. – R-CALF USA today called the U.S. Department of Agriculture’s (USDA’s) proposed rule to lift foot-and-mouth disease (FMD) restrictions on Brazil inaccurate and unscientific. An early version of USDA’s proposed rule (officially scheduled for publication in the April 16, 2010 Federal Register) falsely claims the last outbreak of FMD in the Brazilian state of Parana (which borders Santa Catarina, the state USDA wants to declare free of FMD) was in 2005. 

“This is false,” said R-CALF USA CEO Bill Bullard, who cited disease information from the World Organization for Animal Health (OIE) that shows Parana, Brazil, continued to have new outbreaks of FMD into 2006, just four years ago. “OIE data clearly show that Parana, Brazil, had six new outbreaks and 20 cases of FMD in 2006.”

In addition, Bullard said the proposed rule also fails to mention the 669 cases of FMD that resulted in Brazil’s destruction of over 26,000 head of cattle within the past five years in the state of Mato Grosso do Sul, which borders Parana and is in close proximity to Santa Catarina.

“It is disheartening that USDA has purposely and officially failed to disclose the severity of Brazil’s FMD situation, which is publicly available on OIE’s Web site, in order to advance its own agenda to import high-risk products into the United States,” he said.

Bullard also said USDA has a 100 percent failure rate in its attempts to “regionalize,” or carve out regions, within FMD-affected countries that export meat to the U.S., as it is attempting to do with Santa Catarina, Brazil. 

“In 2000, USDA lifted FMD restrictions imposed on Argentina just before Argentina reported widespread FMD outbreaks in 2001, and then the agency tried to lift FMD restrictions against Uruguay in 2000, just months before Uruguay reported widespread FMD outbreaks in 2001,” he pointed out. “And most recently, in late 2009, USDA issued a final rule to declare South Korea free of FMD and then within just days of when that rule was to take effect, South Korea began reporting new outbreaks of FMD.

“Congress needs to rein this agency in before USDA causes the introduction of FMD in the United States,” Bullard urged. “We’ve already had too many near misses because of USDA’s unrealistic, inaccurate and unscientific evaluation of the true risks of FMD, which is the most contagious disease known to cattle.”

R-CALF USA encourages producers and consumers to urge their members of Congress to take steps to stop USDA from lifting essential FMD protections. 

“It is clear that USDA is continuing to advance the interests of the World Trade Organization while ignoring its duty to protect U.S. livestock,” Bullard concluded.

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

Billings, Mont. – Yet again, R-CALF USA learned through the rumor mill yesterday that Canada had detected the country’s 18^th case of bovine spongiform encephalopathy (BSE) in a 72-month-old Angus cow. Although Canadian officials were purported to have notified the World Organization for Animal Health (OIE) last week, a phone call this morning to OIE revealed that Canada had not yet notified OIE of this latest discovery. However, R-CALF USA Communications Coordinator Shae Dodson was told via telephone by the Canadian Food Inspection Agency (CFIA) that Canada, indeed, had discovered yet another case of BSE. The U.S. Department of Agriculture (USDA) later verified CFIA’s report.

“The CFIA said the BSE-positive case was confirmed Feb. 25, 2010, which means the CFIA and all other governments who knew about this latest BSE case kept it a secret from the public for almost two weeks, said R-CALF USA CEO Bill Bullard. “If we had not discovered this information, the public may never have known.”

At six years of age, this particular animal would have been born in 2003 or 2004, making her the 18^th Canadian-born BSE case and the 11^th BSE-positive animal eligible to be exported to the United States. In November 2007, USDA implemented the OTM (over-30-months) Rule that allows the U.S. to import into the U.S. these high-risk Canadian cattle over 30 months of age, as long as such cattle were born after March 1, 1999.

Already this year, well over 40,000 older Canadian cows and bulls have been imported into the United States for domestic slaughter.

“Consumers – now more than ever – should be telling their grocers they want the products in the meat counter labeled with country-of-origin information so they can decide on their own whether to avoid products from countries with ongoing disease problems, particularly now that USDA chooses not to disclose such important disease information,” said R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group’s animal health committee.

“Forty organizations representing consumers, the cattle industry and other livestock and farming interests sent a joint letter to USDA in November 2009 urging the new Administration to restore the United States’ weakened import standards that are exposing the U.S. to a heightened risk of BSE,” said Thornsberry. “It’s well past time for Agriculture Secretary Tom Vilsack to listen to U.S. citizens and overturn the OTM Rule that is allowing the continuous introduction of BSE into the United States.

“There are no restrictions on these higher-risk OTM cattle when they enter the United States,” he continued. “These higher-risk cattle are allowed to commingle with the U.S. herd, enter the U.S. food supply and enter the non-ruminant U.S. animal feed system. USDA has an absolute duty to protect the U.S. cattle herd as well as U.S. consumers from the introduction of BSE that is known to be occurring under the OTM Rule, and R-CALF is again calling on USDA to immediately rescind the OTM Rule.”

“Since implementation of the 2007 OTM Rule, Canada has detected seven new cases of BSE, six of which met USDA’s age requirement to be imported into the United States,” Bullard said. “It is alarming that while Canada’s BSE problem is ongoing, Canada has significantly reduced its surveillance testing and likely is detecting only a fraction of the BSE cases in the Canadian herd. This haphazard approach to BSE is endangering not only U.S. beef consumers, but the U.S. cattle herd, and we want USDA to immediately halt Canadian cattle imports.”

According to Canadian data, Canada tested only 34,617 cattle for BSE in 2009. In 2008, 48,804 cattle were tested. In 2007, approximately 59,000 head were tested, and in January 2010, only 3,536 Canadian cattle were tested for the disease.

“Canada’s BSE testing is voluntary, and based on the significant numbers of BSE-positive cattle detected under very limited testing, Canada’s BSE prevalence rate is likely far higher than USDA estimated when it predicted that the OTM Rule would result in the importation of 19 BSE-infected cattle during the 20 years covered by USDA’s risk modeling,” Bullard pointed out. “The result is that the United States is assuming a much higher risk for the introduction of BSE than the negligible risk that USDA claims.”

R-CALF USA, the South Dakota Stockgrowers Association, five national consumer groups and several individual ranchers have a pending lawsuit against USDA’s OTM Rule in a South Dakota federal court. As a result of this litigation, the court ordered USDA to reopen the OTM Rule and “to revise any provisions of the OTM Rule it deems necessary.”

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   Join R-CALF USA at http://www.r-calfusa.com/Promotion/081205-donate.join.htm

Stop the Hemorrhaging in U.S. Live Cattle Industry:  Producers to President, Congress, USDA and Justice

Billings, Mont. – R-CALF USA directors, officers and committee chairs, as well as many of its affiliate organizations, jointly sent a letter today to President Obama, Vice President Biden, Agriculture Secretary Tom Vilsack, Attorney General Eric Holder and congressional leaders that describes the U.S. cattle industry as being in an acute crisis. The correspondence states that over $6.4 billion has been stolen from the hands of U.S. cattle feeders and placed in the hands of just a few mega-meatpackers. The signatories ask for immediate and decisive action by the Administration and Congress to avoid further destruction to both the industry and the rural communities supported by the United States’ largest segment of agriculture.

In part, the letter states: “Will your Administration and Congress take decisive action to alleviate the deplorable losses accruing to U.S. independent cattle farmers and ranchers by immediately taking the specific actions we have previously requested and reiterate above? Or, must we now yield to government assistance in the form of TARP funds or other emergency assistance – as have other U.S. industry segments, including our sister dairy and hog industries – to begin to redress the horrific damage caused by the unbridled excesses of the dominant corporate meatpackers and failed U.S. trade policies? Or, do you have a better, market-oriented solution that would allow us to salvage what is left of our injured U.S. cattle industry?”

“We have urged, again and again, Washington decision-makers to take action to restore needed import restrictions to protect the health of our domestic cattle herd and the safety of our beef supply, to restore the competitiveness of our industry through the enforcement of antitrust laws, to prohibit anticompetitive practices, and to make changes to trade policy that recognize the supply sensitive nature of cattle and beef, but these warnings were not heeded and now our industry is facing an insurmountable crisis unless immediate action taken,” said R-CALF USA CEO Bill Bullard.

“Proposed workshops, studies and investigations into the despicable practices and policies that have all but completely destroyed our once vibrant U.S. cattle industry – along with the tens of thousands of rural communities it recently supported – are wholly inadequate as responses to the cataclysmic condition of our industry today,” he pointed out. “Since January 2007, the U.S. fed cattle market alone has lost $6.4 billion, while mega-meatpackers Tyson and JBS each have recently reported hundreds of millions in profits and National Beef Packing Co. brags of an 85 percent net profit increase.”

The letter also states: “This theft occurred in broad daylight. Neither USDA nor the U.S. Department of Justice, nor Congress, has yet lifted a finger to effectively address the systemic lack of antitrust enforcement within our cattle industry, or to prohibit the rampant, anticompetitive practices pervasive in our U.S. cattle market, or to reverse our cattle industry’s horrendous trade deficit…

“…The losses to U.S. cattle feeders continue and are compounding rapidly. Those remaining in the cattle feeding business are becoming fewer and fewer each day. The combination of cattle feeding losses and the closure of cattle feeding businesses translate into even less competition and even more losses for the independent farmers and ranchers who are the very heart of the U.S. live cattle industry – the 757,000 remaining beef cattle operations comprised largely of independent cow/calf producers, backgrounder and stockers who are scattered all across America. Their numbers also are shrinking at an alarming rate, and Rural America is reeling from the consequential, rapid loss of its economic base. We may already have reached the point of no return: the point where it no longer matters if competition is restored because the industry may already lack the critical mass of independent cattle farmers and ranchers necessary to sustain a competitive industry.”

“The hog and poultry industries already have reached that point of no return, and unfortunately, the government’s answer to assist these now nearly fully corporate controlled livestock industries that have purged hundreds of thousands of independent farmers from their ranks is to send these corporations taxpayer money in the form of Troubled Asset Relief Program (TARP) funds or other emergency assistance,” Bullard said. “It’s very doubtful that any of that money will actually ever make it into the hands of the very few independent farmers remaining in either the dairy or hog industries.

“In fact, it’s probable that the lion’s share of that money will likely flow to the very corporations that – because they have been advantaged by corporate-oriented trade policies and have freely operated with impunity from proper enforcement of antitrust laws and prohibitions against anticompetitive practices – are largely responsible for gutting these industries in the first place,” he continued.

“The U.S. cattle industry, literally, is the last frontier within the U.S. livestock and poultry industries,” the letter explains. “It is the only remaining major livestock sector that is not already nearly completely vertically integrated by the mega-meatpackers and processors from birth-to-plate…but this distinction cannot last long under the ongoing and unbearable financial losses plaguing its independent participants.”

“Our nation’s meat safety and meat security are threatened by the continued lack of action on the part of the Administration and Congress,” Bullard emphasized. “Our U.S. cattle markets are broken. Our cattle prices are persistently below the cost of production. Our industry is shrinking, and all the while U.S. consumers are still paying near-record prices for beef to the dominant meatpackers and retailers. There is no light shining at the end of this tunnel. Immediate, decisive action must now be taken to avoid further destruction to the integrity and structure of our independent producer-based U.S. cattle industry.”

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

R-CALF USA FOOD SAFETY RECOMMENDATIONS 
 

The United States’ food safety problems will persist unless Congress addresses their root causes, which are unique to the United States and are three-fold: 

1.      Current food policies promote and facilitate the consolidation and contraction of independent farmers and ranchers and this is inherently dangerous to both food safety and food security. 

2.      Sound U.S food safety standards were weakened when Congress acquiesced to international standards that prohibit it from targeting food safety problems originating in foreign countries with stricter standards – unless Congress first applies the stricter standards to the U.S., regardless of whether the stricter standards are applicable to the U.S. food production system. 

3.      Congress’ adoption of the internationally-touted HACCP[1] food safety system hampers Congress’ ability to ensure that even existing food safety requirements are properly followed. 

Any attempt to remedy our food safety problems by building on these failed components, as was done in the Food Safety Enhancement Act of 2009 (H.R. 2749), would result in complete failure.     

 RECOMMENDATIONS 

1.      Correct and reverse the three above-listed fundamental deficiencies in our food system that makes genuine food safety in the U.S. unattainable.   

2.      Reestablish food safety standards previously weakened when Congress acquiesced to international standards, and then direct agencies responsible for food safety to begin hands-on inspection and enforcement of U.S. food safety standards for all imported food and for food processing facilities where food contamination is known to frequently occur. 

3.      Do not accord international standards more weight than is accorded any other standards, such as those recommended in studies by U.S. land grant universities.

4.      Do not presume that international standards – designed specifically to facilitate trade – are appropriate standards to be imposed on U.S. farmers and ranchers or that corporate food processors can adequately police themselves under HACCP. International standards must not be referenced or cited in U.S. food safety statutes, and HACCP must be reformed.

5.      Take no action that would impose any additional regulatory burdens on any U.S. farmer or rancher, including any requirement to register their farms and ranches with the federal government or participate in a federally mandated food traceability program.

6.      If Congress suspects that a particular segment of U.S. production agriculture is contributing to food safety problems, a formal risk and hazard analysis must be conducted to determine the specific practice(s) that caused or contributed to the food safety problem and the specific type of farming operation involved in that practice (i.e., an independent farming operation or an industrialized food production unit) to determine the specific corrective actions needed. 

Individual U.S. farmers and ranchers deserve no less from Congress than to be presumed careful, conscientious, and law abiding food producers – a reputation earned by them while feeding this great nation during the past two centuries. 

R-CALF USA's letter to all U.S. Senators.

Billings, Mont. – The U.S. Department of Agriculture (USDA) has partnered with Allflex, a private multinational firm that manufactures and sells ear tags in more than seven countries, to help Allflex market, promote and sell ear tags to U.S. cattle producers. Both USDA and Allflex contributed $10,000 or more to become “Platinum Level” sponsors of the private industry conference ID∙INFO EXPO 2009 to be held August 25-27 at the Westin Crown Center in Kansas City, Mo. Among the stated purposes of the conference is to further participation in USDA’s National Animal Identification System (NAIS), a program that would significantly increase the market demand for ear tags.

“This is a perfect example of how USDA is inappropriately using taxpayer dollars to further the interests of private multinational companies,” said R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group’s animal health committee. “This huge contribution clearly shows that USDA is catering to the interests of multinational corporations to the exclusion of the hard-working men and women who are being besieged both by ear tag companies and USDA to force them to comply with NAIS.”

In each of the 14 NAIS listening sessions held throughout the U.S. during May through June, overwhelming opposition was raised by U.S. farmers and ranchers against the USDA’s NAIS program. 

“Despite this overwhelming opposition, and despite repeated pleas from U.S. farmers and ranchers that USDA cease catering to the interests of multinational corporations and begin listening to the concerns of U.S. citizens,  the agency obviously is forging ahead to help its corporate friends,” Thornsberry said.

“Allflex is among a select list of USDA-authorized ear tag manufacturers, so its help from USDA to boost demand for ear tags under NAIS is certain to boost the company’s marketing opportunities,” he added. “We are appalled by USDA’s brazen financial partnership with Allflex and urge Congress to immediately cut all further funding to USDA for the purpose of promoting NAIS.”

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

Billings, Mont. – On Friday, May 15, 2009, the Canadian Food Inspection Agency (CFIA) announced yet another case of bovine spongiform encephalopathy (BSE) – this time in an 80-month-old Alberta dairy cow. This cow would have been born in 2002, making her the 10^th BSE-positive cow young enough to be exported to the United States. In November 2007, the U.S. Department of Agriculture (USDA) implemented a rule to allow the importation of higher-risk Canadian cattle – cattle over 30 months (OTM) of age – into the United States, as long as they were born after March 1, 1999. 

Op-Ed by R-CALF USA President/Region VI Director Max Thornsberry 

Billings, Mont. / Richland, Mo. – Everyone knows that many successful cattle operations rely upon the dedicated loyalty of a well-trained cow horse that can anticipate exactly what to do at the appropriate moment to accomplish the task at hand. R-CALF USA, as a trade association for independent U.S. cattle producers, recognizes this fact, and as such, not only do we oppose the National Animal Identification System (NAIS) overall as a violation of each citizen’s constitutional rights, but we oppose NAIS because of its invasive requirements to demand the reporting of each and every movement of our horses, whether such movement is across the county line, to another pasture, or down the road to a roping, show or rodeo. 

Horse owners should know why the National Animal Identification System (NAIS) is being forced on their industry. The U.S. signed a World Trade Organization (WTO) treaty and is now submitting to global rules on animal trade established by the World Organization for Animal Health (OIE). The OIE wants the U.S. to accept imports from countries where animal disease problems persist. For example, while the U.S. eradicated Equine Piroplasmosis – a tick-borne protozoal infection, the OIE wants the U.S. to accept imports from countries that have not eradicated this disease. With NAIS, horse movements could be traced from birth to death, thus eliminating the need to disallow high-risk imports because, according to the OIE, the U.S. could manage contagious diseases within its borders.

The U.S. Department of Agriculture (USDA) is not following its mandate to prevent the introduction of foreign animal diseases. Instead, USDA spent over $100 million to entice livestock owners to register their property in an NAIS database and obtain a “free” NAIS Premises Identification Number (PIN). Most equine owners and cattle owners have refused to register for this internationally sanctioned encumbrance to their private property. USDA says a PIN is needed to identify all livestock owners’ property so it can trace the movement of animals in the event of a disease outbreak. 

Yet, in Missouri, and I am sure in most states, a 9-1-1 call will bring emergency officials to your doorstep in minutes. At USDA offices, you can obtain your farm description, including an aerial photograph. On Google Earth you can obtain a satellite photograph of sufficient detail to count the horses in your pasture – and USDA says it cannot find your farm following a disease outbreak?

The reason USDA wants you to register under NAIS has nothing to do with its ability to find your farm. Instead, when asked why USDA was pushing so hard for NAIS, former USDA Under Secretary Bruce Knight, in September 2007, told a large group of bovine practitioners at our annual meeting in Vancouver, Canada: “It is quite simple. We want to be in compliance with OIE regulations by 2010.”

USDA told Congress that NAIS would have to be electronic to function properly. This means brands, tattoos, or individual color markings or descriptions would be unsuitable. The only acceptable means of electronically identifying equines is a surgically implanted, glass enclosed electronic microchip. This process is not as simple as some believe. When implanting a chip into a horse, I clip or shave the area, scrub it with surgical preparation soap and spray it with surgical site disinfectant. I then inject the area over the implant site with lidocaine to numb the skin and underlying tissues. To maintain sterility of the chips, I surgically scrub my hands and don surgical gloves. Only after this preparation do I implant the chip in the nuchal ligament of the mid-neck area of my equine patient.

The glass-enclosed chips do not always stay put. Like a splinter in your finger, the body often mounts a response to a foreign object, even one as innocuous as a piece of sterile glass. The response may include the formation of a sterile abscess around the chip, or it may remain painful and generate a negative response when the horse turns its neck. Chips are known to migrate within the body, and finding a chip in some animals becomes a major undertaking. A small percentage of veterinary patients have developed a cancerous growth at the site of implantation. While the incidence is low in animals with short lives, an equine patient has more time to develop a cancerous growth around the implanted chip. 

I don’t know about all equine owners, but most cattle producers do not appreciate an international agency telling us what we can and cannot do with our livestock in the United States. The U.S. has spent untold millions of dollars to eradicate many serious contagious animal diseases. Why would we now expose our privately owned animals to contagious animal diseases just to give away access to our marketplace to animals and meat from countries that chose not to invest in resources to control and eradicate diseases within their country? 

We live in the United States, not the WTO. We have a Constitution that directs our legal system, not the OIE. We have a government by the people, for the people, and of the people. It is time for the people to stand up and say, “Enough with this one world government!” 

Unless equine owners join with other livestock producers to oppose this nonsense, NAIS will become mandatory in the United States. It will cost equine owners in excess of $50/head to implant the electronic microchip. You will then be required to report any movement of your horses when they leave your property for any reason. A study released by USDA the last week of April 2009 and completed by KansasStateUniversity shows that the annual cost of identifying horses individually with microchips is $75.51 per horse. You can see my estimate of $50+/head is considerably lower than what this recent study shows. 

Imagine the bureaucratic nightmare and paperwork requirements of reporting to your government every time you go on a trail ride, go to a show or event, or trailer your mare to a stud. There would have to be an NAIS office in every county seat to process all this data, keep track of your information and report any violations to USDA. Just imagine the fines and enforcement actions that equine and other livestock owners would be subject to right here in the United States of America.

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALFUSA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALFUSA directors and committee chairs are extremely active unpaid volunteers. R-CALFUSA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

Op-Ed by R-CALF USA Region V Director Stayton Weldon

Billings, Mont. / Cuero, Texas – Inherent to every competitive industry is proprietary information. If one competitor gains access to the proprietary information of another, then any competitive advantage associated with that proprietary information is at best lost. At worst, the acquirer of that proprietary information could use it to eliminate competitors. Nowhere in the U.S. economy is proprietary information more important to ensuring competitiveness than in the multi-segmented live cattle industry and beef industry. 

USDA’s (U.S. Department of Agriculture’s) National Animal Identification System (NAIS), however, would grant the four largest meatpackers access to proprietary information held by the tens of thousands of U.S. auction yards and video auctions (markets), as well as cattle feeders. NAIS requires every cattle producer to affix a 15-digit identifier on each animal, which associates each animal to the “premises” of the farmer or rancher who raised the cattle and who sells them to feedlot owners through such markets. 

NAIS will reduce, if not eliminate, competition in the U.S. cattle and beef industries by granting meatpackers access to proprietary information now held by those markets and feedlots, vis-à-vis the 15-digit identifier. Here’s how: 

There are approximately 757,000 independent beef cattle producers remaining in the U.S. who sell approximately 69 percent of their feeder cattle through auction yards and video auctions to the remaining 87,160 U.S. feedlots that, in turn, sell approximately 88 percent of their fed cattle to just four major meatpackers for slaughter. Business relationships have been built between individual cattle producers and these markets and feedlots and they all compete with other similar businesses to acquire the numbers and type of feeder cattle best suited to their respective marketing and feeding programs.   

Over time, these markets and feedlots earn reputations for sourcing, marketing and feeding the specific quality and type of cattle highly coveted by the concentrated meatpackers. Thus, information about the source of the cattle acquired by said markets and feedlots is the proprietary information they use to maintain their competitive edge – and they often pay premiums to, or secure a higher price for, the cattle producers in order to acquire these cattle year-after-year.

To maintain competitiveness, the feedlots and markets do not disclose to meatpackers the sources of their cattle, as these sources are their proprietary information. NAIS, however, would hand this proprietary information over to meatpackers, enabling them to bypass the auction yard, video auction and feedlots by purchasing the specific quality and type of feeder cattle they want directly from the producer and then placing those cattle in their packer-owned feedlots. This would destroy the competitiveness of independent feedlots and the industry markets. 

 What makes this possible is the 15-digit NAIS number affixed to every head of cattle that is directly associated with the property (premises) of the producer who raised the cattle. The NAIS Business Plan clearly states that distribution records for NAIS eartags are required and also are automatically linked to the cattle owner’s premises identification number. All a meatpacker would have to do is collect the NAIS numbers from cattle they slaughter that are of the quality and type they desire and contact the eartag manufacturer to determine the owner of the “premises” those cattle are linked to. Anyone who thinks the meatpackers are without the means to readily obtain this information is kidding themselves.   

In further support of the accessibility of this proprietary information for purposes other than for official disease investigations, the NAIS Business Plan expressly states that these 15-digit NAIS numbers are a convenient means of verifying the origins of cattle for purposes of complying with the new country-of-origin labeling (COOL) law. Such use, of course, would necessarily require access to this proprietary information upon a claim by a meatpacker or other party for non-compliance with COOL, and access to this information in such instances would be for marketing purposes, not for any disease investigation.   

NAIS is but a veiled, governmental marketing program designed to economically disadvantage independent U.S. cattle producers by reducing what little competition remains in the highly concentrated and quickly shrinking U.S. cattle industry.

                                                                                                             # # #

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

Billings, Mont. – Western Ag Reporter Editor Linda Grosskopf, in the April 23, 2009, edition, published a headline that reads, “NAIS...Has R-CALF had a change of mind? If so, what about their policy?” (See:http://www.westernagreporter.com/index.php?option=com_content&view=article&id=1474:nais&catid=3:this-weeks-articles&Itemid=12.) With this headline, Grosskopf publicly – and incorrectly – raises the specter that because    R-CALFUSA supports the expansion of the preexisting brucellosis-type identification system to identify breeding cattle in commerce, the organization has reversed its strong opposition to the National Animal Identification System (NAIS) and has violated its member-established policy.

 “This allegation is demonstrably false and is a blatant attempt by the Western Ag Reporter to undermine and discredit     R-CALFUSA and its members,” said R-CALF USA President/Region VI Director Max Thornsberry. “Western Ag Reporter’s latest attempt to discredit this organization is a tremendous disservice to our members and demonstrates a complete lack of journalistic ethics.
 

“The Western Ag Reporter made no effort to contact R-CALFUSA before it issued its unprovoked public attack and it chose to selectively publish only one of R-CALFUSA’s nine separate policies that address animal identification and NAIS,” he pointed out. “Also, it unethically rearranged and manipulated the article written by Steve Bjerklie, published April 17 at www.meatpoultry.com, to deceptively fabricate and then exaggerate its erroneous claim that R-CALF USA’s position was not grounded in member-established policy. This action is an irresponsible and dishonest attempt to further the interests of pro-NAIS agribusinesses and to undercut the interests of hard-working U.S. cattle producers.” 

R-CALF USA is nationally recognized as the most formidable opponent to the NAIS and is the only organization in complete opposition to the program that has been called on by the U.S. House of Representatives’ Committee on Agriculture, Subcommittee on Livestock, Dairy, and Poultry, and called on by Agriculture Secretary Tom Vilsack, to provide both oral and written testimony to express its members’ views.

 “The Western Ag Reporter’s attack on R-CALF USA plays right into the hands of USDA (U.S. Department of Agriculture) and its NAIS supporters and could potentially weaken the credibility and momentum R-CALF USA has gained in our fight to defend the rights and privileges of independent cattle producers by stopping NAIS,” said R-CALF USA CEO Bill Bullard. “In addition, R-CALFUSA is the only organization that, since 2006, has offered a complete alternative to NAIS as a means of enhancing our nation’s disease traceback capabilities without adopting the invasive NAIS program.” 

In 2006, R-CALFUSA’s board adopted interim policy to support a nationwide expansion of the preexisting brucellosis program-type identification system to enhance our nation’s disease traceback capabilities, which identifies breeding animals with a metal postal-code eartag that does not require premises registration or the report of animal movement.
 

Western Ag Reporter was made aware of this recommendation as early as December 2006 when R-CALFUSA issued a news release announcing it had sent a letter to then-Agriculture Secretary Mike Johanns urging him to adopt R-CALFUSA’s proposal in lieu of pursuing NAIS. 

Yet again, in May 2007, the Western Ag Reporter was informed that R-CALF USA’s membership had adopted the 2006 policy when the organization issued a news release titled “Members Approve Two Animal Health Resolutions.” And in June 2008, the Western Ag Reporter received the group’s news release titled “USDA Urged Yet Again to Reallocate from NAIS Budget Funds to Continue Brucellosis Vaccination, Surveillance.” 

And, in March 2009, the Western Ag Reporter was apprised of R-CALFUSA’s member-established policy in a news release titled “Promise for Change? Not for U.S. Livestock Producers when it comes to NAIS.”

In 2007, R-CALFUSA members overwhelmingly voted to request that USDA use the brucellosis-type identification system currently being used on breeding stock to enhance animal disease traceback. R-CALFUSA has advocated this alternative to NAIS for nearly three years in letters and formal comments submitted to USDA. Specifically, R-CALFUSA member-established policy requests USDA to:

* [C]ontinue brucellosis testing, vaccination, and surveillance in states where such action already occurs, and to implement brucellosis surveillance in all other states where cattle are present but no formal testing program is in place, and to fund all such programs.

* Maintain a nationwide brucellosis surveillance/vaccination program, which would be a means to provide a proven method of animal identification for livestock disease traceback purposes, with minimal financial burden or recordkeeping burdens on independent U.S. livestock producers and related livestock marketing facilities.

*[Use]USDA funds presently appropriated for an animal identification program to be redirected to fund ongoing and existing brucellosis surveillance/vaccination programs.

 R-CALF USA’s animal identification member-established policy passed in 2008 reiterates this animal health position: 

R-CALF USA recommends that USDA-APHIS continue the funding of ear tags and systems pre-dating NAIS for federal disease control programs for livestock and an animal health traceback identification program, in conjunction with brand laws. All data would continue to be held by the states and APHIS, as it is currently. R-CALF USA opposes harmonization of these existing systems with, or the use of, these existing systems to implement or promote NAIS.  

In addition, R-CALFUSA perhaps has the strongest policy against NAIS of any organization, as it expressly opposes registration of private property as a premises and any requirement for producer participation in NAIS.
 

R-CALF USA’s 8-Point Plan clearly states that “R-CALF USA urges Congress and USDA to immediately and completely abandon the flawed National Animal Identification System,” that Congress and USDA should “focus on targeted solutions to the legitimate livestock disease-related challenges faced by U.S. livestock industries,” and, “Under no circumstances should the Federal government maintain a national registry of U.S. livestock or require the national registration of producers’ real property.” This plan would enhance disease traceability without infringing on the rights and privileges of independent U.S. cattle producers. 

In its 8-Point Plan, R-CALF USA combined its member policies: on international trade to call for increased import restrictions to prevent disease introduction as well as permanent branding of all imported live cattle; on animal health to call for identification of breeding stock under a national brucellosis-type identification system, to require tuberculosis testing and quarantine of Mexican cattle, and to focus on disease eradication efforts in wildlife populations; on animal identification to call for a complete end to NAIS, including premises registration; on food safety to require that all imported cattle and beef meet identical – not equivalent – U.S. health and safety standards and to call for increased enforcement of food safety standards in U.S. slaughterhouses. 

“There is nothing even remotely inconsistent with our members’ fierce opposition to NAIS and our strong support for an expanded brucellosis-type system to restore our once-high level of animal identification in our U.S. breeding herd,” Thornsberry pointed out. “In fact, NAIS would completely supplant the brucellosis-type program, eliminating the local veterinarian’s control over what contact information is needed to associate tagged animals with their owner, as well as eliminate the metal postal-code eartag. 

“Every recommendation in R-CALFUSA’s 8-Point Plan is fully and completely supported by member-established policies developed by the thousands of R-CALFUSA members who own cattle,” he continued. 
 

“We can only hope the Western Ag Reporter has not destroyed R-CALFUSA’s efforts to completely block NAIS and to redirect USDA so the agency can strike off on a more responsible course to address the legitimate need to continually improve our nation’s disease traceback capabilities,” he concluded.

# # #

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALFUSA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALFUSA directors and committee chairs are extremely active unpaid volunteers. R-CALFUSA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

Op-Ed by R-CALF USA CEO Bill Bullard 

FDA Plans to Break Food Safety Promise to America

Washington, D.C. – The U.S. Food and Drug Administration (FDA) plans to break its promise to American consumers to timely upgrade the animal feed ban designed to protect U.S. consumers and the U.S. cattle herd against the heightened risk of bovine spongiform encephalopathy (BSE, or mad cow disease).   

Scientific studies have linked BSE to cases of variant Creutzfeldt-Jakob Disease (vCJD) in humans, an invariably fatal disease that most likely results from human consumption of infectious material from cattle with BSE. There have been 212 human deaths in 11 countries caused by vCJD, including the United Kingdom, and there are five known living humans with the disease.      

On April 9, FDA published a special filing in the Federal Register giving the public only seven days to comment on the agency’s plans to delay the scheduled April 27, 2009, implementation of its upgraded BSE feed ban. 

The U.S. faces a heightened risk from mad cow disease because it continues to import millions of live cattle from Canada, where the disease prevalence is between three cases per million cattle to eight cases per million cattle. The U.S. Centers for Disease Control and Prevention (CDC) states this prevalence in Canadian cattle is 18-fold to 48-fold higher than the prevalence in the United States. 

The World Organization for Animal Health (OIE) and scientists the world over stated that Canada’s heightened BSE risk cannot be effectively mitigated with the basic ruminant-to-ruminant feed ban implemented in both Canada and the U.S. in 1997. Following the detection of multiple cases of mad cow disease in cattle born years after Canada’s original feed ban, Canada finally relented to scientists’ urgings and upgraded its basic feed ban in July 2007. The new feed ban protects Canadian consumers against known BSE transmission routes: cross-contamination and inadvertent feeding of contaminated cattle parts. Unfortunately, 10 of Canada’s 16 native mad cow disease cases were found in animals born after the implementation of Canada’s original feed ban.

One year ago, the FDA issued a news release touting its promise to upgrade the U.S. feed ban by stating, “FDA Strengthens Safeguards for Consumers of Beef,” and informing consumers that the new feed ban would become effective on April 27, 2009,  after allowing time for the industry to adapt its practices to the new requirements.
 

But even before that, in late 2007, the U.S. Department of Agriculture (USDA) issued regulations that now allow even higher-risk Canadian cattle into the U.S. – cattle over 30 months (OTM) of age. USDA’s base-case risk model predicts that the importation of OTM cattle will result in the introduction of 19 BSE-infected cattle into the U.S. causing the subsequent infection of two U.S. cattle over the next 20 years. Human exposure to BSE also was predicted to increase by more than 15 percent compared the earlier base-case modeling conducted in 2003 by Harvard University.
 

The unconscionable irony is that the U.S. is importing millions of higher-risk Canadian cattle – allowing them to commingle with the U.S. cattle herd and to freely enter the U.S. human food supply and animal feed supply – without affording U.S. consumers and the U.S. cattle herd the benefit of the scientific safeguards implemented by Canada to protect its citizens and its cattle herd from the BSE infectivity known to be circulating in its cattle herd. In short, the U.S. is accepting Canada’s higher BSE risk without the protections necessary to mitigate that higher risk.  
 

The thousands of U.S. cattle producer-members of R-CALF USA recognize that we have an absolute obligation to protect our U.S. consumers from mad cow disease. Together, the USDA and FDA are undermining our efforts. Under no circumstances should FDA delay implementation of the new feed ban, which already has been found necessary to mitigate Canada’s heightened BSE risk, while the U.S. continues to import Canada’s higher-risk cattle.  
 

Either USDA must immediately eliminate the source of this heightened BSE risk by prohibiting the importation of OTM Canadian cattle, or, FDA must immediately implement the new feed ban to mitigate this heightened risk. There are no responsible alternatives. The FDA has an absolute duty to protect U.S. citizens from the foreign health threat of BSE and must not kowtow to the very industry trade associations – the National Cattlemen’s Beef Association and the American Farm Bureau Foundation – that are fighting to expose U.S. consumers to Canada’s BSE risk before Canada can demonstrate that it has eradicated this deadly disease from its cattle herd.    

Note: Click here to view/download a copy of R-CALF USA’s comments filed with FDA.

                                                                                                             # # #

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

In a roundtable discussion today, Agriculture Secretary Tom Vilsack listened to concerns about the agency’s proposed National Animal Identification System (NAIS) from representatives of various U.S. livestock industries, including R-CALF USA CEO Bill Bullard. 

“NAIS is a radical departure from the highly successful, preexisting disease programs and represents an unwarranted expansion of government agency power that R-CALF USA believes is prohibited under our Constitution,” Bullard asserted. “We believe NAIS is an invasive and unlawful encumbrance on commerce, and its effect is to impose additional production costs on every livestock producer, whether or not they are affected by a disease event, without affording livestock producers any means of recovering those additional production costs from the marketplace. 

“R-CALF also is concerned that NAIS would subject U.S. cattle producers to enforcement and compliance costs associated with the third-party management of a colossal database within which culpability would be difficult to determine – yet producers would remain subject to a command-control relationship with the third-party administrator, the federal government,” he pointed out. “In addition, USDA has provided no analysis that contradicts the effectiveness of the preexisting systems that did not require producers to register their property in a federal database, nor has the agency provided any basis for asserting that such registration would function better than preexisting systems.” 

During the discussion, Vilsack said it is important for USDA (U.S. Department of Agriculture) to listen and learn and that his conversations about NAIS are only beginning. He also mentioned upcoming listening sessions to be scheduled around the country, as well as more opportunities for producers to file comments about NAIS.

Note: To view/download a copy of R-CALF USA’s submission at the NAIS roundtable, please click here.

FDA Comment Period on Feed Ban Starts Today – Ends April 16

Please consider commenting on FDA’s plan to delay the scheduled April 27, 2009, implementation of the BSE feed ban needed to address the heighted risk of BSE we already have assumed by allowing high-risk Canadian cattle into the United States.

Below is a short background, instructions on how to submit comments, and a sample letter you can use to submit your comments.  We need thousands of comments on this issue!

Background:   Our April 7 Member Alert provided more background on this issue but today the U.S. Food and Drug Administration (FDA) has opened a 7-day public comment period to solicit public comments on whether the FDA should delay implementation of its upgraded bovine spongiform encephalopathy (BSE) feed ban.  The U.S. Department of Agriculture (USDA) and the FDA have purposely positioned the cattle industry between a rock and a hard place.

There is no doubt that cattle producers who rely on rendering services to pick up deadstock will experience a hardship if the FDA’s new BSE feed ban rule takes effect.  The government is banking on cattle producers to support this last minute delay for this very reason.  But, the government has purposely backed our cattle industry into a corner and we should not kowtow to its manipulation. 

The fact is that the government, through USDA, purposely exposed U.S. consumers and the U.S. cattle herd to an unacceptable risk of BSE by allowing Canada’s highest-risk cattle – cattle over 30 months (OTM) of age – to freely enter the U.S. food supply, feed supply, and cattle herd.  USDA should not have allowed these higher-risk cattle into the U.S. until after it determined if it was feasible to assume the additional costs necessary to mitigate this increased risk – the cost of upgrading the U.S. feed ban.

But this is exactly what has happened and this is what we are now faced with.  We now have a choice:  We can either do what is right to protect the health and safety of our cattle herd and our consumers or we can kowtow to the government and follow the path that they have devised for us.  R-CALF USA chooses to do what is right!

We must force the government to do what is right as well.  So, must change-up this debate and instead of capitulating to the government’s manipulative tactics, we should give them a choice:  Either eliminate the source of our higher BSE risk by closing the border to OTM Canadian cattle or immediately implement the upgraded feed ban needed to minimize this higher risk.  There are no responsible alternatives. 

Below is a sample letter you can use to submit your comments to the FDA.  We need thousands of comments submitted within the next 7 days, so please circulate this Alert as widely as possible and encourage as many people as possible to submit comments as well. 

How to submit your written comments (Deadline April 16, 2009):   
 

1.      Go to:         www.regulations.gov

2.      Type in:      FDA-2002-N-0031

3.      Click on:     box that states: “Select to find documents accepting comments or submissions.”

4.      Click on:     Go>>

5.      Click on:     the balloon shaped icon that states “Send a Comment or Submission.”

6.      Follow the instructions on the “Public Comment and Submission Form.”

Sample Comment Letter for Your Use (You are free to use all or part of this letter):
     

April 9, 2009 

Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD  20852 

Re:      Docket Number:  FDA-2002-N-0031 (formerly Docket No. 2002N-0273) 

Dear Administrator, 

            Under no circumstances should the U.S. Food and Drug Administration (FDA) delay its April 27, 2009, scheduled implementation of the final rule titled “Substances Prohibited from Use in Animal Food or Feed,” commonly referred to as the 2008 BSE final rule, while the U.S. Department of Agriculture (USDA) continues to subject U.S. consumers and the U.S. cattle herd to a heighted risk of bovine spongiform encephalopathy (BSE) from imports of live Canadian cattle, particularly imports of Canadian cattle over 30 months (OTM) of age. 

            U.S. consumers and the U.S. cattle herd are now subjected to a heightened risk of BSE because the U.S. continues to import millions of live cattle from Canada, where the disease prevalence is between three cases per million to eight cases per million cattle. The U.S. Centers for Disease Control and Prevention (CDC) states this level of BSE prevalence in the Canadian cattle herd is 18-fold to 48-fold higher than the prevalence estimated in the U.S. cattle herd. Just in 2008, nearly 1.6 million Canadian cattle were imported into the United States.    

When USDA reopened the U.S. border in 2007 to Canada’s highest-risk cattle population – OTM cattle –  its risk modeling based on a Canadian BSE prevalence of fewer than 4 cases per million predicted that the U.S. would import over 100 head of BSE-infected cattle from Canada over the next 20 years. In addition, the risk modeling showed that human exposure to BSE would increase. However, as the CDC explained, the BSE prevalence in Canada could well be 8 cases per million, meaning that USDA likely has grossly underestimated the risk of introducing BSE-infected cattle into the U.S. as a result of allowing OTM Canadian cattle imports.  

Canada already has detected 16 native cases of BSE in its OTM cattle herd, 10 of which were born after the 1997 feed ban. The most recent of these cases was detected just last November. Nine of Canada’s BSE-infected cattle met USDA’s age requirements to be exported to the United States, as they were born after March 1, 1999, the date after which USDA erroneously claims BSE-infectivity was no longer circulating in Canada.                

The current U.S. feed ban implemented in 1997 is comparable to the initial Canadian feed ban also implemented in 1997. Canada’s feed ban proved ineffective at preventing the spread of BSE in Canada. Despite the repeated urging of international scientists, Canada resisted any upgrades to its feed ban until after it detected multiple BSE cases in cattle born years after its 1997 feed ban. Canada’s July 2007 upgraded feed ban now protects Canadian consumers against the spread of BSE from Canadian cattle by closing known transmission routes, including cross-contamination and inadvertent feeding of contaminated cattle parts. It is unthinkable that the FDA would not afford U.S. consumers the same level of protection against these same Canadian cattle that are imported into the United States. 

            The FDA cannot legitimately argue that its current feed ban implemented in 1997, which is nearly identical to Canada’s original feed ban also implemented in 1997, is any more effective at mitigating Canada’s heightened BSE risk within U.S. borders than it was in mitigating Canada’s heightened BSE risk in Canada. Nor can FDA ignore the scientific evidence that overwhelmingly shows that the current U.S. feed ban is insufficient to mitigate the heightened BSE risk associated with OTM cattle imported from Canada. These higher-risk OTM Canadian cattle are entering the U.S. at the rate of several thousand per week, are being commingled in the U.S. cattle herd where some would be expected to die, and are entering both the U.S. food system as well as the U.S. animal feed system. The U.S. already is accepting Canada’s higher BSE risk without the protections necessary to mitigate that higher risk.  

The FDA cannot bury its head in the sand and pretend the upgraded feed ban contained in the 2008 BSE final rule is not urgently needed to mitigate the increased BSE risk associated with the importation of millions of Canadian cattle. In fact, the FDA already has failed to timely implement an upgraded feed ban, which should have been implemented before USDA began to expose U.S. consumers and the U.S. cattle herd to Canada’s heightened BSE risk. 

            The FDA has an absolute responsibility to protect the health and safety of U.S. consumers and the U.S. cattle herd against this foreign animal disease that is always fatal, believed to be transferable to humans, and is not known to be circulating in the U.S. cattle herd. The FDA must break away from the manipulative actions by corporate-controlled, self-serving trade associations that have caused both FDA and USDA to endanger the health and safety of U.S. consumers and the U.S. cattle herd by exposing them to an unnecessary and avoidable risk of BSE.

             Either USDA must immediately eliminate the source of this heightened BSE risk by prohibiting the importation of OTM Canadian cattle, or FDA must immediately implement the 2008 BSE final rule to mitigate this heightened risk. There are no responsible alternatives.

Sincerely,

Op-Ed 

NAIS Will Hamper Cattle Disease Traceback Efforts 

This 671-word piece is authored by R-CALF USA Animal Identification Committee Chair Kenny Fox, a 3^rd generation cow/calf producer who has fought tirelessly against NAIS since 2003.  

Billings, Mont. / Belvidere, S.D. – The U.S. Department of Agriculture (USDA) wants cattle owners to register their real property, as well as each animal they own, in a new federal database. This is the first step in USDA’s plan to implement a National Animal Identification System (NAIS). USDA claims NAIS would reduce disease spread by shortening the time it takes to identify the birthplace of cattle suspected of disease.  

If it sounds too good to be true, it generally is.

After USDA forces producers to register their property and cattle in its federal database, the agency will replace the numbering systems now used on existing disease-oriented identification devices with a new numbering system that includes an “840” prefix. This “840” prefix is the international number assigned to the United States of America. Under NAIS, all cattle born in the U.S. would be identified with a string of numbers beginning with the “840” prefix. To determine where in the United States an individual animal was born, however, health officials must first access the federal NAIS database – and hope there are no errors in the database, which would contain 100 million or more “840” prefix numbers for U.S. cattle.  

If an answer is found by following the money, it’s generally right. 

This “840” system benefits multinational meatpackers who now must pay premiums to U.S. cattle producers so they will voluntarily participate in value-added programs that verify the U.S. origin of their cattle. This value-added service makes the beef from their cattle eligible for export. But, under USDA’s mandate, all cattle born in the U.S. would officially be verified as having a U.S. origin, and no longer would meatpackers have to pay any premiums to U.S. cattle producers. What a deal!   

If something smells fishy, it generally is. 

But, what does this international “840” prefix – which is paramount to the government’s NAIS – have to do with shortening the time to trace a suspected diseased animal back to its birthplace? Nothing.   

The most important component of USDA’s NAIS scheme – the “840” number assigned to all U.S.-born livestock – has no value in tracing an animal suspected of disease back to its birthplace. How could it? Every bull, cow, heifer and steer in the U.S. that does not have an official foreign import marking, as is presently required for all cattle imported from both Canada and Mexico, is already known to originate in the United States. The “840” prefix provides U.S. health officials with no information they do not already have.  

If you suspect your government is lying, quit supporting its nonsense. 

NAIS is designed to increase the profitability of multinational meatpackers that want cattle producers to pay the market cost of verifying the U.S. origin of beef destined for export. NAIS accomplishes this by eliminating the current disease-oriented numbering system that uses 50 different prefixes to identify which of the 50 states the animal is from and the numbering sequence that identifies the local veterinarian who applied the identification device to the animal.   

Under the existing system, a cow suspected of a disease anywhere in the U.S. would bear a metal eartag with a prefix number that identifies the state from which the animal originated. With a phone call to that state, the identity of the local veterinarian who applied the eartag and the location of the original owner could be found. Quarantine and other containment measures, if necessary, could immediately be initiated – no waiting to access a computer to access the NAIS database, no worry that data in the NAIS database may be corrupted, and no need for the federal government to maintain private data on citizens.   

I urge you to contact your U.S. Senators and Representative to tell them to put a stop to this NAIS nonsense. The role of government is to protect, not to give multinational meatpackers an advantage in the international market. To learn how the government can improve our nation’s ability to prevent and control livestock diseases without infringing on the rights and privileges of cattle producers, visit www.r-calfusa.com and click on “Animal ID.” 

# # # 

R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, non-profit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. R-CALF USA represents thousands of U.S. cattle producers on trade and marketing issues. Members are located across 47 states and are primarily cow/calf operators, cattle backgrounders, and/or feedlot owners. R-CALF USA directors and committee chairs are extremely active unpaid volunteers. R-CALF USA has dozens of affiliate organizations and various main-street businesses are associate members. For more information, visit www.r-calfusa.com  or, call 406-252-2516.   

A printable version is available here.

 For a printable version visit http://www.r-calfusa.com/animal_id/090331-eight_point.pdf

Eight-Point Alternative to NAIS

A Practical Solution to Improve Animal Disease Prevention, Control and Eradication,
As well as Meat Food Safety in the United States

R-CALF USA

March 31, 2009 

R-CALF USA urges Congress and USDA to immediately and completely abandon the flawed National Animal Identification System (NAIS). Instead, R-CALF USA recommends that Congress and USDA focus on targeted solutions to the legitimate livestock disease-related challenges faced by U.S. livestock industries, and take steps to meaningfully address legitimate food safety challenges, as are evidenced by recent and massive recalls of meat produced in U.S. slaughtering plants. Specifically, R-CALF USA recommends the following eight-point alternative course:

 1.      Prevent the importation of serious cattle diseases and pests from foreign sources by: 

a.       Prohibiting the importation of livestock from any country that experiences outbreaks of serious zoonotic diseases, including pests, until scientific evidence demonstrates the diseases and/or pests have been eradicated or fully controlled and there is no known risk of further spread. This recommendation includes a request for an immediate ban on live cattle imports from Canada, which harbor a heightened risk for BSE. 

b.      Requiring all imported livestock to be permanently and conspicuously branded with a mark of origin so identification can be made if a zoonotic disease or serious pest outbreak occurs in the exporting country subsequent to importation. 

c.       Requiring all livestock imported into the United States to meet health and safety standards identical to those established for the United States, including adherence to U.S. prohibitions against certain feed ingredients, pesticide use on feedstuffs, and certain livestock pharmaceuticals. 

d.      Requiring TB testing of all imported Mexican cattle and further requiring that all Mexican cattle remain quarantined in designated feedlots until slaughtered. 

e.       Reversing USDA’s efforts to carve out regions within disease-affected foreign countries in order to facilitate imports from the affected country before the disease of concern is fully controlled or eradicated. 

f.        Increasing the testing of all imported meat and bone meal to prohibit contaminated feed from entering the United States. 

2.      Adopt the surveillance and identification components of the preexisting brucellosis program, including the metal eartag and tattoo that identifies the state-of-origin and the local veterinarian who applied the identification devices, and require breeding stock not otherwise identified through breed registries to be identified at the first point of ownership transfer.     

3.      State and Tribal animal health officials should be solely responsible for maintaining a statewide database for all metal tags applied within their respective jurisdictions and should continue to use the mailing address and/or the production unit identifier determined appropriate by the attending veterinarian to achieve traceback to the herd of origin should a disease event occur. Under no circumstances should the Federal government maintain a national registry of U.S. livestock or require the national registration of producers’ real property. 

4.      The Federal government should enter into agreements with State and Tribal animal health officials to pay for the States’ and Tribal governments’ costs of identifying breeding stock and maintaining the State and Tribal databases, as well as bolstering disease surveillance at livestock collection points such as livestock auction yards and slaughtering plants, including increased surveillance for BSE. 

5.      The Federal government should coordinate with the States and Tribes to establish electronic interface standards and to establish improved communication protocols so it can more effectively coordinate with the States and Tribes in the event of a disease outbreak. 

6.      The Federal government should coordinate with the States and Tribes to establish improved protocols for the retention and searchability of State and Tribal health certificates, brand inspection documents and other documents used to facilitate interstate movement of livestock.   

7.      Establish specific disease programs and focus increased resources toward the eradication of diseased wildlife in States where wildlife populations are known to harbor communicable diseases. 

8.      To address the challenge of increased incidences of tainted meat products, Congress and USDA must substantially reform the current hands-off inspection system known as Hazard Analysis and Critical Control Point (HACCP).  HACCP has fundamentally failed to ensure adequate sanitary practices at major slaughterhouse establishments.  As part of the HACCP reform, Congress should implement a requirement that meat sold at retail and at food service establishments be traceable back to the slaughterhouse that produced the meat from live animals, not just back to the processor that may have further processed tainted meat. This simple improvement would enable investigators to determine and address the actual source of meat contamination – primarily the unsanitary conditions that allow enteric-origin pathogens, such as E. coli O157:H7, to contaminate otherwise healthful meat.

R-CALF USA - P.O. Box 30715 Billings, MT 59107 Phone: 406-252-2516 Fax: 406-252-3176
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E-mail: laurelmasterson@r-calfusa.com