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Comments needed for proposed rule #53.4
by Rosalee Coleman
Nov 23, 2011 | 332 views | 0 0 comments | 5 5 recommendations | email to a friend | print
Editor:

The Texas Animal Health Commission (TAHC) is proposing new rules that I think are unnecessary and will be very expensive for every producer. They are asking for comments at this time and I hope my fellow ranchers will take the time to contact them.

The TAHC, in proposed rule #53.4 is asking that every adult animal that goes through an auction barn be tagged or if they are already tagged, the tag be read, and all numbers be recorded. TAHC does not have funding for this program, so they are requiring that the producer be charged for this and suggesting a fee of $5-$10 per head chute fee. They also don’t have money to catalog the information, so they say they will “put it in boxes” in the TAHC office. You can bet that another fee will be coming to record all this information and the producer will be expected to pay.

This is unfair and unnecessary and hopefully if enough people object, TAHC will delay this project until if and when we are required by the Federal Government to individually ID our cattle. I would expect that if and when the Government does do this, there will be some kind of funding to offset the enormous cost involved. It is important to note that at the present time, USDA is only requiring that animals be tagged if they cross state lines. They are not asking for tagging of all adult animals in the state.

I could write pages about the cost and uselessness of the proposed TAHC rule, but I will only try to make a few points here:

1. The metal ear tags were only moderately successful when used for the brucellosis program. Tags were lost and misread with alarming regularity. There is no reason to think they would be any better on this go round.

2. Cattle are already identified as to buyer and seller when they go through the auction. To require an extra tagging will cost the producer up to $10 per head plus the hidden cost of extra bruising, time lost, and stress on man and beast. The auctions will have to hire extra hands just to handle the tagging of cattle. In the short time that we have not had to tag cattle for the brucellosis program, there has been an immediate increase in slaughter cow prices and decrease in stressed and buckling cattle. We don’t want to see this go away.

3. TAHC is already tagging cattle that have diseases such as TB or trichomonaisis and if there ever should be another brucellosis case. Therefore, it doesn’t make sense to tag millions of well cattle. The cost/benefit analysis for this program would not add up.

4. TAHC says the reason they want to do this is to ensure good traceability for cattle in Texas. However, their rule does not cover cattle sold by private treaty, on satellite sales, or going directly to packing houses. It will only penalize producers selling through auction barns, which again, makes no sense. I f they must issue a rule for tagging cattle, it should cover all cattle sold in the Sate of Texas. However, it would be much better not to impose this troublesome requirement on anyone at this time.

5. Finally, the rancher does not need this extra expense now, when we are battling extreme drought, wildfires and escalating feed prices, along with smaller calf crops due to the dry conditions.

Please take the time to contact TAHC and ask them to delay tagging of adult cattle until we are required by the federal government to do so. Maybe by then we will have better technology and maybe there will be funding available to put the program in place.

TAHC is asking for comments at this time and they need to hear from us. The addresses you can use to voice your opinion are 2105 Kramer Lane, Austin, TX 78758 attention Carol Pivonka Texas Animal Health Commission or comments@tahc.state.tx.us mention proposed rule #53.4. The comment period will be over on Wednesday, Dec. 7, so please don’t delay. Thank you very much.

Rosalee Coleman

George West

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