The Department of Agriculture has proposed costly regulations to force ranchers, related business, and livestock agencies to tag and track animals that cross state lines.

USDA’s animal traceability rule is a solution in search of a problem. USDA says the rule is to protect animal health. But, the rules don’t identify any specific problems or diseases of concern.

These regulations will harm rural businesses, waste taxpayer dollars, and do little to deal with animal disease, food security, and food safety

Send your comments today to make sure USDA’s final rule works for farmers and ranchers, and is paid for by the meatpackers that will benefit most.

At a time when farmers and ranchers face significant economic challenges, the last thing they need is more burdensome rules hindering their operations.

You can read more information about the proposed rule on WORC’s website.


Please submit comments to USDA today! You can submit comments either online or by mail.


Please personalize these comments!  Include a personal story at the beginning of your comments so that it’s not just a form letter. The personalization can be just a few sentences, but it does make a difference.

Dear Secretary Vilsack:

I am a __________________ (farmer, local foods consumer, backyard poultry owner, horse owner, etc.).   I am very concerned that the proposed rule will __________ (not be workable for my farm; impose costs on my farmers that will then be passed on to me, etc.)

If the export market would benefit from the proposed rule, as the agency claims, then the meat packing companies that export meat should pay the costs and offer economic premiums to livestock producers to encourage them to participate in a voluntary system.

The agency’s analysis does not address the full costs of the program, and this is a waste of money at a time when both private and government resources are already stretched thin.  The proposed rule is an unfunded mandate on state agencies, private businesses, and individuals.

I urge you to make the following changes in the proposed rule to make it more workable for farmers and ranchers:

  • Ask the agency to address and justify the full costs of the program.
  • Apply the requirements to breeding-age cattle only and exempt feeder cattle from all new requirements.
  • Exempt all direct-to-slaughter cattle, both for custom and for retail sales.
  • Recognize the brand as “official identification” among and between all states that currently have official state brand programs and “official supplementary identification” for all other states.
  • Do not impose any new requirements for identifying poultry.  There has simply been no showing that imposing new requirements on small-scale poultry operations is needed, while it will definitely cause significant harm. 
  • Provide that a physical description qualifies as an official identification method for horses without having to be approved by the health officials in the receiving State or Tribe.

In closing, I urge you to extend the comment period on the proposed rule for sixty days. This is a busy time of the year for ranchers, and more time will help ensure those who are most affected by this proposed program are given the time they need to review it.

City, State Zip


You can send you comments online here.


Docket No.APHIS–2009–0091
Regulatory Analysis and Development
PPD, APHIS, Station  3A–03.8
4700 River Road Unit 118
Riverdale, MD 20737–1238

The deadline for comments is WEDNESDAY, NOVEMBER 9, 2011.

Please also send a copy of your comments to your Congressman and Senators. You can find contact information for the House here and the Senate here.

What you can say in your comments

  • Increase the comment period by 60 additional days to allow farmers and ranchers as well as consumers to comment fully.
  • Insist the agency address the full costs of the program so that this does not become an unfunded mandated a colossal waste of money at a time when both private and government resources are already stretched thin. 
  • Exempt feeder cattle from all new requirements
  • Exempt all direct-to-slaughter cattle, both for custom and for retail sales. The proposed rule provides for a temporary exemption, but then phases these animals into the program.
  • Recognize hot iron brands as “official identification among and between all states that currently recognize brands and “official supplementary identification” for all other states.
  • Request specific assurances that information will be kept private and used only by agencies for disease tracking


You can read the proposed rule on USDA’s website.

You can read the USDA’s regulatory analysis, which includes its analysis of the costs of the program and the alleged benefits to the export market, here.