Page 78 - Fall2012

EXCERPTS FROM LETTER TO THE OMB ON ANIMAL ID

Contrary to assertions made by the USDA, the proposed rule exceeds the threshold to be recognized as economi-
cally significant. The cost of the proposed rule to the U.S. cattle industry alone is far in excess of $100 million, and
there will be additional significant costs to ancillary cattle-related businesses (such as sale barns and veterinarians) and
to small-scale poultry farmers and backyard poultry owners.

As proposed, the ADT rule would ultimately require that every bovine that crosses state lines be tagged with
an official form of identification. The identification number would have to be recorded on a certificate of veterinary
inspection (CVI). Businesses such as livestock sale barns and veterinarians would have to keep records of the official
identification for each animal for five years. The implementation of these requirements would occur in two phases,
beginning with dairy cattle and cattle over the age of 18 months (commonly referred to as “breeder cattle”) and then
covering cattle under that age (commonly referred to as “feeder cattle”).

In estimating the costs, USDA made several deeply flawed assumptions, discussed below.

The estimate that it would cost only eighteen cents in labor costs to apply the tag is based on the claim that it takes
only one person one minute to tag a cow. But cattle are living animals, not inanimate objects. Cattle do not always
run quickly and quietly through chutes, nor do they stand perfectly still to have their ears tagged. It typically requires a
team of multiple people to manage these large, powerful animals. … The time and labor involved is not only the exact
moment of placing the tag, but gathering the cattle, sorting the calves from the adult cows, running them through the
chutes, restraining each animal individually and placing the tag. The amount will vary based on the conditions, number
of animals, behavior of the animals, type of equipment used and the handlers’ experience. A more realistic estimate for
all of the labor involved would be anywhere from 5-12 minutes with a crew of three people, at a cost of $2.70 - $6.48
in labor. … A study from North Dakota, which involved tagging 14,432 calves, estimated the cost of labor at $7 for
working the calves, tag placement and documentation combined.

Even assuming that USDA is correct that 35 percent of the cattle that would be subject to the rule are already
using official identification, that means that at least 19.5 million cattle will be subject to new regulatory requirements
under the rule. Based on the North Dakota study, that would mean a cost of $331 million to $526 million for cattle
owners, not including the cost of the tags or the tag applicator. The North Dakota study also did not include the costs
from the risk of injury to people or the requirement for certificates of veterinary inspection, so the true costs would be
even higher.

Under the proposed rule, poultry moving interstate must be officially identified either through group identification
or with a permanent sealed and numbered leg band. There are no exceptions to the ID requirement, and they apply to
both the person who sends and the person who receives the animals. “Group identification” is defined so that it only
applies when a “unit of animals” is managed together as one group “throughout the preharvest chain.” This definition
describes the management practices at large, vertically-integrated facilities, but does not apply to the majority of small-
scale poultry owners who frequently commingle poultry of different ages and from different sources.

In part because of the issues discussed below, the USDA Secretary’s Advisory Committee on Animal Health rec-
ommended that no new regulatory requirements be imposed on poultry owners.

CONCLUSION
The USDA has failed to conduct the required comprehensive cost-benefit analysis of the ADT rule. At numerous
points in its analysis, the agency failed to consider available data showing that the scope of the rule and its impact on
the industry would be far broader, and its costs far more extensive, than the agency admitted. We urge the OMB to
return the rule to USDA for a thorough and complete analysis, which must acknowledge that the rule is economically
significant.

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