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and counter-productive. the need for increased traceability, while not
The comments concluded: responding to requests for a specific, fact-based
analysis of the existing programs and what the
It is critical that FDA’s new regulations weak links are. The reality is that the agency
recognize the unique characteristics of raw remains focused on what will help the export
milk cheese, bone broths, and fermented market, rather than on animal health.
vegetables. These traditional nutrient-dense Because of its focus on market issues, the
foods have excellent track records for safety. agency has included provisions in the proposed
Treating these artisanal foods as if they were rule that are both unnecessary for animal health
inherently dangerous would undermine and unfairly burdensome. The most prominent
their quality, while not serving the mission issue is the inclusion of what are known as
of food safety. We urge the agency to learn “feeder cattle” – cattle under the age of eighteen
more about these traditional foods and to months, the majority of which are destined to be
approach the regulatory process from that slaughtered for meat at an early age rather than
perspective, rather than applying the typical entering the breeding herd. Because of their
assumptions developed through experience short life-span, these animals are not significant
with mass-produced industrial products. factors in long-term chronic diseases such as
tuberculosis, brucellosis, or mad cow disease.
During this time, while FDA is gathering moreover, feeder cattle vastly outnumber breed-
information in preparation for writing the rules, ing cattle, and including them in the program
it is most effective for organizations to file com- significantly increases the burden on producers.
ments, and WAPF will continue to speak up for The program would require even those cattle that
both consumers and local producers. Once the go directly to slaughter to be tagged and accom-
agency publishes proposed rules, we will need panied by an interstate certificate of veterinary
every member to submit their own comments to inspection or other paperwork. This does nothing
show the level of public concern. So please stay for disease control—but it does provide the meat
tuned for action alerts to help us protect our food. packers with the important benefit of traceable
animals for the export market without having to
AnImAl IDenTIFIcATIOn, ROunD TWO pay premiums to producers.
Along with food safety, the issue of animal The inclusion of feeder cattle in the program
identification has also re-emerged. When USDA is even more burdensome because of the record-
announced that it was dropping its plans for the keeping requirements. Vets and sale barns would
National Animal Identification System (NAIS) have to keep records of every tag distributed and
back in early 2010, Secretary Vilsack also an- copies of every interstate certificate of veterinary
nounced his intention to propose a simpler, inspection for five years, long after most of the
more limited program for animal traceability. cattle will be dead. copies of these records would
That new proposal has finally been released, and also have to be maintained by state agencies,
the agency is taking public comments through creating costly and inefficient duplication. Small-scale
november 9. Small-scale diversified farms face additional diversified
The new rule is significantly less onerous challenges because of the provisions for dairy
than NAIS was, primarily because it (1) applies cattle and poultry. While the proposal would farms face
only to animals that cross state lines, and (2) phase in feeder cattle in the beef industry, the additional
provides for the use of low-tech forms of iden- proposed rule would immediately require iden- challenges
tification, rather than requiring microchips and tification and interstate certificates of veteri-
RFID tags. But the proposed rule suffers from nary inspection for all “dairy cattle” that cross because
some of the same serious flaws as NAIS. state lines, even young males. The definition of of the
Fundamentally, like nAIS, the new “animal "dairy breed" is vague and overbroad, creating provisions for
disease traceability rule” is a solution in search additional problems for farmers who use dual-
of a problem. The agency continues to promote purpose breeds such as Devons and Dexters. dairy cattle
the program based on generalized claims about The requirements on poultry would be and poultry.
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