1. Proper care of livestock, poultry and fur-bearing animals is essential to the efficient and profitable production of food and fiber. No segment of society has more concern for the well-being of poultry and livestock than the producer. Animal-based medical research benefits both humans and animals - including pets, farm animals and endangered species. Research utilizing animals is necessary to ensure more effective human and veterinary medical practices.
2. Results from peer reviewed animal stress research should be emphasized along with practical ways to implement the results on farms and ranches.
3. We will encourage all commodity groups to pool resources to create and continue a direct concentrated effort to educate consumers on the facts associated with the production of livestock and other agricultural commodities using accepted best management practices.
4. Regulations should not unduly restrict the right of farmers, distributors, or retailers to hold and sell live animals. Likewise, the right of individuals to purchase live animals to prepare for food consistent with their personal or cultural beliefs should not be restricted beyond reasonable safeguards relating to the health of the species, safe handling, processing of animals and ensuring food safety.
5. We support:
5.1. The proper treatment of animals;
5.2. A farmer’s right, in consultation with their veterinarians, to set appropriate protocol for common animal husbandry practices to be administrated by the farmer or trained employee that are appropriate for their farm;
5.3. Properly researched and industry-tested poultry and livestock practices that provide consumers with a wholesome food supply and enable farmers to improve the care and management of livestock and poultry;
5.4. The use of scientifically proven technologies for agricultural production practices;
5.5. The rights of individual commodity groups to develop a voluntary national production standard;
5.6. Continued cooperation with other agricultural and agricultural- related organizations to address the animal care issue;
5.7. The practice of educating livestock exhibitors and breeders about ethics and positive animal care practices;
5.8. The exemption of farm visits by the general public, whether for profit or not, from licensing under the federal Animal Welfare Act;
5.9. Vigorous enforcement of fines and/or reimbursement for animal research lost and all costs and damage incurred when farms or research facilities are willfully damaged. Responsible persons or organizations should pay all costs;
5.10. Criminal prosecution for individuals obtaining employment or entry into agricultural facilities under false pretenses;
5.11. Legislation that requires person(s) witnessing animal abuse to report findings to management and/or the proper authorities within 24 hours of witnessing such action;
5.12. A proactive and aggressive effort to address attacks by activist organizations on animal agriculture and the food industry;
5.13. Legislation to prohibit photography or audio recordings on private premises without the landowner’s knowledge or consent;
5.14. The interstate commerce clause of the U.S. Constitution for all food commodity products which comply with public health or food safety regulation. There should be no restrictions on state-to-state movement of food products that do not affect the safe and healthy use of those products; and
5.15. Producer-led, voluntary quality assurance programs for all livestock sectors. We encourage all segments of the value chain, from farm to fork, to participate in their respective quality assurance program.
6. We oppose:
6.1. Legislation or regulations that limit a producer’s rights to breed livestock or domestic animals on the farm;
6.2. Any mandatory requirement that producers establish psychological profiles or daily psychological monitoring of individual animals;
6.3. Initiatives, referendums or legislation that create standards above sound veterinary science and best management standards;
6.4. Any laws or regulations which would mandate specific farming practices in livestock production;
6.5. Federal legislation or regulations attempting to place an additional tax or fee associated with animal care practices on each animal produced by an agricultural production facility;
6.6. Legislation and regulations which would prohibit or unduly restrict the use of animals in research;
6.7. The use of educational materials in our public schools that discourage use of animal products;
6.8. The concept of animal rights and the expenditure of public funds to promote the concept of animal rights;
6.9. Laws or regulations elevating the well-being of animals to a similar status as the rights of people;
6.10. Legislation that would give animal rights organizations the right to establish standards for the raising, marketing, handling, feeding, housing or transportation of livestock including equines, poultry, aquaculture and fur-bearing animals; and
6.11. Any legislation that would pay bounties to complainants.
7. We urge Congress to continue to address the problem of animal rights terrorism:
7.1. We support the Animal Enterprise Protection Act of 1992 and urge all states to adopt similar statutes;
7.2. Amend the federal tax code to allow for suspension or revocation of tax-exempt status for federally recognized charities linked to terrorist groups in the event that such relationships are confirmed by federal or state investigation;
7.3. The IRS should diligently pursue removal of tax-exempt status to animal rights organizations whose level of political activity exceeds the level allowed for charitable organizations; and
7.4. Direct the Office of Personnel Management to allow for permanent removal of the charity from the Combined Federal Campaign list of eligible charities in the event that such relationships are confirmed by federal investigation and be required to return all funds they have received as a result of being on the Combined Federal Campaign list.
8. We recommend:
8.1. Stricter enforcement of laws requiring livestock market owners to water and feed livestock kept overnight in stockyards and markets;
8.2. Industry-coordinated, non-ambulatory animal handling educational activities and oppose additional unreasonable federal regulations;
8.3. The livestock industry oppose the shipment of non-ambulatory livestock from the farm to livestock markets or auctions;
8.4. Separate classification of non-ambulatory livestock -- those due to an injury or accident and those which are diseased. Non-ambulatory livestock due to injury or accident should be allowed to be slaughtered and processed for personal use;
8.5. Non-ambulatory livestock be properly handled or treated on the farm to avoid unnecessary suffering;
8.6. If the proper professional treatment on the farm fails, non-ambulatory livestock be euthanized on the farm and properly disposed;
8.7. If livestock becomes non-ambulatory during transport or while being held at livestock markets, non-ambulatory livestock should receive appropriate veterinary treatment, and special arrangements be made to have animals that remain nonresponsive after treatment euthanized, properly disposed and not used for human consumption;
8.8. The livestock industry support additional research and evaluation of livestock husbandry including proper methods for the movement of non-ambulatory livestock, design of livestock production, handling and transportation systems; and
8.9. The livestock industry encourage aggressive initiatives within its ranks to communicate the best modern animal husbandry and handling practices, including but not limited to:
8.9.1. Methods to prevent livestock from becoming non-ambulatory;
8.9.2. Information on practical and acceptable methods for the proper movement of non-ambulatory livestock; and
8.9.3. Facility designs that promote the safe and appropriate production and movement of livestock.
1. Animal disease has a direct impact on food safety, which is fundamental to international trade.
2. Adequate USDA animal health facilities are critical to maintaining our world-class research on both foreign and domestic diseases. The United States should use every means necessary to ensure that these diseases do not reach U.S. soil.
3. We recommend that the USDA continue to work to develop an accurate rapid testing program for Johne's disease. Additional research is needed for developing diagnostics and vaccines, understanding the biology of organisms and determining why diseases emerge. We and the international community must give priority to other emerging infectious diseases such as foot-and-mouth disease (FMD), Exotic Newcastle Disease (END), West Nile Virus, vesicular stomatitis (VS), bovine spongiform encephalopathy (BSE), classic swine fever (CSF), porcine epidemic diarrhea virus (PEDv), pseudorabies, tuberculosis, salmonella, E. coli, scrapies and contagious equine metritis (CEM).
4. We support:
4.1. The continued education and regulations for biosecurity issues already in place;
4.2. The development of a new world-class national animal health emergency management system for the United States and fully funded animal disease response teams to respond in a quick and adequate manner;
4.3. The development of pre-approved on-farm disposal plans to help manage Class A animal disease outbreaks;
4.4. A farm premises identification program that is confidential and only used in case of a Class A animal disease outbreak;
4.5. Cooperative efforts, between government and industry, at the international, national, state and local levels in crafting this management system, such as the National Animal Health Emergency Management system. Components of this system include prevention, preparedness, response and recovery;
4.6. Expansion of the North American Vaccine Bank for foot-and-mouth disease to meet emergency response requirements as defined by the USDA;
4.7. The international border-state tuberculosis standards and adequate regulations to ensure imported cattle are tuberculosis-free;
4.8. The development and production of foot-and-mouth disease vaccine on U.S. soil and/or by a U.S.-controlled company;
4.9. Funding for emerging infectious animal disease research on scrapie, Johne's, porcine reproductive and respiratory syndrome (PRRS), anthrax, chronic wasting disease, porcine circovirus type 2 (PCV2), influenzas and similar respiratory diseases affecting domestic livestock and poultry, and cryptosporidosis, which is a critical component to a national animal health emergency management system; and
4.10. The inspection of all species and equipment from any country known to have FMD and/or BSE or any other disease that may pose a threat to the U.S. livestock industry.
1. We urge Congress to continue and adequately fund regional aquaculture centers.
2. Recognizing the extremely short shelf life of some aquaculture feeds, we recommend that aquaculture feed labels include date of production and be legible.
3. Individual tagging or other marking of aquacultural products should not be required. Records commonly maintained in the course of normal business should be sufficient to document legally produced aquacultural products.
4. We recommend that soft shell crabs and turtles be included in any future aquaculture census conducted by U.S. government agencies.
5. We recommend that USDA's National Agricultural Statistics Service conduct a national census of aquaculture every five years.
6. We recommend that freshwater aquaculture producers be exempt from permits and fees required as a prerequisite to allow them to hold, raise and sell aquaculture species.
7. We encourage USDA and Animal Plant Health Inspection Service (APHIS) to work with the aquaculture industry and producers in developing rules to contain Viral Hemorrhagic Septicemia (VHS) while not adversely affecting the marketing and including interstate transport of live fish not infected with the virus.
8. We urge the Aquatic Nuisance Species Task Force to adopt farm-level aquatic invasive species (AIS) hazard analysis and critical control point (HACCP) programs as a means to prevent the spread of AIS. Environmental DNA (eDNA) and polymerase chain reaction (PCR) testing should not be used as primary regulatory enforcement tools.
9. We urge Congress to adequately fund USDA Veterinary Services' budget requests for surveillance funding for VHS disease to prevent its spread within the United States.
10. We support:
10.1. Federal legislation recognizing aquaculture and aquaponics as an agricultural industry with full benefits of traditional agriculture such as production insurance, health certification, loan guarantees and expedited approval;
10.2. APHIS as the lead agency in establishing animal health certification and a national aquatic animal health plan;
10.3. “Icing/Chill Kill” being recognized by USDA/APHIS as a form of euthanization;
10.4. Efforts to resolve the fish import situation, particularly Vietnamese and Chinese Basa. Efforts should include all areas such as anti-dumping, increased Food and Drug Administration (FDA) inspection and specific labeling;
10.5. Federally funded U.S. aquaculture research priorities that are developed with industry input and direction to assure such findings will serve industry needs, including the development of a live fish test to address disease concerns. Federally funded aquaculture research at publicly funded institutions (including the regional aquaculture centers) should not compete with private sector aquaculture. Such aquaculture research funding should contain an extension component to get research results out to the targeted U.S. aquaculture industry;
10.6. Action being taken to amend the Lacey Act to allow free interstate commerce of legitimately grown or harvested aquaculture products. Any limits to the movement of nonindigenous species should be balanced with the need to investigate new species to culture;
10.7. Legislation to exempt private aquacultural products from the Lacey Act. Until such an exemption occurs, we support:
10.7.1. Reducing the extreme penalties that are assessed with a violation;
10.7.2. Increasing the market value from $350 to $50,000 to trigger the felony provisions;
10.7.3. Changing the current language from “knowingly” to “willingly or purposely”; and
10.7.4. Exempting farmers and farms from warrantless arrest and search and seizure;
10.8. Federal assistance in the form of low-interest loans or other disaster relief for fish farmers who must remodel or go out of business due to whirling disease;
10.9. General labeling of aquaculture drugs for classes, families or other groupings or life stages of aquatic species. We oppose species-by-species labeling of drugs;
10.10. The concept of group or lot identification and oppose individual identification for aquaculture in the event animal ID is maintained;
10.11. Congressional action to transfer authority for wildlife damage to aquaculture crops and livestock from the Fish & Wildlife Service (FWS) to USDA's Wildlife Services regarding the control of predatory birds and other predators;
10.12. The coordination of the various segments of the industry in order to promote industry understanding and harmonization;
10.13. The 1991 language of nationwide permit 4 with regards to planting shellfish in submerged aquatic vegetation beds, instead of the 1996 revision language;
10.14. A scientific study of the beneficial environmental and economic effects of shellfish aquaculture in coastal regions of the United States;
10.15. The exemption of fish farms from Farm Service Agency (FSA) restrictions on loans in a floodplain;
10.16. The strict enforcement of current laws and penalties in cases of theft and/or willful destruction of fish and shellfish raised for sale;
10.17. The legalization of the sale of U.S.-propagated freshwater turtles that have been certified salmonella-free;
10.18. FWS and the National Marine Fisheries Service (NMFS) allow aquaculturists to obtain plant materials, invertebrates, vertebrates, broodstock, eggs or juveniles from the wild as required for aquaculture purposes as long as the wild population is not adversely affected;
10.19. Any legally acquired plant materials, invertebrates, vertebrates, broodstock, eggs or juveniles should be the property of the aquaculturist upon arrival at the farm and be considered agricultural products;
10.20. The development of a rapid response team by the federal government to control nonindigenous aquatic species should be a joint APHIS and FWS effort, since APHIS is the most experienced federal agency in dealing with invasive species;
10.21. The use of private aquaculture for contracts prior to building new public hatcheries or expanding existing facilities. Priority should be given to aquatic species quality and full cost of production of those species;
10.22. The development of paddlefish and sturgeon farming through continued research on captive propagation and husbandry practices. We also support a cooperative effort between paddlefish and sturgeon farms and state and federal agencies. We recommend amending the Endangered Species Act to allow free interstate and international commerce of legitimately grown or harvested paddlefish and sturgeon products including the shortnose sturgeon;
10.23. USDA Food Safety and Inspection Service should, as directed by the 2008 Farm Bill, immediately begin the inspection of all domestic and imported fish that is called or considered "catfish";
10.24. Increased funding for consumer education, research and economically practical methods for treatments of shellfish to control and remove Vibrio and urge the FDA to allow time for such research to be conducted before moving forward with ongoing efforts and proposals to prevent summertime harvesting of shellfish intended for raw consumption; and
10.25. Funding for National Oceanic and Atmospheric Administration (NOAA) to be the lead agency in facilitating the discussion on the expansion of marine aquaculture sites in federally regulated waters with industry and local, state and federal agencies. NOAA having a cohesive plan to:
10.25.1. Identify marine aquaculture sites in federal waters;
10.25.2. Assist industry in the placement of marine aquaculture in federal waters;
10.25.3. Reduce conflicts among competing uses;
10.25.4. Minimize adverse impacts on the environment; and
10.25.5. Identify activities for potential co-location with aquaculture operations.
11. We oppose:
11.1. Any federal regulatory agency that would duplicate or supersede state controls in regulating the aquaculture industry at the state level;
11.2. FWS listing any species as injurious wildlife under the Lacey Act until a formal risk assessment has been conducted on that species by FWS;
11.3. FWS listing aquatic animal diseases as injurious species under the Lacey Act because USDA/APHIS already regulates aquatic animal diseases in the United States;
11.4. FWS requiring fish farmers to keep a daily, instead of monthly, log on birds killed under an FWS depredation permit or depredation order;
11.5. Any change or reclassification of baitfish as a food additive by the FDA;
11.6. The listing of triploid black carp and grass carp as an injurious wildlife species;
11.7. Any component of the Management and Control Plan for Asian Carp that might place unnecessary and/or burdensome regulations on aquaculture producers;
11.8. Canadian restrictions on importation of live bighead and grass carp. All carp must be killed before leaving a Canadian fish market; and
11.9. FDA mandated sale prohibitions without consultation with the interstate Shellfish Sanitation Conference.
1. We support:
1.1. Regulatory or legislative reform of federal requirements for maintenance of logbooks by commercial fishermen which divulge proprietary information and individual trade secrets; and
1.2. The commercial harvesting of Atlantic herring to be rendered into a fish meal product to be used in aquaculture feed.
2. We oppose all legislation that attempts to make any commercially caught fish a gamefish only or to make the sale of such fish illegal.
1. We support the Beef Promotion and Research Act of 1985 and the Federation of State Beef Councils. We favor allowing the free market system to work in the U.S. beef industry.
2. We support the following changes to the beef checkoff provisions:
2.1. An opportunity to petition for a referendum;
2.2. An increase of the checkoff rate;
2.3. Enhanced understanding of the Federation of State Beef Councils; and
2.4. Making the checkoff more inclusive.
3. Unless approved by a cattle producer referendum in advance, we oppose:
3.1. Any national beef checkoff program established under the Commodity Promotion, Research, and Information Act of 1996; and
3.2. Other changes to the selection process for the Cattlemen’s Beef Board.
1. We support:
1.1. The use of equine for transportation, recreation and business;
1.2. Legislation and rulings that allow the sale, possession and transport of horses intended for processing or rendering, and encourage a national education campaign targeted toward legislators and the media as to the consequences of eliminating equine harvest, resulting in unintended animal abuse and neglect, and the negative impact on the equine industry;
1.3. Domestic ownership, control and location of equine processing facilities with the understanding that facility owners will pay for approved USDA inspection if federal funding is not available;
1.4. The reopening or development of new equine harvesting facilities;
1.5. The classification of horses as livestock;
1.6. Maintaining accessibility to federal and state lands for equine activities through the passage of the National "Right to Ride" Act;
1.7. Funding for USDA Food Safety and Inspection Service (FSIS) inspectors in facilities that harvest horses;
1.8. Including all aspects of the equine industry in the agricultural census;
1.9. Encouraging equine owners to follow American Association of Equine Practitioners (AAEP) core vaccination guidelines for equine health and disease related issues;
1.10. Including horses in the definition of livestock as it applies to qualifying for federal disaster programs;
1.11. Individual and non-governmental organization rights to save horses from harvest as long as they take possession of the horses and are responsible for their care and feeding;
1.12. When an equine is in the custody of a government agency and an adoption has not been able to take place within 6 months, that equine should be euthanized with minimal stress without delay and processed;
1.13. Legislation that would recognize the inherent risks of equine activities;
1.14. The development of a national testing and surveillance program for Piroplasmosis;
1.15. Funding for USDA FSIS to create withdrawal protocols for animal remedies used in the equine industry;
1.16. Working with veterinary schools and veterinary associations to encourage education on the use of captive bolt gun for equine euthanasia. This AAEP and American Veterinary Medical Association (AVMA) approved euthanasia method is more environmentally friendly than barbiturate overdose and ensures more options for carcass disposal;
1.17. Congress directing funds that were previously allocated to inspection of processing plants (and removed in 2015 budget) to research withdrawal times for equine pharmaceuticals and develop rapid diagnostic drug residue testing procedures for horses bound for processing;
1.18. All inspection processes relative to the Horse Protection Act by industry and/or USDA should include science-based criteria to arrive at an objective summation of compliance or non-compliance; and
1.19. The unrestricted use of horse pads for purposes of shoeing horses.
2. We oppose:
2.1. The passage of the Horse Slaughter Prevention Act or similar legislation;
2.2. The classification of horses as companion animals;
2.3. Any regulations that prohibit the harvest of equines;
2.4. Any legislation that would curtail movement into Mexico and Canada of horses that meet the requirements of existing trade agreements;
2.5. Coggins testing for horses going directly to slaughter; and
2.6. Legislation or regulation that would ban the use of double deck livestock trailers for horses as long as the trailers are adequately designed.
1. We recognize the need for feed additives and medication in livestock, poultry and minor species. We favor judicious use and withdrawal restrictions of feed additives and therapeutics. We oppose the banning of such additives and therapeutics. We urge thorough investigation of the accuracy of the tests used by government agencies to determine drug residues in livestock and poultry. Producers who have had a drug tissue residue violation and remain compliant for 12 consecutive months should have their names removed from all violators lists.
2. When animals or groups of animals are partially or completely condemned, there should be a complete written report to the seller recording any permanent identification of the animals and stating the reason for condemnation.
3. Livestock feed labels should provide clear, concise and accurate information regarding ingredients and nutritional information. The Food and Drug Administration (FDA) and state feed control officials should consider making modifications in labeling requirements by developing more specific classifications of animal protein sources such as "non-ruminant derived animal proteins," "ruminant derived animal proteins" and "non-mammalian derived animal proteins" to provide producers with the information they need to make the certifications about feeding practices that the marketplace is demanding. It is unnecessary to label feed ingredients according to species origin. We support the use of the current warning statement of feed labels that states, "Do not feed to cattle or other ruminants" if the feed contains ingredients prohibited to be fed to ruminants by FDA rules.
4. To help ensure international uniformity in standards for pharmaceutical approval the FDA should use scientific research data of foreign countries to assist in approving animal health products for use in the United States. We further encourage Congress to ensure adequate funding for the National Animal Disease Center, National Veterinary Services Laboratory and Center for Veterinary Biologics and the Poison Plant Disease Center.
5. In an effort to protect the entire livestock and poultry industry, we believe that farm animals raised in urban areas should follow similar animal health protocol and production practices as those raised in agricultural areas.
6. We encourage producers to participate in voluntary quality assurance programs.
7. We encourage the use of electronic animal health papers, with the ability to include but not require actual digital photos of the animal, for relevant species. Digital photos of equine may be practical; however, digital photos of mass transit animals like cattle and hogs are not practical.
8. In an attempt to minimize economic impacts, no human disease should be named after an animal or commodity.
9. We oppose any producer checkoff or assessment to fund national livestock disease eradication programs, including but not limited to brucellosis, scrapie and pseudorabies.
10. We support:
10.1. Legislation that would continue the ability of veterinarians to prescribe drugs and the accepted extra label usage of drugs needed for proper animal care. Adequate funding should be provided for the Food Animal Residue Avoidance Databank to allow for continued, free, immediate expert consultation to livestock owners and veterinarians in the event of accidental drug or toxin exposure to livestock or poultry. Veterinarian-prescribed and FDA-approved animal medication should be permitted to be stored in production facilities in properly secured enclosures;
10.2. The continued sale of veterinary prescribed and over-the-counter animal health products and oppose further restrictions on their use, including any required on-farm reporting of drugs administered to livestock;
10.3. Amending the Controlled Substance Act to allow a veterinarian to transport and dispense controlled substances in the usual course of veterinary practice at a site other than the registrant’s registered principal place of business or professional practice, so long as the site is within a state where the veterinarian is licensed to practice;
10.4. Adequate funding for FDA's proposals to increase the research development and availability of approved animal drugs for minor uses and minor species (MUMS Document) as well as the concept that there should be different requirements for drug approval for minor species and minor uses;
10.5. Research, development and importation of labeled animal health products;
10.6. Expedited approval for import to the U.S. of U.S. approved products which, due to economic constraints, are no longer manufactured in the U.S.;
10.7. The development of a core animal disease control and eradication program to prevent the introduction of foreign or emerging animal diseases and poultry diseases and pests into this country and to control and eradicate those that exist;
10.8. The efforts of state agencies to control rabies. We recognize the need for restricted labeling of rabies vaccine. We encourage continued research into effective ways to immunize wildlife against rabies and make those vaccines readily available to responsible state agencies;
10.9. The development and identification of a swift and accurate live animal diagnostic test for Chronic Wasting Disease (CWD) and an eradication program;
10.10. Federal agencies assisting in providing funding for genetic resistance research to eliminate CWD in cervidaes;
10.11. Farm animal vaccines containing potentially dangerous endotoxins be required to be labeled to identify possible side effects and preventive measures;
10.12. The National Veterinary Medical Services Act (NVMSA), which provides veterinary school graduates student-loan repayment if they agree to work in underserved areas. We encourage Congress to fund NVMSA and USDA to work with the livestock industry to develop participation guidelines that include giving priority to those who agree to enter the food animal and rural veterinary fields;
10.13. We support the elimination of the tax on Veterinary Medicine Loan Repayment Program (VMLRP) awards;
10.14. USDA continuing to work with the livestock and dairy industries to further develop methods to control leukosis;
10.15. USDA requiring all commercial feeds being sold show the total digestible nutrients in the feed;
10.16. Animal and Plant Health Inspection Service (APHIS) actively pursuing epidemiological studies on Vesicular Stomatitis (VS) and that the Agricultural Research Service (ARS) move quickly to study vectors, reservoirs and mode of transmission;
10.17. APHIS and ARS supporting research for the development of a licensed VS vaccine and protocol for vaccine use;
10.18. APHIS maintaining adequate staff involvement and monetary support to find solutions for the current outbreak and prevent recurrence of VS;
10.19. APHIS carefully evaluating international restrictions on animals and especially on products to assure that such restrictions are science-based;
10.20. Federal legislation, regulations or programs that support regionalization by APHIS to modernize animal movement regulations;
10.21. More research and education on the impact of Lyme disease and other tick-borne diseases carried by wildlife that cause serious illness to humans and animals;
10.22. The United States having its own testing requirements for animal diseases based only on sound science, with every effort to adhere to the Office of International Epizootics risk assessment standards;
10.23. Producers’ continued access and ability to use polyether ionophores (e.g., monensin, lasalocid) as a feed additive to reduce methane production in cattle and to serve as a coccidiostat in poultry;
10.24. Changing the federal definition of a veterinary-client-patient relationship (VCPR) to allow for the use of telemedicine when making an animal health diagnosis and recommending a course of treatments; and
10.25. Ionophores used in livestock and poultry production be reclassified as antiparasitics, not antibiotics.
11. Animal Antibiotics
11.1. To protect the continued use of critical animal health products we support the following:
11.1.1. Clarification and further review of FDA’s veterinary feed directive (VFD) in regards to therapeutic drug use protocols. We also support a plan for education regarding the purpose and implementation of the VFD for producers, feed distributors and veterinary professionals;
11.1.2. FDA’s Veterinary Feed Directive (VFD) preserving the right for producers to use feed additives and injectable antibiotic products;
11.1.3. Sound science as the basis for decision-making and policy development regarding antibiotics/antimicrobials used in food animal production;
11.1.4. Use of the National Antimicrobial Resistance Monitoring System, the National Animal Health Monitoring System and USDA's food safety monitoring system to address issues of antimicrobial resistance trends in food-borne bacteria and animal health;
11.1.5. Regulation of antibiotics/antimicrobials at the national level to avoid a state-by-state patchwork of regulation;
11.1.6. A multi-agency approach to on-farm antimicrobial-resistant bacteria trend research and surveillance that includes APHIS, ARS, Food Safety and Inspection Service and livestock producers;
11.1.7. Rather than limitations or elimination of animal health and food safety protection tools, we would accept veterinarian oversight of antibiotic use, where veterinarian oversight is defined as a working relationship with a licensed veterinarian and allow for the purchasing of animal pharmaceuticals using a prescription without the requirement of purchasing directly from a veterinarian;
11.1.8. The veterinary/patient client relationship as it relates to medical use and antibiotics, and the information should remain confidential and not subject to Freedom of Information Act requests. Similar to other farm data, all animal health records are the property of the farm and require the owner’s written permission to be accessed;
11.1.9. Current slaughter surveillance, testing and inspection as appropriate food safety and animal health protocol;
11.1.10. The use of a standard symbol for all drugs that require a withdrawal time;
11.1.11. The FDA allowing the extra label use of cephalosporin antimicrobial drugs in animals when warranted; and
11.1.12. Amending the VFD to allow veterinarians to prescribe extra-label use of antimicrobial drugs in animals when warranted, including in the treatment of minor species. The VCPR establishes sufficient oversight of veterinarians for extra-label use when necessary.
11.2 We oppose any attempt to reclassify over-the-counter non-prescription injectable antibiotics to prescription-only status.
12. Bovine Spongiform Encephalopathy (BSE)
12.1. We support:
12.1.1. Continued research to verify the means of transmission of BSE and methods to inactivate the causative agent;
12.1.2. Federal legislation, regulations or programs which will support the establishment of a fund within USDA to pay beef and dairy producers to voluntarily submit the heads of downer animals for increased BSE surveillance;
12.1.3. A uniform international standard to confirm BSE;
12.1.4. Confidentiality of all inconclusive BSE test results;
12.1.5. Announcements relating to BSE testing be made during non-trading hours at the Chicago Mercantile Exchange (CME);
12.1.6. Continued monitoring and surveillance programs for BSE and other Transmissible Spongiform Encephalopathies (TSE) in the United States; and
12.1.7. A ban on the inclusion in ruminant feeds of any animal proteins scientifically shown to transmit BSE.
13.1. Since brucellosis is a dangerous disease agent transmittable from wildlife to domestic livestock and humans, we support the enactment of a mechanism and the appropriation of funds to require federal agencies in custody of wildlife to compensate livestock owners and other aggrieved entities for actual expenses and losses brought about by conflicts from wildlife when such losses can be substantiated.
13.2. We support the Bi-National Tuberculosis and Brucellosis Committee in its effort to control/eradicate bovine TB and brucellosis in Mexico and to prevent its spread to this country. We urge USDA to adopt regulations consistent with the border states' consensus document. The goal is the complete eradication of the diseases in both countries. This should include the development and validation of rapid tests for the diseases as well as the ability to trace infected animals back to their point of origin. If TB-infected cattle continue to arrive in the United States from any Mexican state, we should urge USDA to place more stringent inspection, quarantine and testing requirements on all imported animals from that state.
13.3. We support:
13.3.1. A quarantine of wildlife in Yellowstone Park until it is certified free of brucellosis and TB;
13.3.2. Adequate program funding to complete eradication and provide needed monitoring and surveillance;
13.3.3. The federal government continuing full funding of brucellosis control activities in all infected states;
13.3.4. A voluntary herd depopulation program and increased surveillance in order to speed up brucellosis control;
13.3.5. Efforts to strengthen brucellosis laws and regulations and make them uniform among states;
13.3.6. Updating state and federal rules regarding vaccination of cattle to coincide with RB51 vaccine science versus Strain 19 vaccine, including mandatory vaccination of heifers for breeding and possibly adult cattle; and
13.3.7. State and federal funding for developing a more effective vaccine for protecting cattle and wildlife from brucellosis spread by wildlife and expanding research and diagnostics to understand the true health exposure.
14.1. We support:
14.1.1. Implementation and funding for the National Strategic Plan for the Cattle Fever Tick Program developed in 2006;
14.1.2. Immediate funding to eliminate Fever Ticks from the temporary preventive quarantine areas and prevent their spread throughout the United States;
14.1.3. Research to develop a test for accurate chute-side testing for Persistent Infectious Bovine Viral Diarrhea (PI-BVD);
14.1.4. The program developed by the cattle industry requiring that all bulls 18 months of age and older offered for sale, at auctions or at private treaty, be for slaughter only unless verified trichomoniasis-free with written certification of a negative trichomoniasis test within 30 days prior to sale; and
14.1.5. Research and eventual eradication of the screw worm.
15. Johne’s Disease
15.1. We support:
15.1.1. Implementation of a multi-year program to identify Johne's disease infected animals and to provide an indemnity payment at fair market value for disposal of cattle whose fecal culture has tested positive for this disease; and
15.1.2. The voluntary Johne's herd status program developed by USDA and an accurate rapid testing program. USDA should:
126.96.36.199. Develop an accurate blood test for Johne's Disease; and
188.8.131.52. Support funding to reduce the producer's cost to test for Johne's Disease.
16. TB (Tuberculosis)
16.1. We support:
16.1.1. USDA developing a more accurate TB test;
16.1.2. USDA allowing states to have split state status for TB certification;
16.1.3. The Emergency Action Plan to complete the eradication of TB, and sufficient federal funding for the elimination of TB in the United States;
16.1.4. Amending the Code of Federal Regulations (CFR) and the Uniform Methods and Rules (UM&R) governing the USDA TB eradication program to allow the state's animal health authority to quarantine TB-infected herds, employ test-and-remove procedures to eliminate infection, and control movement within areas of risk defined by scientific analysis, rather than requiring depopulation of infected herds and downgrading the TB status of the entire state. Additionally, we support amending the CFR and UM&R to base any downgrading of states' status on prevalence and risk of disease spread;
16.1.5. Counting test-and-remove herds as TB positive herds only for the one year in which the herd had a positive TB test;
16.1.6. Changes in the national Mycobacterium bovis TB testing requirements that eliminate the need for an individual test for animal movement from a lower disease prevalence zone to a higher disease prevalence zone; and
16.1.7. The establishment and utilization of a science based zoning approach and testing process to address disease risk (e.g. a 10-mile radius zone around new TB positive domestic livestock herds where wildlife is involved).
17.1. We support:
17.1.1. A ban on the inclusion of ruminant animal proteins in poultry feeds;
17.1.2. The practice that all poultry crates and Pullman trailers used to haul live fowl (spent hens) for slaughter be cleaned and sanitized after each use at the poultry processing plant;
17.1.3. The development of a high-containment facility by USDA to study avian influenza and an appropriate vaccine;
17.1.4. The continuation of the federal-state cooperative agreement for animal avian health and surveillance of low-path H5/H7 avian influenza at current levels;
17.1.5. Authorization of poultry disaster assistance for growers, including contract growers, implemented by USDA to cover Avian Influenza (AI) production /revenue losses and associated disposal and clean-up costs;
17.1.6. Preventing, detecting and responding to future cases of highly-pathogenic AI as a priority for poultry growers, industry and federal and state animal health officials. Prevention starts with sound workable biosecurity procedures included in the daily management activities carried out by growers and integrators; and
184.108.40.206. We support:
220.127.116.11.1. Expanding federal, state and industry response capabilities to enable rapid detection and response in domestic poultry flocks;
18.104.22.168.2. Modifying USDA’s indemnity program to split payments between owners/integrators and contract growers in the event of flock depopulation; and
22.214.171.124.3. Streamlining the process for payment of indemnity and the cost of eliminating viruses to assist growers in returning to production.
17.2. We oppose mandatory testing of commercial laying flocks for Salmonella enteritidis until there is a statistically significant reliable testing procedure and protocol. Furthermore, we recommend that the trace-back program be discontinued.
18.1. We support:
18.1.1. More research and education on the impact of Bluetongue in livestock;
18.1.2. All owners of sheep participating in the Federal Scrapie Eradication Program;
18.1.3. Identification and trace back of source flocks for scrapie. All source flocks for scrapie should be identified for a minimum of one year even if there is a change in ownership. The National Scrapie Eradication Program should be administered consistently across state lines, including rules for tagging and identification of breeding animals;
18.1.4. Continued priority funding for scrapie research until the disease is controlled through the ongoing testing regimen; and
18.1.5. The implementation and funding of a USDA Sheep and Goat Scrapie Voluntary Flock Certification Program. We will support efforts to develop a swift and accurate live animal diagnostic test for scrapie and other TSEs.
18.2. We oppose banning domestic sheep from federal and state lands where Big Horn Sheep have been introduced.
19. Specialty Livestock
19.1. We support:
19.1.1. USDA recognizing privately-owned cervidae and camelidae as domestic livestock. We urge individual states to take similar action;
19.1.2. USDA seeking authority to regulate the interstate movement of cervidae and camelidae and developing uniform standards of testing and appropriate follow up procedures. Individual states are encouraged to adopt these standards; and
19.1.3. The removal of the Department of the Interior’s (DOI) authority to regulate exotic animal agriculture. DOI should continue to regulate non-domesticated animals.
20.1. We support:
20.1.1. Adequate funding of the pseudorabies eradication plan developed by the swine industry and strengthening the pseudorabies laws and regulations to require cleanup of infected herds;
20.1.2. Programs to develop and utilize swift and accurate tests to diagnose trichina in swine at slaughter and ultimately certify the United States trichina-free;
20.1.3. An efficient, strong, and adequately funded brucellosis control program leading to eradication of this disease in swine from the United States and Puerto Rico;
20.1.4. USDA continuing to assist countries which have experienced outbreaks of African swine fever to eradicate this disease and prevent its spread to the United States; and
20.1.5. Creating assurance among swine producers, veterinarians and packers allowing for the timely marketing of animals from herds infected with a non-reportable disease (e.g., Seneca Valley Virus) where animals are otherwise safe to travel, not contagious and pose no food safety risk.
21. Transportation/Interstate & International
21.1. Agencies that have import responsibility for mammal, gastropod, reptile, avian or aquatic animal species should be mandated legislatively to coordinate import requirements with USDA to reduce the risk of animal diseases being introduced. Firmer measures should be taken and more stringent penalties imposed to avoid the smuggling of pet birds into the country by requiring the micro-chipping of all imported birds during the time they are in commerce.
21.2. We support:
21.2.1. The USDA program to prevent the introduction of exotic diseases into the United States from foreign countries;
21.2.2. The USDA working with the state animal health officials on the development of an electronic signature option for animal health certificates that require a veterinary signature;
21.2.3. USDA regulations allowing certified veterinarian technicians to issue health certificates for interstate movement of livestock;
21.2.4. Federal regulations and programs which will encourage greater uniformity among states and countries in the testing and health requirements necessary for interstate and international transportation of livestock, nontraditional livestock and birds;
21.2.5. The establishment of a reciprocal agreement among brucellosis-and TB free states which would enable interstate movement of cattle originating from brucellosis and TB free herds by waiving the requirement for multiple pre-movement brucellosis and TB testing;
21.2.6. Stepped-up surveillance to prevent the illegal entry of livestock, avian, aquatic and reptilian species from any foreign country; and
21.2.7. Permanent inspection stations for imported livestock on the U.S. side adjacent to the border.
1. A national animal identification system that facilitates animal disease traceability should be considered a separate and distinct issue from country-of-origin labeling. We favor the continued use of legally recognized traditional methods of permanent identification of livestock for individual ownership.
2. Any new method of livestock identification should only be considered if it is proven equally practical and effective as current methods and is a legally recognized form of proof of ownership in all states having livestock brand law. We urge the USDA to conduct a full cost analysis study of a national animal identification system program and to publish the details. No action should be mandatory until Congress has published the cost figures and appropriated funding.
3. We support the establishment and implementation of a voluntary national animal identification system capable of providing support for animal disease control and eradication. Individual states and/or tribes should have control of the animal ID program, not a private "for profit" company. We support the opportunity for each state to decide the entity controlling their respective animal ID program database. However, in the event of a disease outbreak, the controlling entities must be equipped to communicate and utilize the system to track and trace animals in a timely manner.
4. A cost effective national system of livestock identification, with adequate cost share among government, industry and producers should be established and regulated by an advisory board of producers, processors and USDA. Any such program must protect producers from liability for acts of others after livestock leaves the producers' hands, including nuisance suits naming everyone who handled particular livestock.
5. We support the following guidelines for a livestock identification program:
5.1. The program must be as simple and inexpensive as possible for producers to implement;
5.2. Cost share support from the federal government is vital especially for development and implementation;
5.3. Producer information shall be confidential and exempt from disclosure under the Freedom of Information Act (FOIA);
5.4. Information shall be made available only to the proper animal health authorities in the event of an animal disease incident. Any unauthorized use shall constitute a felony;
5.5. The identification of animals will not be required until transported across state lines;
5.6. All imported animals should be permanently identified regarding their country of origin upon entry into the United States;
5.7. Ensuring the security of producer information and respecting the privacy of producers by only collecting data necessary to establish a trace-back system;
5.8. All current animal disease programs should be incorporated into a national animal identification system. Producers should need only one number for all programs; however, due to the voluntary nature of a national animal identification system, an opt-out method should be available to producers at their request;
5.9. Allowing an exclusion from any government mandated livestock traceability program for cattle under 18 months of age and those going directly to slaughter;
5.10. The development of uniform standards for electronic identification;
5.11. The development and adoption of livestock identification technology which will enhance the implementation of value-based marketing;
5.12. The hot-iron brand identification method as a legal, federally recognized method of permanent identification/proof of ownership in those states that have livestock brand laws; and
5.13. Meeting the reasonable identification requirements of foreign trade partners and overseas customers, ensuring the U.S. reputation as a reliable supplier of meat.
6. We oppose the labeling of the U.S. and Canadian cattle herds as one North American herd.
1. We support mandatory price reporting for the livestock industry.
2. We support accurate and timely reporting of wholesale and retail meat prices.
3. Price reporting programs should be administered by the Agricultural Marketing Service (AMS) of USDA.
4. We support:
4.1. Price reporting information being provided to the Grain Inspection, Packers and Stockyards Administration to enhance enforcement of the Packers and Stockyards Act;
4.2. State and federal market reporting activities involving auction barns, special and seasonal feeder animal sales and beef, swine, poultry, dairy, lamb and goat breeding animals being continued;
4.3. USDA-AMS developing protocols and rules to allow auctions to self-report results and price information when conditions or funding prevent official reporters from attending individual auctions or sales;
4.4. Modernizing the livestock market reporting by the USDA for daily accurate and correct market information that will minimize the possibility of manipulation by market speculators;
4.5. USDA including in its monthly livestock reports, information indicating the number and origin of imported and destination of exported livestock;
4.6. USDA implementing publication rules that maintain confidentiality of individual and private business information; and
4.7. USDA developing better reporting mechanisms for sheep, lamb and goat market information.
1. Livestock producers should have access to competitive markets for price discovery that accurately determines the value of their products.
2. We support:
2.1. Development and implementation of value-based marketing systems which convey the true value of product quality from the retail market to the farm;
2.2. Contracts and marketing regulations should recognize species-specific business and marketing structures;
2.3. Rights of producers and packers to enter into formula pricing, grid pricing and other marketing arrangements and contract relationships. Contracts and marketing arrangements should specify a negotiated base price before commitment to deliver. Such contracts and pricing arrangements should not be used to manipulate the market to the detriment of producers. We encourage producers to retain control over contract delivery and/or contract completion in furtherance of value-added marketing;
2.4. Encouraging co-ops to play a larger role in the meat industry by building or acquiring packing houses; and
2.5. Development of new risk management tools to enhance the ability of family livestock farmers to cope with market fluctuations.
1. Organic agricultural by-products, including manure, are valuable resources and we oppose classifying them as industrial, solid or hazardous waste, or raw sewage.
2. We believe:
2.1. In investment in technical support and the development of information resources in conjunction with the Soil and Water Conservation District, Cooperative Extension Service, and Natural Resources Conservation Service;
2.2. Adequate research should be completed to determine air quality and odor parameters that provide scientifically proven levels for livestock health and worker safety;
2.3. There must be no direct discharge from manure storage systems or livestock facilities to surface waters, drainage ditches or field tiles due to negligence, poor management and faulty structural design. Direct discharges due to natural causes should be exempt from civil and punitive penalties and damages;
2.4. Research on manure management is a high priority including such topics as odor reduction, waste and nutrient management and artificial wetland remediation of nutrients. Some flexibility should be allowed in wetlands management;
2.5. Any proposed law, rule or regulation which would restrict a farmer's nutrient management practices shall only be implemented if consistent with best management practices (BMPs) developed at the state level with the cooperation and assistance of our state land grant institutions with considerations given for local conditions. The authority for enforcement and implementation of these standards should be clearly defined to protect farmers from differing interpretations by state or federal agencies;
2.6. Coordination is required between the permitting agency for a livestock facility and the agency which designs the facility;
2.7. Government agencies must utilize proven scientific practices when developing policies concerning manure management facilities and the application of manure;
2.8. Government cost-share funding should be made available to producers for constructing manure handling facilities to correct existing problems;
2.9. Industry should develop guidelines for responsible and balanced environmental protection for confined animal units. These guidelines should include, but not be limited to, provisions covering manure control and management, separation distances, odor management, emergency spill response plans, etcetera; and
2.10. Expansion of any existing regulatory authority should not threaten the ability of independent producers to compete. Any standards that require changes in infrastructure for existing facilities must be based on proven scientific research and shall consider a cost-benefit analysis.
3. We support:
3.1. Programs that educate farmers on techniques regarding properly managed organic nutrient systems and a public relations program to emphasize methods by which farmers protect the environment by using properly managed organic nutrient systems; and
3.2. The concept of a voluntary certified nutrient applicator program.
4. We oppose:
4.1. Efforts to impose a new layer of federal regulations and bureaucracy to existing federal and state regulations affecting agricultural operations;
4.2. Any federal mandate on nutrient management. Each state should negotiate and/or implement its own specific program. Information obtained by government agencies on agricultural producers pertaining to nutrient management plans should be kept confidential;
4.3. Awarding punitive damages in odor lawsuits; and
4.4. Undue restrictions on spreading poultry litter on farmland.
1. We will work with the Grain Inspection, Packers and Stockyard Administration (GIPSA) for stricter enforcement of regulations requiring poultry to be weighed on the nearest scale within a reasonable time, not to exceed eight hours, after the poultry is picked up at the farm.
2. USDA, in conjunction with the Department of Justice (DOJ), should closely investigate all mergers, ownership changes or other trends in the meat packing industry for actions that limit the availability of a competitive market for livestock producers. Action should be taken to oppose further concentration of meat packers. USDA and DOJ should more aggressively enforce current antitrust laws pertaining to packer concentration.
3. Beef packers who process more than 1,000 head per day should be monitored so they cannot manipulate the market through forward contracting.
4. From a regulatory standpoint, captive supplies should be defined as all cattle owned, or controlled or contracted by a packer seven or more days prior to delivery.
5. The bonding requirement for livestock dealers and packers should be strengthened and more stringently enforced. The requirement should be reviewed on a quarterly basis and be adjusted to reflect the volume of the maximum financial exposure to producers and/or their brokers and then be made available to the public.
6. We support:
6.1. Continuation of GIPSA as a separate agency of USDA;
6.2. The addition of dairy cattle and milk processors as named in the Packers and Stockyards Act;
6.3. An amendment to the Packers and Stockyards Act of 1921 that would include the ratite (emu, ostrich and rhea) industry wherever applicable;
6.4. Legislation on a state and national basis, establishing GIPSA as the overall authority and provider of oversight to ensure livestock contracts are clearly-written, confidentiality concerns are addressed, investments are protected, enhanced price transparency and price discovery are enhanced and terms of contracts are honored;
6.5. More vigorous enforcement of U.S. antitrust laws in keeping with original intent; to include the Sherman Act of 1890, Clayton Act of 1914 and Packers and Stockyards Act of 1921; and
6.6. Legislation that would prohibit packers from manipulating the number of captive supply cattle slaughtered from week to week in order to manipulate the cash market.
7. We oppose:
7.1. Any attempt to lessen the ability of GIPSA to adequately enforce anti-trust laws and regulations;
7.2. Prohibiting a packer or livestock buyer from purchasing, acquiring or receiving livestock from another packer, livestock buyer or another packer's or livestock buyer's "affiliate" companies or farms;
7.3. The government making livestock buyers, packers, contractors or livestock owners justify in writing why and how they are buying or selling livestock on the spot market; and
7.4. Any ban on contract livestock buyers purchasing livestock for more than one packer.
8. The Packers and Stockyards Act should be amended to:
8.1. Extend prompt pay requirements to wholesalers and retailers of livestock products;
8.2. Include a dealer trust provision;
8.3. Provide jurisdiction and enforcement over the marketing of poultry meat and eggs as already exists for livestock;
8.4. Strengthen the ability of GIPSA to stop predatory practices in the meat packing industry;
8.5. Provide producer restitution when a case is successfully prosecuted;
8.6. Provide GIPSA enforcement authority to ensure that all instruments used in quantifying quality factors for value determination for livestock are performing to a set standard; and
8.7. Include breeder hen and pullet operations so they are treated the same as broiler operations.
9. Any proposed GIPSA rules or legislation should address the following:
9.1. Separate and different rules should be allowed for different species of livestock;
9.2. An economic impact study must be conducted by USDA;
9.3. Opportunities for marketing arrangements between packers and producers must be allowed and preserved;
9.4. Confidentiality of contract information must be maintained; and
9.5. Establish legal thresholds for proof of injury.
1. We encourage individual producers to voluntarily adopt and follow litter/manure management plans.
2. We should continue to seek opportunities with poultry companies to further understanding between companies and farmers. Special emphasis should be on integrity of the present contractual relationship.
3. We encourage closer cooperation between builders of poultry houses and agricultural insurance companies and lenders to make sure the houses meet specifications of building codes.
4. We urge companies to justify mandatory modification of buildings and equipment through research documentation. Any modification should be a long-term agreement, negotiated in writing, between the grower and company before installation. The length of contracts should adequately protect a grower's investment in buildings and equipment.
5. We encourage exporting poultry meat products and continuing efforts to ensure that these products are not discriminated against by foreign markets.
6. We request the availability of a non-insured crop disaster assistance program for contract poultry farmers on a per flock basis, to be administered through the Farm Service Agency.
7. We support:
7.1. Our poultry farmers and their role in the poultry industry;
7.2. Open dialogue between the individual poultry farmer and the company representative as the most effective method of issue resolution;
7.3. Collecting information concerning economic conditions of poultry farmer/members and farmer/poultry company relations;
7.4. The National Poultry Technology Center and encourage support for federal funding for the Center to improve efficiency, effectiveness and economic viability of poultry production facilities;
7.5. Affected growers being compensated for loss of income if an integrator closes a processing facility;
7.6. Contract producers continuing to be furnished weight tickets for all poultry sold from their farms and for feed delivered to the farm. The weight tickets and feed charges should be in the farmer's hands by the time the producer receives the check;
7.7. The pay averaging criteria be revised to compensate for company production decisions that influence a farmer/producer's settlement;
7.8. Maintaining tournament production contracts allowing growers the opportunity to earn better than average pay as a result of proper management and capital investment;
7.9. Integrators and farmers work together to practice all possible bio-security methods to help prevent disease;
7.10. Integrators notifying all producers of any contagious diseases in their area;
7.11. The burial of dead birds as an emergency management option when mortality exceeds normal daily mortality and the capacity of normal disposal or treatment methods;
7.12. Aggressive research to address the inadequate scientific information concerning phosphorus;
7.13. Changes to Animal and Plant Health Inspection Service (APHIS) plans to use normal mortality rates instead of using “remainder of the flock” in determining compensation; and
7.14. Development of an insurance product through Risk Management Agency (RMA) to protect contract poultry growers from losses due to Avian Influenza (AI) or other infectious diseases.
8. We oppose poultry integrators being allowed to void contracts or cut bird placements of growers because of failure to update equipment when their performance is equal to the company average in the area.
1. We encourage research that adds value and marketability of rendering facility products.
2. We support:
2.1. The streamlining of the permitting process for rendering facilities and encourage livestock producers to use rendering facilities; and
2.2. Legislation that provides economic and regulatory relief to rendering facilities and encourage further development and construction of rendering facilities and collection points.
1. The USDA should evaluate the testing requirement of the wool grading program with emphasis on producer cost and feasibility.
2. Imported goat milk or curd must meet USDA milk quality regulations.
3. We support:
3.1. The continuation of a strong sheep, goat, wool and mohair industry in the United States and recognize the need for continued promotion and development of value-added processing;
3.2. The use of domestically raised lamb and goats;
3.3. The designation of sheep and goats as minor species so that cattle research data can be used to approve animal health products for use in these species;
3.4. The development of a separate sheep and goat checkoff program for promotion of their respective industries;
3.5. The current loan program for wool and mohair;
3.6. A lamb checkoff if consistent with our commodity promotion policy;
3.7. The use of livestock protection animals on federal, state and public lands;
3.8. Free trade of breeding stock that meet USDA health standards;
3.9. The development of an orderly marketing framework involving all countries importing lamb into the United States; and
3.10. The development of an appropriate somatic cell count test for dairy goats and sheep.
4. We oppose using a somatic cell count test designed for bovines to regulate dairy goat and sheep milk.
1. Controlling wildlife damage is a critical factor in maintaining the success of American agriculture. Toward that goal we support:
1.1. Developing practical recommendations on methods for controlling all wildlife pests by providing adequate funding to USDA for intensive research;
1.2. Contracts with land grant universities being considered to conduct this research. The results of all research should be more widely distributed to livestock producers;
1.3. Programs to control prairie dogs on private and public land;
1.4. Establishment of statewide or interstate compacts designed to administer a predator bounty system;
1.5. Continuation of all established predator control practices and broader use, including traps and chemical toxicants under federal or state supervision;
1.6. Aerial hunting to help control predator numbers;
1.7. The use of livestock protection collars in animal damage control;
1.8. Legislation which would require the control of wildlife including endangered species or provide depredation permits for farmers who suffer losses from wildlife;
1.9. The continuation of the federal-state cooperative program for funding and administration of predator control;
1.10. The continuance, in rural and urban areas, of predator and rodent control which benefits public health and safety;
1.11. Control programs to reduce wildlife populations to manageable levels in areas where they are numerous and destructive;
1.12. A standing depredation order for black vultures and the double-crested cormorant;
1.13. The U.S. Fish and Wildlife Service (USFWS) refunding the $100 application process fee for depredation permits not issued;
1.14. New and more effective means of predator control;
1.15. Federal, state and local officials to create a consistent process for livestock producers to follow when obtaining federal depredation permits. The process should include the ability for producers to work with local agencies to complete and submit all needed paperwork;
1.16. Congress taking immediate steps to provide agencies/research scientists with adequate funds for wildlife pests and predator control and research designed to develop additional control methods, such as electronic surveillance and detection devices;
1.17. Research to document the losses of livestock and game animals caused by predators and the resultant economic losses;
1.18. Reinstatement of more effective permits which allow commercial duck and fish producers to control depredating gulls and other predators;
1.19. USDA reviewing the availability of government trappers;
1.20. All Fish and Wildlife refuges allowing hunters and trappers to control pests and predators on any refuges with overpopulation;
1.21. Property owners having the right to protect crops and livestock from protected wildlife and predators;
1.22. A system to compensate farmers for damage from state or federally protected wildlife;
1.23. USDA Animal and Plant Health Inspection Service (APHIS) Wildlife Services working to eradicate feral hogs;
1.24. USDA taking action through the administrative rules process to end the release of live feral hogs in the United States. We support the eradication of feral hogs as an invasive species. All landowners should be encouraged to eradicate feral hogs on their land by any means possible;
1.25. A continued increase in funding for USDA-APHIS Wildlife Services for their continued legal depredation efforts and roost dispersal of avian species that affect aquaculture production. This funding shall be utilized to efficiently manage, mitigate and further assist aquaculture producers in their efforts to deter avian depredation at aquaculture production facilities. This shall include adequate staffing and the use of efficient and proven dispersal and depredation practices; and
1.26. The current ability to obtain depredation permits of avian predators that affect aquaculture production.
2. We oppose:
2.1. The introduction or reintroduction of any species, including rodents, that prey on livestock, damage crops or animals that potentially carry contagious or zoonotic disease if such introduction or reintroduction is done without the approval of the state legislature;
2.2. USFWS or anyone else, being able to release dangerous predators on or near private property. It should be mandatory to require them to capture and remove them; and
2.3. Bureau of Alcohol, Tobacco, Firearms and Explosives regulating explosive pest control devices under federal explosive laws that require individual permitting and qualified storage facilities for the use of such devices.
1. Agricultural chemicals are important in continuing to supply consumers with an abundant, safe, nutritious, high quality and reasonably priced food supply. We are committed to continuing the use of agricultural chemicals in a safe and judicious manner so as to protect the health and safety of producers, our employees, our families, our communities and the environment.
2. We encourage people using pesticides for nonagricultural purposes to become better educated on the safe application of these products.
3. We support access to critical pesticides used for crop and livestock production, along with increased funding for research on alternative crop and livestock protection tools. We request the Environmental Protection Agency (EPA), the Food and Drug Administration (FDA) and USDA increase cooperation and expedite registration of additional new crop protection tools and traits.
4. We will work with and encourage the agricultural chemical industry through its advertising to present a positive and professional image of farmers and agriculture to the general public.
5. We encourage state control of container disposal and recycling programs.
6.1. We believe implementation of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) should be based on credible scientific information in order to benefit farmers, the environment and the public and should be the sole federal regulatory authority over pesticides.
6.2. The United States, Canada and Mexico should harmonize registration guidelines, labeling requirements and accept registration material for agricultural pesticides from those countries.
6.3. We encourage testing of pesticides based on realistic levels of exposure or consumption.
6.4. We believe that when a pesticide product receives an emergency use exemption under Section 18 of FIFRA, the state administering the pesticide provisions where the exemption was issued be authorized to re-issue that emergency use until a full FIFRA assessment is completed.
6.5. We urge that risk/benefits be considered when the Environmental Protection Agency (EPA) or other agencies make a determination to restrict or cancel pesticides or agrichemicals.
6.6. EPA should consider actual use data in its risk assessment process to support pesticide registrations and avoid decisions based on worst case assumptions. EPA should not assume that farmers apply pesticides at the maximum dosage rates or frequency of application as the label will allow.
6.7. USDA and EPA should work cooperatively to find alternatives for pesticides that, as a result of regulatory action, have lost registrations and uses. We encourage the development of voluntary Pest Management Strategic Plans.
6.8. We also request re-evaluation of previously canceled pesticides based on current scientific data.
6.9. USDA should expand its scientific capabilities to better serve as a full partner with EPA in pesticide regulatory activities. EPA should be required to strengthen and take more seriously its required consultation with USDA.
6.10. EPA should be able to contract with USDA to perform the testing for pesticide residues.
6.11. Pesticide manufacturers and formulators should be held responsible for the safety and efficacy of crop protection products, if the chemical is used in accordance with the label.
6.12. Atrazine, Acetachlor and Simazine are effective, economical crop protection chemicals that must continue to be available to farmers.
6.13. Provisions for experimental use, emergency exemptions and state special use registration are particularly important until federal registration is completed.
6.14. We support:
6.14.1. Legislation that would limit authority for pesticide regulation solely to federal and state governments;
6.14.2. Adoption of a negligible risk standard;
6.14.3. The right to import U.S.-approved pesticides from other countries;
6.14.4. The continued use of agricultural chemicals which currently have no viable alternatives, such as methyl bromide. We encourage research funded through state and federal agencies to find alternatives for methyl bromide that are economically viable, of equal performance and sensitive to the exposure needs of individual crops. Until a viable alternative is found, we support the use of a fair, science-based process for Critical Use Exemptions. The process should contain a reliable, consistent set of standards equitable to all parties involved;
6.14.5. Clean Air Act amendments to allow U.S. producers to have access to methyl bromide consistent with phase-out dates for non-industrialized countries as outlined in the Montreal Protocol;
6.14.6. Continuation of the Pesticide Data Program which provides pesticide residue information in food products for use by EPA in setting tolerance standards and registering pesticides;
6.14.7. We recognize the ecological importance of pollinators and the necessity to judiciously utilize crop protection products to protect against loss of crop yield. We support the coexistence of crops and pollinators and urge that any pollinator risk assessment required for registration or regulation of crop protection products be based on field-relevant, sound scientific data;
6.14.8. The concept of state management plans. However, we oppose the proposed EPA state management plan rule which fails to recognize effective state programs and imposes federal requirements to maintain uses of important crop protection tools;
6.14.9. The continued use of the neonicotinoid pesticide group for agricultural and horticultural crops; and
6.14.10. If a crop protection product has gone through a review three times or more, the time frame between reviews should be doubled.
6.15. We oppose:
6.15.1. Any legal action made against the federal government based on excessively broad interpretations of environmental laws, which restrict or limit the safe and proper use of agricultural chemicals. Actions impacting a limited geographical region may set harmful and nationally recognized legal and regulatory precedent;
6.15.2. Any regulation that would require a permit prior to application of a chemical for crop protection;
6.15.3. Any requirement that applicators be required to notify all neighbors prior to any pesticide/fertilizer application and/or fumigant buffer zone limitations proposed by the EPA;
6.15.4. Any curtailment of the safe and proper use of agricultural chemicals unless research and scientific data determine that injury to health and well-being would result;
6.15.5. The inclusion of the Private Right of Action provision in the language of FIFRA;
6.15.6. Any reduction to the quantity of methyl bromide requested by methyl bromide users for nomination as Critical Use Exemptions to the Parties of the Montreal Protocol, and we oppose any reduction by the EPA in the amount of Critical Use Exemptions authorized by the Parties of the Montreal Protocol; and
6.15.7. Any additional EPA regulation of seed treatments for planting.
7. Labeling and Handling
7.1. We recommend the agricultural chemical industry and agricultural producers work with the appropriate agencies to develop and use reusable, returnable and soluble pesticide containers and an economically and logistically feasible plan to dispose of containers.
7.2. We recommend that compliance with federally approved label instructions absolve farmers from liability claims for environmental pollution and from paying the cost of cleaning up environmental contamination.
7.3. We recommend that EPA financially support continued education on the proper use and handling of agricultural protectants.
7.4. We recommend that farmers triple rinse or pressure rinse containers and to return them for recycling in areas where such programs are currently available.
7.5. We support:
7.5.1. Clarification of the current label on 2,4-D to allow its continued use as part of no-till systems;
7.5.2. The use of vegetable oils as the base or carrier for pesticides;
7.5.3. EPA cooperating in sponsoring amnesty programs for proper disposal of hazardous chemicals and discontinued chemicals;
7.5.4. A permanent labeling system covering product name, date of manufacture, effective life and proper storage requirements being required to avoid the use of ineffective pesticides;
7.5.5. EPA reconsidering labeling for pesticide application wind speeds in view of advancements in engineering and technology such as wind guards and low drift spray tips;
7.5.6. The development and immediate use of uniform, permanent international symbols on agricultural chemical containers to ensure proper handling;
7.5.7. Printing the EPA registration number and re-entry interval of each pesticide active ingredient in legible type size directly below its name;
7.5.8. Periodic upgrading of EPA/state pesticide applicator training to ensure a sound and effective source of training, information and certification on the proper handling and safe use of pesticides;
7.5.9. The development of more effective equipment for farm applications;
7.5.10. The safe use of pesticides and practices which will ensure the safety of handlers, applicators and agricultural workers; and
7.5.11. A list available online of all label changes.
7.6. We oppose:
7.6.1. Politically mandated buffer zones; and
7.6.2. EPA’s attempt to shorten the permit certification timeline for pesticide applicator licensing and increase testing standards to make it more difficult for farmers to obtain a pesticide applicator license.
8. Data and Record-keeping
8.1. We support:
8.1.1. Uniform pesticide record-keeping and statistically valid reporting for use in evaluating and maintaining pesticide registrations. The enforcement of record-keeping for restricted use farm chemicals should be done at the state level and in a manner that educates and is helpful to the producer rather than punitive;
8.1.2. The voluntary collection of actual residue data from farm and orchard products to establish use patterns of the agricultural chemicals used in crop production. This data should be used in the pesticide registration, reregistration, cancellation and special review process only; and
8.1.3. Increased funding for the USDA to increase credible information on pesticide use collected by the National Agricultural Statistics Service (NASS).
9. Specialty (Minor) Crop Chemicals
9.1. We urge Congress and the appropriate agencies to address the cost of label registration and reregistration for chemicals to be used on minor use crops and to provide methods of label clearance for them. Reregistration of specialty use chemicals should not be required unless research by qualified specialists demonstrates a need to change the registration.
9.2. To expedite specialty crop pesticide registrations, we urge that chemicals cleared for application on edible food crops be additionally registered, with agreement of the manufacturer, for like applications of that same crop when planted for nonfood uses. If a chemical is cleared for control of a specific pest on an edible food crop, it should also be cleared for pest control on nonfood crops.
9.3. We support:
9.3.1. Legislative solutions to ensure availability of specialty crop use pesticides. These solutions shall include, but not be limited to, expanded Interregional Research Project #4 (IR-4) activities, tax credits to registrants who maintain these uses and reduced third-party registration liability;
9.3.2. Encouraging the EPA to re-register Monosodium Methanearsonate;
9.3.3. The use of Canadian data by the EPA for the registration of chemicals for use on minor oilseed crops; and
9.3.4. Aerial application of agricultural chemicals is a safe and effective tool for farmers, and we oppose any efforts to limit or restrict this application method.
9.4. We oppose any farmer, landowner or chemical dealer liability when anhydrous ammonia, ammonium nitrate or any other legitimate farm chemical is stolen from a farm premise.
1. We will encourage and educate producers to be good stewards of biotechnology to:
1.1. Maintain the integrity of the U.S. food and grain supply;
1.2. Ensure technology remains effective through adherence to regulations (i.e. buffer, refuge, storage, transport, Integrated Pest Management); and
1.3. Preserve opportunities for future biotech products and processes.
2. We urge state and federal political leaders to develop a positive national strategy for biotechnology research, development and consumer education. Part of this strategy should include an open and frank dialogue with all interested parties. We believe that our competitive advantage in world markets will be maintained only by the continued support and encouragement of technological advancements.
3. The approval of new products should be based on safety and efficacy criteria. Consideration of socioeconomic criteria should not be required.
4. We support initiatives that assist in the research, development and regulatory clearance of specialty crop biotechnology products. U.S. government agencies, particularly the USDA and the Food and Drug Administration (FDA), should continue to serve their respective roles in providing unbiased, scientifically-based evaluations concerning the human and animal safety and wholesomeness, as well as the environmental impacts of biotechnology-enhanced commodities. U.S. government agencies should evaluate whether there are improvements in the regulatory approval process or removal of obsolete statutes that could further enhance consumer confidence. We encourage USDA to take a lead in coordinating efforts to evaluate and move approved products and technologies to the marketplace in a timely manner.
5. We encourage seed companies to continue producing and making available conventional and genetically modified seed varieties. We favor strong patent support to encourage these new technologies. Patents should be broad enough to provide reasonable protection of development costs but should not be so broad as to grant one developer the right to a whole class of future developments for common plants or growing processes already in the public domain.
6. We oppose legislation outside of the established protection of intellectual property which serves to limit competition or innovation in biotechnology, either through intent or unintended consequences.
7. We support:
7.1. Increased efforts through biotechnology and animal stem cell research to more rapidly develop traits with recognized consumer benefits, to increase the marketability of our products, to solve environmental concerns, to increase net farm income by decreasing input costs and to improve product quality and quantity to feed our ever-growing population;
7.2. Patenting of animals to allow biotechnology companies to recover the costs of research and development of transgenic animals for agriculture. However, royalties from patents on transgenic animals must be structured in a manner which allow producers a clear understanding of their obligations and do not disrupt the existing livestock marketing systems;
7.3. The continued development of animal cloning as a means to advance assisted reproductive technology such as artificial insemination, embryo transfer and “in-vitro” fertilization;
7.4. Active involvement by the United States in the development of international standards for biotechnology. In order to protect producers from liability, adequate testing methods must be made available for all commercialized crops. Producers should not be penalized for testing costs. The original buyer of commodity crops should be responsible for testing of the commodity and upon taking delivery such testing should be accepted by end users. Producers shouldn't bear liability for off-farm introduction of biotech matter;
7.5. Harmonization of international standards for biotech, testing and adventitious presence. The international bodies established to administer the sanitary and phytosanitary agreement of the World Trade Organization should retain the authority to influence the regulation of international trade in agricultural products enhanced through biotechnology;
7.6. Seed tags on packages of agricultural seed stock that warrant genetic purity of seed contained therein. We will also support legislation which allows producers to recover all damages in those instances where the seed does not conform to the genetic purity indicated on the seed tag. Adequate and accurate information on acceptable markets and market and planting restrictions must be provided in writing to producers prior to the time they purchase the original input product;
7.7. Measures to reimburse farmers when there is independent documentation that biotech products have lost their effectiveness. In such cases, we call on seed companies to refund the technology fees paid by farmers;
7.8. The maintenance of U.S. export markets by securing foreign regulatory acceptance of biotech products. Sellers of agricultural products enhanced through biotechnology should assume major responsibility for this acceptance. Extra efforts should be made to make farmers aware of markets where the products are not accepted by using such methods as color markings on bags, boxes or bulk delivery systems and/or seed tags;
7.9. Scientifically accurate consumer education about the safety and benefits of genetically engineered crops;
7.10. Congress taking the appropriate actions to ensure that the USDA's Agricultural Research Service plant-breeding programs be permitted to utilize biotechnology and other developing technologies in their breeding programs;
7.11. An industry developed protocol for biotech crops before coming off patent that brings advanced technology to the market place and facilitates negotiated data sharing and use;
7.12. Establishing domestic low level presence standards for biotechnology, including maximum acceptable levels; and
7.13. Developing standards for trading partners for the testing of low-level presence of biotech events that are not acceptable so that other products can move in the trading market.
8. We oppose:
8.1. All attempts by local political subdivisions to limit the production or use of genetically modified crops or animals;
8.2. Any law or regulation requiring registration of farmers who use or sell products, including biotechnology. approved for sale by the FDA;
8.3. Individual states establishing separate policies on agricultural biotechnology labeling, identification, use and availability;
8.4. Split registration or limited use registration of seeds enhanced through biotechnology. Producers should seek and seed companies should provide adequate and accurate information on acceptable markets and market restrictions in writing to producers prior to the time they purchase the original input product. Adequate and universally accepted testing methods for biotech adventitious presence in seed should be established. Seed that is approved for restricted use or controlled distribution should be labeled and have visually distinguishing characteristics. FDA should set acceptable standards for determining what is non-biotech. Standards governing the identification or availability of biotech products should be established uniformly across the United States;
8.5. The imposition by foreign countries of any import restrictions, labeling or segregation requirements of any agricultural product enhanced through biotechnology, once such commodity has been certified by the scientific community as safe and not significantly different from other varieties of that commodity;
8.6. The adoption of policies, such as the creation of an indemnity fund, that tax or penalize growers for choosing to use approved biotechnology traits;
8.7. The practice of seed marketers imposing a surcharge on U.S. customers that is not imposed on foreign customers; and
8.8. Classifying plants derived through biotechnology as pesticides.
9. Products Not Destined for Food or Feed
9.1. Plant-made pharmaceuticals offer benefits in preventing and treating diseases. USDA should ensure appropriate protocol for the approval of research and production of pharmaceutical or industrial crops to protect the integrity of agricultural products.
9.2. Producers of biopharmaceutical crops and the regulatory agencies governing them should take extraordinary measures to ensure food safety and to protect the integrity of the U.S. food and grain marketing system. We urge the USDA and FDA to utilize a scientifically sound risk-based approach (tolerances) to regulation of introduced proteins in biopharmaceutical and industrial crops. FDA should consider establishment of risk classifications of such proteins and USDA should take these risk classifications into account when establishing requirements for experimental field trial and production permits.
1. Fertilizer is a necessary input for agricultural producers.
1.1. We support:
1.1.1. The use of industry developed Best Management Practices (BMPs) for ensuring the safe and responsible holding, storage, transportation and use of all fertilizers;
1.1.2. Continued research into the discovery of alternative sources of plant nutrients;
1.1.3. Expansion of existing mines and development of new mines and production facilities;
1.1.4. The creation of a USDA-led, inter-agency working group to develop specific strategies or actions to help address and alleviate shortages and excessive price increases for fertilizer;
1.1.5. Coal gasification technology being used to produce nitrogen-based fertilizers; and
1.1.6. Increased research in nutrient use and stewardship.
2. Each chemical, production process and fertilizer is unique. Therefore, we believe:
2.1. Anhydrous ammonia:
2.1.1. If suppliers are mandated to modify anhydrous ammonia by adding deterrents, the supplier should be compensated by the government authority mandating the deterrent's use so that the additional cost will not be passed on to the farmer;
2.1.2. If a farmer or landowner takes reasonable steps to secure anhydrous ammonia on their property, we oppose any criminal or civil liability being imposed on the farmer/landowner if the product is stolen and/or used for an illegal purpose;
2.1.3. The continued availability and use of anhydrous ammonia as a valuable tool for agricultural production;
2.1.4. The classification and labeling of anhydrous ammonia as a nonflammable gas;
2.1.5. The Surface Transportation Board continuing to regulate the pricing of transportation of anhydrous ammonia through pipelines;
2.1.6. Vigorous prosecution of the theft and/or use of anhydrous ammonia for methamphetamine production or other illegal purposes; and
2.1.7. Research on additives or deterrents for anhydrous ammonia that would prevent its illegal use.
2.2. Ammonium Nitrate:
2.2.1. Department of Homeland Security (DHS) granting advance approval, rather than at the point of each sale, for purchase of ammonium nitrate when protocol is followed in confirming ID and registration;
2.2.2. In regulation of the sale of ammonium nitrate, as long as the requirements are reasonable for farmers, fertilizer distributors and dealers; and
2.2.3. We are opposed to any reformulation of ammonium nitrate that reduces its effectiveness as a fertilizer or increases its cost.
1. The American food supply is the safest, most abundant and affordable in the world. Agricultural chemicals and other technological advances play a major role in maintaining both the quality and quantity of our food supply.
2. We will monitor initiatives to improve and streamline food safety to ensure that policies and procedures are in place that build trust and reliability in U.S. agriculture.
3. We believe food safety issues at the producer level should be handled through "quality assurance programs."
4. We encourage the education of all food handlers on the proper preparation, cooking and serving of all food products and on sanitary practices as part of state licensing procedures.
5. Ensuring a safe, secure food supply is a critical concern when establishing domestic and international policy. We should continue to communicate accurate, timely information on food safety issues to the mainstream media and the general public. Our goal is to improve awareness and understanding of agriculture's commitment to providing a safe, high quality food supply at a reasonable price to the public.
6. We encourage food regulatory agencies to research and develop expedient and efficient processes to trace food contamination outbreaks, which result in economic losses and a lack of consumer trust. Food origin traceability should not extend to the field level or input level. Any system should be non-intrusive and economically feasible.
7. Producers of legal agricultural products should not be held responsible or liable for long-term health problems claimed to occur from the products’ consumption or use.
8. We support:
8.1. The consideration of both the risks and the benefits of pesticides in the evaluation of chemical products;
8.2. The establishment and promotion of sound scientific research criteria which ensure the safety of food additives;
8.3. Legislative and regulatory decisions concerning food irradiation (cold pasteurization) based on valid research;
8.4. Utilization of USDA approved technologies, such as cold pasteurization and high pressure processing to eliminate E. coli and other pathogens from our food supply;
8.5. The use of modern technology in the processing and the handling of food to assure food safety and to promote consumer confidence in the food supply. More research should be conducted by agricultural colleges into inspection methods to eliminate the risk of pathogens in food;
8.6. Immediate actions by USDA and the Food and Drug Administration (FDA) to raise the priority of, and resources devoted to, federal safety and inspection services including Food Safety and Inspection Service and Animal and Plant Health Inspection Service;
8.7. Protection of our food supply by requiring that imported food products be subjected to the same high safety standards and testing as food products produced in the United States;
8.8. Funding appropriate inspection services at a level permitting effective inspection of imported and domestic food products;
8.9. Legislation to require the FDA and the Environmental Protection Agency (EPA) to prepare, in advance of final rule- making, agricultural cost/benefit statements on proposed regulations having a significant impact on agricultural producers;
8.10. Cooperative efforts with food processors, chemical companies, government agencies, scientists and others who are responsible for the food supply of our nation to provide factual information on the safety of our food supply;
8.11. Open communication with willing consumer groups;
8.12. Provisions to allow the transport and storage of fresh eggs based on current USDA standards of 45 degrees Fahrenheit or less, but oppose the mandatory pasteurization of fresh eggs;
8.13. State efforts to ensure the quality and integrity of unpasteurized fruit juices. We oppose FDA regulation of these products;
8.14. Promoting science-based, voluntary commodity quality assurance products;
8.15. Additional research on food safety technology advances;
8.16. USDA and FDA removing E. coli as an adulterant;
8.17. The right of private industry or farmers to meet quality demands exceeding U.S. Government standards for products they produce;
8.18. The ability of cheese makers to use wood planks during production to age their cheese;
8.19. The exemption of all sunflower seed from the Food Safety Modernization Act (FSMA) Proposed Rule for Produce Safety;
8.20. The health benefits of animal fat being included with meat promotions;
8.21. The use of preservatives in the meat of farm-bred exotic animals; and
8.22. Increased education efforts among producers on the prevention of all pathogens within the food and agricultural industry.
9. We support efforts to develop food safety guidelines to help prevent microbial contamination of fresh produce. The guidelines must:
9.1. Be based on sound science and risk;
9.2. Provide flexibility to accommodate the great diversity of the fresh produce industry including those in geographically challenged areas;
9.3. Be practical to implement;
9.4. Take the form of good agricultural practices rather than federal or state mandates;
9.5. Be consistent with existing state and federal regulations and guidelines;
9.6. Support Good Agricultural Practices (GAP) and Good Handling Practices (GHP) standards;
9.7. Be implemented in a manner that will not impair our ability to export produce items;
9.8. Provide adequate resources to carry out an education program for the industry and consumers;
9.9. Be tailored to the size, type and capacity of the farm;
9.10. Include a provision that only agricultural products subject to FSMA count toward the gross sales threshold; and
9.11. Allow for animal manure application that is flexible enough for utilization, food production and food safety.
10. Any food safety legislation or regulatory actions should adhere to the following principles:
10.1. Increases in federal or state funding should not come in the form of fees or fines to farmers unless these fees are in the form of industry assessments under a marketing agreement order; and
10.2. Any additional mandated regulatory requirements should not financially impact producers. An indemnification program should be instituted to properly compensate farmers when the government issues an inaccurate food safety warning or recall that causes losses.
11. USDA should be designated as the lead agency in the development and administration of food safety guidelines and should serve as the sole federal agency responsible for food inspection and safety. We support having employees from state agencies act as authorized agents of FDA to conduct required federally authorized inspections mandated under FSMA.
12. We oppose the establishment of user fees, licensing fees or other mandates compelling farmers to hire a third party to comply with federal or state food safety laws.
13. In the event Congress grants FDA food safety authority, FDA should coordinate with USDA in the development and administration of any food safety guidelines related to fresh produce or other agricultural production. FDA should not have on-farm authorities unless a food safety-related cause is indicated by sound science. Any recordkeeping requirements must be accompanied by assurance that information accessed by Federal or state government authorities in regards to food safety protocols will remain confidential. The guidelines must exempt farms engaged in direct sales to consumers from FDA oversight for sale of fruits and vegetables.
14. Following the initial publication of a proposed rule on food safety regulations, FDA should allow a second public comment to allow stakeholder review of any revisions before the final rule is promulgated.
15. We recommend funding to assist in the implementation of food safety regulations should come from the state and federal governments mandating the regulations.
16. Those making public health decisions that result in product recalls, product seizures or destruction of perishable goods must be held accountable when such decisions prove erroneous. Such entities must be required to compensate or indemnify individuals and companies for the monetary losses that occur.
17. We oppose incorporating water quality standards that require recreational water standards for agricultural water.
18. Good Agricultural Practices (GAP)
18.1. GAPs are a set of recommendations that can help improve the quality and safety of the produce grown.
18.2. We support:
18.2.1. All government agencies following food safety and security protocol on farm operations;
18.2.2. All GAP auditors complying with the same rules;
18.2.3. Training for all auditors being consistent and uniform for both private and USDA auditors;
18.2.4. GAP certification should have requirements reviewed by industry and science groups; and
18.2.5. USDA’s effort to harmonize GAP audits and coordinate them with already established and related certifications to minimize conflicts, overlap and paperwork.
18.3. We oppose:
18.3.1. Expanding GAP programs beyond unprocessed ready-to-eat fruits and vegetables; and
18.3.2. The FDA classifying ethanol by-products, spent grain and other animal feed as food stuffs under FSMA.
19. We support FDA educating the food services industry on the dangers of the mammal meat food allergy, Alpha-gal.
1. As Environmental Protection Agency (EPA) implements the FQPA of 1996, we will actively participate in the regulation writing process to assure satisfactory implementation of the law and to protect farmers' use of many important and safe agricultural chemicals. Balanced and science-based implementation of the FQPA is of the utmost concern to farmers and ranchers.
2. Failure to implement the FQPA in a balanced way will have serious negative effects on pest management and food and fiber production in the United States, with subsequent adverse impacts on the health and well-being of the American people.
3. Specifically, we support the following FQPA principles:
3.1. Sound Science—implementation decisions must be based on peer-reviewed science founded on reliable and accurate information;
3.2. Transparency—the public must be informed of the criteria used to assess risk and the process by which decisions are reached;
3.3. Balance—as EPA considers canceling older pesticide products as a result of the tolerance reassessment and reregistration process, it must give high priority to the review and approval of new products; and
3.4. Workability—the law must be administered in a practical and realistic way. If EPA fails to follow congressional intent during the implementation process, we support the use of options such as litigation and legislation.
4. We will work aggressively to persuade EPA to find a workable and reasonable implementation of the FQPA. To achieve this, EPA must:
4.1. Use sound science and reliable information, as intended by Congress, in fulfilling the FQPA mandate to protect public health from unacceptable risk of exposure to pesticides;
4.2. Acknowledge to Congress and the public that sound science requires good data and validated methodologies, which require time to develop;
4.3. Not use unrealistic default assumptions in the tolerance reassessment process;
4.4. Abandon the idea of wholesale revocation of tolerances for the organophosphate insecticides;
4.5. Determine whether to apply additional uncertainty factors on a chemical specific, case-by-case basis, considering the weight of all available and reliable scientific evidence;
4.6. Use the most relevant toxicity endpoints in the tolerance reassessment process;
4.7. Establish and maintain a deliberate, consistent and transparent decision-making process;
4.8. Give higher priority to making sound scientific decisions than to completing final tolerance reassessments by statutory deadlines. EPA should use the authority provided in the law to make preliminary decisions on tolerances and delay effective dates for a reasonable period of time to allow for data development;
4.9. Revoke only those tolerances that pose unacceptable risk and avoid removing uses that only pose a theoretical risk based on worst-case assumptions;
4.10. Not revoke tolerances unless tolerance reassessments are based on actual pesticide use and usage information;
4.11. Propose and maintain policies and methods for risk allocation and make them available for public review and comment;
4.12. Allow adequate time for pesticide users to make a reasonable transition to economic and effective alternative products and practices when existing product tolerances are revoked;
4.13. Redress the current resource imbalance between tolerance reassessment and new chemical new registration and accelerate the pace of making decisions of new products and uses. EPA should adopt an incremental risk approach to evaluating Section 18s;
4.14. Give high priority to the protection of minor crop uses;
4.15. Use USDA's knowledge and expertise throughout the entire decision-making process; and
4.16. Maintain pesticide use tolerances if cancellation of a tolerance results in increased imports or until effective, affordable products are in place.
5. To further achieve the goal of having a science-based workable implementation of the FQPA which will assure producers' access to safe, effective and economical crop protection products, we support:
5.1. Giving top priority to streamlining the Section 18 registration process so products become quickly and readily available for emergency use;
5.2. Grower input on products that may lose crops from labels, prior to the agency and the registrant reaching registration decisions;
5.3. Developing additional incentives for registrants to register new products and reduced risk products;
5.4. Utilizing negligible risk to speed the registration process for Sections 3 and 18 registrations and to reduce the cost of registration;
5.5. Increased funding for the Interregional Research Project #4 (IR-4) so land grant institutions may conduct the necessary research needed to meet legislated guidelines for product review;
5.6. Working with industry groups and the appropriate agencies to reduce the impact of the implementation of FQPA on the farm community;
5.7. Inclusion of human risk data, whenever such data are available, in the tolerance reassessment process. Peer reviewed and ethically obtained human risk data should have priority over animal study data; and
5.8. Expansion and full funding of the USDA's Pesticide Data Program to provide accurate data on exposure to pesticide residues at the final point of sale. Tolerance reassessment should rely on these data to the greatest extent possible.
6. We will:
6.1. Urge Congress to review the implementation of the FQPA;
6.2. Ensure the FQPA is being implemented as originally intended by Congress; and
6.3. Support congressional action that will ensure a workable and reasonable implementation of the FQPA.
7. We recommend that EPA use a 95 percent confidence interval when evaluating pesticides for registration.
1. IPM can reduce the risk of output loss, the per-unit cost of production and liability from chemical damages.
2. IPM is a defensible use of pesticides because it focuses use where problems have been identified.
3. The loss of environmentally benign pesticides for specialty crops through the reregistration process will weaken IPM efforts.
4. We urge the Environmental Protection Agency and USDA to consider the impacts of pesticide product use losses and minimize their adverse effects on specialty and minor use crops.
5. IPM should continue to be a budget priority for USDA and land grant institutions. They should expand their research and development of IPM techniques on a regional basis.
6. We support:
6.1. The widespread promotion and voluntary use of integrated pest management (IPM) as a method of reducing costs, risks, liability and total dependence on farm chemicals;
6.2. Continued research and development of pesticides which degrade more rapidly, are less environmentally persistent and are compatible with accepted IPM practices;
6.3. The removal of pheromones from the pesticide classification in order to permit, expedite and encourage their usage;
6.4. Increased biological pest control research to determine where biological pest control measures can provide practical and feasible substitutes for, and supplements to, chemical controls;
6.5. A "beneficial insects" category in USDA's Competitive Grants program; and
6.6. Expanded educational programs to encourage the widespread adoption of IPM, including the addition of IPM instruction to pesticide applicator training programs.
1. We support proper labeling of feeds, foods, fibers and other agricultural products, including the specific oils and percentages used in food products. Safe handling instructions on agricultural commodities are encouraged. Warning labels on products should be based on conclusive scientific proof. The correct nomenclature for imitation products used as substitutes for traditional foods and fibers is an integral part of consumer protection. We do not object to new food products entering the market; however, these products should stand on their own merits. Manufacturers of imitation foods should be allowed to label their products with any available name provided no reference is made to the product being simulated and no descriptions are used that imply the traditional food origins. Labels on imitation products should state on the main display panel of the package that the product is an imitation.
2. Labels should not be required to contain information on production practices that do not affect nutrition or safety of the product.
3. We support voluntary Country of Origin Labeling (COOL) that conforms with COOL parameters and meets WTO requirements.
4. USDA should administer rules and regulations for certification. The implementation of COOL should not impose undue compliance costs, liability, recordkeeping and verification requirements on farmers and ranchers.
5. We support the inclusion of all dairy products in COOL legislation.
6. We recommend implementation of COOL to include all peanut products, raw and processed.
7. We support Congressional funding for the implementation of COOL.
8. We support the inclusion of honey and dry beans in COOL.
9. Imported products should be labeled at the distribution point and retail level as to the country of origin and date of packing. Labels on imported products should state on the main display panel of the package that the product is imported in letters not less than one-half the size of the product name. Labels on imported bulk food products should appear on the container panel/bin or in close proximity.
10. Products produced mostly in another country and “finished” in the U.S. or simply moved to the U.S. before final sale should not be labeled as U.S. produced.
11. For animal products to receive a "Grown in the USA" label the animal(s) must have been exclusively born, raised and processed in the United States.
12. The Federal Standards of Identity for fruit juices should not be further weakened. We support percentage labeling for all processed juice and juice beverages to declare juice content. Fruit juices reconstituted from concentrate should be reconstituted at a Brix level equal to the average of the single-strength juice produced from that fruit in the United States. We support the timely enforcement of Food and Drug Administration (FDA) regulations concerning the adulteration of juice.
13. We support:
13.1. Consumer-friendly, science-based labeling of agricultural products that provides useful information concerning the ingredients, nutritional value and country of origin of all food sold in the United States;
13.2. USDA-approved market-based certification programs that identify production practices used to produce such food;
13.3. Legislation to require labeling of clothing and fabrics according to their degree of flammability and melting point when exposed to heat;
13.4. The science-based labeling policies of FDA, including:
13.4.1. No special labeling requirement unless a food is significantly different from its traditional counterpart, or where a specific constituent is altered (e.g., nutritionally or when affecting allergenicity); and
13.4.2. Voluntary labeling using statements that are truthful and not misleading;
13.5. A voluntary and uniform labeling system for products designated as genetically modified organisms (GMOs);
13.6. Voluntary labeling of identity-preserved agricultural and food products that is based on a clear and factual certification process;
13.7. The use of the "REAL" seal only on dairy products made with U.S.-produced cow’s milk;
13.8. All levels of government to vigorously enforce laws regarding the fraudulent and misleading labeling of dairy products;
13.9. Truth in advertising when live plants are offered for sale to the general public;
13.10. Imposing severe penalties for intentional mislabeling of agricultural products;
13.11. Requiring all food products containing animal or vegetable ingredients being labeled as to the percentage and type of each;
13.12. Requiring wines derived from grapes labeled as American or U.S.A. appellations containing 100 percent U.S. grapes;
13.13. U.S. origin products proudly displaying the American flag in a prominent position on the label;
13.14. The placement of a Quick Response (QR) Code linked to nutritional information in lieu of providing the actual required nutritional information on packaging; and
13.15. Alcoholic cider being defined as made primarily from apples, and pear cider being defined as primarily from pears.
14. We oppose:
14.1. False, misleading, negative or deceptive marketing and promotion and/or label claims such as food products derived from the use of biotechnology;
14.2. FDA's proposal which would require warning labels on unpasteurized juices and fresh fruits and vegetables;
14.3. Use of "all natural" and "GMO free" synonymously with "organic" as a way to avoid producer certification as an organic grower;
14.4. Any product labeling that states or implies that organic food is in any way superior to other farm products;
14.5. The creation of the new Bureau of Alcohol and Tobacco, Tax, and Trade regulations regarding nutritional labeling of alcoholic beverages; and
14.6. Applying the Federal Uniform Packaging and Labeling Regulation requirements to horticultural live plants grown in containers when these products are sold at the retail level.
1. We support:
1.1. A uniform sampling and grading standard that takes into account the actual mycotoxin levels;
1.2. The present uniform test for mycotoxin for use in all states and development of an accurate method for testing and sampling at the marketplace;
1.3. Research that accurately reflects the level of mycotoxin that may be ingested by a particular species with no harmful effects;
1.4. Research on the prevention of mycotoxins by USDA and increasing research into the use of mycotoxin-affected commodities;
1.5. Research for more accurate tests to determine mycotoxin levels as opposed to the black light test for final determination of mycotoxin;
1.6. To ensure consistency in price discounts and crop insurance indemnities, we recommend grain buyers base any applicable mycotoxin discounts on tests conducted by trained personnel at Risk Management Agency (RMA) approved labs, and we support the efforts to develop programs that would allow local elevators and feed mills that utilize RMA-approved personnel, testing equipment and procedures to become RMA-approved labs;
1.7. The Food and Drug Administration (FDA) ruling on interstate shipments of grain and other products which contain mycotoxin as long as the ruling provides protection for animals and humans;
1.8. Commodity Credit Corporation changes in the tolerance levels of mycotoxin for privately stored corn in the government loan program to the same levels for public storage facilities;
1.9. The removal of FDA restrictions on interstate and export shipments of mycotoxin corn and cottonseed which has been treated with a high pressure-high temperature ammonification process to reduce the mycotoxin to insignificant levels;
1.10. Funding for an Aflatoxin Mitigation Center for Excellence;
1.11. The standardized use of the "thin layer" test for determining vomitoxin levels in grains and end products; and
1.12. Making permanent the 2012 FDA national emergency corn blending waiver for aflatoxin contamination. This waiver allows corn under 20 parts per billion (ppb) to be blended with corn up to 500 ppb to reach a species-specification level.
1. We support rules and procedures for removing quarantines on affected agricultural commodities. We recommend the federal government, in consultation and cooperation with state and local agencies, have the authority to impose regional quarantines.
2. Quarantines restricting the interstate movement of agricultural products should be based on conclusive science.
3. A quarantine period should not exceed 30 days. By the end of that period, the governmental agency imposing the quarantine should be required to take one of the following actions:
3.1. Revoke the quarantine;
3.2. Continue the quarantine for an additional 30 days, for a total quarantine not to exceed 60 days; except in the case of poultry, the total quarantine should not exceed 30 days;
3.3. Condemn the product and dispose of it within 10 days; or
3.4. If the quarantine extends into the second 30 days, loan arrangements should be made available to producers whose products are quarantined for conditions beyond their control.
4. We support a revision of the USDA pre- and post-harvest treatment manuals relating to quarantines.
1. We support:
1.1. The USDA definition of Direct Marketing Farmers: Farmer-producers that sell their own agricultural products directly to the general public, which includes fruits and vegetables, meat, fish, poultry, dairy products, and grains; and
1.2. The USDA recognizing and accepting State Inspection of Meat and Poultry products at USDA facilities.
1. We support periodic review and revision of federal grades and standards for fruits and vegetables to better reflect conditions due to modern harvest and marketing methods.
2. Fruit and vegetable grades and standards should not be changed solely on the assumption that such a change would alter crop production practices.
1. Farm Bureau, USDA and the grain trade should continue to work cooperatively to improve grain standards which accurately reflect the importance of test weight, protein content, insect infestation levels, moisture, dry matter basis and foreign material in determining quality, grading and pricing factors for soybeans, wheat and feed grains.
2. We support:
2.1. Adjusting U.S. grains and oilseeds premiums and discount schedules to encourage the storage, delivery and export of high-quality, clean grain;
2.2. Offering incentives to minimize the percentage of moisture, foreign material, dockage and shrunken and damaged kernels;
2.3. Strengthening and enforcing federal standards that would reflect the quality of grain sold in world trade;
2.4. USDA accelerating research to develop more objective tests and promoting the use of those tests to accurately differentiate between types of classes of grains based on hardness, protein content and physical and biological characteristics;
2.5. USDA conducting a comprehensive study to identify the changes in grading procedures and standards including sampling and testing methods needed to ensure that class and grade will accurately indicate the appropriate end use for each lot of grain;
2.6. USDA allowing all information available, such as identification by variety, to be used in the classification procedures, pending the adoption of acceptable objective tests;
2.7. Continued development of new grain standards to improve the present U.S. Grain Standards Act. Revised grain standards should indicate clearly and give assurance that we will provide clean, identity-preserved grains for our customers at home and abroad;
2.8. Grading in increments of tenths;
2.9. Premium and discount schedules being consistent and stated at the time of contracting and not be subject to change at delivery;
2.10. Encouraging processors and elevators to provide the economic rationale for all discount rates;
2.11. Amending the United States Grain Standards Act for soft white wheat to include the level of alpha-amylase enzyme based on the falling number test;
2.12. USDA ensuring that grain imported into the country complies with domestic grain quality standards;
2.13. Giving proper and timely notification to farmers and grain dealers if grading procedures or standards are changed;
2.14. Working for the development and funding of a voluntary certification process for identity-preserved grain;
2.15. Development of contract language on grain that will not extend producer liability for grain quality or type past the point of delivery;
2.16. Imposing a late cash payment penalty on grain brokers and mills who fail to pay by the agreed upon contractual date. This penalty should include the contractual payment price plus compensation for delay in payment;
2.17. The prohibition of the practice of adding foreign material, other grains or screenings to a shipment of grains to meet a certain grade. Criminal penalties for violations should be swiftly and surely administered;
2.18. Inspection and cargo weight checks of all export shipments by the Grain Inspection, Packers and Stockyards Administration (GIPSA). GIPSA should also verify the cleanliness, quality and test weight of every export grain shipment;
2.19. Producer representation on the GIPSA advisory council;
2.20. The adoption of the equivalent bushel concept for grain marketing which rewards producers for delivery of a quality product. Because the current grain marketing system discounts producer return for high moisture grain, a change to the equivalent bushel concept would eliminate the economic incentive of manipulating moisture levels and more accurately reflect the commodity's true value;
2.21. Further research of new and advanced technology in testing grains for quality, such as protein and oil content, to determine the profitability of adopting these testing procedures to enhance income of grain producers;
2.22. Standards for the quality and safety of feed co-products coming out of ethanol plants; and
2.23. The continual use of guidelines so that blending of like products can be continued.
3. We oppose:
3.1. The establishment of defect action levels in grain by the Food and Drug Administration unless sound science demonstrates a real need;
3.2. Federal grain warehouses being exempted from state grain indemnity laws and applicable coverage; and
3.3. Regulations which prohibit the mingling of grain and feed ingredients at farm and feed milling sites.
1. We support:
1.1. The use of the National Forage Testing Association's (NFTA) Lab Certification Program;
1.2. All forage testing labs becoming certified;
1.3. Proper sampling techniques and the use of NFTA-certified labs for all forage testing; and
1.4. Farm Bureau providing leadership for advancing NFTA standardized forage quality testing in the United States.
1. The objective of federal and state meat and poultry inspection programs is to provide consumers with a supply of wholesome meat and poultry products. This is a service to consumers and costs should be paid from general revenue funds.
2. We support USDA approval of management tools that improve food safety based on cost benefit analysis.
3. We urge that all tests required by other countries for the export of our meat products be conducted by the Food Safety and Inspection Service (FSIS). If FSIS is unable to do the required tests, FSIS should be required to coordinate and facilitate the transfer of any required tests to certified laboratories.
4. We believe all meat, poultry and seafood products should be inspected and tested to the same standard. Funding sources for any new federally mandated seafood inspection program should be consistent with existing funding for other food commodities.
5. Regulations governing the application of federal inspection programs to custom slaughtering plants, locker plants and producer-slaughterers should be modified so as not to eliminate these local services.
6. We favor modifying U.S. beef, lamb and pork grade standards if scientific research shows that changes will provide leaner, more acceptable beef, lamb and pork that will benefit consumers, processors and producers.
7. We recommend the USDA provide processing facility plans to assist processers through the requirements associated with constructing a plant.
8. USDA should:
8.1. Adopt a program taking advantage of new techniques proven by research to be effective in reducing bacterial contamination;
8.2. Focus an aggressive education program on safe food handling of perishable foods to minimize the risk of pathogen contamination. The public also must be educated about the relative and changing risk status to individuals;
8.3. Fund and inspect seafood, farm-raised rabbits, privately-owned cervids, buffalo and ratite meat as currently being done with poultry, pork and beef;
8.4. Support small-scale meat processors and examine existing requirements to alleviate the immense burdens placed on small-scale meat processors;
8.5. Develop electronic beef, lamb and pork grading machines and institute their use where practical; and
8.6. Provide more training opportunities and communication regarding meat inspection requirements including Hazard Analysis and Critical Control Points (HACCP) training.
9. We support:
9.1. Limiting FSIS inspectors’ authority to shut down plants only for violations of food safety or the Humane Methods of Slaughter Act. FSIS should work to ensure consistency of interpretation and application of regulations, guidelines and directives to plants. We encourage FSIS to work cooperatively with the plant manager when actions to shut down a plant impact the health and welfare of livestock being delivered;
9.2. Changes to Humane Methods of Slaughter Act that will allow more flexibility for inspectors to recognize that every attempt is being made to be in compliance with the law and that no violation exists when a second shot or stun method is immediately employed;
9.3. USDA approval of the use of hot water, steam and other proven rinses of carcasses prior to further processing. We also support USDA approval of the use of pasteurization and completion of research of high intensity pulses of light to kill pathogens;
9.4. Granting the secretary of agriculture authority to impose mandatory quarantine and recall of meat products based on scientific testing and detection procedures. Authority to do trace backs to the farm should be focused on control and eradication of animal health diseases and related epidemiological studies;
9.5. Development of analytical methods for on-site detection of contaminants and other adulterants that may impact food safety;
9.6. Changes to the Wholesome Poultry Act to allow more than one person to slaughter or process poultry at a facility;
9.7. Changes to USDA regulations to allow for part-time supervision of small local slaughterhouses;
9.8. USDA revisions of the yield grade standards for lamb and mutton. This includes mandatory coupling of yield and quality grading and the removal of the kidney and pelvic (KP) fat on the slaughter floor;
9.9. Establishing federal standards for packing plants that purchase cattle, sheep and hogs on a grade and yield basis;
9.10. Legislation to eliminate unnecessary inspection;
9.11. Producer-led quality assurance programs that deal with issues of food safety;
9.12. Enforcement of meat inspection standards. We recommend that the meat inspection program remain under USDA and not be placed with the Food and Drug Administration (FDA);
9.13. Allowing states to enter into Memorandum of Understanding (MOUs) to allow the sale of state inspected meat into other states;
9.14. Meat inspectors being deemed essential employees in cases of government shutdowns;
9.15. Reclassifying rabbits raised for food from exotic animals to livestock for processing purposes;
9.16. Federal meat inspectors being made available to small meat processors; and
9.17. An exemption for poultry processing facilities of fewer than 20,000 birds annually, allowing them to lease to other processors who have a Hazard Analysis and Critical Control Points (HACCP) plan and are processing their own birds.
10. We oppose:
10.1. User fees to finance federally mandated meat, poultry, non-traditional food animals and seafood inspection;
10.2. The use of excessive penalties on producers, processors and handlers. Producers should have feasible control or prevention programs available to them before punitive actions are taken;
10.3. Characterizing meat animals as carriers of E. coli;
10.4. Uniform grade names for all graded foods; and
10.5. Cutbacks in funding of the federal meat inspection programs unless the regulations are changed.
1. We support continued evaluation and improvement of the USDA organic accreditation system.
2. Organic growers should be responsible for taking appropriate measures to protect their crops from pollen drift or other factors that affect the integrity of their crops.
3. We recommend that the National Organic Program (NOP) follow recommendations of the National Organic Standards Board (NOSB) regarding livestock medications, pasture and composting.
4. Changes to the NOP animal welfare standards should not impair the current practices that allow producers to maintain the biosecurity of their herds and flocks.
5. The discovery of marked, genetically modified steriles, such as the DS Red Sterile Pink Bollworm Moth, in organically grown crops should not impact the status of organic certification of the crops.
6. To maintain the integrity of organic agriculture, we support USDA's National Organic Standards with the following changes:
6.1. Keeping organic standards strictly organic, i.e. not allowing some drugs or non-organic feed to be used and the product still retain the certified organic label;
6.2. That certified farmers should be able to participate in their certification management boards;
6.3. Imported products labeled as organic must be subject to the same standards as the U.S. organic standards;
6.4. The Organic Materials Review Institute's list of approved materials should be the USDA's approved list; and
6.5. All persons selling, handling or processing organic products from bulk or opened packages need to be certified.
7. We support:
7.1. All methods of agricultural production, including hydroponic, aquaponic and aeroponic agriculture, and marketing provided they offer opportunities to all producers who qualify or meet required standards;
7.2. Efforts to enhance marketing opportunities for producers of organically grown commodities just as we support such efforts for conventionally produced crops;
7.3. Auditing and enforcement of the USDA-certified organic program in line with its increasing economic importance and growth;
7.4. Broad availability of information on the USDA-certified organic program, certification process and labeling requirements, as well as other unbiased information on organic products or production; and
7.5. Monitoring the activities and protocol of the NOSB. American Farm Bureau Federation should work with the state Farm Bureaus to fill vacant positions on the NOSB when applicable.
1. For decades, the Plant Variety Protection Act (PVPA) has played a critical role in the protection, maintenance and propagation of agricultural seed varieties. While the advent of biotechnology and the applicability of plant and utility patents to plants have complicated the plant protection landscape, PVPA should still play a substantial role in the protection and propagation of current and future plant varieties. In order to do that, PVPA must remain relevant and effective.
2. Companies that sell biotech seed should help keep the price of seed competitive for U.S. farmers with farmers from other countries; however, plant breeders should not sell patented seed in countries that do not provide the same intellectual property rights protection.
3. We encourage the timely release of information regarding increases in tech fees and seed prices to allow for appropriate planning by producers.
4. Farmers should be allowed to save and replant biotech seed by paying a minimal technology fee on saved seed.
5. In order to strengthen the rights of plant breeders and maintain a farmer's ability to save seed for the land he or she farms and dispose of incidental amounts of seed, we support:
5.1. Strong intellectual property rights protection to allow seed developers the ability to recover the costs of research and development of seeds, while abiding by all antitrust laws;
5.2. Restricting the sales of protected varieties without the permission of the owner;
5.3. The present provision which allows a farmer to save seed for use on all the land that he or she farms;
5.4. A provision to allow growers of seed varieties protected under the PVPA to sell the seed according to local commercial law if the seed company fails to abide by the grower contract;
5.5. Maintaining the international and domestic gene/germplasm banks/stores. These should remain easily accessible to the public;
5.6. Continued plant variety research in the public sector;
5.7. Compensation for the public contribution to a joint public-private venture; and
5.8. Uniformity in the establishment of tech fees globally.
1. We support:
1.1. Adequate funding at the local, state and federal levels for research, organization and administration of regulatory and pest control programs in each of the infested states, including all land in the affected area;
1.2. Continuation by USDA of its fire ant program;
1.3. Cost sharing by the Natural Resources Conservation Service on farms for chemical, predator or biological control of fire ants;
1.4. Expanded research by Animal and Plant Health Inspection Service to provide safe, effective and practical treatments for multi-year certification of field and container-grown nursery stock;
1.5. Relaxation of United States quarantine requirements to allow the importation of the Phorid fly for the sole purpose of controlling Imported Fire Ants; and
1.6. The special approval of Section 18 chemical usage for the control of fire ants, crazy ants and Argentine ants. We encourage the Environmental Protection Agency to make special considerations to control these invasive ant species.
1. We believe federal, state and local agencies should work more closely with private landowners and industry to address harmful invasive species problems.
2. We support a comprehensive national policy addressing the introduction and management of harmful invasive species. Programs should rely on cooperative, voluntary, partnership-based efforts between public agencies, private landowners, industry and concerned citizens.
3. The development and adoption of statutory policy and control measures to deal with harmful invasive species should be based on the following principles:
3.1. Regulations and statutes should not be allowed to interfere with or erode property rights;
3.2. Clear criteria must be established to delineate what are harmful invasive species, which should not be defined to include beneficial non-native species;
3.3. Regulations should include emergency measures to allow for the timely use of chemical controls;
3.4. Any consideration of endangered or threatened species should have a component recognizing and addressing the role of harmful invasive species;
3.5. State and federal funding should be adequate to develop sound science sufficient to determine long-term effects of non-native species;
3.6. We support the indemnification of crop and livestock losses from harmful invasive species when it can be documented that the quarantine requirements or treatment methods are the basis for the loss. We support an increase in funds for inspection services and facilities. Funding should also be made available for public education and outreach efforts;
3.7. Public lands should be managed to reduce and eliminate impacts of harmful invasive species as effectively as private lands and in coordination with neighboring privately owned or leased land. Such management on public lands should be exempt or excluded from the National Environmental Policy Act process. Any efforts on public lands that affect the uses and private rights held by public land permittees and users shall be subject to compensation and fair market value for the taking of these property rights by the introduction or proliferation of harmful invasive species;
3.8. Proper incentives should be provided for farmers and ranchers to effectively control noxious and aquatic weeds along with support for an Integrated Pest Management approach;
3.9. Any harmful invasive species program that is proposed should not create additional restrictions on agricultural producers, landowners and industry; and
3.10. Harmful invasive species should not be defined to include agricultural products.
4. We support states’ efforts to prevent the introduction of quagga and zebra mussels into their waters and encourage cooperation between states to control the current infestation.
1. Federal and state livestock and poultry indemnification laws and regulations should be revised to reflect current market value and trends in marketing conditions and production programs in these industries. Revisions should also take into account the period of government-enforced business interruptions and economic restrictions.
2. Indemnification should be provided for losses of agricultural products when products are impounded, farms are quarantined or movement or sales are restricted in the public interest.
3. Producers should be compensated in these cases and not held responsible for conditions beyond their control. We urge financial assistance for testing feed in efforts to locate the source of pesticides and residues.
4. Producers should be responsible for losses resulting from condemnations from animal drugs and pesticide residues due to negligence on their part.
5. Current law should be amended to include indemnification for losses due to the use of chemicals, drugs or vaccines which are not caused by producer negligence. There should be no retroactive liability for property owners, farmers or their agents for chemical applications made in accordance with laws in effect at the time of application.
6. We support:
6.1. State-federal funded eradication programs for plants, livestock and poultry that provide indemnification as needed to control the spread of and eradication of serious communicable diseases. Prompt indemnity payments should be based upon current market values;
6.2. Legislation indemnifying farmers and farm owners for the cost of cleanup and other damages arising from the pollution of their land by the willful or negligent acts of others;
6.3. Re-evaluation of the indemnities for foreign animal diseases;
6.4. In the event of an outbreak of a major animal disease appropriating the necessary funds to farmers for indemnification of lost animals and income until the affected farms are approved to resume operations;
6.5. Including integrators, contract growers and producers in all federal indemnity payment programs pertaining to the livestock and poultry industries. When a company receives an indemnity payment, a pro-rata share should go to the grower;
6.6. Federal and state efforts to control tracheal and Varroa mites and to provide suitable indemnity if bee colonies are destroyed in the process; and
6.7. The need to post a bond in a reasonable amount by environmental organizations that sue state or federal agencies to protect workers and the company owners from loss of income due to work stoppages. In the event that the suit is unsuccessful, the bond should be forfeited to the company in order to defray their losses.
1. We support:
1.1. An aggressive national and state effort to halt the spread of non-native pathogens and pests which endanger agricultural production;
1.2. The establishment of a program to analyze the effectiveness of state, federal and international plant and animal diseases and insect control measures. This analysis should estimate the risk of spread of undesirable plants, animals and insects under current control procedures. Recommendations to improve control measures should be included in the analysis. Findings should be made known to the affected industries; Measures taken by USDA should include:
1.2.1. A ban on untreated products and packing materials from countries with known populations of destructive pests not native to North America;
1.2.2. Intensive monitoring of all imported products; and
1.2.3. Funding of research on eradication methods.
1.3. Pest control funding should be made available when the need arises because the control of plant and animal pests is an important factor in reducing farm losses. Programs should be developed so when a problem arises the funds and facilities can be put in place expediently. We also encourage the Animal and Plant Health Inspection Service (APHIS) to undertake early monitoring to determine the location of pest infestations in order to maximize resource allocation;
1.4. The departments or agencies of the federal government should implement and pursue an effective program for the control of noxious plants and other undesirable plant species on all lands under their control or jurisdiction, including wilderness areas and national parks. Such programs should be in accordance with state and federal weed laws and should be in cooperation with the state departments of agriculture and/or with a designated agency where there is a state weed and pest organization. States that are sentinel states for pest introductions should receive increased focus and support to strengthen pest protection efforts;
1.5. The concept of multinational cooperation in the areas of research exchange, technology transfer and the development of new plant varieties to offset the loss of federal and state research dollars devoted to preventing the introduction of new plant pest diseases;
1.6. A greater international effort to control the spread of noxious plants, insects and animal pests. Quarantine protection from these pests should not be compromised in international trade negotiations;
1.7. The separation and autonomy within USDA of APHIS and the scientific advisory panel;
1.8. Increasing the efficiency of the APHIS programs and increased funding for APHIS inspections and stronger regulation of plant materials entering the U.S;
1.9. The transfer of authority for agricultural inspections at the U.S. ports of entry from the U.S. Department of Homeland Security to APHIS and increased funding for the agency or agencies responsible for these inspections;
1.10. The employment of technical staff qualified to address new and more complicated phytosanitary and sanitary matters. Improvements to infrastructure, facilities and shared database technology must become a priority for the agency or agencies responsible for agricultural inspections;
1.11. Increased monitoring of raw wood products and other plant-based construction material including packaging materials;
1.12. The removal of spending limitations from the APHIS user fee trust fund included in the USDA appropriations act. User fees should be used to fund vacant inspection positions at ports of entry;
1.13. The development and maintenance of effective pest exclusion programs at ports of entry. These programs should include increased inspection of travelers, as well as public awareness programs, to inform travelers of the threats to agriculture from imported pests;
1.14. Aggressive enforcement of phytosanitary protocol at ports of entry to detect illegal plant and animal products, diseases, pests or harmful invasive species. Immediate expansion of USDA's Plant Protection and Quarantine Branch personnel and facilities to take care of increased plant imports. We further request that sufficient fees be imposed on the plant material imported to cover the costs of adequate inspection and fumigation. USDA should re-evaluate and strengthen the risk assessment criteria it uses in determining the impact of importing plants, animals and their products from areas with exotic pest infestations. In determining pest-free zones, USDA should be required to hold any public field hearings in the domestic production area which will be affected;
1.15. Mandatory identification of manifests of organic shipments for targeted inspection;
1.16. Increased cooperation between the U.S. Postal Service and APHIS to increase first class mail inspections at high risk entry points;
1.17. Increased fines for private and commercial smuggling of agricultural products. Fines should be severe enough to deter smuggling and be used to fund the APHIS/Agricultural Quarantine Inspection System (AQI);
1.18. A prohibition on the use of untreated wood products from countries known to have the Asian Longhorn Beetle;
1.19. An awareness program to provide education to assist Texas ranches in identifying and controlling the Fever Tick. We also recommend that we solicit Mexico's assistance to increase the width of the Mexican "border barrier zone";
1.20. Implementation and funding for the National Strategic Plan for the Cattle Fever Tick Program developed in 2006;
1.21. Legislation that would require USDA to fund and implement dipping facilities at sale barns in south Texas to control fever ticks;
1.22. Strengthening of Quarantine 37 and continuing efforts to require enforcement. In addition, other protection regulations that safeguard producers from plant diseases and exotic pests including citrus canker should not be weakened;
1.23. The APHIS proposal to allow the importation of certain fruits from Hawaii, including lychee, provided they are not held in transit in any state that is host for the tri-fly complex and provided they are irradiated or treated immediately after arrival;
1.24. The continued development of domestic currant cultivation by allowing the importation of new cultivars from European Union countries via an appropriate phytosanitary protocol;
1.25. All wheat imported from Mexico meeting equivalent testing standards as U.S.-produced wheat; and
1.26. Full disclosure of the contents of seed lots by amending the Federal Seed Act to require the tag or label to list each plant species therein by name and rate of occurrence.
2. We oppose:
2.1. Any importation of citrus, nursery stock and citrus products other than juice from any country having citrus canker or any other harmful phytosanitary problems and pests until that citrus is certified free of all harmful phytosanitary problems and pests;
2.2. The combining of APHIS and U.S. Customs Service;
2.3. To weed seed being sold as bird feed unless it has been treated so that it will not germinate; and
2.4. All sales of Tamarisk as a nursery stock.
3. Bacteria, Diseases and Virus
3.1. We support:
3.1.1. The development and implementation of a formal plan such as Florida's Citrus Health Response Plan that helps growers manage and control the spread of citrus pests and diseases (e.g., citrus canker, citrus greening);
3.1.2. Increased citrus greening exclusion efforts and research funding for vector and disease detection efforts and eradication, inoculation and best orchard management for the protection of the U.S. citrus industry;
3.1.3. Continuation of strict enforcement of the virulent potato wart virus quarantine on all Canadian potatoes, and any livestock fed fresh Canadian potato stock within 30 days of shipment, until such time that Canada is declared free of the potato wart virus;
3.1.4. USDA protecting U.S. potato production by investigating the magnitude of the threat of the root-lesion nematode ( Pratylenchus neglectus) to and if warranted taking action up to and including a moratorium on shipments of Canadian seed and/or commercial potatoes into the United States;
3.1.5. Scientifically-based, federally-funded programs for the survey and control of the spread of plumpox virus in North America including eradication if necessary. We further support indemnity payments based on established values of established orchard trees as well as nursery trees and ornamental nursery stock affected in the eradication program. Indemnification should take into account business interruptions as well as long term economic losses;
3.1.6. APHIS protecting the interests of U.S. soybean producers by actively engaging in monitoring and surveillance activities to control Soybean Rust. We support testing and development of crops resistant to diseases that are not yet present in the United States. Testing and development should be conducted in non-sensitive areas to protect the health of present crops; and
3.1.7. Funding for the National Plant Diagnostic Network to allow for continued high-quality and coordinated expert diagnostic services to growers and plant protection officials in the event of an introduction to the U.S. of an invasive or emerging plant pest, disease, or weed.
4. Karnal Bunt
4.1. The tolerance on karnal bunt must be based on sound science and appropriate to each segment of the industry, for karnal bunt in wheat, wheat products and other commodities. USDA should work towards that goal by:
4.1.1. Sponsoring an international meeting of scientists to evaluate the status and strategies for management of the smut and bunt diseases of cereals worldwide, with particular attention to karnal bunt;
4.1.2. Taking a leading role in re-evaluation of international policies on the use of quarantines to prevent the movement of cereal smut and bunt fungi; and
4.1.3. Maintaining an aggressive research effort on smut and bunt diseases of cereals, including karnal bunt.
4.2. In order to protect and expand U.S. wheat exports, USDA, U.S. Trade Representative (USTR) and the wheat industry should actively promote and gain acceptance of karnal bunt as a quality issue at the earliest possible date. Karnal bunt should be deregulated and handled as a quality issue in a manner that facilitates the marketing of grain and prevents market disruptions.
4.3. We encourage continuation of compensation discussions and should keep the minimum compensation level the same as 1996.
4.4. Compensation should be established for harvesters and transporters and consistent regulations need to be established for sanitizing equipment.
5. Noxious Weeds
5.1. We support:
5.1.1. Control programs for designated noxious weeds and invasive species and the necessary funds from the federal government for eradication;
5.1.2. USDA taking immediate action to enact a program to control and/or eradicate Tamarisk (Salt Cedar); and
5.1.3. USDA taking immediate action to enact a program to control and/or eradicate giant salvinia in the lower Colorado River.
6. Pests and Invasive Species
6.1. We support:
6.1.1. Recession of presidential Executive Order No. 13112 with its broad scope and potential for uncontrolled costs;
6.1.2. Increased and extended funding for the integrated pest management programs;
6.1.3. Irradiation as an approved technology for pest control;
6.1.4. USDA controlling the West Indian sugarcane weevil;
6.1.5. Efforts to control or sterilize the starling, blackbird and crow populations to the point where they are no longer an economic problem for agriculture;
6.1.6. Adequate funds be allocated for the eradication of harmful species of fruit flies in the United States and its territories;
6.1.7. APHIS studying and monitoring the Russian Wheat Aphid and taking the necessary action to control its spread;
6.1.8. Programs that will lessen the impact of the gypsy moth and southern pine bark beetle;
6.1.9. Voluntary compliance programs that certify nurseries free of new or emerging plant pests and encourage regional cooperation in the absence of federal programs to aid in interstate shipments of plants; and
6.1.10. Allowing acceptable integrated pest management (IPM) options until removing the Pallida Globodera Nematode, also known as the Pale Cyst Nematode (PCN), from the world quarantine list.
7.1. We support:
7.1.1. Continued research and implementation of detection, exclusion, control and eradication measures;
7.1.2. The Land Grant Universities, National Institute of Food and Agriculture (NIFA) and Natural Resources Conservation Service (NRCS) Plant Materials Laboratory) continuing to search for and develop plant material for forage production, conservation and wildlife uses;
7.1.3. The best plant species available, native or non-native, be used for forage production, conservation or wildlife purposes. Universities, NIFA and federal agencies should promote the use of domestically developed, imported and native plant species for forage production, conservation and wildlife activities. Further, NRCS should continue support and allow the use of domestically developed and/or imported plant species in their cost share programs;
7.1.4. Research to learn how to effectively and economically manage domestic European honeybees in the area where Africanized honeybees exist;
7.1.5. Research efforts to address viable control methods for Phytophthora capsici and Downy Mildew;
7.1.6. Continued research and development into the problem of preventing the importation of exotic species in the ballast tanks of cargo ships. Shippers should be required to use only those methods that are financially reasonable and technologically feasible to prevent exotic species in ballast tanks;
7.1.7. Research to combat new emerging pests (e.g., Brown Marmorated Stink Bug, the Spotted Wing Drosophila Fruit Fly, etc.); and
7.1.8. Research and development of methods to control weeds/invasive species that may be becoming resistant to chemical control measures.