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NMPF Submits Comments on USDA Disease Traceability Proposal

January 6, 2012

As part of the dairy industry’s strong proactive stance in advocating mandatory animal identification and disease traceability, NMPF provided comments on the proposed USDA disease traceability rule. The rule would establish general regulations for improving the traceability of U.S. livestock moving across state lines when animal disease events take place. In the comments consistent with long standing policy, NMPF stated its support for mandatory animal identification and disease traceability to serve as a collective industry insurance policy against catastrophic animal disease outbreaks.

NMPF recommended that USDA proceed with mandatory animal identification and traceability standards that are unique for the dairy industry and these not need to be aligned to any requirements for the beef industry. In the past, USDA has attempted to have a unified animal identification and traceability rule for bovines in general, thus having the same requirements for the dairy and beef industries. USDA is well aware of the differences in opinion between the dairy and beef industries relative to the need of mandatory versus voluntary animal identification and traceability.

Because animal diseases do not respect political boundaries, NMPF believes that disease traceability must be consistent across all state, tribal, and territorial governments. Without this consistency, there will be a negative impact on the effectiveness of the program for animal identification and disease traceability for the dairy industry. It is conceivable there could be different systems implemented by each political entity. Since a significant number of dairy producers operate in more than one political jurisdiction, this will likely result in confusion and added expense for producers. Therefore NMPF recommended that USDA exercise federal preemption to provide a far more beneficial national system with all state, tribal, and territorial governments utilizing a central system, making it easier for producers and other industry partners to participate.

NMPF recommended that USDA require official 840-RFID tags for all female dairy cattle and those male dairy cattle used for reproductive purposes. Along with our IDairy partners, NMPF has long supported the use of RFID tag technology as the appropriate animal identification for dairy cattle to allow for disease traceability at the speed of commerce. RFID tag technology is being readily adopted by dairy producers as part of their herd management systems for animal health, reproduction, performance, genetic, and other purposes. NMPF also recommended to USDA for the allowance of the replacement of AIN’s with the same number which will protect the long-standing and important animal management philosophy the dairy industry utilizes today.