Important Action Item – NAIS
STEP 2: Send a copy of your comments to your Congressman and Senators.
You can find who represents you, and their contact information, at www.congress.org
Organic Consumers Association has set up an automated system for folks to submit
comments on the proposed USDA NAIS rule
https://salsa.democracyinaction.org/o/642/campaign.jsp?campaign_KEY=26665
STEP 3: Spread the word! Forward this alert to your friends, neighbors, and any
agriculture or food-related mail lists you are on. You can also download a flyer and
the sample comments at https://farmandranchfreedom.org/content/take-action to put out at
local farmers markets, riding stables, feed stores, etc.
BACKGROUND
The USDA has been working for over five years to force NAIS onto American animal owners.
NAIS is designed to identify and track each and every individual livestock and poultry
animal owned by family farmers, hobby farmers, homesteaders, and pet owners across the
country.
USDA claims that NAIS is a disease tracking program, but has refused to provide any
support for its claims. In reality, NAIS will impose high costs and government
surveillance on every farmer and animal owner for no significant benefits, and will
likely force many small producers out of business.
NAIS does nothing to improve food safety for consumers or prevent animal diseases. This
program is a one-size-fits-all program developed by and for big Agribusiness. NAIS will
increase consolidation of our food supply in the hands of a few large companies and put
the brakes on the growing movement toward local food systems.
Despite promises to the contrary, the USDA’s new proposed rule would make portions of
the NAIS mandatory for thousands of people in every state. Anyone who participates in
federal disease control program for cattle, sheep, goats or swine will have their
premises registered. The NAIS Premises Identification Number (PIN) will become the
only form of premises identification acceptable for USDA animal health purposes, with no
opt-out provision.
The proposed rule would also limit official Animal Identification Numbers to the
NAIS-compliant 840-numbering system, laying the groundwork for future regulations that
would limit people’s options on the types of tags they could use.
The proposed rule is not final yet. You can help stop it by visiting the Federal
Registry and making a comment. Go to
https://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2007-0096
and click on the yellow balloon under “add comments.” And send a copy of your comments
to your elected officials, letting them know how you feel about NAIS.
The grassroots movement has already successfully stalled USDA’s plans for NAIS, which
originally called for the entire program – premises registration, animal identification,
and tracking – to be mandatory by January 2009. The proposed rule is an opportunity to
get thousands of objections in the formal record, and have an even greater impact. It
is imperative that people speak up to protect our right to farm and our food supply!
FOR MORE INFORMATION
Go to www.FarmAndRanchFreddom.org or contact Judith McGeary, 512-243-9404 or
Judith@FarmAndRanchFreedom.org
SAMPLE COMMENTS
[Mail two copies to the address below. Or submit comments online at:
https://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648081c664
]
Date: ____________________
Docket No. APHIS-2007-0096
Regulatory Analysis and Development PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Re: Docket No. APHIS-2007-0096
I urge the USDA to withdraw its proposed rule to implement portions of the National
Animal Identification System (NAIS), Docket No. APHIS-2007-0096.
I am a _____________________________________________________________________
___________________________________________________________________________
[State who you are – for instance, are you a farmer, consumer, or horse owner — and why
this issue matters to you]
The proposed rule mandates the NAIS Premises Identification Number (PIN) as the sole
means of identifying properties for USDA animal health purposes. The proposed rule also
mandates the use of the NAIS numbering system (i.e. the “840 numbering system”) for
eartags using official animal identification numbers. Tags using other numbering
systems would be required to be linked to a NAIS PIN.
The draft rule is seriously flawed for multiple reasons:
1) Does not substantiate the alleged benefits to animal health. USDA makes general
claims about the benefits of identifying locations where animals are kept, but the
agency does not address the ability of existing programs to meet this purpose, nor how
the proposed rule would improve the capability to identify locations.
2) Ignores the costs and burdens. The proposed rule would substantially increase costs
for livestock owners and taxpayers. Costs include the development and maintenance of a
massive database; purchase of 840-numbered tags by animal owners; changes by state
agencies to make existing programs consistent with the rule; and increased federal
government intrusion into the lives and daily activities of farmers and other animal
owners.
3) Violates individuals’ religious beliefs. Amish, Mennonite, and some other
individuals have religious objections to the universal numbering system under NAIS.
4) Creates disincentives for people to seek veterinary care for their animals and
participate in existing disease control programs. The proposed rule lists four animal
disease programs-tuberculosis , brucellosis, scrapie, and Johne’s – and will also impact
others. These programs include provisions for veterinary care through vaccinations and
testing. Animal owners who object to NAIS may avoid participating in these programs,
thereby increasing health risks to the public and farm operations.
The proposed rule is a significant step towards implementing the entire NAIS program.
Thus, the agency should address the fundamental question of whether it should be
implementing NAIS at all. In addition to the problems with the draft rule listed above,
there are many additional objections to the entire NAIS program:
1) No significant benefits: USDA’s assertions that NAIS will provide benefits for animal
health are not supported, and actually contradict basic scientific principles.
2) High costs for animal owners and taxpayers: These costs include: (1) the
development, maintenance, and update of massive databases; (2) the costs of tags, most
of which will contain microchips; (3) the labor burdens for tagging every animal; (4)
the paperwork burdens of reporting routine movements; and (5) the costs of enforcement
on millions of individuals.
3) Impracticality: The databases to register the properties, identify each animal, and
record billions of “events” will dwarf any system currently in existence.
4) Waste of money: The USDA has already spent over $130 million on NAIS implementation,
but has yet to develop a workable plan for the program.
5) Diverts resources from more critical needs such as disease testing, disease
prevention through vaccination and improved animal husbandry practices, and disease
detection in currently uninspected livestock imports.
6) Damage to food safety efforts: NAIS will not prevent foodborne illnesses, such as e.
coli or salmonella contamination, because the tracking ends at the time of slaughter.
Food safety is better served by focusing on programs such as increased testing for
bovine spongiform encephalopathy (BSE or Mad Cow), improved oversight of slaughterhouses
and food processing facilities, and increased inspections of imported foods. Programs
such as NAIS that burden small, sustainable farmers will hurt efforts to develop safer,
decentralized local food systems
7) Discourages involvement in farming or animal husbandry: Because of costs and
government intrusion, some people will choose not to stay in farming or go into farming.
This will result in less competition, greater reliance in foreign imports and poor
quality at higher prices.
I urge the USDA to withdraw the proposed rule to implement portions of the National
Animal Identification System, Docket No. APHIS-2007-0096.
Sincerely,
Name: ___________________________________
Address: __________________________________
City, State Zip: _____________________________
Additional Comments:
HAVING TROUBLE SUBMITTING COMMENTS?
Some people have reported problems with the online Federal Register comment process. If
you don’t see your comments posted on the website within a few hours, think about these
issues:
1) Make sure you clicked on the yellow balloon under “add comments” next to the very
first listed document (the proposed rule). You can also use this link:
https://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648081c664
2) Be sure to fill out all of the required fields, marked with a red star
3) Submitting attachments with other comments can sometimes cause a problem. If you
wish to submit a word or pdf document, submit it separately from comments typed into the
“general comments” field
4) If you don’t get a page showing a confirmation number, go back through each step.
5) Ultimately, you can always submit using the regular mail as an alternative. Send TWO
copies to:
Docket No. APHIS-2007-0096
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
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