ACTION ALERT: Take action
now to stop intrastate identification of dairy cattle
The Texas Animal Health Commission (TAHC) has proposed a new
regulation, 4 TAC section 43(n), which provides that all dairy cattle being
transported within Texas shall be identified with "official identification
devise or identification devise approved by the
Commission." (The agency presumably meant "device", not
"devise") The stated reason for the requirement is based on the risk of
tuberculosis (TB) exposure from untested dairy cattle.
The proposed regulation is unnecessary. According to TAHC,
the risk of tuberculosis infection is coming from out of state - so the agency
should be focused on entry requirements and testing out of state cattle coming
in to Texas, not burdening in-state producers.
The proposed regulation also opens the door for the agency
to require RFID tagging and NAIS premises registration requirements for dairy
cattle. The proposed regulation limits the identification to a “device,"
which may or may not include traditional forms of identification such as
tattoos and brands. We've already seen a similar approach in Michigan. The
Michigan Department of Agriculture made a "policy decision" that the only form
of acceptable identification under its tuberculosis program was NAIS-compliant
RFID tags, complete with premises registration! The proposed Texas regulation
by itself won't force dairy cattle owners to register and use electronic tags -
but it would be very easy for the agency to take that next step, with no
additional regulations or notice.
This is not just about dairy cattle! If we allow the agency
to require unnecessary intrastate tagging of dairy cattle, then it will be that
much easier for them to require it of beef cattle next ... then sheep and goats
... then horses ... then chickens .... We need to stand together.
Take Action
The TAHC is accepting comments on the proposed regulation
until Monday, July 23. You can submit them through email, fax, or hard-copy
letters. Send your comments to Delores Holubec, Texas Animal Health Commission,
2105 Kramer Lane, Austin, Texas 78758, by fax at (512)719-0721, or by e-mail at
comment@tahc.state.tx.us.
Keep your comments short, simple, and to-the point. A sample
letter is below, but it is important that you send a personalized letter with
your thoughts, not just a form letter. If you own dairy cattle, be sure to
discuss how the new identification requirement would affect you.
The Texas Association of Dairymen was involved with
developing this new regulation. If you're a member of the Association and you
don't agree with what they did, be sure to mention that. And if you own dairy
cattle and you're NOT a member of the Association, mention that - the agency
needs to realize that there are many animal owners in this state who are not
represented by the big lobby groups.
The proposed regulation can be found at:
http://www.sos.state.tx.us/texreg/archive/June82007/PROPOSED/4.AGRICULTURE.html#13.
And you can read the TAHC's meeting minutes at
http://www.tahc.state.tx.us/news/meetings/Synopsis_CommMtg_May2007.pdf.
The discussion of the proposed TB regulation starts on page
3.
As always, if you have any questions, contact us at
info@farmandranchfreedom.org
or call 866-687-6452.
Sample Letter: Personalize and put it into your own words
for the greatest impact. Talk about why YOU are against the regulation.
Delores Holubec
Texas Animal Health Commission
2105
Kramer Lane
Austin, TX 78758
comment@tahc.state.tx.us
FAX: (512) 719-0721
Re: proposed 4 TAC section 43(n)
Dear Ms. Holubec:
I am writing to oppose the adoption of the proposed new
regulation for mandatory identification of dairy cattle, 4 TAC section 43(n).
The proposed regulation it is not necessary, and it unnecessarily limits the
types of identification that can be used.
I am a ... (dairy farmer, consumer, other animal owner, etc.
Put in a couple of sentences about yourself and why you care about the issue).
The reason given for the proposed regulation is that some
other states have had cattle test positive for tuberculosis. This fact means
that the TAHC should increase its enforcement of entry requirements, not create
new requirements for intrastate movement. It is not necessary or fair to burden
in-state producers who have already worked hard to reach tuberculosis-free
status in Texas.
In addition, the language of the proposed regulation
mentions only identification devices and does not include forms of
identification such as tattoos and brands. This is a stark contrast to the
existing regulation for identifying cattle tested for tuberculosis, which
specifically lists identification devices, tattoos, and brands. The new
regulation provides fewer options for identifying untested cattle than for
identifying tested animals, which does not make sense.
Last, because of the agency's policy of promoting the
National Animal Identification System (NAIS), I am concerned that the agency
will connect the official identification device required under the new
regulation to the NAIS.
I urge the Commission not to adopt the proposed section
43(n). At a minimum, the language of the proposed regulation should be changed
to expressly allow for inexpensive, non-electronic forms of identification
(such as tattoos and brands) that are not connected to the National Animal
Identification System.
Sincerely,
Name
Address
City, State Zip
Email if you
have it
Working together, we cna make our voices heard.
Sincerely,
Judith McGeary
Farm and Ranch Freedom Alliance
www.farmandranchfreedom.org
866-687-6452
judith@farmandranchfreedom.org
by Farm and Ranch Freedom Alliance | 8308 Sassman Rd |
Austin | TX | 78747
|