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Agricultural News


Cattle Group Has Concerns About Brazil and FMD

Fri, 18 Jun 2010 6:25:33 CDT


The National Cattlemen's Beef Association (NCBA) has submitted comments regarding the U.S. Department of Agriculture Animal and Plant Health Inspection Service's (APHIS) proposed changes to the livestock disease status of Santa Catarina, Brazil. The proposed rule would relieve certain restrictions on the importation into the United States of live swine, swine semen, pork meat, pork products, live ruminants, ruminant semen, ruminant meat and ruminant products from Santa Catarina.

The NCBA says in their comments that "While we recognize and are supportive of the tremendous effort of the federal and state governments, industry and international organizations in South America to control and eradicate FMD, we remain concerned about the lack of ability to completely eradicate FMD in Brazil and the South American continent. We also appreciate APHIS' working to develop regionalization from a concept into a successful reality. NCBA is supportive of regionalization generally but strict and robust adherence to scientific analysis in all aspects (risk to animal health, economic analysis and environmental assessment) must be thoroughly followed. This is all the more important with contagious, difficult to control and economically devastating diseases such as FMD. FMD is considered the single largest animal-health threat for beef producers, and an outbreak in the U.S. would cost domestic beef producers an estimated ten to 34 billion dollars.

"USDA has not performed a risk analysis sufficient to ensure that the health of the U.S. herd would be protected if this rule were to move forward. APHIS has failed to conduct even a minimum semi-qualitative risk analysis-much less a robust quantitative analysis, which NCBA feels is appropriate due to the risk and the severe consequences of an FMD case in the United States. The risk-assessment also fails to include any mention of wildlife-susceptible species in Santa Catarina and its neighboring regions, or the surveillance and biosecurity measures that are in place to mitigate the transmission of FMD from wildlife to livestock species. Additionally APHIS did not adequately evaluate biosecurity measures related to regulatory control as well as at the borders of Santa Catarina, especially in light of potential movement of animals and animals products from areas of higher risk into the state.

"Furthermore, the economic analysis does not analyze the marketing pressures on the export side, or the economic consequences on the import side if this rule resulted in a case of FMD in the U.S. The analysis also gives the false impression that Santa Catarina is incapable of exporting fresh beef to the United States. While this could possibly be the case in 2010, it is inaccurate to assume that this will always be the case.

"Finally, USDA's environmental assessment oddly focuses more on risk and economics than on actual environmental factors. Due to varying state environmental laws and geographical environmental differences, as well as the diversity of the U.S. cattle industry based on location, an environmental assessment is extremely complex. It therefore requires the use of multiple scenarios and modeling. Unfortunately, the published document does not indicate that this was done."

To address these issues, NCBA is requesting that APHIS go back and conduct a robust quantitative risk analysis, thorough economic analysis and an accurate environmental assessment before proceeding on the rule.

 

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