The False Promise of Traceability in our Food Supply
In most years, only a few select committee members in Congress pay much attention to agricultural issues. But food safety has pushed agriculture onto the short list of hot issues in Congress this year. Between the extended hunt for the culprit in the recent salmonella outbreak, the recall of meat from Whole Foods, and the debacle at the California slaughterhouse over downer cows, the American public is getting nervous and demanding that their legislators take action. The flaws in the industrial agriculture system, including its heavy reliance on imported food and centralized distribution, are beginning to become obvious even to mainstream consumers.
Unfortunately, rather than fix the underlying causes, Congress appears to be fixating on band-aid solutions developed by industry. One of the emerging favorites is “traceability.” Whether it’s the New York Times or Congressional staffers, the allure of traceability has taken hold. “Farm to fork” has become the new buzzword, which threatens to ignore all logical and scientific evidence on what is truly needed to fix our food supply problems.
What’s the Problem?
For those of us who participate in direct farm-to-consumer transactions, traceability is an important theme. The food our farmers sell is 100 percent traceable because the consumer knows the farmer, but the safety of our food does not come from that traceability. The safety comes from the relationship that creates the traceability. As a farmer who sells directly to customers, I do not think in terms of “It costs me X dollars to make this food safe. Is that worth it?” I cannot even imagine having to face one of my customers and explain that we made a decision to protect our profits, which led to their child getting sick from our food! Moreover, sustainable, grassbased farms create conditions for healthier animals, leading to healthier food. Our food safety comes from our entire approach, a combination of farming practices and relationship marketing.
Traceability by itself does not improve food quality or safety. The laws and regulations that govern the mainstream food supply are supposed to create minimum safety standards, but there are many failures in the system as huge corporations seek to maximize their profits while stretching the limits within (and sometimes outside) those laws and regulations. Traceability might create some disincentive for corporations to sell harmful products, but even that level of protection requires the ability to connect the harm done to the source of the harm, in either a court of law or the political arena. As we’ve seen in the world of pharmaceuticals, corporations can get away with doing a lot of harm even when their products are traceable. The corporations will only change their practices if and when the harms that they are forced to pay for outweigh the profits they can make by taking shortcuts. So, in the big picture, traceability might make consumers feel better but without making their food supply significantly safer. Traceability is about placing blame after the fact, if you can prove it, not taking steps to prevent harm in the first place.
Despite this fundamental flaw, the concept is gaining traction in Congress. The Safe Food Act of 2007, which attracted multiple sponsors in both chambers, would have created a new agency for food safety and required it to establish traceability for all food. The bill provided that the agency, “shall establish requirements for a national system for tracing food and food producing animals from point of origin to retail sale,”
including “any farm, ranch, orchard, vineyard, aquaculture facility, or confined animal-feeding operation.” (HR 1148/ S654, Sections 3(14) & 210). While the Safe Food Act was not voted on last year, several lawmakers are now discussing including similar provisions in a different food safety bill this year.
The National Animal Identification System (NAIS), which has been discussed in many previous issues of Wise Traditions, gave us an early warning about this craze for traceability. The ability to track every single movement of every single livestock animal in the country is a concept that seems to have strong appeal for legislators and bureaucrats. While USDA states that NAIS is not a food safety program, many legislators and the public view it as one. In May, Congresswoman DeLauro (D-CT) inserted a provision into the House Agriculture Appropriations Bill that would require the USDA to buy meats from NAIS-registered farms for the School Lunch Program. While the bill is stalled in Committee for unrelated reasons, the provision gained wide support, particularly among the Democratic leadership.
Not only will traceability not significantly help the mainstream food supply, it will actively harm food safety for those of us following the WAPF traditions. NAIS and the proposals to track produce do not distinguish between the industrial agriculture system and our local, sustainable options, but seek to regulate everyone who grows food under any system. These regulatory programs would create extreme labor and monetary burdens on the small farmers, driving many out of business and reducing consumer choices.
If you want to retain the option to buy nutrient-dense foods from your local farmers, then it is vital to become informed and active. We must make Congress understand that simply tracking things—whether it is live animals or vegetables—is not the answer to the problems of the food supply system. Take a few minutes to call your Representative and Senators, and talk with their agricultural staffer about the concept of real food safety from local, sustainable farms. Take a few more minutes, and go to www.FarmAndRanchFreedom.org. You can sign up for free e-mail alerts and download materials to educate people at your local feed store, sales barn, farmers market or co-op. We can also provide informational materials to give to your legislators, and work with them on legislation to stop programs like NAIS.
Contact us at info@farmandranchfreedom. org or call 866-687-6452 for more information to help influence your legislators and protect your food supply.
Why the National Animal Identification System will not Address Food Safety
Livestock producers, who bear the burden under NAIS, are not the source of most food-borne illnesses. These illnesses are from bacteria such as salmonella, E. coli, and campylobacter, or the Norwalk viruses, which contaminate food due to poor practices at slaughterhouses or in food handling.1 The NAIS would do nothing to prevent these problems from occurring. Moreover, because the tracking would end at the time of slaughter, the NAIS would not improve the government’s ability to trace contaminated meats once they leave the slaughterhouse and enter the food chain.
NAIS is also not an effective control for BSE, or “Mad Cow Disease,” even though it affects live animals. BSE is believed to be caused by feeding infected animal material to cattle. So the key to addressing it is prevention through a strong feed ban. The second key to addressing Mad Cow disease is testing all or a significant percentage of the animals that enter the food supply, as is done in Japan and Europe. The USDA currently tests only about one out of every thousand slaughtered cattle,2 and has opposed increased testing, whether government or private.
Although Congress has devoted more than $100 million in appropriations towards the program since 2004, Congress has never mandated NAIS, nor even mentioned NAIS in authorizing legislation. NAIS would impact millions of animal owners, including people raising food for themselves, hobby farmers, recreational horse owners, and those who own livestock as pets. Congress needs to hold hearings with a full and open debate on the validity of NAIS, not implement it via the back
The concept of tracking every movement of every livestock animal in massive databases may sound impressive, but it is not founded in sound science, economics, or practicality. USDA has not provided any studies showing why 48-hour traceback is “optimal” nor why 100 percent of animals must be included. The susceptibility of animals to disease and the likelihood of transmission differ greatly depending on the species of animal, the exact disease, and the conditions under which the animals are kept. Therefore, it is obvious that a “one size fits all” solution cannot be based on science. USDA as yet has failed to complete a cost-benefit analysis, despite four years of implementing the program. Moreover, the experience of Australia, the only other country to implement mandatory electronic tracking of cattle so far, indicates that the databases are unwieldy and unworkable. The GAO’s 2005 report on agroterrorism and livestock disease made it clear that parts of the U.S. animal health system needed improvement, but did not identify a need for increased tracking of live animals.5
NAIS and the School Lunch Program
In July, the Weston A. Price Foundation and the Farm-to-Consumer Legal Defense Fund joined 80 other organizations in sending a letter to the House and Senate Appropriations Committees opposing the linking of NAIS to the School Lunch Program. The text of the letter is reprinted below. Make a copy of the letter to send directly to your Congressman and state legislator, together with your personal letter asking them to oppose the NAIS and support local farmers!
“We, the undersigned organizations, urge you to remove the provision from the House Agriculture Appropriations bill that requires USDA to purchase for the School Lunch Program meat products that are derived from farms (premises) registered with the National Animal Identification System (NAIS). This provision undermines the School Lunch Program and promotes a flawed policy.
“The subcommittee provided two reasons for including this 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 its 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.4 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-toschool programs help improve children’s nutrition 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.
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.5 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 remove the provision that requires School Lunch Programs to purchase meat products from NAIS-registered premises. Additional background information on why NAIS is a flawed system to address food safety is attached.
We thank you for your consideration.
Signed [82 organizations]
- See Centers for Disease Control and Prevention, http://www.cdc.gov/ncidod/dbmd/diseaseinfo/foodborneinfections_ g.htm#mostcommon. Campylobacter, salmonella, and E. coli are all found in the intestines of animals, so that contamination occurs during the slaughter process. The Norwalk viruses are believed to spread primarily from one infected person to another, through handling of food by infected kitchen workers or fishermen.
- During a period of “heightened” testing in a two year period from 2004 to 2006, the USDA tested fewer than 700,000, or approximately 1% of the cattle slaughtered. See News Release, Statement by USDA Chief Veterinary Officer John Clifford (DVM) Regarding Positive BSE Test Results (Mar. 13, 2006). In contrast, the European Union countries tested more than 8 ½ million cows just in 2003, and tested over 6 million in just the first 9 months of 2004. See U.K. Food Standards Agency, Results of BSE testing in the EU, http://www.food.gov.uk/bse/facts/cattletest. In 2006, the USDA announced that it was reducing testing by 90%.
- United States Government Accountability Office, GAO-05-214, Homeland Security: Much is being done to protect agriculture from a terrorist attack, but important challenges remain (Mar. 2005) (hereinafter “GAO Report on Agriculture”).
- See Doug Gurian Sherman, CAFOs Uncovered: The Untold Costs of Confined Animal Feeding Operations, Union of Concerned Scientists (April 2008).