The current Washington State Department of Agriculture proposal to force ranchers to put RFID tags in cows and bulls in Washington State is being opposed by Cattle Producers of Washington for the following reasons:
1.The proposal would create an undue burden on cattle producers. The rule would put an undue burden on cattle producers in the state, both in the forms of financial outlay and increased labor demands. The RFID proposal would also put Washington State at a competitive disadvantage compared to other states that are not forcing the use of RFID tags.
In addition, Washington producers would not only have to purchase the reading equipment and computer software to read the tags, but the man hours required to successfully read, record and transmit information are prohibitive for most cattle producers. With many operations running a lean and efficient crew of owner-operators, this regulation would demand time and labor beyond the capacity of most operations.
2.The proposed RFID regulation does not address imported cattle. Cattle imported into Washington are not addressed in the proposed rule. In recent years, disease outbreaks in cattle have not manifested from within Washington State, but have been from imported cattle. The proposed rule does not currently apply to imported cattle but rather is applied to Washington herds that are currently disease free.
3.The proposal would discourage the current practice of using bangs vaccinations and Trichomoniasis testing. The rule would discourage producers from either bangs vaccinating or Trichomoniasis testing their cattle for fear of undue government intrusion and regulation of their business. Bangs vaccination and Trichomoniasis testing are currently an industry standard, but they are not mandated by law and many producers may choose to stop these practices if they are linked to the forced use of an RFID tag. Small producers will be particularly inclined to forgo these practices in order to avoid the government intrusion, thereby weakening Washington’s overall cattle herd health.
4.Security of proprietary information is not assured by the proposal. The proposal currently has no assurance that proprietary ranch information recorded with an RFID tag and transmitted to the state would be secure. The proposal does not list how the information would be safeguarded or who would have access to the information. Expecting ranches to turn over their private business information with no surety of confidentiality or secure storage is unreasonable. In addition, proprietary ranch information should not be used without producer consent to market meat products, as outlined in the proposal.
5.Tag durability and retention is not certain. Data regarding RFID tags to date shows that there is roughly a 20 percent loss of the tags in an average herd of cattle. Additionally, there are no safeguards against fraud, as tags can be easily removed and replaced on any animal. There is also no data to show if tags in mother cows will last as long as the rancher generally retains a mature cow, which could be as long as eight to 10 years.
6.Successive phases of the proposed rule have not been outlined. WSDA has failed to outline what the successive phases of an RFID mandatory tag implementation would be. While outlining only an initial step, it has failed to outline an overall system which would likely include mandatory premises registration and other pending regulations. Failing to outline an entire plan is misleading and may induce ranchers to utilize the first component of the system (tags) without realizing the successive obligations and costs they will incur as new phases of the program are mandated.