Animal Disease Traceability Proposal

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November 5, 2011


Re: Animal Disease Traceability Proposal Docket No.APHIS-2009-0091


Animal Identification should be left to the states and tribes to lead towards a beneficial system.  I would urge USDA to make this proposal a guideline in place of a regulation.  Allow a three year phase in period to allow states to achieve compliant systems for animal disease traceability.  

The proposal should exclude all feeder cattle and livestock being shipped direct to slaughter.  Requiring special identification and record keeping under this rule for short life spanned animals is costly and an additional burden upon agencies, both state and federal, which regulate livestock transfer and movement.

Requiring extra costs and inputs from producers to provide additional special identification for feeders and direct to slaughter animals will further burden the farming and ranching businesses already stressed by escalating costs of production. 

Hot Iron Brands should continue to be recognized as official identification.   This traditional form of identification is currently used by states for tracking and should continue to be accepted by sending and receiving states as well as USDA.  States should be allowed to opt out on the use of brands if they so choose. 

USDA must facilitate the formation of cooperative agreements between livestock sending and receiving states to ease the burden of additional national requirements upon states, producers and businesses.  This will reduce detrimental effects to the speed of commerce and interference with the supply of meat products to consumers.