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R-CALF files supplemental comments on reopening Canadian border
In its ongoing efforts to help protect both United States' and international consumers, as well as the U.S. cattle herd, against the introduction of bovine spongiform encephalopathy (BSE) into the U.S. from Canada, R-CALF USA recently filed supplemental comments to the United States Department of Agriculture (USDA) regarding the agency's proposed rule titled "Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities."
These supplemental comments can be reviewed under the "litigation" and "BSE" links on R-CALF USA's website: www.r-calfusa.com.
USDA's proposed rule, if it becomes final, would allow Canada to begin exporting virtually all beef products, as well as live Canadian cattle under 30 months of age, to the United States. In 2003, two positive cases of BSE were detected in Canadian-born cattle.
R-CALF USA previously submitted comprehensive comments to USDA's Animal and Plant Health Inspection Service (APHIS) on this subject Jan. 5, 2004, and again on April 7, 2004. In both instances, R-CALF USA urged the agency to withdraw its proposed rule because compelling scientific evidence suggested the rule would expose U.S. consumers and international consumers--plus the U.S. cattle industry--to substantially greater and unacceptable risks that BSE would be introduced into the United States.
"R-CALF USA requested APHIS to continue to enforce its longstanding policy of prohibiting the importation of ruminants and ruminant products from any country known to have BSE or that presents an undue risk of introducing BSE into the United States, and we continue to urge APHIS to enforce its prohibition on imports of ruminants and ruminant products from each of the 37 countries listed in the Code of Federal Regulations, which includes Canada and Japan," R-CALF USA wrote in their comments.
The comments state that several new and dramatic developments have transpired during the eight-month period that followed the April 7 closing of the public comment period for the proposed rule. These developments include: new scientific discoveries regarding BSE detection within infected animals; new research on how BSE is spread; new research suggesting the importance of increased testing of Canadian cattle; the decision by the World Organization for Animal Health (OIE) not to give the U.S. a favorable BSE-risk classification; the adoption of more stringent BSE restrictions by the OIE; and, the fact that USDA has not detected a case of BSE in the U.S. cattle herd following its increased BSE testing program.
These developments "reinforce the already compelling need for APHIS to withdraw its proposed rule," the comments said
In R-CALF USA's new 21-page submission (with more than 70 references, including 15 attachments, many of which are recent scientific studies and reports from BSE scientists around the world), R-CALF USA challenges USDA on five basic points:
1. The proposed rule ignores scientifically established international BSE standards.
2. The proposed rule fails to distinguish between what is scientifically known and unknown about BSE.
3. The proposed rule is incongruent and disadvantages U.S. consumers, international consumers, plus the U.S. cattle industry.
4. The proposed rule fails to consider known compliance complications.
5. The proposed rule overturns the United States' historically successful disease protection policy.
"APHIS' proposed rule and USDA's current BSE policy don't take into account the current science regarding BSE," said Bill Bullard, R-CALF USA CEO. "USDA must change its policy because there are gaping holes in its efforts to prematurely reintroduce Canadian beef and cattle imports into the United States, and by side-stepping science, USDA will expose the U.S. cattle industry and consumers to risks they have never before had to face."
R-CALF USA President Leo McDonnell said the reason R-CALF USA submitted its detailed and unsolicited comments to USDA is to provide an opportunity for USDA and the U.S. cattle industry to work together to ensure that adequate BSE protections are maintained as the United States tries to help Canada eradicate BSE within its country.
"We are letting USDA know in a formal way that we want to resolve this important issue through direct communications with the Administration, if we can," McDonnell said. "We are again viewing litigation as a last resort."
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