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September 17, 2008

Dear Chairmen and Honorable Members of the Committees:

We, the undersigned organizations, urge you to support true food safety measures and not to include any provision for the National Animal Identification System (NAIS) in any food safety bill. The NAIS is a fundamentally flawed program that should be halted by Congress, and we further urge you to stop all funding for the NAIS.

The NAIS is a three-step program that calls for every person who owns even one livestock or poultry animal to register their property, tag each animal when it leaves its birthplace, and report a long list of movements to a database within 24 hours. The listed species include chickens, horses, cows, sheep, goats, pigs, llamas, alpacas, elk, deer, bison, turkeys, and more. The provisions would apply to every person with even one of these animals, whether or not it is used for commercial purposes, and would directly impact millions of people who own these animals. Group or lot identification would only be allowed where animals are managed as a group from birth to death and never commingled with animals outside of their production system. In practice, group identification would apply mainly, if not entirely, to confined animal feeding operations (CAFOs) and vertically integrated operations.

The stated goal of the NAIS is to provide 48-hour traceback of all live animal movements, under the claim that such tracking is needed for the control of animal disease. Yet we have extensive tracking mechanisms already in place that have been proven successful. Programs such as tuberculosis and scrapie, combined with branding and back tagging at sales barns, provide a low-cost way to track animals when needed. The proponents of NAIS have not provided a scientific basis for replacing these existing programs with a significantly more expensive and intrusive new program.

Some proponents of the program have claimed that NAIS is needed to address recent scandals in food safety, ranging from the slaughter of downed cows to the failure to find a source for salmonella outbreaks. But, under NAIS, the tracking of the animals ends when the animal dies. Tracking live animals is not the same as tracking pathogens in our food supply. As shown by data from the CDC, the vast majority of food-borne illnesses in meat are the result of practices in the slaughterhouse, food processing facilities, and food handling,[1] all of which occur after the NAIS tracking would end. The government’s money and resources would be better spent on valid food safety measures, such as inspection of imported foods, testing for BSE, and tracking of meat from the slaughterhouse to the consumer, which is when most contamination by pathogens occurs.

The NAIS will harm American agriculture, the environment, and consumers. Many small and sustainable farmers will be unwilling or unable to comply with this program, creating greater consolidation of our food supply in the hands of a few large corporations. By creating incentives for CAFOs, the group identification provision of the NAIS will harm both the public health and the environment.[2] Americans who are increasingly seeking out local and sustainable foods will find their ability to obtain these foods limited. And thousands of people who own livestock as pets or for personal use will be burdened with expensive and invasive requirements even though their animals will never enter the public food supply.

For these reasons, we strongly urge you to exclude the NAIS from any food safety bill and to stop all funding for the program. Additional background information on why the NAIS is a flawed system to address food safety is attached.

We thank you for your consideration.

Sincerely,
Adopt a Farm Family
American Grassfed Association
American Policy Center
Cattlemen's Texas Longhorn Registry
Chez Panisse Foundation (CA)
Citizens for Private Property Rights--Missouri
Colorado Independent CattleGrowers Association
Community Food Security Coalition
Cornucopia Institute
Downsize DC
Empire State Family Farm Alliance (NY)
Environmental Conservation Organization
Equus Survival Trust
Fair Food Matters (MI)
Family Farm Defenders
Farm and Ranch Freedom Alliance
Farm to Consumer Legal Defense Fund

Gun Owners of America
Illinois Independent Consumers and Farmers Association
Innovative Farmers of Ohio
International Texas Longhorn Association
Iowa Citizens for Community Improvement
Local Harvest
Maine Alternative Agriculture Association
Maine Organic Farmers and Gardeners Association
Massachusetts Small Holders Alliance
Michigan Farmers Union
Michigan Land Trustees
Michigan Organic Food and Farm Alliance
Missouri Rural Crisis Center
Montana Farmers Union
National Association of Farm Animal Welfare
National Farmers Organization
National Latino Farmers and Ranchers Trade Association
North Carolina Contract Poultry Growers Association
Northeast Organic Farming Association--Massachusetts Chapter
Northern Illinois Draft Horse and Mule Association
Northern New Mexico Stockman's Association
Northern Plains Resource Council (MT)
Oregon Consumers and Farmers Association
Organization for Competitive Markets
Ozarks Property Rights Congress--Missouri
Paragon Foundation
Property Rights Congress
R-CALF
Regional Farm and Food Project (NY)
Rural Vermont
South Dakota Stockgrowers Association
Sovereignty International
Texas Eagle Forum
Texas Landowners Council
Virginia Land Rights Coalition
Western Organization of Resource Councils
Weston A Price Foundation
White Earth Land Recovery Project (MN)

For more information, contact: Judith McGeary, 512-243-9404, Judith@FarmAndRanchFreedom.org

[1] See Centers for Disease Control and Prevention, http://www.cdc.gov/ncidod/dbmd/diseaseinfo/ foodborneinfections_g.htm#mostcommon. Campylobacter, salmonella, and e. coli are all found in the intestines of animals, so that contamination occurs during the slaughter process. The Norwalk viruses are believed to spread primarily from one infected person to another, through handling of food by infected kitchen workers or fishermen.

[2] See Doug Gurian Sherman, CAFOs Uncovered: The Untold Costs of Confined Animal Feeding Operations, Union of Concerned Scientists (April 2008).

Why the National Animal Identification System Will Not Address Food Safety

Livestock producers, who bear the burden under NAIS, are not the source of most food-borne illnesses. These illnesses are from bacteria such as salmonella, e. coli, and campylobacter, or the Norwalk viruses, which contaminate food due to poor practices at slaughterhouses or in food handling.[1] The NAIS would do nothing to prevent these problems from occurring. Moreover, because the tracking would end at the time of slaughter, the NAIS would not improve the government’s ability to trace contaminated meats once they leave the slaughterhouse and enter the food chain.

NAIS is also not an effective control for BSE, or “Mad Cow Disease,” even though it affects live animals. BSE is believed to be caused by feeding infected animal material to cattle. So the key to addressing it is prevention through a strong feed ban. The second key to addressing Mad Cow disease is testing all or a significant percentage of the animals that enter the food supply, as is done in Japan and Europe. The USDA currently tests only about one out of every thousand slaughtered cattle,[2] and has opposed increased testing, whether government or private.

In the recent Hallmark/Westland beef recall, the fault lies with the packing plant for violating existing regulations and with the USDA for failing to properly inspect the plant. “Downer” cows were slaughtered and the meat then provided to the School Lunch Program. In the video from the Humane Society, every time there was a clear shot of a cow’s left ear, one can see a tag.[3] Changing the type of tag to an NAIS electronic tag would do nothing to address the problem.

NAIS will impact millions of animal owners, including people raising food for themselves, hobby farmers, recreational horse owners, and those who own livestock as pets. The concept of tracking every movement of every livestock animal in massive databases may sound impressive, but it is not founded in sound science, economics, or practicality. USDA has not provided any studies showing why 48-hour traceback is “optimal” nor why 100% of animals must be included.

The susceptibility of animals to disease and the likelihood of transmission differ greatly depending on the species of animal, the exact disease, and the conditions under which the animals are kept. Therefore, it is obvious that a “one size fits all” solution cannot be based on science. USDA as yet has failed to complete a cost-benefit analysis, despite four years of implementing the program. Moreover, the experience of Australia, the only other country to implement mandatory electronic tracking of cattle so far, indicates that the databases are unwieldy and unworkable. The GAO’s 2005 report on agroterrorism and livestock disease made it clear that parts of the U.S. animal health system needed improvement, but did not identify a need for increased tracking of live animals.[4]

[1] See Centers for Disease Control and Prevention, http://www.cdc.gov/ncidod/dbmd/diseaseinfo/ foodborneinfections_g.htm#mostcommon. Campylobacter, salmonella, and e. coli are all found in the intestines of animals, so that contamination occurs during the slaughter process. The Norwalk viruses are believed to spread primarily from one infected person to another, through handling of food by infected kitchen workers or fishermen.

[2] During a period of “heightened” testing in a two year period from 2004 to 2006, the USDA tested fewer than 700,000, or approximately 1% of the cattle slaughtered. See News Release, Statement by USDA Chief Veterinary Officer John Clifford (DVM) Regarding Positive BSE Test Results (Mar. 13, 2006). In contrast, the European Union countries tested more than 8 ½ million cows just in 2003, and tested over 6 million in just the first 9 months of 2004. See U.K. Food Standards Agency, Results of BSE testing in the EU, http://www.food.gov.uk/bse/facts/cattletest. In 2006, the USDA announced that it was reducing testing by 90%.

[3] http://www.youtube.com/watch?v=kaM7Hpu47FY

[4] United States Government Accountability Office, GAO-05-214, Homeland Security: Much is being done to protect agriculture from a terrorist attack, but important challenges remain (Mar. 2005) (hereinafter “GAO Report on Agriculture”).

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