December 21, 2011
www.gfb.org
Vol. 29 No. 51
GFB SUBMITS COMMENTS ON PROPOSED TRACEABILITY RULE Asking that a national animal traceability program be federally funded, Georgia Farm Bureau submitted comments on the USDA’s proposed animal disease traceability (ADT) rule. “Our members understand the importance of animal disease control,” GFB President Zippy Duvall wrote in a letter to Agriculture Secretary Tom Vilsack. “Our organization supports the establishment of a voluntary national animal identification system capable of providing for animal disease control.” Duvall noted that since the ADT program is intended to benefit the general U.S. population, farmers should not be expected to pay for it, stressing the importance of any such program being fully funded by the USDA. Without sufficient funding to properly implement the ADT program, the rule has the potential to become an unfunded mandate for states and an undue burden on producers. He also raised concerns over confidentiality of farmers’ private data, potential for liability for issues outside of their control or responsibility and the practicality of inspection certificate requirements in the proposed rule. Duvall asked for strict privacy protections and limitations on those having access to the information. The data should only be used for a trace-back system in the event of a food-borne illness. He questioned the practicality of the rule’s call for interstate certificates of veterinary inspection (ICVI) each time animals cross state lines, noting that, for example, a livestock owner traveling to a bordering state for a weekend show would be required to get one certificate when leaving his or her home state and another upon returning. The proposed rule as written would be implemented in two phases. The first phase would apply to reproductively intact cattle more than 18 months old, dairy cattle of any age and cattle of any age used for rodeo, recreational events, shows and exhibitions. The second phase, requiring the identification of all cattle moving across state lines, would be initiated by a notice published in the Federal Register upon completion of the first phase. Duvall asked that the implementation of the second phase be done through a separate rulemaking process to assure that any issues identified during the first phase can be addressed through a transparent process. Implementing the second phase through a separate rulemaking process would also allow cattle farmers the opportunity to review and comment before the second phase is put into practice. Visit http://www.regulations.gov/#!documentDetail;D=APHIS-2009-0091-0001 to view the entire proposed rule.