Illinois Coalition For Public Awareness

We re-formatted the letter, to split it into a much shorter letter and a
background piece. The substance has not changed.

Please pass on to any organization that you think would be interested.
Thanks!
Judith
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Alert to all organizations concerned about the National Animal
Identification System! The House Agriculture Appropriations
Subcommittee has included a pro-NAIS provision in the ag appropriations
bill, which will require the School Lunch Program to buy meats only from
NAIS-registered premises. You can read the full press release at
http://appropriations.house.gov/pdf/DeLauroSubMarkup06-19-08.pdf

Below is a sign-on letter opposing this provision. If your organization
is willing to sign on, please email Judith@farmandranchfreedom.org or
Irene@nffc.net by WEDNESDAY, JUNE 25 -- tomorrow -- by 2 pm ET.

We realize this is a very short deadline, but the timing is critical.
The full House Appropriations Committee meets on Thursday morning, and
we need to deliver the letter to them prior to the meeting.

If the Appropriations Committee does not remove the provision, we will
continue to collect signatories after that deadline, through Monday,
July 7. The letter with the full list of signatories will then be
delivered to the full House and Senate.

PLEASE sign on by Wednesday, June 25 at 2 pm, so that we can have the
greatest impact on the House Appropriations Committee! Send your
sign-on to Judith McGeary, judith@farmandranchfreedom.org, or Irene Lin,
irene@nffc.net. If you have questions, call Judith at 866-687-6452 or
Irene at 202-543-5675.

--
Text of the sign-on letter and accompanying background piece: (please
ignore any formatting issues related to the footnotes)

The Members of the House Appropriations Committee

Dear Representatives:

We, the undersigned organizations, urge you to remove the provision from
the House Agriculture Appropriations bill that requires USDA to purchase
for the School Lunch Program meat products that are derived from farms
(premises) registered with the National Animal Identification System
(NAIS). This provision undermines the School Lunch Program and promotes
a flawed policy.

The subcommittee provided two reasons for this including provision. The
first reason is to address public health concerns, specifically related
to meat recalls. The second reason is to increase participation in the
NAIS. Both reasons are fundamentally flawed.

NAIS is a three-step program that calls for every person who owns even
one livestock or poultry animal to register their property, tag each
animal when it leaves it birthplace, and report a long list of movements
to a database within 24 hours. The listed species include chickens,
horses, cows, sheep, goats, pigs, llamas, alpacas, elk, deer, bison,
turkeys, and more, whether or not the animal is used for food. Group or
lot identification would only be allowed where animals are managed as a
group from birth to death and never commingled with animals outside of
their production system. In practice, group identification would apply
mainly, if not entirely, to confinement operations (CAFOs) and
vertically integrated operations. The stated goal of NAIS is to provide
48-hour traceback of all live animal movements.

NAIS will harm independent farmers and increase the consolidation of our
food supply into the hands of a few large corporations. The school lunch
provision in particular will favor the most vertically integrated farms
that can easily prove that all their meat is from a NAIS-registered
farm, as well as confinement operations that will be able to use group
identification under NAIS. By creating incentives for CAFOs, the
provision will harm both the public health and the environment. [1]
Americans who are increasingly seeking out local and sustainable foods
will find their ability to obtain these foods limited.

Linking NAIS to the School Lunch Program will also harm the growing
movement of farm-to-school programs, while benefiting only large-scale,
confinement operations that manufacture unsafe food in the first
instance. The farm-to-school programs help improve children’s nutrition
while providing family farms with a reliable market. They also promote
the local economy and environmentally sustainable agriculture, and
re-connect children with the source of their food. But many of the
small, local farmers who are participating in these programs, or who
want to participate, are opposed to NAIS. Whether for philosophical
reasons or the costs and burdens imposed by NAIS, these farmers are
unlikely to be able to comply with the provision in the appropriations bill.

In the recent Hallmark/Westland beef recall, the fault lies with the
packing plant for violating existing regulations and with the USDA for
failing to properly inspect the plant. “Downer” cows were slaughtered
and the meat then provided to the School Lunch Program. In the video
from the Humane Society, every time there was a clear shot of a cow’s
left ear, one can see a tag. [2] Changing the type of tag to an NAIS
electronic tag would do nothing to address the problem.

For these reasons, we strongly urge you to remove the provision that
requires School Lunch Programs to purchase meat products from
NAIS-registered premises. Additional background information on why NAIS
is a flawed system to address food safety is attached.

We thank you for your consideration.

Sincerely,

FN:

[1] See Doug Gurian Sherman, CAFOs Uncovered: The Untold Costs of
Confined Animal Feeding Operations, Union of Concerned Scientists (April
2008).

[2] http://www.youtube.com/watch?v=kaM7Hpu47FY

BACKGROUND: Why the National Animal Identification System Will Not
Address Food Safety

Livestock producers, who bear the burden under NAIS, are not the source
of most food-borne illnesses. These illnesses are from bacteria such as
salmonella, e. coli, and campylobacter, or the Norwalk viruses, which
contaminate food due to poor practices at slaughterhouses or in food
handling. [1] The NAIS would do nothing to prevent these problems from
occurring. Moreover, because the tracking would end at the time of
slaughter, the NAIS would not improve the government’s ability to trace
contaminated meats once they leave the slaughterhouse and enter the food
chain.

NAIS is also not an effective control for BSE, or “Mad Cow Disease,”
even though it affects live animals. BSE is believed to be caused by
feeding infected animal material to cattle. So the key to addressing it
is prevention through a strong feed ban. The second key to addressing
Mad Cow disease is testing all or a significant percentage of the
animals that enter the food supply, as is done in Japan and Europe. The
USDA currently tests only about one out of every thousand slaughtered
cattle, [2] and has opposed increased testing, whether government or
private.

Although Congress has devoted over $100 million in appropriations
towards the program since 2004, Congress has never mandated NAIS, nor
even mentioned NAIS in authorizing legislation. NAIS will impact
millions of animal owners, including people raising food for themselves,
hobby farmers, recreational horse owners, and those who own livestock as
pets. Congress needs to hold hearings with a full and open debate on the
validity of NAIS, not implement it via the back door through appropriations.

The concept of tracking every movement of every livestock animal in
massive databases may sound impressive, but it is not founded in sound
science, economics, or practicality. USDA has not provided any studies
showing why 48-hour traceback is “optimal” nor why 100% of animals must
be included. The susceptibility of animals to disease and the likelihood
of transmission differ greatly depending on the species of animal, the
exact disease, and the conditions under which the animals are kept.
Therefore, it is obvious that a “one size fits all” solution cannot be
based on science. USDA as yet has failed to complete a cost-benefit
analysis, despite four years of implementing the program. Moreover, the
experience of Australia, the only other country to implement mandatory
electronic tracking of cattle so far, indicates that the databases are
unwieldy and unworkable. The GAO’s 2005 report on agroterrorism and
livestock disease made it clear that parts of the U.S. animal health
system needed improvement, but did not identify a need for increased
tracking of live animals. [3]

FN:

[1] See Centers for Disease Control and Prevention,
http://www.cdc.gov/ncidod/dbmd/diseaseinfo/
foodborneinfections_g.htm#mostcommon. Campylobacter, salmonella, and e.
coli are all found in the intestines of animals, so that contamination
occurs during the slaughter process. The Norwalk viruses are believed to
spread primarily from one infected person to another, through handling
of food by infected kitchen workers or fishermen.

[2] During a period of “heightened” testing in a two year period from
2004 to 2006, the USDA tested fewer than 700,000, or approximately 1% of
the cattle slaughtered. See News Release, Statement by USDA Chief
Veterinary Officer John Clifford (DVM) Regarding Positive BSE Test
Results (Mar. 13, 2006). In contrast, the European Union countries
tested more than 8 ½ million cows just in 2003, and tested over 6
million in just the first 9 months of 2004. See U.K. Food Standards
Agency, Results of BSE testing in the EU,
http://www.food.gov.uk/bse/facts/cattletest. In 2006, the USDA announced
that it was reducing testing by 90%.

[3] United States Government Accountability Office, GAO-05-214,
Homeland Security: Much is being done to protect agriculture from a
terrorist attack, but important challenges remain (Mar. 2005)
(hereinafter “GAO Report on Agriculture”).