R-CALF USA opposes disease zoning proposal
July 21, 2014
In comments filed July 14, R-CALF USA urged the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) to abandon its plan to establish yet another international bureaucracy, this one to implement APHIS' proposed Draft Framework for Implementing the United States-Canada Foreign Animal Disease Zoning Arrangement (Zoning Arrangement).
The Zoning Arrangement entails the establishment of a new U.S.-Canadian governance structure that would essentially encourage each country to recognize and respect the others' zoning plans implemented after a foreign animal disease outbreak. The zoning plans would allow each country to declare certain zones free of disease while the country works to control and eradicate diseases in its affected zones
"This proposal is but another of APHIS' ongoing efforts to systematically dismantle essential import restrictions that protect the United States from the introduction and spread of dangerous foreign animal diseases," said R-CALF USA Bill Bullard.
Under APHIS' proposal, decisions to allow the importation of livestock and livestock products from designated zones within Canada while Canada is combating one or more foreign animal diseases in other zones would be made by APHIS' chief veterinary officer, and the decision would not be subject to the public rulemaking process.
The group wrote that it interprets APHIS' proposal to mean that "if an outbreak of foot-and-mouth disease (FMD) were detected in one of Canada's eastern provinces and Canada declared its western provinces to be disease free zones, then APHIS' CVO (Chief Veterinary Officer) could unilaterally decide to continue allowing the importation of cloven-hoofed livestock from Canada's western provinces without first conducting a public notice and comment rulemaking."
The group listed several reasons why APHIS' proposal was "wrongheaded" including:
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APHIS should not be allowed to relax import controls that would increase the risk of disease introduction without first going through a public notice and comment rulemaking process.
The Agriculture Secretary should not authorize the Chief Veterinary Officer to make trade-related decisions without the Secretary's ultimate approval.
APHIS has a poor track record for balancing the competing interests of international trade and domestic livestock and food safety and it is only by sheer luck that APHIS has not facilitated the introduction of foot-and-mouth disease (FMD) into the United States.
APHIS has demonstrated dismal performance in its handling of the ongoing porcine epidemic diarrhea virus (PEDv) and porcine deltacoronavirus (PDCoV) outbreaks that have affected over 30 states, killed an estimated 8 million pigs, and is reportedly causing consumer pork prices to rise.
"APHIS should immediately abandon its misguided United States-Canada Foreign Animal Disease Zoning Arrangement. Instead, APHIS should redirect its limited recourses internally to improve its disease prevention, identification, and control capacity here in the United States. APHIS should also direct its limited resources to bolster its vigilance over imported products and animals that may harbor foreign animal diseases that APHIS is presently ill-equipped to handle should they arrive on U.S. soil," concluded the group's comments.