A Preliminary Analysis of the USDA’s NAIS User Guide of November 2006

Copyright 2006 by Mary Zanoni. The following article may be distributed solely for personal and non-commercial use without prior permission from the author. Non-commercial distribution and posting to assist in disseminating information about NAIS is, in fact, encouraged, so long as proper credit is given and the article is reproduced without changes or deletions. Any other distribution or republication requires the author’s permission in writing and requests for such permission should be directed to the author at the address/phone/e-mail address below.

A Preliminary Analysis of the USDA’s NAIS User Guide of November 2006

by

Mary Zanoni, Ph.D., J.D.

P.O. Box 501

Canton, NY 13617

315-386-3199

mlz@slic.com

The following are preliminary points meant to contribute to the early and continuing discussion of this newly released (as of November 22, 2006) USDA document concerning the National Animal Identification System. I plan to write further on some of the key issues related to the User Guide in the near future. At the close of the discussion is a list of suggestions for further action.

1. The only real “difference” from this year’s prior Implementation Plan documents is the absence of stated dates for certain target levels of participation. The document still envisions making everyone comply with NAIS eventually. (See, e.g., User Guide, p. 5, “The goal is to establish a complete record of all locations, or premises, in the United States that manage or hold livestock and/or poultry.”) (Emphasis added.)

2. Note that Rep. Collin Peterson (D. Minnesota, 7th Dist.), expected to chair the House Agriculture Committee in the next Congress beginning in January 2007, lately has been quoted as favoring a “mandatory” NAIS. (Presumably Rep. Peterson does not yet understand the harms NAIS will cause to small farmers and animal owners, and the unfair boon it will be to the multinational meat industry and tech industry. Let’s help him realize the true state of affairs by contacting his office and pointing out the harms of NAIS.)

The USDA’s increased (but misleading) emphasis on “voluntary” may well be nothing more than an attempt to shift blame to Rep. Peterson and some of his fellow party members for a “mandatory” plan that the present administration’s USDA really hopes will be implemented.

3. Note that the User Guide was released late in the day on Thanksgiving eve. This is a typical tactic for actions that bureaucrats hope might escape too much notice. Further, unlike the release of the Implementation Plan of April 2006, the release of the User Guide was not accompanied by a well-publicized news conference by Secretary Johanns.

4. The User Guide subtly reveals some new tactics the USDA is planning to employ for imposing “creeping mandatory” NAIS on animal owners who do not actually “volunteer.” Note the following passage from p. 8 of the Guide:

“USDA believes participation in the main components of NAIS can occur as a result of standard business practices. For example, in order for producers to obtain official identification devices, they first need to register for a premises identification number. Accordingly, the success of the premises registration component would be achieved through the participation of producers in longstanding disease management programs and compliance with interstate movement regulations.”

Translation of the above bureaucratic verbiage: If you want to buy, sell, or move animals in interstate transactions, or if you participate in a required (e.g., for many dairy producers) or voluntary disease program such as TB or brucellosis testing or calfhood vaccination, the USDA is going to force you to use NAIS Animal Identification Numbers (AINs) for these programs, and will also force you to get a premises ID as a prerequisite to getting the forced AINs.

5. The USDA propaganda machine really went into high gear to produce the User Guide. The main propaganda objective is falsely to paint any NAIS non-participants as somehow “antisocial.”

Of course, the real facts are that people opposed to NAIS base their opposition on their positive religious, spiritual, social, and ethical values, and they want to create a more just world for all. NAIS opponents want a local, human-scaled economy that supports true family farming, offers fair compensation for producing food and other basic needs, and discourages greed, excessive commercialism, and materialism. In contrast, the pushers of NAIS -- originally multinational meatpackers and tech corporations -- are driven by greed for undeserved profit and power. In particular, the tech corporations will happily microchip your grandmother or your baby if they think they can make a buck doing it -- these corporations absolutely do not care about the obviously negative spiritual, social, and political consequences of their behavior.

The USDA User Guide attempts to turn these true values of things upside down. Consider the following statement from the Guide (p. 2):

“There are a number of reasons for producers to participate in NAIS. One of the most important reasons is to better protect animal health. People who own or work with animals, or depend on them for income, understand how absolutely important this is -- for themselves, their neighbors, and their surrounding communities.”

Thus the USDA spinmeisters falsely paint NAIS opponents -- who in reality are religiously and socially dedicated people sacrificing their own time and money to promote a better future for all people, all animals, all of creation and nature -- the USDA falsely paints these dedicated people as somehow not sufficiently attentive to “neighbors” and “communities.”

Curiously, the USDA never seems to have anything bad to say about the CAFOs and CAFO-dependent multinational meatpackers who pollute our air and water, create dangerous resistant bacteria by overuse of antibiotics, squander immense amounts of fossil fuels to produce and transport their products, treat animals like fungible “units of production” to be kept in total confinement, pay displaced foreign workers substandard wages, and drive family farmers and small local entrepreneurs out of business.

Suggested Actions

The issuance of the User Guide should not change the planned actions of NAIS opponents; rather, the Guide’s misleading propaganda should inspire NAIS opponents to continue their socially responsible work.

-- Do not rely on expressing your opinions to NAIS Working Groups or other “insiders” such as extension agents or government animal-health workers. Instead, make your opposition to NAIS known where it counts -- to your U.S. Congressman and U.S. Senator and to state senators and representatives.

-- Seek an end to all federal funding of NAIS. Good organizations to support in this regard are the National Independent Consumer and Farmer Advocates Fund (NICFA) and the Virginia Independent Consumers and Farmers Association (VICFA) -- check them out at www.vicfa.net.

-- Work for state legislation to prohibit acceptance of USDA NAIS funds by state agriculture and animal health departments, and legislation prohibiting state involvement in premises ID/animal ID/animal tracking.

-- Demand animal products produced without participation in NAIS.

-- Avoid purchasing industrially-produced animal products and encourage others to boycott such foods.

-- Obviously, do not sign up for any “voluntary” aspects of NAIS. Avoid any actions that might trigger “forced voluntary” NAIS, such as need for interstate shipping permits or participation in “voluntary” government-sponsored animal-related programs.

-- Avoid attending any animal-related fairs or shows that require NAIS premises ID or animal ID. Instead, arrange your own animal-related events with trusted neighbors or friends.

-- Oppose any attempts by the USDA or state agriculture departments to obtain statutory exemptions from freedom-of-information laws for NAIS information. Remember, bureaucrats will be unable to implement NAIS if they cannot get FOIA exemptions for their databases.

-- Work to repeal the already-mandatory premises ID in Wisconsin and Indiana, and the soon-to-be-mandatory RFID tagging for cattle in Michigan. Help your friends and family from these states to relocate, if necessary.

-- Refuse to buy any land that has a premises ID or any animals that have NAIS animal identification numbers.