N.D. cattle group opposes Brazil fresh beef proposal, talks FMD risk in Argentina
May 2, 2014
Last week, the North Dakota Stockmen's Association (NDSA) issued comments in opposition to a proposed rule that would allow the importation of fresh, maturated, deboned beef from a 14-state region in Brazil into the United States. Citing the recurrent history of the highly contagious and economically devastating foot-and-mouth disease (FMD) in the surrounding region, NDSA President Jason Zahn, a Towner, N.D., cow-calf producer, told the U.S. Department of Agriculture (USDA), "The risk to the U.S. beef industry and other agricultural sectors is much too great and the consequences much too significant to move forward with the proposed rule."
Generally, the NDSA supports free and open trade based on internationally accepted, scientifically sound principles, "but no trade is worth jeopardizing the health of the domestic herd," Zahn explained. "After reviewing the proposed rule and supporting documents, we are not convinced that Brazil has the resources, infrastructure or will to consistently perform adequate risk management steps in order to mitigate the risk of FMD entering the United States through the importation of its fresh beef," he said.
Zahn pointed out deficiencies in USDA's risk analysis for FMD risk, including the inconsistency of and lack of transparency in the Animal and Plant Health Inspection Service's (APHIS) site visits to Brazil, as well as the country's repeated compliance shortcomings noted in Food Safety Inspection Service audits, ranging from lack of government oversight and inspector conflict-of-interest issues to residue compliance problems and laboratory operation shortcomings.
Brazil has also had a poor track record when it comes to prompt disease reporting, Zahn said. This was evidenced following the death of a BSE-infected animal in Brazil in December 2010. Initial testing of the animal was done in early 2011, yet confirmation of BSE in that animal was not reported to the World Organization for Animal Health, or OIE, until July 2012. When Brazil was reprimanded for the 18-month delay, it cited "laboratory overload" as the reason. "What assurances do we have that the 'overload' problem has been rectified, and that the country would be able to identify and report a case of FMD in a timely fashion?" Zahn asked.
He pointed out a series of Brazilian FMD risk factors, such as the country bordering at-risk neighboring countries; its history of FMD outbreaks, even under systematic vaccination; and the possibilities of illegal movement of animals into the export area. "By APHIS' own admission, international border crossings in Brazil are not always manned by both countries, and not all crossings are visited," Zahn said. "If the proposed rule would be adopted, it would be reasonable to expect that there would be higher prices offered in the export region and that that could very well increase the number of illegal animal movements there."
In a separate USDA-APHIS proposed rule regarding the status of FMD and rinderpest risk in the Patagonia region of Argentina, the NDSA told federal officials that it shared concerns about the weaknesses identified in APHIS' risk analysis regarding FMD risk through the importation of suspectible species and products from Patagonia.
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Zahn pointed to Argentina's record of diminishing compliance with the regulatory requirements of the Federal Meat, Poultry Products and Egg Products Inspection Acts, as attested to in USDA's Food Safety Inspection Service audits, which "raises the NDSA's level of concern over the country's ability to successfully and consistently employ mitigation strategies to prevent FMD introduction into this country."
He also acknowledged audit findings of Argentina's FMD and related certification procedures for bovine and ovine fresh meat intended for export identified by the European Commission's Food and Veterinary Office, which identified points of concern related to border controls, animal identification and registration, vaccination controls, FMD surveillance measures and wildlife management plans.
"The best line of defense against the introduction of FMD is to have adequate import controls and quarantine measures for live animals in place and to properly assess the hazards associated with the importation of products from FMD-affected areas," Zahn concluded. "We're not confident that those defenses are in place and, thus, have significant concerns about the risk that importation from regions in close proximity to FMD-affected areas could pose here."
–N.D. Stockmen's Association