Experts say vaccine's benefits outweigh potential risk By RAQUEL RUTLEDGE Milwaukee Journal-Sentinel, November 12, 2007 Straight to the Source
A record 130 million Americans are expected to get a flu shot this season in hopes of ducking the nasty virus, but as the needle pierces the skin more than 80% will also get what some say is a hefty and dangerous dose of mercury.
The U.S. Centers for Disease Control and Prevention recommends that almost everyone - including pregnant women - get the injection, despite written warnings from the vaccine manufacturers.
Citing an estimated 36,000 deaths a year from the flu and flu-related illness, the mainstream medical community, including the American Academy of Pediatrics and American Lung Association, says the benefits far exceed any risk from the shot.
In a typical year between 5% and 10% of the population will get the flu virus, resulting in roughly 200,000 hospitalizations, according to the CDC. The flu can be especially dangerous for very young children and people 65 and older. Elderly people account for about 90% of all flu-related deaths.
Simply stated: The flu shot saves lives, the CDC says.
Yet a growing number of doctors, scientists and citizen organizations, such as Safe Minds, the Coalition for Mercury-Free Drugs and Moms Against Mercury, say mercury in flu shots has not been proven to be safe and can be linked to neurological disorders and other serious problems. They push for mercury-free shots that are available in limited quantities but that few know about.
"Mercury causes tremendous damage to the brain," said Paul King, scientific adviser for the Coalition for Mercury-Free Drugs.
Mercury is among the most toxic heavy metals and is known to poison the central nervous system, liver, gastrointestinal tract and other systems in the body.
About 80% of all flu shots distributed in the United States contain a mercury-based preservative called thimerosal. Thimerosal consists of 49.6% ethyl mercury, an anti-bacterial, anti-fungal that allows manufacturers to sell the vaccine in large, multi-dose containers without fear of contamination.
You will notice that in the National and Local sections of Arkangel I have included information about environmental organisations (Greenpeace, Friends of the Earth etc.) as well as the more usual animal rights/protection ones. I feel this is very important as, although these environmental groups do not operate from a strictly "animal rights" standpoint, their work has a very important part to play in the achievement of animal liberation.
Too often animal rights campaigners, heavily involved in their constant battle against vivisection, factory farming, the fur trade etc, ignore the extent to which animals are persecuted by the destruction of the environment. Vivisection labs and factory farms may well be the concentration camps of the human Reich, but they are, in a sense, only the tip of the iceberg of animal persecution and getting rid of them would only go part of the way to giving the animals back their freedom. More animal suffering and oppression probably arises from environmental destruction than from any other single cause.
It would do well for us to speak of human imperialism. Not content with just having its fair share of the planet, the human species has everywhere invaded and despoiled territories which rightfully belong to other creatures. Perhaps the worst words ever spoken (if, indeed, they were) were "Go forth and multiply". A call for a human occupation of the world similar to that of the Nazis for "Lebensraum". Thus the end of vivisection labs, of factory farms, will never be enough because it still leaves behind the injustice and oppression of the original "enemy" occupation. True animal liberation will not come merely through the destruction of the Dachaus and Buchenwalds that the occupiers have built for their victims, but demands nothing less than the driving back of the human species to pre-invasion boundaries.
So, in practical terms, what does this mean? It means the end of environmental pollution and the industrial society which causes it. The end of such things as the private car. The end of methods of agriculture relying on pesticides, artificial fertilizers and other poisons. The end of cities and vast urban conurbations, which are like deserts to most wild animal species. The end of large-scale farming which provides little habitat for them either. And perhaps above all, a drastic cut in the number of the human species. The radical American environmental group Earth First! has estimated that the right level of human population world wide should be about 50 million.Today more than that number live just in Britain.
Thus true animal liberation doesn't just require a tinkering with the worst excesses of human oppression but widespread and radical changes in the very way we live. The only form of human society conducive to the just treatment of other creatures is one which is decentralized with people living in small communities rather than towns or cities, de-industrialized, employing small scale organic (veganic), methods of farming and with a vast reductIon in human numbers (by humane methods of course).
Sadly this may all be too much for many "animal protectionists" who still want their jobs their cars their umpteen kids, their domestic appliances. But half a liberation is no liberation. Animal rights campaigning needs to extend itself to other areas which hitherto it has hardly touched on. To fighting against pollution, industrialization and habitat destruction.
Thus we have to work hand in hand with Green and environmental organisations, not just (as is their motive) to create a better world for "our children and our children's children", but to give freedom, Justice and life itself to other animals and theirs.
i think the idea is very good. Of course, it will take them forever to figure out what is healthy or not, but health foodstores should use this method. The Package May Say Healthy, but This Grocer Begs to Differ
For many grocery shoppers, the feeling is familiar: that slight swell of virtue that comes from dropping a seemingly healthful product into a shopping cart.
But at one New England grocery chain, choosing some of those products may induce guilt instead.
The chain, Hannaford Brothers, developed a system called Guiding Stars that rated the nutritional value of nearly all the food and drinks at its stores from zero to three stars. Of the 27,000 products that were plugged into Hannaford’s formula, 77 percent received no stars, including many, if not most, of the processed foods that advertise themselves as good for you.
These included V8 vegetable juice (too much sodium), Campbell’s Healthy Request Tomato soup (ditto), most Lean Cuisine and Healthy Choice frozen dinners (ditto) and nearly all yogurt with fruit (too much sugar). Whole milk? Too much fat — no stars. Predictably, most fruits and vegetables did earn three stars, as did things like salmon and Post Grape-Nuts cereal.
At a time when more and more products are being marketed as healthy, the fact that so many items seemed to flunk Hannaford’s inspection raises questions about the integrity of the nutrition claims, which are regulated by the Food and Drug Administration — or possibly about whether Hannaford made its standards too prissy or draconian. Either way, the results do seem to confirm the nagging feeling that the benefits promoted by many products have a lot more to do with marketing than nutrition.
Furthermore, the rating system, introduced in September, puts the grocery store in the awkward position of judging the very products it is trying to sell, not to mention the companies that supply the foods. In fact, most of Hannaford’s own store-branded products did not get stars.
Hannaford says it is not trying to be preachy or to issue a yes-or-no checklist, just to offer guidance to shoppers who want it — and if the average consumer’s reliance on the United States Department of Agriculture’s food pyramid system is any yardstick, many do not. Furthermore, the company said, there is a place for no-star foods in every balanced diet.
“We are saying there are no bad foods,” said Caren Epstein, a Hannaford spokeswoman. “This is a good, better and best system.”
Food manufacturers, she said, were apprehensive at first but relaxed when they learned that neither they nor their products would be penalized. “The people who represented salty snacks and cookies understood that they weren’t going to get any stars,” Ms. Epstein said.
Hannaford’s nutritionists acknowledge that their system is more stringent than the guidelines used by the F.D.A. The food agency sets standards that food manufacturers must use when they define a product as, say, low in fat or high in fiber, and companies may use those designations even if the product is loaded with less desirable ingredients. Hannaford’s panelists said their formula was more balanced, taking into account all the positives and negatives.
The store chain, with 158 supermarkets in five states, is believed to be the first grocery retailer to have developed such a comprehensive assessment program, and it is trying to have its food-rating algorithm patented.
Not surprising, the food industry still is not entirely happy, and it disputes Hannaford’s conclusions.
“We don’t like the idea that there are good and bad foods out there, and these sort of arbitrary rating systems,” said John Faulkner, director of brand communication at the Campbell Soup Company. The Healthy Request line of soup, he said, was “aligned with the government definition of what healthy is.”
Similarly, a spokeswoman for ConAgra Foods, Stephanie Childs, said that her company would like to know how Hannaford concluded that many items in its Healthy Choice line did not merit any stars.
“This is surprising to us,” Ms. Childs said. Healthy Choice, which offers a range of items from frozen meals to pasta sauces and deli meats, “has to use F.D.A.’s very stringent requirements for what is healthy.”
Admirers of Guiding Stars say the ratings illustrate how nutrition claims on packages can mislead consumers even if they are technically true. Many packages trumpet the benefits of a few attributes — high fiber, for instance, or no trans fats — while ignoring negatives like too much sodium, they said.
“You look at a General Mills product and it looks like the bee’s knees, but it may be nutritionally flawed,” said Michael F. Jacobson, executive director of the Center for Science in the Public Interest, an advocacy group based in Washington. “It may be high in sugar even though it has fiber in it.”
Many products that are marketed as healthy received zero stars from Hannaford because they contain too much salt or sugar or not enough nutrients, said Lisa A. Sutherland, an assistant professor of pediatrics and a nutrition scientist at Dartmouth Medical School who was part of the advisory panel that developed Hannaford’s formula.
V8, for instance, which says it has “essential antioxidants” and is “vitamin rich,” is “like drinking a vitamin with a lot of salt on it,” she said. Ms. Sutherland said that the F.D.A.’s guidelines for labeling, including its definition of “healthy,” were simply too lenient. Even the low-sodium version of V8 got no stars under the Hannaford system.
The F.D.A., for its part, points to its specific requirements for foods that make health claims as well as their labels. It also acknowledges that its policing abilities go only so far.
“The thing is, a lot of claims we see out there are puffery,” said Joseph R. Baca, director of the office of compliance at the F.D.A.’s Center for Food Safety and Applied Nutrition. “But they don’t get to the point where we can call them fake or misleading.”
Although Hannaford’s star ratings are posted on the same shelf tags that display prices, the chain has not changed the way it shelves products or markets them. This may have kept food manufacturers from rebelling, but it has not stopped them from questioning whether Hannaford is qualified to be the arbiter of healthiness.
“You end up with a lot of consumer confusion,” said Mr. Faulkner of Campbell Soup, which makes V8 as well as Healthy Request. “Do you defer to the Hannaford Brothers? The federal government?”
The label of Campbell’s Healthy Request Tomato soup, for instance, boasts that it is 98 percent fat-free, has zero grams of trans fat, low cholesterol and 30 percent less sodium than Campbell’s standard tomato soup. “I don’t know what their system is,” Mr. Faulkner said, referring to Hannaford. “What are they calling too much salt?”
Hannaford, part of Delhaize America, a division of the Delhaize Group in Brussels, started Guiding Stars after customer surveys indicated that people were confused about the nutritional information available to them. Hannaford formed a seven-member advisory panel of nutritionists and a physician to develop a formula for evaluating the healthiness of food.
That algorithm evaluates a 100-calorie serving of each product using only the information that is available on the “nutrition facts” panel and the ingredients list. A product receives credit for vitamins, minerals, dietary fiber and whole grains, but is docked points for trans fat, saturated fat, cholesterol, added salt and added sugar.
People who choose to adhere closely to the Hannaford ratings will have Spartan diets indeed. Not only did cookies and potato chips rate poorly, but so did whole milk (although skim milk received three stars) and products with nourishing-sounding names like Healthy Choice Old-Fashioned Chicken Noodle Soup.
Indeed, the “three star” lunches and snacks recommended on Hannaford’s Web site probably bear little relation to the meals most Americans are accustomed to eating. Hannaford suggests snacking on grapes, apple slices, raisins, plain yogurt, celery sticks, carrots and one to two ounces of popcorn — presumably without salt. A good lunch would be grilled chicken on a bed of spinach with a multigrain roll and an apple.
A. Elizabeth Sloan, president of Sloan Trends, which tracks the food industry, said that food manufacturers deserve credit for reformulating their products to make them healthier. But she said it was unrealistic for the manufacturers to remove all the fat, sugar and salt because nobody would buy the result.
“They have to keep the taste,” she said. “Look at all those super-duper healthy products that are in those healthy food stores. They don’t taste good.”
She added, “Nothing is healthy if you get right down to it, except mother’s milk, and that’s probably got too much fat.”
It is hard to tell whether Hannaford’s nutrition index has had any impact on what consumers are buying. The chain declined to provide sales data.
At a Hannaford store in New Windsor, N.Y., several customers said they had heard about Guiding Stars in radio advertisements or seen it in the store, but that it had not influenced their purchasing. Several shoppers said they did not see the point.
“I buy whatever it is on my list,” said Karen Wilson, 43. “If my kids want Cheerios, I buy them Cheerios and don’t look at the stars.”
LiseAnne Deoul, 34, said she liked the idea of Guiding Stars even though the system had not helped her narrow her choices during a quick stop last week to buy pasta.
“All of it was the same,” she said. “They all had two stars.”
Hannaford officials and members of the advisory panel emphasized that foods with no stars were not meant to be shunned.
“They are not everyday foods,” said Ms. Sutherland. “They are great sometimes foods.”
Nutritionists and food industry analysts said that Hannaford’s findings highlight some unpleasant truths about Americans and their eating patterns. People want to be healthier but do not want to change their behavior, and so marketers have stepped in with products that improve on the originals but still leave something to be desired.
The poor marks doled out by Hannaford show “what happens when an independent group sets the criteria,” said Marion Nestle, a professor of nutrition at New York University.
“As for health claims, expect to see more and more and more,” she said. “It’s the only thing that sells food these days.”
Americans are known around the world for our voracious appetite for sugary treats. Our collective sweet tooth compels us to ingest mountains of candy and cookies, truckloads of ice cream and sodas, and many other confections.
But we also swallow enormous amounts of “hidden” sugars that are added to a bewildering array of processed foods, from cereals to ketchup and from canned fruits to some vitamins.
Consumption of sweeteners in the U.S. has risen from 113 pounds per person per year in 1966 to around 142 pounds per person per year in 2004, according to the U.S. Department of Agriculture (USDA). Compare that to an average of 8.3 pounds of broccoli and 25 pounds of dark lettuces for 2003, according to U.S. News and World Report. Americans now consume an average of 61 pounds a year of high fructose corn syrup (especially in sodas), and we scarf down 20 teaspoons of added sugar a day (not including lactose or fructose naturally found in milk and fruit).
The USDA recommends adults consume no more than eight or nine teaspoons of sugar for a typical 2,000-calorie diet. Staying within this limit can be much easier said than done, however, considering that some candy bars, 12-ounce sodas and one-cup servings of ice cream contain around nine teaspoons of sugar.
What’s wrong with sugar? In addition to its tooth-rotting properties, Marion Nestle, professor of nutrition and public health at New York University, explains, “Sugar’s empty calories (meaning lack of nutrients) contribute to the big problem with the American diet: too many calories.” Sugar has also been widely linked to increasing risk for type II diabetes. Plus, the sweet stuff has a considerable environmental footprint (see EarthTalk, this issue).
Closely related to sugar is the now ubiquitous high fructose corn syrup, which is prepared by treating cornstarch with acids or enzymes. The sticky, tooth-attacking syrup is often made with genetically engineered corn, and, like sugar, it contains no nutritional value beyond its caloric content. During the past few decades, corn syrup (which tastes sweeter than sugar) has become the sweetener of choice for many food processors, who load it into everything from baked goods to sauces, jellies, drinks and even frozen fruit. In fact, corn syrup recently overtook sugar itself as America’s most popular sweetener.
Corn syrup is a blend of fructose and glucose, while refined sugar is made of the larger molecule sucrose. Recent research suggests that fructose may be handled differently in the body than other sugars. “It appears to behave more like fat with respect to the hormones involved in body weight regulation,” Peter Havel, associate professor of nutrition at the University of California, Davis, told the Washington Post. “Fructose doesn’t stimulate insulin secretion. It doesn’t increase leptin production (a hormone that helps regulate appetite and fat storage) or suppress production of ghrelin (which helps regulate food intake). That suggests that consuming a lot of fructose, like consuming too much fat, could contribute to weight gain.”
Partly because they are also sweeter than sugar pound for pound, a number of artificial sweeteners have been on the U.S. market for years, and are ubiquitous in such foods as diet soda and “sugar-free” candy. Perhaps echoing the sentiment of many environmentalists, Nestle cautions, “I don’t like artificial sweeteners because I do not like artificial anything when it comes to food.” Observers have also questioned whether the widespread adoption of artificial sweeteners has made much of a dent in the ever-growing American waistline.
Less popular than it once was, saccharin (often known as Sweet ‘N Low) has long raised red flags among food safety scientists after it was definitively linked to bladder cancer in male rats. The industry denies those studies have any application to human beings, but the Center for Science in the Public Interest (CSPI) points out, “In some studies, saccharin has caused bladder cancer in mice and in female rats and other cancers in both rats and mice.”
The group also suggests staying clear of the German-made sweetener acesulfame-k, which it says has been linked to cancer and other ailments in lab animals. Safety tests of the chemical, conducted in the 1970s, were of “mediocre quality,” reports CSPI.
The sugar substitute aspartame, known as NutraSweet, Equal and Spoonful, accounts for 75 percent of adverse reactions to food additives reported to the FDA. In recent years, aspartame has been at the center of an Internet firestorm, in which various advocacy websites have linked it to cancer, ADD, autism, Parkinson’s disease and other problems. CSPI cautions, “Most such claims are not supported by studies.” However, the group does point out that a 2005 study found that “even low doses of aspartame increased the incidence of lymphomas and leukemia in female rats and also might have caused occasional brain tumors.”
A relatively new sweetener on the block is British-made Splenda, which was first approved in the U.S. in 1998. Splenda is the trade name of the patented sweetener sucralose, which is marketed solely by Johnson and Johnson subsidiary McNeil Nutritionals.
When it was first introduced, sucralose sparked considerable consumer excitement, because it is extremely low in calories. Sucralose is now appearing in everything from baked goods to sweetener packets, and makes up about 50 percent of the U.S. sugar substitute market, according to the Associated Press.
However, Splenda’s success hasn’t been entirely sweet. Lawsuits have been filed in several states against McNeil Nutritionals on behalf of the sugar industry, which claims the company misrepresents Splenda with its slogan “made from sugar, so it tastes like sugar.” In fact, Splenda is made in a patented, highly industrial process that adds chlorine atoms to sucrose. McNeil countersued, claiming the sugar industry is waging a “malicious smear campaign”—including promotion of the slick Truth About Splenda website—by trying to convince consumers that Splenda is “unhealthy or unsafe” and that they “would be better off consuming refined sugar.”
Jim Murphy, a Sugar Association lawyer, told the Associated Press, “I think one of the concerns is that there really have been no long-term studies that resolve whether or not consumption of Splenda is healthy.” Echoing this concern, natural products retailer Whole Foods moved to ban sucralose from its stores on the basis that there aren’t enough studies to prove that it is safe and the fact that it requires heavy industrial processing.
The good news is a number of more natural alternatives are becoming widely available to help people enjoy their food without risking their health (see “How Sweet It Isn’t,” Eating Right, November/December 2003). Better choices include maple syrup, honey and date sugar, which at least provide some nutrients in the form of vitamins, amino acids, enzymes and minerals, even though their sugar content is very similar to regular sucrose.
Agave nectar absorbs more slowly into the bloodstream than traditional sugar, making it less likely to result in an energy “crash” after consumption. Natural birch sugar, called xylitol, packs fewer calories than cane or beet-based sugar. Some nutrients are also found in Sucanat, a brand name for organically grown, dehydrated cane juice.
BRIAN C. HOWARD is managing editor of E.
Center for Science in the Public Interest 1875 Connecticut Avenue NW Suite 300 Washington, DC 20009 Phone: (202) 332-9110
I have carefully examined the Draft Program Standards (Standards) and Draft Strategic Plan (Plan) issued by the USDA (the Department) on April 25, 2005, in furtherance of the Department's proposed National Animal Identification System (NAI. Many aspects of the Standards and Plan appear to create insurmountable legal, fiscal, and logistical problems. The comments below address five categories of problems:
1. Constitutional infirmities of the proposed program; 2. An enormous economic cost to animal owners, the States, the Department, and, ultimately, to American taxpayers and consumers for a program likely to be ineffectual; 3. Weaknesses in the stated rationales for the program; 4. A lack of consideration of alternative, far cheaper and more easily administered measures which would more effectively protect animal health and food security; and 5. A lack of notice and an opportunity to be heard for medium-scale, small-scale, and home farmers, and for other citizens owning livestock solely for their own use or pleasure, in the Department's process thus far.
1. The Standards and Plan Violate Many Provisions of the Constitution.
First Amendment Violations - Many Christians (as well as persons of other religious beliefs) cannot comply with the Department's proposed program because it violates their First Amendment right to free exercise. For example, the Old Order Amish believe they are prohibited from registering their farms or animals in the proposed program due to, inter alia, Scriptural prohibitions.
The way of life of these devout Christians requires them to use horses for transportation, support themselves by simple methods of dairy farming (most ship milk to cheese producers, since their faith prohibits the use of the technologies required for modern fluid milk production), and raise animals for the family's own food.
The proposed NAIS would place the Amish and other people of faith in an untenable position of violating one or another requirement of their most important beliefs. Further, it is not unlikely that enactment of the NAIS as presently proposed would force the Amish and other devout people to seek migration to another nation. It would greatly injure the status of our country among the community of nations if the Department's actions were to result in the forced migration of such simple, devout, and peaceful people.
Fourth Amendment Violations - The Department proposes surveillance of every property where even a single animal of any livestock species is kept; and to require, at a minimum, the radio-frequency identification tagging of every animal. (Standards, pp. 3-4, 6, 17-18.)
Perhaps the Department had in mind as its model large commercial facilities where thousands, or in many cases tens of thousands, of animals are housed or processed. However, aside from large livestock businesses, there are also tens of millions of individual American citizens who own a pet horse, keep a half-dozen laying hens, or raise one steer, pig, or lamb for their own food.
In these instances, the "premises" that the Department plans to subject to GPS satellite surveillance (Standards, p. 10) and distance radio-frequency reading (Standards, p. 27) are the homes of these tens of millions of citizens. The government is not permitted to use sense-enhancing technologies to invade the privacy of citizens' homes. Kyllo v. United States, 533 U.S. 27 (2001). The sanctity of the home is entitled to privacy protection in circumstances where an industrial complex is not. See Dow Chemical v. United States, 476 U.S. 227, 238 (1986).
Therefore, the Department should abandon its present proposals, insofar as they entail enormously intrusive surveillance against unsuspecting innocent citizens who have done nothing more than to own an animal (a common form of personal property under the American system of law). Fifth and Fourteenth Amendment Violations - The proposed NAIS is the first attempt by the federal government at forced registration in a huge, permanent federal database of individual citizens' real property (the homes and farms where animals are kept) and personal property (the animals themselves). (Standards, pp. 8-13; Plan, pp. 8, 12-13)
Indeed, the only general systems of permanent registration of personal property in the United States are systems administered by the individual states for two items that are highly dangerous if misused: motor vehicles and guns. It is difficult to imagine any acceptable basis for the Department to subject the owner of a chicken to more intrusive surveillance than the owner of a gun.
For example, whereas the owner of a long gun generally can take the gun and go hunting beyond the confines of his or her own property without notifying the government, the Department proposes that the chicken owner, under pain of unspecified "enforcement," must report within 24 hours any instance of a chicken leaving or returning to the registered property. (Standards, pp. 13, 18-19, 21; Plan, p. 17.)
Even more important than the trammeling of basic property rights under the program is the insult to fundamental human rights, which must remain free from government interference.
* See; Lawrence v. Texas, 539 U.S. 558, 565 (2003). * These fundamental human rights include decisions about nutrition and bodily integrity. * See also; Cruzan v. Director, Missouri Dept. of Health, 497 U.S. 261 (1990); * See also; Rochin v. California, 342 U.S. 165 (1952).
Surely it is overreaching for the Department to propose, as it has, the constant surveillance of one's home and animals when the citizen is only attempting to raise food for the household or for a limited local area, and there is no intention of distributing the food on a wider scale.
The foregoing numerous constitutional infirmities are bound to enmesh the Department and state governments in extremely costly litigation for years to come. Therefore, please reconsider the Department's plans to institute a program so at odds with fundamental American values.
2. Practical and Cost Impediments to Enforcement.
As discussed more fully below (see no. 5, Lack of Notice), most owners of a small number of livestock are not even aware of the USDA's proposals at present (see, e.g., "Helping to Head Off A Livestock I.D. Crisis," Lancaster Farming, May 28, 2005, p. A38, discussing difficulties of informing all farmers of the NAIS requirements).
The Department does not plan to issue "alerts" to inform livestock owners of the requirements until April 2007, only eight months prior to the date when it will be mandatory to submit the GPS coordinates of one's home and the RFID of one's animal to the USDA database. The final rule governing mandatory home and animal surveillance will not be published until "fall 2007" (Plan, p. 10), leaving only a couple of months, at best, for notification and compliance before January 2008.
The citizens apt to own small numbers of livestock are rural dwellers who have chosen their way of life partly as a means of escaping excessive corporate and government bureaucracy. These factors suggest the likelihood of a noncompliance problem of heroic proportions.
In addition, the proposals call for an animal owner to report, within 24 hours, any missing animal, any missing tag, the sale of an animal, the death of an animal, the slaughter of an animal, the purchase of an animal, the movement of an animal off the farm or homestead, the movement of an animal onto the farm or homestead. (Standards, pp. 13, 18-19, 21.) The Department plans to demand the following actions by all animal owners according to the stated timeline:
* January 2008: All premises registered with enforcement (regardless of livestock movements). * January 2008: Animal identification required with enforcement. * January 2009: Enforcement for the reporting of animal movements." (Plan, p. 17; emphasis added.)
Moreover, the NAIS will "prohibit any person" from removing an I.D. device, causing the removal of an I.D. device, applying a second I.D. device, altering an I.D. device to change its number, altering an I.D. device to make its number unreadable, selling or providing an unauthorized I.D. device, and "manufacturing, selling, or providing an identification device that so closely resembles an approved device that it is likely to be mistaken for official identification." (Standards, p. 7.)
Thousands of enforcement agents would have to be employed to find the potentially tens of millions of unregistered premises and violations of the animal identification and animal tracking requirements. Indeed, beyond the expense, the specter of these government agents entering onto citizens' property to find possible unregistered homes and animals brings to mind the actions of a frightening police state, not the actions of a government agency whose mission should be to assist rural people, not to hunt them down.
The proposed NAIS makes clear that animal owners will have to pay the costs of registration and surveillance of their homes, farms, and livestock. ("[T]here will be costs to producers, private funding will be required..." (Plan, p. 11) "Producers will identify their animals and provide necessary records to the databases... All groups will need to provide labor..." (Plan, p. 14.) In fact, the financial and labor requirements for animal owners would be huge. Livestock owners, even the owner of one pet horse who takes rides off the property, would have to invest in RFID reading devices and software to report information. The Standards and Plan do not enlighten us about the amount of these costs.
Many rural people do not have (and do not want) computers at home and even those who have them often cannot get high-speed connections. Even if some system of written or manual reporting were allowed as an alternative, this would only greatly increase the labor required for citizens who elected it. Indeed, with or without access to technology, the labor requirement would be huge.
Consider a small-to-moderate size dairy, milking 160 head. A total of about 150 cattle (75 bull calves, 50 cull cows, and 25 excess heifers) would leave such a farm each year. The farmer would be required to report each tagging of an animal and each event of an animal shipped off the farm (300 reportable events).
Plus let's assume that the farmer has 50 growing heifers outside during pasture season, and, as heifers are prone to do, they breach the fence and go off into the neighbor's fields twice during the season, and the farmer has to herd them back. This results in an additional 250 reportable events - 50 instances of heifers having to be tagged (strictly speaking, the rules would require tagging before they leave the farm -- (Plan, p. 8) -- one hopes the enforcement agents might overlook the technical violation of the farmer perhaps not being able to tag them until they are herded back), plus 100 instances of individual heifers leaving the farm, and 100 instances of individual heifers returning to the farm.
The farmer now has at least 550 total reportable events, or an average of over 1.5 times per day, 365 days per year, that the farmer must interrupt his or her other work and submit data on premises identification, animal identification, and an event code to the USDA's database. Further, the animals shipped from this farm would generate at least an additional 600 reportable events per year for other stakeholders (i.e., 75 bull calves into and out of the auction house, then onto a veal farm, off the veal farm, and to a slaughter facility (375 events); 50 cull cows into and out of the auction house, then to a slaughter facility (150 events); and 25 heifers into and out of the auction house, then onto new farms (75 events).
Thus, only one modest-sized farm would generate well over a thousand events per year requiring recordkeeping and reporting.
Indeed, the only economic advantage of the NAIS is an advantage to the corporations that manufacture high-tech tags, ID equipment, and the vast amount of hardware and software required for the system. This "advantage" is totally outweighed by the economic costs to both large and small segments of the livestock industry and the social and civil-rights costs to small producers, home farmers, and non-farming animal owners. The Department's mission should be to protect and foster agriculture, not to protect and foster manufacturers of tagging and computing equipment.
3. Infirmities in Supposed Justifications.
The primary justifications given by the Department for the NAIS are animal health issues, specifically, foot-and-mouth disease (FMD) and bovine spongiform encephalopathy (BSE). (Plan, p. 1.)
There has been no FMD in the United States for over 70 years and the possibility of its reintroduction is speculative. Of course, FMD is a viral disease exclusively of cloven-hoofed animals and does not infect humans. Moreover, FMD is primarily an economic disease. Animals may become temporarily lame or refuse to eat because of the lesions caused by the virus, but nearly all animals recover within a few weeks.
Thus, the primary effects are a setback in weight gain for animals produced for meat, reduced lactation in dairy animals, and restrictions on exports for countries where FMD is present. NAIS proponents need to carefully consider whether a disease, of no risk to humans, not present in the United States and only of temporary effect to animals, can possibly justify a gravely flawed system such as the proposed NAIS.
There have been only two known cases of BSE in the United States. There have been no cases of humans contracting, while within the United States, the related condition of variant Creutzfeldt-Jakob disease. The Department has put into place all necessary safeguards and assures that the American beef supply is safe and that transmission of BSE prions to humans cannot now occur in the United States. After the banning of meat and bone meal from ruminant feeds in 1997, any possible instances of BSE would now occur only in relatively old cattle.
Obviously, the number of such cattle diminishes yearly and even assuming the longest potential lifespan of cattle; any slight possibility of BSE in the U.S. cattle herd will disappear in about 12 to 15 years. Thus, BSE is a very low-incidence, self-limiting, rapidly disappearing disease in the United States. BSE has not resulted in transmission of a single case of human disease in the United States. BSE is, rather than a health threat, primarily an economic problem affecting exports and imports of cattle and beef. It is apparent that the Department's position that sufficient controls are in place is correct. Thus, as with FMD, BSE cannot justify the creation of a huge, permanent, expensive, and intrusive NAIS.
A further asserted justification is the risk of "an intentional introduction of an animal disease." (Plan, p. 7.) Far from preventing deliberate interference with the livestock industry or food supply, the proposed plan creates numerous new opportunities for mayhem. The Department's own proposals suggest that the counterfeiting and theft of tags will quickly become a problem. (Standards, p. 7.)
Application of counterfeit tags could easily mask the introduction of a sick animal into a facility containing thousands or tens of thousands of other animals. Consider also the scenario in which someone brings a sick animal to a slaughter facility and falsely reports its farm of origin as a large operation with tens of thousands of animals in production. The resulting baseless scare has the potential to create a huge disruption of food supplies and the profitability of animal agriculture, regardless of whether the hoax might ultimately be discovered.
4. Lack of Consideration of Alternate Methods.
As discussed above, the NAIS is a violation of civil rights, extremely expensive and burdensome, likely to be ineffective, and not justified by human health, animal health, or food safety considerations. Given these numerous and probably insurmountable flaws, the Department should carefully consider alternative methods that would be much more successful in accomplishing the stated objectives.
The security of America's food supply and the resilience of livestock in the face of diseases are best served by the decentralization and dispersal of food production and processing, and of the breeding and maintaining of livestock. If more citizens could depend on food raised and processed within, say, 100 miles of their homes, the danger of large-scale disruptions would be minimized, the costs of transport would be less affected by volatile fuel prices, and any food-borne diseases that might occur would be contained by the natural geographic limits of the system.
Similarly, if animals, such as cattle, for example, are kept in small herds of, say, ten to a hundred animals, infectious diseases will have much more difficulty in spreading beyond a discrete geographical area. In this regard, the NAIS would actually be counterproductive, since it would tend to drive more small producers and small processors out of business. Thus, the Department should consider an approach and programs to support and promote smaller, local herds and local food processing.
Smaller herds would also entail the possibility of many more closed herds than our agricultural model supports at present. Especially in dairy operations, where artificial insemination is the norm, only modest government incentives would be necessary to encourage small and medium sized producers to maintain closed herds. In the case of beef cattle, and of other species not commonly using AI, a state-level program requiring vet checks and recordkeeping for new animals introduced to herds would be obviously far simpler, as well as more effective, than the proposed NAIS. Another contribution the Department could make to food safety and animal health at low cost would be the encouragement of integrated producer/processor operations. Despite economic and marketing forces that are stacked against them, many small producers throughout the United States still process and market their own dairy products, or raise meat that is processed on site or at small local slaughterhouses and distributed directly to consumers or to local retail outlets.
Consumers love not only the high quality of such products, but also the assurance that comes from actually knowing the farmers who, for example, finish their steers on grass and have the butchering done at a local small business. Very modest programs of financial incentives and encouragements to the streamlining of federal and state permitting procedures would help this hopeful segment of our nation's agriculture to flourish.
Many recent developments in the agricultural sciences have demonstrated time and again that the least-cost and least intrusive method is the most effective and protective of health. For example, leading-edge research now rejects the routine deworming of all cattle and sheep, in favor of eliminating parasite-susceptible individuals as breeding stock. The once-heralded approach of routine deworming, it turns out, only resulted in resistant super-parasites and perpetuation in the gene pool of animal families naturally subject to the largest infestations.
Similarly, in recent years our thinking has done an about-face on the subject of routine use of antibiotics in the feed of beef steers and dairy heifers, and in udder infusions for dry dairy cows who exhibit no clinical mastitis. Once heralded as a means of increasing weight gain and providing extra insurance against fresh-cow mastitis, those routine uses of antibiotics in healthy animals are now rejected because they are known to produce resistant super-bacteria that may cause not only animal infections, but human infections.
Unfortunately, it takes years for knowledge gained in the latest research to reach the farmer, and the inappropriate overuse of anthelmintics and antibiotics is still very common. Thus, another low-cost and simple initiative the Department could undertake would be an intensive educational initiative to end the inappropriate use of drugs in animal agriculture.
The foregoing are just a few of the many possible more effective animal-health and food-safety initiatives to which the Department could devote its finite resources. It is appropriate for the Department to study fully these alternatives before concluding that a bloated NAIS bureaucracy is our only alternative.
5. Lack of Notice and an Opportunity to be Heard for Small Farmers and Animal Owners.
The original impetus for a nationwide animal I.D. program came from a private membership group, the National Institute for Animal Agriculture (NIAA). (Plan, pp. 1, 4.) The members of the NIAA include such well-known industry entities as Cargill Meat Solutions, Monsanto Company, Schering-Plough, and the National Pork Producers Council.
Further, of those NIAA members listed as "National Associations and Commercial Organizations," nearly 25% appear to be manufacturers and marketers of identification technology systems. In April 2002, the NIAA "initiated meetings that led to the development of" the NAIS. (Plan, p. 1.) The NIAA "established a task force to provide leadership in creating an animal identification plan." (Plan, p. 4.) The NIAA already had been promoting animal I.D. for months before the Department, through APHIS, became involved in the effort. Moreover, the Department says that "[t]he development of [the Draft Program Standards] was facilitated by significant industry feedback." (Standards, p. 1.) Essentially, a private group has dominated animal I.D. thinking and has dictated the NAIS plan now being proposed by the Department.
Moreover, the Department asserts a "broad support for NAIS" (Plan, p. 1) when there is no such support. The Department says that it conducted "listening sessions" for six months (June-November 2004) on NAIS. However, only 60 comments were apparently made during these six months of sessions. If the Department had made a truly widespread attempt to determine citizens' views on animal I.D., surely it would have received far more than 60 comments on an issue that affects tens of millions of Americans.
The Department relies upon the NIAA's survey of itself as supposed evidence of public support. (Plan, p. 7.) The Department quotes responses from the survey and cites the National Institute for Animal Agriculture as its source. However, when one visits that page, one finds a statement by the NIAA that the survey is not scientific, that the survey's results are intended for use by NIAA members only, and that any reproduction of the survey is prohibited.
Thus, the Department is presenting as "evidence" a private, unscientific report that the public is forbidden to quote in opposition. To correct this gross violation of normal agency procedure, the Department must immediately publish this entire NIAA survey in the docket and issue a press release specifying that the public is permitted to use the survey freely in studying the relationship of the NIAA to the genesis of the NAIS. This is not only a spurious example of "public support" but also an affirmatively misleading rationale for a mandatory NAIS. It tells us nothing about truly public support to say that the NIAA, an organization of the largest livestock businesses and manufacturers of identification equipment, considers mandatory I.D. to be good for its own private interests.
One further troubling instance of the failure to consider the needs of the larger public deserves mention. The NIAA lists as public institutional members some state departments of agriculture and animal health commissions. These include representatives of several states with significant populations of members of plain faiths, e.g., Pennsylvania, New York, Ohio, Indiana, Michigan, Wisconsin, Missouri, Iowa. Yet it appears no consideration whatsoever was given to the fact that the NAIS as proposed would violate the right of these citizens to practice their religion without government hindrance.
Thus, the NAIS is not the result of any true consensus or concern for the welfare of the citizenry as a whole. Rather, the NAIS is the predictable result of allowing a small coterie of financially interested "stakeholders" to create the agenda for animal identification.
NAIS Information RFID Information National Animal ID Run Amok Group Fears RFID Chips USDA Launches National Animal ID Site Tracking School Kids Animal Identification Directory National Animal ID Run Amok Roll Out Official NAIS ID Numbers RFID Protects Elk Herds Why You Should Oppose NAIS NH: Approves 'Tracking Device' Agriculture unveils draft for animal ID system Fingerprint Check Coming The National Animal Identification System (NAI RFID And The Apocalypse USDA Awards $14.3 Million Satan's Micro Minions Comment Period for Animal ID Extended Raise an Alarm USDA Unveils Multi-Year Draft Strategic Plan TX: Premises & Animal Identification What Now? NAIS Discussion Sign The Petition
The NAIS proposals as embodied in the Standards and Plan are unworkable because of economic costs, the huge burdens of reporting, and enormous and needless complexity. Their justifications based on animal diseases and food safety would not be served but in fact would be harmed by the NAIS. The Department has failed to consider numerous alternative methods that might actually further animal health and food security without the vast problems of the proposed NAIS. The Department has limited any input on the NAIS chiefly to a small group of parties with a preexisting bias toward mandatory animal ID; the Department did not make its plans known to small farming interest groups and did not seek any input from such groups. Last, and first, the most fatal flaw of the proposed NAIS is its disregard for fundamental human rights enshrined in our Constitution: the right to religious freedom, the right of property ownership, the right of privacy.
Not since Prohibition has any government agency attempted to enshrine in law a system, which so thoroughly stigmatizes and burdens common, everyday behavior and is so certain to meet with huge resistance from the citizens it unjustly targets.
Therefore, the Department should:
1. withdraw the present Standards and Plan as failing to embody a fair or workable system; 2. reconsider whether, particularly in light of the present effective measures against BSE, any animal I.D. scheme is warranted at present; 3. consider implementing the low cost and easily undertaken measures that would more effectively protect animal health, human health, and the food supply; 4. review its procedures for development of programs such as NAIS to correct the limitation of input to self-selected groups and the failure to notify the vast majority of affected parties; and 5. institute procedures to assure that, in the future, proposed programs will not be permitted to threaten the constitutional rights of citizens.
Very truly yours,
Mary Zanoni, Ph.D. (Cornell), J.D. (Yale), Executive Director of Farm for Life™ Reliable Answers: News and Commentary
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