Jim Dickrell is the editor of Dairy Herd Management and is based in Monticello, Minn.
Animal ID Delays: Playing with Fire
Oct 10, 2011
Last Friday’s announcement by USDA that it was extending the comment period for 30 days on its animal disease traceability proposal is just one more delay in this "Waiting for Godot" melodrama.
The Farm and Ranch Freedom Alliance and R-CALF USA, among others, requested the extension to conduct an economic analysis of the proposal. But some within the animal identification community also wonder if this is merely a delaying tactic that could push implementation into 2013, even 2014.
By delaying the comment period now to Dec. 9, USDA’s analysis of those comments could push publication of the final rule well into spring. Then, there will be the inevitable additional comment period—30, 60, 90 days—for folks to respond and object to the final proposal. And given the history of groups such as R-CALF, it’s a safe assumption that they will object.
By then, we’ll be well into summer and in the heat of the 2012 election campaign. USDA will be unable to move the proposal forward in the midst of the campaign. And so we’ll have to wait for the election results come November.
If President Obama does get re-elected, there’s the very real possibility of turnover within USDA’s political appointees. It happened when President George W. Bush was elected to a second term; it likely will happen if President Obama somehow gets re-elected. That will lead to the inevitable hold on any new regulations as the new guys review and stamp "OK" on any proposed regs.
And if the Republicans gain control of the White House, you can be assured there will be major delays in federal rulemaking. First, a new Secretary of Agriculture will have to be named and approved. Then his team will have to be put in place. And then that team will have to review any proposed rules in the hopper.
All of this delay is playing Russian roulette with American access to global markets. Take the case of Paraguay, which discovered foot-and-mouth disease (FMD) just three weeks and a day ago. Immediately, Paraguay was forced to suspend beef exports to 20-plus countries. Even if it gets the outbreak under control, it likely will be a year before exports can resume, given the bureaucracy of world animal health requirements.
Opponents to national animal identification bury their head in the manure and say it will never happen here. But that’s what they said about the 2003 Christmas surprise when a dairy cow in Washington state was discovered with bovine spongiform encephalopathy (BSE). It could happen again; it likely will happen again.
Having disease trace-back capability is absolutely critical to containing disease outbreaks. Even USDA’s current watered-down animal disease traceability proposal is better than nothing. And yet opponents want to delay even this weak approach.
Dairy producers are enjoying unprecedented strong beef prices this year, allowing them to almost buy springing heifers for the value of the cull cow they’re replacing. Yes, the small beef-cow herd and the drought in Texas have a lot to do with these strong prices. But strong meat exports also play a critical role.
Loss of those markets will mean hundreds of dollars per head less revenue. And I don’t even want to think about the loss of dairy product exports should something such as an FMD outbreak occur here. Delaying a national animal traceability program is not only playing with fire, it’s the very definition of insanity.
More information on USDA’s animal disease traceability proposal can be found here.