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USDA’s Proposed Rule for Animal Traceability

Overreach, politics, big business, forward thinking, or best management practice are all terms used by the various beef, dairy, and livestock groups when the idea of electronic identification is discussed. In the beef and dairy industries, the recent release of the USDA’s proposed rules has promoted a very diverse and divided response[1]. However, there is one factor that can be universally agreed upon regardless of viewpoint; the magnitude of impact a disease such as Foot and Mouth (FMD) would have on a livestock herd. The short- and long-term economic impact would be astounding to international trade and this doesn’t even consider the impact on the US market, loss of genetics, consumer trust and the livelihoods of American cattlemen[2].

The discussion point throughout the summary of USDA’s proposed rule is the speed and accuracy that the response will gain by moving to an electronic identification system. Two items that should be highlighted is that according to the USDA’s estimate only around 10 to 11% of the cattle and bison herd would be tracked using this electronic identification system. Recreational animals, show stock, and breeding animals moving across state lines are included in this regulated population; however, these populations of livestock would not typically be disease vectors to our primary beef production herd in the feed yards. The second is the multiple mentions of bovine tuberculosis, a disease that has been nearly eradicated from the US herd. In review of the slaughter surveillance data from the past twenty years the majority of the cases were found in foreign animals[3].

In the entirety of the proposed rule publication, tuberculosis is listed 4 times and FMD 3 times, while there is no mention of security or biosecurity. Likewise, the cattle and bison page for USDA APHIS has links for eradication programs, surveillance, and Bi-National Committee with Mexico regarding tuberculosis but no mention of biosecurity[4]. When visiting the same USDA APHIS pages for avian and swine both have areas for biosecurity[5]&[6].

Under the Emergency Response link is where information regarding the Secure Beef Supply (SBS) and Secure Milk Supply (SMS) is discussed with links for additional resources. The goals outlined by the USDA APHIS for these two plans are as follows:

· “Maintain business continuity for producers, haulers, processors, and packers during an outbreak.”

· “Minimized disease spread.”

· “Assure a continuous supply of milk and milk products to consumers.”[7]

Based upon these goals the purpose of the SMS and SBS is not the prevention and securing of the beef and milk supply but rather a post infection document to enable the industry to voluntarily prepare for an outbreak to maintain “Continuity of Business”.

· “Limit exposure of their animals through enhanced biosecurity.”

· “Move animal to processing and another premises under a movement permit issued by Regulatory

Officials”, and

· “Maintain business continuity for the beef industry, including producers, haulers, and packers during an

FMD outbreak.”[8]

Mexican cattle the standard USDA metal ear tags is considered to be adequate by the USDA for their importation into the United States as a mean for individual identification[9]. Between 1.1 and 1.5 million head of Mexican origin cattle are annually imported into the US[10]. As outlined in the informational text accompanying the USDA proposed rule the use of visible tags only and the hand recording of these tag numbers is both labor and time intensive and has the potential for misidentification of animals. Given the nearly eradicated state of bovine tuberculosis in the US herd and compared to that of our trade partners in Mexico these seems counter intuitive to mandate additional identification measures on the US herd and not the 1.5 to 2 million head of cattle imported into the United State.

Examining this process at a state level, the importation of feeder steers using the online tool provided by the Kansas Department of Agriculture Division of Animal Health multi states can be reviewed. From the preliminary review, interstate movement of feeder steers to feed yards is not required to have individual identification just a certified veterinarian inspection (CVI). This would not be the case for steers born on dairy specific breed cattle as they are required to have individual identification for transport to feed yards.

With the importation of livestock from a country without adequate control of bovine tuberculosis this appears to be a rule aimed at trade relations rather than actual biosecurity and disease prevention.

Matthew T Steele, PhD, PE

CEO / Executive Director

Kansas Cattlemen's Association

[1] [2] Page 25 Feedlot Magazine – November, 2022 - [3] [4] [5] [6] [7] [8] [9] [10]

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