Reply Letter to Mr. Strong

United States Department of Agriculture
National Agricultural Statistics Service

July 1, 2021
Zack Strong
Senior Staff Attorney
Animal Welfare Institute
Dear Mr. Strong:
Thank you for your recent letter concerning the renewal of the annual mink survey. The primary functions of the
National Agricultural Statistics Services (NASS) are to prepare and issue State and national estimates of crop and
livestock production, disposition, and prices and to collect information on related environmental and economic
factors, whole farm characteristics, and operator demographics. Timely, reliable, and detailed statistics help
maintain a stable economic atmosphere and reduce risk for production, marketing, and distribution operations.
NASS is the primary data collection agency of the US Department of Agriculture. NASS is one of only thirteen
Federal agencies whose primary mission is statistical in nature. Our data is protected under the Confidential
Information Protection and Statistical Efficiency Act (CIPSEA). The data we collect from farm and ranch
operators is kept confidential and is only released to the public as summarized data. Rest assured that NASS will
not disclose any Personally Identifiable Information (PII) data.
NASS is a statistical agency, not a regulatory agency, and therefore, data collected by NASS are used for
statistical purposes only. Under the Paperwork Reduction Act (PRA), all Federal agencies are required to
minimize respondent burden on the public by limiting the amount of data collected and the frequency of the data
collections.
The content of the annual mink survey has been developed over the years based on wants and needs of producers
and data users. Below are responses to each of your requests.
Request 1: To the extent not already collected, the full contact information for all of the mink farm’s owners and
operators.
Reply: NASS currently collects full contact information for all the mink farm operations. However, as described
above, NASS does not share PII information.
Request 2: The address of each place of business at which the mink farm conducted business.
Reply: NASS currently collects the address of each mink operation. However, as described above, NASS does
not share PII information.
Request 3: The legal descriptions of any lands upon which the mink farm conducted business.
Reply: This request denied. The scope of the survey as approved from OMB does not account for this
information.
Request 4: All trade names under which the mink farm conducted business.
Reply: This recommendation is denied. NASS does not share any PII information.

United States Department of Agriculture • Washington, DC 20250
USDA is an equal opportunity provider, employer and lender.

United States Department of Agriculture
National Agricultural Statistics Service

Request 5: The number of individuals who worked on the farm.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 6: The number and sex of individual mink raised.
Reply: NASS currently collects the number of female minks. However, the scope of the survey as approved from
OMB does not account for the number of male mink raised information.
Request 7: The source of each individual mink and a detailed description of how the animals were transported,
and the route taken, if applicable.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 8: The number of individual mink purchased, transferred, or sold and the name of each person or entity
to whom or from whom such animals were purchased, transferred, or sold.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 9: A description of the size, number, and type of the mink farm’s pens, cages, or other such enclosures.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 10: A description of the barrier(s) that were used to contain the mink on the farm and prevent other
animals from gaining access to the farm.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 11: A description of the procedures the mink farm used to dispose of manure, and carcasses and any
parts thereof, to ensure the health and safety of farm workers, the public, and the captive and wild animals.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 12: The number of mink that died or were killed, the cause of death, and, if killed by humans, the reason
each was killed and the method used.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Recommendation 13: A description of the measures the mink farm adhered to in compliance with the current
American Veterinary Medical Association guidelines relevant to fur farm operations, including euthanasia and
depopulation.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.

United States Department of Agriculture • Washington, DC 20250
USDA is an equal opportunity provider, employer and lender.

United States Department of Agriculture
National Agricultural Statistics Service

Request 14: A description of the measures the mink farm adhered to in compliance with the latest guidelines and
recommendations developed by the USDA, the CDC, and any other federal agencies, in order to prevent the
transmission of COVID-19 or other diseases to mink or other captive furbearing animals or to wildlife, fur farm
workers, and the public.
Reply: This recommendation is denied. The scope of the survey as approved from OMB does not account for this
information.
Request 15: NASS Must collect data about all fur farms:
a) fox, rabbit, mink, chinchilla, marten, fisher, muskrat, karakul and all other fur-bearing animals, raised in
captivity for breeding or other useful purposes shall be deemed domestic animals;
(b) such animals and the products thereof shall be deemed agricultural products; and
(c) the breeding, raising, producing, or marketing of such animals or their products by the producer shall be
deemed an agricultural pursuit.
Reply: This request was denied as due to the PRA and industry recommended to collect only mink fur
information to reduce respondent burden. Scope and resources will not allow this request to be granted.
Request 16: NASS must disseminate data about all fur farms to the public.
Reply: NASS currently publishes data collected from the survey at an aggregate level, following CIPSEA policy.
The annual mink survey is extremely important to our data users. Your comments will be provided as part of the
submission to the Office of Management and Budget.
Please let us know if you have any questions or concerns.
Again, many thanks!
Digitally signed by Travis Averill
Date: 2021.07.01 09:40:44 -05'00'

Travis Averill
Chief, Livestock Branch
U. S. Department of Agriculture
National Agricultural Statistics Service

United States Department of Agriculture • Washington, DC 20250
USDA is an equal opportunity provider, employer and lender.