Mandatory animal identification numbering systems

March 11, 2009

Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Re: Docket No. APHIS-2007-0096 Official Animal Identification Numbering Systems

Dear USDA-APHIS:

On behalf of PCC Natural Markets, I’m writing to share our concerns about the proposed animal ID program (docket: APHIS-2007-0096). We ask that you reject this proposal and instead shift your focus to addressing solutions for food safety.

PCC Natural Markets is the largest community-owned natural foods retailer in the country. We have 45,000 active member-households with nine certified-organic retail stores in the Puget Sound area. We do $135 million in annual sales.

We recognize that concerns about mad cow disease (BSE), avian flu, and E. coli contaminations might make the Animal Identification Numbering System (AINS) seem like a good idea. Unfortunately it would reward the very factory farms whose practices have encouraged disease while crippling small and mid-size farmers whose practices help prevent disease.

For industrial-scale livestock and poultry operations, AINS would mean business as usual; they could identify large numbers of confined animals in one feedlot (CAFOs) and on through the production process with one number. For them, the cost of ANIS would be negligible.

For smaller operations, especially diversified family farms that keep a range of livestock and move them from one pasture to another, each and every animal would be required to have an individual number. In practice, the cost of tracking thousands of animals through a factory system could cost the same as what one family farmer would have to pay for just one animal! This is the concern we are hearing from our local ranchers.

Given that USDA estimates the costs at $3 for each tracking device, $2,000 for each reader, plus additional taxes and fees (not to mention $1,000 fines each day a farmer fails to comply), smaller-scale ranchers very easily could be forced out of business.

The result would be that sustainably raised, healthy animal meat and dairy products would become scarce if not disappear altogether. This would have a profound impact on us as a certified organic grocery retailer, since healthier, sustainably raised meats and dairy are at the core of our business. It is what the market is demanding more and more every day.

It is no surprise that corporate agribusiness interests are promoting AINS, apparently hoping it would create an image of enhanced food safety to mollify skittish foreign markets that have refused to import US beef. The purpose of AINS, in fact, is to enable a 48-hour traceback for BSE so U.S. beef can meet international export rules.

AINS would do absolutely nothing to address the causes of disease and contamination from crowded feedlots and unnatural diets. AINS would not address the causes of the two largest meat recalls in history that followed each other these past few years, or the three cases of confirmed BSE in U.S. cattle.

In addition, the microchip implants used to track animals have been found to cause cancer. A 2007 report released by Consumers Against Supermarket Privacy Invasion and Numbering reviewed 11 studies researching the link between microchips and cancer. It found that in nearly all the studies, malignant tumors arose at the site of the microchip implants and sometimes spread to other parts of the body.

AINS also does not provide any new information. We already have traceability of cattle, for instance, through existing branding and vaccination programs. Our Washington state veterinarian acknowledges that AINS would not provide any new information that we do not have already.

For these reasons, NAIS is neither a feasible nor sensible way to address disease and food safety problems. Far better solutions would include stricter controls requiring inspections at the border; slower lines at slaughterhouses to allow for more careful inspections; and increased support for animal husbandry practices that emphasize animal health — such as pasturing, less crowded living conditions, and diets suited to the species.

Tracy Wolpert
Chief Executive Officer
PCC Natural Markets

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