From the desk of President J.J. Goicoechea :
January 2012
As I prepared to email off my monthly article, I couldn’t help thinking that we have all heard so much about the USDA proposed rule on traceability. In spite of the almost constant barrage of information on this issue, I feel it is extremely important to us, especially those of us in an almost exclusive export state such as Nevada. So sit back, enjoy a few more moments in the warmth of the house before stepping outside and allow me to stand on my soapbox for a short spell.
A few years back, the industry overwhelmingly rejected the federal government’s attempt at a National Animal Identification System (NAIS). Now we are staring down the barrel of a proposed rule that will in effect institute NAIS through the back door. I know that Agriculture Secretary Tom Vilsack has said, “We are proposing a flexible approach in which states and tribes can develop systems for tracing animals that work best for them and for producers in their jurisdiction. This approach offers great flexibility at the state and local level and addresses gaps in our disease response efforts.” This sounds like a great and simple plan. That should be our first clue something is amiss, Washington cannot adopt a simple plan, I am convinced it is becoming all but impossible. Almost as quickly as it was said it would be left to states and tribes, the agency then told states and tribes how to do it.
The proposed rule did not allow for the use of brands or group lot movement, unless individual agreements where made between each state. The problems with Nevada needing to enter into agreements with dozens of states receiving our cattle should be obvious. As a way of not needing the brand agreements, the USDA said they would issue individual bright tags for the animals. (Sounds a little like NAIS doesn’t it?) In an attempt to avoid this proposal, a group of animal health officials and industry leaders from several western brand states, including Nevada, signed a joint letter to the Secretary of Agriculture, asking that group lots of cattle be allowed to move using brands as the identification. The letter requested that this become an official part of the proposed rule. For years, brand programs have been in effect and with quality personnel can provide a means of tracing cattle movements all the way back to the ranch of origin. The economic importance of being able to move large groups of cattle on group lots cannot be underestimated. As I recently stated in an article for Northern Nevada Business Weekly, “Ranchers in northern Nevada raise herds with 3,000 or more steers. Putting each steer through a chute to tag it with an alpha-numeric code, and then later recording those codes before cattle are placed on trucks for shipping, places a significant financial burden on Nevada ranchers because almost all the beef raised in the state crosses state lines for fattening before slaughter."
I realize that the number of animals that a lot of Nevada ranches deal with is unimaginable to many eastern producers. Those producers don’t brand their cattle or have facilities to process their cattle. For these producers, the use of government issued bright tags that can be placed at the sale barn is a good fit. For those of us in Nevada, the thought of running several hundred head of steers through a chute to tag them before they are loaded on trucks, and recording what tags are on what truck is just as unimaginable. While the argument is made that the government is going to issue the two cent tags to producers for their use, so the cost is nominal; they don’t realize the cost of processing those cattle. Whether it is the shrink on the cattle, the inevitable broken leg, broken neck, or otherwise injured animal, this proposed unfunded mandate will cost producers in Nevada.
Now at the risk of sounding as though I am opposed to any form of identification outside brands, let me say that our operation uses RFID tags in all our steers and we also use RFID brucellosis vaccination tags in our heifers. I also assist many of my clients with similar programs and use several thousand RFID brucellosis tags in client cattle each year. The vast majority of these tags are used as part of an age and source verification program. I definitely see the need for these programs and tags in value added marketing. That is how I feel individual identification should best be handled, through VOLUNTARY and value added programs. In discussions with Dr. Phil Larussa, the Nevada State Veterinarian, he is comfortable that the use of brands in group lots will enable him to meet the requirements of trace back as set forth by the USDA.
The majority of reportable disease incidence that occurs in our domestic beef herd occurs in adult animals. It is rare that a group of steers or feeder heifers that will be harvested less than 30 months of age will have a disease problem that needs to be traced back to a ranch of origin. That said, as a large animal veterinarian; let me be the first to say that we have a program in place, which when in full effect, identifies half of the annual cattle produced in Nevada. The brucellosis vaccination program utilizes an alphanumeric code to individually identify vaccinated females. These females are the future mature cows that produce our calves for export. These females are the cattle that are at the most risk of a reportable disease due to the simple fact they live long enough to have a disease manifest itself. Should the current use of our brands and brucellosis vaccination tags be scrapped for a program that requires all cattle, even those low risk steers and feeder heifers to be individually identified? I doubt many of you are in any hurry to process calves after sorting and weighing, or after selling them at a Fallon sale barn and before they can leave the state.
NCA will continue to fight to protect the resident cow herd of Nevada and for using brands and group lot movements. Keep your eyes open for the final rule that we expect to see sometime early 2012. If you have the opportunity, please call and thank Dr. Phil Larussa for his work on this issue. As I stated before, we are an export state and need to ensure we can export our product with as little stress on the animals (and producers) as possible.
Until next month, live each day to the fullest and hope for precipitation!
J.J. Goicoechea, DVM