ISSUES AND POLICY
NCBA Opposes Proposal on Brazilian Imports
FMD undertaken by APHIS in making their decision. While we appreciate the granting of the initial ex-
tension by APHIS, we must request an additional ex- tension to the comment period based upon our failure to receive for review documents through Freedom of Information Act requests to APHIS and FSIS. Based on what information we have been able to
review, NCBA feels that we must actively oppose this proposed rule. NCBA has failed to receive publicly available docu-
By Bob McCan, NCBA president I
N DECEMBER, THE USDA ANIMAL AND PLANT HEALTH IN- spection Service (APHIS) proposed a rule to amend regulations to allow the importation into the U.S.
of fresh, maturated, deboned beef from a region of 14 states in Brazil. For the National Cattlemen’s Beef Association (NCBA)
and our members, this proposed rule raises a serious concern regarding the risk of FMD to our domestic cattle herd. These 14 states that make up the region under con-
sideration are recognized by the World Organization for Animal Health (OIE) to be “Foot-and-Mouth Disease (FMD) Free Zones where Vaccination is Practiced.” As we know, FMD is a contagious, rapidly spreading, and economically devastating disease that can affect any cloven-hoofed species, not just cattle. This proposed rule would affect 84 percent of the
cattle population in Brazil, and APHIS forecasts that annual imports of fresh beef from Brazil would aver- age 40,000 metric tons. To put that in perspective, that would increase U.S. beef imports by less than 1 percent. And under current law, regardless of country-of-origin labeling, all fresh imports must be labeled with their country of origin. While NCBA generally supports free and open trade
based on internationally accepted, scientifi cally sound principles, no trade is worth jeopardizing the health of our domestic cattle herd. Therefore, we needed to look at this from the perspective of Brazil’s ability to mitigate the risk of FMD in the fresh beef they ship to the U.S. and their capability and willingness to con- sistently manage their FMD risk. Since the announcement of the proposed rule,
NCBA has requested an extension to the comment period to request and review all pertinent documents related to the scientifi c inquiry or risk analysis for
tscra.org
ments related to the proposed rule in a timely manner from both APHIS and FSIS under FOIA requests. We did receive information from APHIS concerning the data submitted by the Brazilian Ministry of Agriculture for their export request. Unfortunately, more than 600 pages of these documents were in Portuguese with no available English translations at APHIS. At the time of this writing, we have received only
partial information requested on the proposed rule, so we have fi led our comments to the docket as preliminary comments and requested a 120-day extension to, it is hoped, receive and review the outstanding documents that we have previously requested. NCBA has uncovered problems with the risk analy-
sis for FMD risk from the importation of fresh beef from Brazil into the U.S. NCBA is extremely concerned that the APHIS site visits to Brazil, which are used by APHIS to verify information concerning the animal health status of the region and critical to developing accurate conclusions for the risk assessment, have no apparent requirement for written documentation or reporting. An obvious lack of management controls for the APHIS site visits and the site review process questions quality assurance and threatens to erode the necessary transparency for the entire APHIS risk assessment process. The current APHIS risk assessment needs to reduce
subjectivity and provide a better analysis of the uncer- tainty and effectiveness of the mitigation measures in place for FMD risk. We would suggest that a quantita- tive risk assessment that objectively identifi es the risks would provide a more rigorous analytic process than the current qualitative risk assessment. It is critical that APHIS consider an economic impact
analysis to evaluate the impact of an FMD outbreak in the U.S. for the various “at risk” commodity groups. Additional questions need to be answered and addi- tional work needs to be done by APHIS to secure the necessary information to make responsible decisions concerning the proposed rule.
June 2014 The Cattleman 105
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