U.S. Senate Committee on Appropriations
Room S-131, The Capitol
Washington, DC 20510
July 15, 2008
Dear Members of the Senate Appropriations Committee:
We, the undersigned organizations, urge you to keep appropriations for the School Lunch
Program separate from the National Animal Identification System (NAIS). The reason for this
letter is that the House Agriculture Appropriations Subcommittee included a provision that
would require USDA to purchase for the School Lunch Program meat products that are derived
from farms (premises) registered with the NAIS. This provision undermines the School Lunch
Program and promotes a flawed policy.
The House subcommittee provided two reasons for this including provision. The first reason is to
address public health concerns, specifically related to meat recalls. The second reason is to
increase participation in the NAIS. Both reasons are fundamentally flawed.
NAIS is a three-step program that calls for every person who owns even one livestock or poultry
animal to register their property, tag each animal when it leaves it birthplace, and report a long
list of movements to a database within 24 hours. The listed species include chickens, horses,
cows, sheep, goats, pigs, llamas, alpacas, elk, deer, bison, turkeys, and more, whether or not the
animal is used for food. Group or lot identification would only be allowed where animals are
managed as a group from birth to death and never commingled with animals outside of their
production system. In practice, group identification would apply mainly, if not entirely, to
confinement operations (CAFOs) and vertically integrated operations. The stated goal of NAIS is
to provide 48-hour traceback of all live animal movements.
NAIS will harm independent farmers and increase the consolidation of our food supply into the
hands of a few large corporations. The school lunch provision in particular will favor the most
vertically integrated farms that can easily prove that all their meat is from a NAIS-registered farm, as well as confinement operations that will be able to use group identification under NAIS.
By creating incentives for CAFOs, the provision will harm both the public health and the
environment.1 Americans who are increasingly seeking out local and sustainable foods will find
their ability to obtain these foods limited.
Linking NAIS to the School Lunch Program will also harm the growing movement of farm-to- school programs, while benefiting only large-scale, confinement operations where food safety
problems are more likely to occur. The farm-to-school programs help improve children’snutrition while providing family farms with a reliable market. They also promote the local
economy and environmentally sustainable agriculture, and re-connect children with the source of their food. But many of the small, local farmers who are participating in these programs, or who
want to participate, are opposed to NAIS. Whether for philosophical reasons or the costs and
burdens imposed by NAIS, these farmers are unlikely to be able to comply with the provision in
the appropriations bill.
See Doug Gurian Sherman, CAFOs Uncovered: The Untold Costs of Confined Animal Feeding Operations, Union
of Concerned Scientists (April 2008).
In the recent Hallmark/Westland beef recall, the fault lies with the packing plant for violating
existing regulations and with the USDA for failing to properly inspect the plant. “Downer” cows
were slaughtered and the meat then provided to the School Lunch Program. In the video from the
Humane Society, every time there was a clear shot of a cow’s left ear, one can see a tag.2
Changing the type of tag to an NAIS electronic tag would do nothing to address the problem.
For these reasons, we strongly urge you to not include any provision linking the School Lunch
Program to NAIS. Additional background information on why NAIS is a flawed system to
address food safety is attached.
We thank you for your consideration.
Adopt a Farm Family
America Raw Milk Producers Pricing Association
American Grassfed Association
American Land Foundation
American Policy Center
Arkansas Animal Producers Association
California Dairy Campaign
California Farmers Union
Carriage Operators of North America
Catholic Charities, Diocese of Sioux City, IA
Cattlemen’s Texas Longhorn Registry
Center for Rural Affairs
Chez Panisse Foundation (CA)
Citizens Action Coalition of Indiana
Citizens for Private Property Rights - Missouri
Colorado Independent Cattlegrowers Association
Community Food Security Coalition
Dakota Rural Action (SD)
Davis Mountain Trans Pecos Heritage Association (TX)
Diocese of Jefferson City, MO
Empire State Family Farm Alliance (NY)
Environmental Conservation Organization
Equus Survival Trust
Fair Food Matters (MI)
Family Farm Defenders
Farm and Ranch Freedom Alliance
Farm to Consumer Legal Defense Fund
Federation of Southern Cooperatives
Focus on Agriculture in Rural Maine Schools (FARMS)
Food for Maine's Future
Illinois Independent Consumers and Farmers Ass'n