R-CALF USA officials submit comments opposing importing beef from Namibia
November 19, 2015
Billings, Mont. – This week R-CALF USA submitted comments to the U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) regarding the agency's proposed rule, Eligibility of Namibia to Export Meat Products to the United States.
The comments explain that it is inappropriate to allow beef exports from Namibia and they request the FSIS to withdraw its proposed rule from any further consideration. The group based its request on four major deficiencies identified in the comments.
First, the comments explain that the proposed rule is actually based on non-binding assurances by the Namibian government.
"R-CALF USA is deeply concerned that the FSIS is recommending approval of this Proposed Rule based largely on statements and assurances by the Namibian government that it: 1) "intends" to limit exports to the U.S. to only boneless (not ground) raw beef products, such as primal cuts, chuck, blade, and beef trimmings; 2) "intends" to certify only one Namibian slaughtering plant to export beef to the United States ; and, 3) does not "inten[d]" to export head and cheek meat to the United States.
“R-CALF USA is deeply concerned that the FSIS is recommending approval of this Proposed Rule based largely on statements and assurances by the Namibian government that it: 1) “intends” to limit exports to the U.S. to only boneless (not ground) raw beef products, such as primal cuts, chuck, blade, and beef trimmings; 2) “intends” to certify only one Namibian slaughtering plant to export beef to the United States ; and, 3) does not “inten[d]” to export head and cheek meat to the United States.” R-CALF USA
"Those three significant intentions proffered by the Namibian government to obtain FSIS approval for its exports are not binding limitations on future exports. This fact was clearly acknowledged by FSIS when it stated that Namibia would not be precluded from exporting other meat products in the future under this Proposed Rule."
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Second, the group argues the public is not provided sufficient information to formulate thoughtful comments. Referencing several non-compliance reports mentioned in the FSIS' audit report for a Namibian packing plant, the group states it cannot determine the risks associated with those non-compliance reports because the nature and scope of the reports are not disclosed.
Third, the group asserts the FSIS is ignoring the health and safety risks of exporting meat from the southern region of Africa.
Referencing a 2012 risk analysis conducted by the Namibian Meat Board, the comments state that Rift Valley fever, which is not known to exist in the United States, is endemic in Namibia. Rift Valley fever is a viral disease that can cause fatalities in cattle and humans, and which can be transmitted via meat products.
The comments argue that the FSIS does not explain how it will prevent diseases like Rift Valley fever or Namibia's other endemic foreign animal diseases, foot-and-mouth disease (FMD), from entering the United States. The comments point to evidence showing that a section of the veterinary fence that is supposed to restrict FMD outbreaks to Namibia's northern region has been taken down by authorities to provide elephants and buffaloes more access to range. Further, the comments raise concerns about Namibia's own import practices of importing both cattle and beef from countries not free of FMD.
Finally, the comments criticize FSIS' Economic Impact Analysis calling it woefully inadequate.
"Alarmingly, the agency made no attempt to determine the economic impact caused by the importation of an additional 1.9 million pounds of beef during the first year of the Proposed Rule's finalization or by the additional 12.5 million pounds expected to be imported by the fourth-year following finalization. "
Based on FSIS' estimate of the amount of Namibian beef that would be exported to the United States, R-CALF USA estimated the negative impact to the U.S. economy would be $14.9 million the first year and $96 million by the fourth year after the rule's implementation.
"It should be no surprise to FSIS that increasing the supply of beef imports, however small, will have a profound impact on U.S. cattle farmers and ranchers given the farm level elasticity of demand for fed cattle. Researchers have found that a 1 percent increase in fed cattle supplies is expected to reduce fed cattle prices by as much as 2.5 percent. Thus, increased imports of live cattle (and by extension beef) will significantly depress domestic cattle prices and harm U.S. cattle farmers and ranchers."