The memo sets out various activities that will trigger involuntary registration, including vaccinations, diagnostic tests, and the application of official eartags for the regulated diseases. The list of diseases spans every species and includes brucellosis, tuberculosis, pseudorabies, Johne's, scrapie, and communicable diseases in horses. The memo clearly states that if a property owner refuses to register his or her property, the veterinarian or the state authorities are to collect the information and assign a registration number to the property. The failure to voluntarily register for NAIS further results in the property being assigned a special code so that the government knows who refused to "volunteer."
Given the USDA's constant re-writing of documents, it may come as no surprise that there have been various denials and reinterpretations provided. The Texas Animal Health Commission (TAHC) initially told one of our members that the memo would not be enforced, and then later told a reporter to talk to the USDA instead. Other state agencies have denied plans to enforce the memo, or have simply not responded to inquiries. One state agency has stated that it will apply the memo for programs that are paid for by the USDA, such as Johne's testing.
Pro-NAIS industry groups have also gone into action to try to explain away the memo. The American Horse Council (AHC) sent a memo to its members claiming that the USDA memo addressed how premises identification numbers "are to be used and allocated in the future," despite the clear present tense used in the memo. AHC also claimed that an EIA, or Coggins, test would not require a premises number under the memo. Yet the USDA's memo specifically lists communicable disease in horses, as regulated under Title 9, Part 75 of the Code of Federal Regulations - and that entire Part deals solely with EIA (equine infectious anemia)!
The U.S. Animal Health Association's Livestock Identification Committee adopted a resolution praising the memo and asking the USDA to confirm the legal authority behind it. You can read the resolution at http://usaha.org/committees/resolutions/2008/resolution30-2008.pdf
Dr. Hillman, the Executive Director of the TAHC, chairs the committee. The vice chair of the committee is the founder of Global VetLink, a company whose entire business is online tracking of animals, while the committee's membership includes people with connections to other technology companies and organizations that have received money to promote NAIS. Yet the USDA will undoubtedly use the committee's statement as "proof" that "the industry" supports its latest move towards a mandatory program.
One thing is certain: In issuing the memo USDA has clearly shown its intent to make the NAIS mandatory.
In our efforts to get legislation passed to stop NAIS, one of the most common stumbling blocks has been the claim that there is no need for such legislation because USDA has declared NAIS to be voluntary. Download a copy of the memo from http://farmandranchfreedom.org/content/Government-documents
and send it to your state and federal representatives today!
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Now is the time to pass legislation stopping the agencies from forcing NAIS on people.