CIDG takes USDA to task on ID

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Geni Wren In August, USDA-APHIS published a proposed rule establishing minimum national official identification and documentation requirements for the traceability of livestock moving interstate with an extended public comment period ending Dec. 9.

In November 2009, a group of cattle industry organizations, the Cattle ID Group (CIDG), representing the beef, dairy and marketing sectors, came together to develop a consensus on industry-directed principles for a national cattle ID and traceability plan, and to respond to anticipated USDA animal disease identification/traceability initiatives such as these new proposed rules.

CIDG has been actively involved in reviewing and commenting on the USDA’s Animal Disease Traceability Framework and its impact on the production and marketing sectors of the U. S. cattle industry. Read the full comments.

While there was general agreement among the CIDG on nearly all of the issues identified in this document, there remains some divergence of views on certain issues by certain individual CIDG organizations, and it is strongly suggested that cattle industry stakeholders consult their individual member or industry sector organizations if there is any doubt as to their position on the following ADT issues.

The issues
What follows is a brief list of issues CIDG has outline. To read CIDG’s full responses, comments and explanations to these issues, and issues with Phase 1 and Phase 2, click here.

Identification/Tagging

1. The delisting of Brands as an official ID method for interstate movement.

2. Tagging cattle moved interstate direct to a receiving location, other than to an approved livestock tagging site or approved livestock facility.

3. Elimination, in Phase 2, of the newly defined “temporary” backtag for cattle 18-months of age or older moving direct to slaughter. 

4. The proposed rule prohibits the “Use of more than one official identification device or method…” with certain exceptions. 

5. The APHIS ADT General Standards Document Version 1.1 dated March 18, 2011 was published as supplemental material to the ADT proposed rule.  Page 4, Table 1 footnote in this document states that APHIS intends on phasing out manufacturer coded tags (982, 985, etc). Specifically, “AINs with the alpha characters USA or the numeric code assigned to the manufacturer’s ISO 11784/85-compliant identification device by the International Committee on Animal Recording may be used as alternatives to the 840 prefix until 1 year after the effective date of the final rule, APHIS Docket-2009-0091, ‘Traceability of Livestock Moving Interstate’.”

6. Replacement of non-viable or lost AIN/840 tags.

7. The proposed rule requires that tags be collected and made available to APHIS at slaughter. It does not require them to retire the tag number and record the retired tag or other ID methods for those states that would want the information.

Interstate Movement with an Interstate Certificate of Veterinary Inspection (ICVI)

1. The recording of individual identification numbers on the ICVI or other approved shipping/shipper documents is not required, under the proposed rule, for sexually intact cattle or bison under 18 months of age, or steers or spayed heifers, except for sexually intact dairy cattle of any age or cattle or bison used for rodeo, exhibition, or recreational purposes. 

2. Exemptions to ICVI requirements: Cattle less than 18-months of age may be moved interstate with documentation other than an ICVI, e.g. a brand inspection certificate, as agreed upon by State or Tribe animal health officials in the shipping and receiving States or Tribes. This exemption would not apply to sexually intact cattle or bison over 18-months of age or older. CIDG says the use of alternative shipping documents to the ICVI should be permitted for all ages of cattle and bison where there is agreement between or among State and Tribe animal health officials

3. The use of an electronic ICVI in tracking interstate cattle movements is not required but is permitted where available.

4. USDA has requested comments on the ICVI requirements, in particular the benefits of veterinary inspection in the cases where it is to be used. Also, they wish to receive comments on whether veterinary inspection, especially of large herds, will yield substantial benefit, and whether it will impose costs on businesses, particularly small or very small businesses?

Implementation of States and Tribes Traceability Performance Standards and Traceability Evaluation

1. The Traceability Performance Standards, by which USDA would assess the ability of the States and Tribes to carry out the ADT program, has yet to be fully determined and are to be taken up in a separate rulemaking process. It is, however, USDA’s current thinking that additional restrictions would be imposed on those States and Tribes failing to measure up to certain traceability performance criteria or levels of compliance.

2. USDA’s Traceability Performance Standards for the States and Tribes are described in the proposed rules as the department’s current thinking thus leaving them to be more fully established in a separate rulemaking process. 

For more information on the CIDG, contact Nancy Robinson, Livestock Marketing Assn.; 800-821-2048; or e-mail nrobinson@lmaweb.com.


The CIDG includes the American Angus Assn.; American Farm Bureau Federation, Dairy Farmers of America, Livestock Marketing Assn.; National Cattlemen’s Beef Assn.; National Farmers Union; National Livestock Producers Assn.; National Milk Producers Federation; Red Angus Assn; Southeastern Livestock Network; Texas Cattle Feeders Assn.: Texas and Southwestern Cattle Raisers Assn.; and U.S. Cattlemen’s Association.


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