The National Chicken Council submitted comments today to the Animal and Plant Health Inspection Service regarding their proposed rule entitled “Traceability for Livestock Moving Interstate,” published in the Federal Register on August 11, 2011. The comments described the vertically integrated broiler industry and how the industry is clearly different than other animal agriculture sectors.  The comments also outlined the number of birds that are moved from hatcheries to grow-out facilities to slaughter facilities and that a five-year record-retention time was excessive given the sheer number of birds that are produced each year.

The proposed rule indicates that APHIS is “particularly concerned with current inadequacies in disease tracing capabilities in the cattle industry” and that the traceability programs in existing regulations for poultry “are comprehensive…and largely sufficient at this time.”

The letter concludes that “the proposed rule would inappropriately establish a one-size-fits-all records-retention policy not reflective of the broiler chicken industry.”  The comments suggest that a two-year requirement for record retention for broiler chickens transported interstate would minimize the burden on regulated companies while still ensuring a meaningful traceability system.

The letter submitted to APHIS is available here NCC Comments on Docket No APHIS 2009-0091 Traceability of Livestock Moving Interstate.