April 13, 2023
Dr. Aaron Scott
Director, National ADT and VAC, Strategy & Policy Veterinary Services, APHIS
2150 Centre Avenue Fort Collins, CO 80526
RE: Docket No. APHIS-2021-0020; Proposed Rule; Use of Electronic Identification Eartags as Official Identification in Cattle and Bison.
Thank you for this opportunity to provide feedback to the U.S. Department of Agriculture (USDA) regarding the proposed rule issued by the the Animal and Plant Health Inspection Service (APHIS), entitled “Use of Electronic Identification Eartags as Official Identification in Cattle and Bison.” Our feedback highlights the important roles agricultural cooperatives and their farmer-owners have in the production, handling, and marketing of livestock.
Since 1929, the National Council of Farmers Cooperatives (NCFC) has been the voice of America’s farmer-owned cooperatives. NCFC members include regional and national cooperatives, which in turn consist of nearly 2,000 local farmer cooperatives across the country. Farmer cooperatives—businesses owned, governed, and controlled by farmers and ranchers—are an important part of the success of America’s agricultural supply chain that includes suppliers of goods and services to the country’s working lands, the farmers and ranchers responsible for the abundance that comes from those lands, and the processing, manufacturing, packaging, marketing, and sale of that abundance to agriculture’s customers. More information about NCFC can be found at www.ncfc.org.
Support For APHIS’s Efforts to Increase Traceability
NCFC commends USDA APHIS for its efforts to increase traceability in the cattle and bison production systems. Many NCFC members are responsible for the sale and marketing of livestock and appreciate these additional measures to increase traceability and reduce the spread of animal diseases.
Additional Considerations for Implementation of the RULE
Provide Adequate Resources
It is critically important that APHIS consider the costs faced by the livestock industry supply chain with this new rule. Producers and marketing cooperatives’ members need the certainty that there will be an adequate supply of eartags, applicators, readers, software, and cabling available at a reasonable price. Additional consideration should be given to assist with possible livestock facility improvements to accommodate the new eartag systems. APHIS should, when possible, leverage lost-cost electronic tagging devices that come from federal and/state funds. This also includes providing additional resources to states to facilitate the objectives of animal disease traceability and include transition costs.
Data Privacy and Protection
The protection and confidentiality of the information associated with the owners of the animals need to be protected from disclosure to future owners and/or unintended parties. The movement of livestock and their associated information are incredibly value information in terms of supply chain security. The increased transparency also poses greater risk of needless/warrantless litigation from activists’ groups. Producers need protection from liability from acts of others after cattle/bison have left the producers’ control. Additionally, it is critical that data integrity is maintained at the highest possible standards throughout the system, including retagging/retirement of tags at harvest, to protect from future issues.
World Organization for Animal Health (WOAH) compatibility
It is important that this rule as implemented is compatible with the World Organization for Animal Health’s adopted guidelines. Most major beef exporting countries have implemented identification and traceability systems to differentiate themselves from the United States in the global markets, ensuring compatibility will increase our competitiveness in these markets.
NCFC appreciates USDA APHIS’s effort to move the livestock industry forward with increased traceability. We stand ready to work with the agency to ensure smooth implementation. If you have any questions, please reach out to Zachary Gihorski (firstname.lastname@example.org.)
Charles F. Conner
President & CEO