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MICH-ORGANIC  June 2006

MICH-ORGANIC June 2006

Subject:

Fw: INFORMATION ALERT: NAIS UPDATE FOR SMALL FARMERS

From:

Jane Bush <[log in to unmask]>

Reply-To:

Jane Bush <[log in to unmask]>

Date:

Mon, 12 Jun 2006 19:05:39 -0400

Content-Type:

text/plain

Parts/Attachments:

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text/plain (269 lines)

Jane Bush
[log in to unmask]
EarthLink Revolves Around You.


> [Original Message]
> From: HT Network <[log in to unmask]>
> To: Healthy Traditions Network <[log in to unmask]>
> Date: 6/10/2006 2:01:49 PM
> Subject: Fw: INFORMATION ALERT: NAIS UPDATE FOR SMALL FARMERS
>
>
> ----- Original Message ----- 
> From: "Bill Sanda: Weston A. Price Foundation" <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Saturday, June 10, 2006 8:01 AM
> Subject: INFORMATION ALERT: NAIS UPDATE FOR SMALL FARMERS
>
>
>
> WESTON A. PRICE FOUNDATION
> INFORMATION ALERT
> June 9, 2006
>
> NEW NAIS GUIDANCE FOR SMALL-SCALE FARMERS AND RANCHERS
>
> On June, 2006, the USDA released a new guidance for small-scale and 
> non-commercial farmers and ranchers 
>
(http://en.groundspring.org/EmailNow/pub.php?module=URLTracker&cmd=track&j=8
1621614&u=748299).
>
> For the first time, the USDA officially states that the focus of the 
> National Animal Identification System (NAIS) is animal health, primarily 
> within the commercial animal production sector in which animals move from 
> their birthplace to a subsequent location(s) over the animal's life
cycle. 
> USDA claims that its NAIS efforts will therefore largely focus on
commercial 
> operations and animals at such locations because of their higher risk of 
> spreading diseases among multiple locations and for greater distances,
not 
> small-scale farmers and non-commercial producers. But this provides
limited 
> reassurance because the USDA's definition of "non commercial" is
incredibly 
> narrow, as discussed below.
>
> The NAIS participation guidelines for small, non-commercial producers is 
> based on how you manage (move, market, etc.) animals and the associated
risk 
> of disease exposure and spread. Again, the NAIS covers only cattle and 
> bison, cervids (e.g., deer and elk); goats; horses; camelids (e.g.,
llamas 
> and alpacas); poultry; sheep; and hogs.
>
> Definition of Non-Commercial Producer for NAIS:
> 1. Individuals whose animals are not moved to auction barns or from their 
> location to those of commercial producers; and/or
> 2. Individuals whose animal movements are limited to those moved directly
to 
> custom slaughter; movement within a single producer's premises; local
fairs 
> and local 4-H events.
>
> Although the USDA includes this description of non-commercial producers
as 
> being people who do not take their animals to auction barns, they do not 
> create an actual exemption for anything other than born on property and 
> never leaves the property except for slaughter.  Even if everything they
say 
> in this document is true, people who buy a calf from their neighbors or a 
> few baby chicks from the local feed store would have to identify and
track 
> them.
>
> Guidance for Non-Commercial Producers Premises Registration:
> USDA encourages, but does not require, all livestock and poultry owners
to 
> register their premises with the animal health authority in their State, 
> regardless of the size of their operations or the number of animals
present 
> at the facility. Voluntary registration of premises does not obligate 
> producers to identify their animals or to report the premises-to-premises 
> movement of their animals.
>
> The USDA's repeated admonition in this document that premises
registration 
> is voluntary is not consistent with its other documents nor with what is 
> actually happening.  The USDA's prior documents - which it has not 
> disclaimed - state that it expects 100% participation by January 2009, or
it 
> will consider regulations.  In other words, USDA's program is only
voluntary 
> temporarily.  And, even now, USDA is providing grants to several states
to 
> implement NAIS.  Some states, such as Wisconsin and Indiana, are already 
> mandating premises registrations., while others have proposed doing so. 
> USDA's avoidance of "mandatory" regulations does not mean that NAIS is 
> voluntary as that word is commonly understood.
>
> Animal Identification and Reporting Animal Movements:
>
> Scenarios that would not call for animals to be identified and/or
movements 
> reported in the NAIS include:
> animals that never leave the farm/location of birth;
> animals moved from their birth premises directly to custom slaughter for 
> personal use of the animal's owner;
> livestock moved from pasture-to-pasture within one's operation;
> participation in local fairs and parade,
> the local trading of birds among private individuals; and
> animals that "get out" and cross over into the neighbor's land.
>
> Animals used for recreational purposes do not need to be identified if
they 
> are permanently cared for at their birth premises. Taking your animal on
a 
> trail ride with a neighbor would not be a reportable movement.
>
> Also, household pets (e.g., parakeets, cats and dogs) are not reportable
to 
> the NAIS.
>
> These "scenarios" are an interesting mix.  Moving animals from 
> pasture-to-pasture on one's own property was clearly not a reportable
event 
> under the Draft Plan, since it did not involve leaving the "premises." 
The 
> same logic applies to animals that never leave the premises on which they 
> were born.  But what do these two scenarios really mean?  How many people 
> have animals that are born on their property, never leave their property, 
> and die on their property?  Even the exclusion for custom slaughter is,
in 
> practice, almost meaningless.  How many people have their own breeding
herds 
> or flocks, but raise animals only for their own personal consumption? 
> Almost anyone who has enough land and resources to support breeding
animals 
> also sells at least some of their offspring for one reason or another.
>
> The USDA even contradicts itself in its attempts to discuss these
reassuring 
> scenarios.  In this document, USDA states, "Reportable movements are
those 
> that involve a high risk of spreading disease, such as moving livestock
from 
> a farm to an event where a large numbers of animals are brought together 
> from many sources."  Anyone who has ever been to a local fair or parade 
> knows that they fall within this description.  And the USDA's current Q&A
on 
> their website includes the following:
> "Q. If a Person Only Shows Animals or Only Takes Them to Trail Rides, Do 
> They Need to be Identified?
> A. When people show or commingle their animals with animals from multiple 
> premises, the possibility of spreading disease becomes a factor. Those 
> animals will need to be identified."
>
> So participation in local fairs and parades will have to be reported.
>
> Will NAIS require that all livestock animals be microchipped?
> USDA's official answer is "No." The notion that USDA will require all 
> animals - ranging from livestock to chicks - to have microchips is false, 
> according to this document. With regard to the question of how an animal 
> could be identified (i.e., ear tag, tattoo, microchip, leg-banding), USDA 
> declares its neutrality. The USDA claims that such questions should not
be 
> answered for producers; instead, such questions would best be resolved by 
> producers themselves.
>
> While it is accurate that USDA has not proposed microchipping birds,
USDA's 
> claim to neutrality is nonsense.  They have already included, in the
Draft 
> Program Standards, that RFIDs are the preferred/default ID for cattle. 
The 
> Michigan Department of Agriculture, using funding from USDA, has just 
> announced that all cattle will have to have RFID tags by March 2007 - no 
> other form of ID will be acceptable in the TB zones.  And the Equine
Species 
> Working Group has also specified RFID chips.  NAIS is not technology 
> neutral.
>
> Will NAIS require that all animals to be tagged individually?
> No. USDA states that tagging each and every animal individually would be 
> unrealistic and impractical. Group/lot ID is an option for both large-
and 
> small-scale producers, depending on the circumstances, such as animals
that 
> move as a group through the production chain (e.g., groups of pigs or 
> chickens). If a producer chooses to participate in the animal
identification 
> system for a group of animals and utilizes the group/lot identification 
> method and later removes an animal from the group, that animal should
then 
> be identified individually. However, this would be the case with animals 
> from any size farming operation, large or small.
>
> In this section, USDA has again made a technically correct statement that 
> does not tell the whole story.    The definition of group ID makes it
useful 
> only for confinement operations.  USDA's Draft Program standards stated
that 
> group identification can only be used where groups of animals are managed 
> together from birth to death and not commingled with other animals".  Few 
> small farms manage their animals in completely isolated, single-age
groups.
>
> What about individuals' religious freedoms?
> The USDA claims to be sensitive to individuals' religious beliefs. We are 
> respectful of these beliefs and are committed to ensuring that workable 
> options are available to religious communities.
>
> Send Your Comments Regarding USDA's NAIS Program.
> Comprehensive recommendations for identifying animals and reporting 
> movements are in development in cooperation with the species-specific 
> working groups and State-Federal animal health authorities.
> We encourage you to make suggestions about NAIS by contacting the working 
> group(s) for the species of animal(s) you raise. The working group 
> information is on the left side of the NAIS Web page 
>
(http://en.groundspring.org/EmailNow/pub.php?module=URLTracker&cmd=track&j=8
1621614&u=748300); 
> under "Browse by Audience" click the "Select a Working Group" dropdown 
> button. Stakeholders can also submit comments to a particular working
group 
> via e-mail at [log in to unmask] Please include the species 
> name and the term "working group" in the subject line of your e-mail.
>
> Although USDA is trying to direct comments to the working groups, it is 
> important that you also let your elected representatives know what you
think 
> about NAIS.  We encourage you to copy your representative and senators on 
> all correspondence that you send to the agency and working groups.  To
find 
> the names, mailing address, e-mail address or fax of your Senators and 
> Representative, please link to 
>
http://en.groundspring.org/EmailNow/pub.php?module=URLTracker&cmd=track&j=81
621614&u=748301.
>
> *******************************************************
>
> Bill Sanda
> Executive Director
> Weston A. Price Foundation
> [log in to unmask]
>
>
>
>
>
> ----------------------------------------
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send 
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>
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>
> Our postal address is
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> 4200 Wisconsin Avenue, NW
> Washington, District of Columbia 20016
> United States
>

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