R-CALF has requested the immediate retraction of a recent memorandum on the grounds that the memo “constitutes an unlawful, final regulatory action initiated and implemented without public notice or opportunity for comment.

The letter was sent to the United States Department of Agriculture APHIS. Also receiving the formal letter were Sen. Tom Harkin, D-Iowa, who chairs the Senate Agriculture Committee, and Rep. Collin Peterson, D-Minn., who chairs the House Agriculture Committee, as well as the ranking members of each committee. Additionally, animal health officials in each state received a copy of R-CALF USA’s correspondence.

“The effect of this memo is that premises registration under NAIS (National Animal Identification System) is now mandatory for producers engaged in interstate commerce and who participate in any one of the dozen or more regulated disease programs, despite APHIS’ express promise to the industry and to Congress that NAIS would remain a voluntary system,” said R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group’s animal health committee.

This memo declares that the Premises Identification Number (PIN) established under the agency’s NAIS “is to be the sole and standard location identifier for all VS program activities,” and that premises “will be registered in the NAIS.”

“This agency action by APHIS is unlawful,” Thornsberry emphasized. “We request immediate retraction of this memo, and we additionally request that APHIS be directed to immediately inform each state animal health official that the agency no longer is requiring the registration of premises as a condition of producer participation in regulated animal disease programs, or for any other purpose.”

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