U.S. Cattlemen’s Association Comments on USDA’s Proposed Rule Regionalizing Brazil

USCA (June 18, 2010) - The U.S. Cattlemen’s Association (USCA) agrees with the U.S. Department of Agriculture (USDA) that liberalizing foot and mouth disease (FMD) standards and product allowances from certain regions in Brazil would increase the risk of importing FMD into the United States, and therefore, USCA believes the rule should be abandoned. Accordingly, on June 15 the U.S. Cattlemen’s Association (USCA) filed comments requesting that USDA abandon the proposed rule to amend regulations governing the importation of specific animals and animal products by adding the Brazilian State of Santa Catarina to the list of regions recognized as free of FMD, rinderpest, African swine fever and classical swine fever.

USCA’s comments focused on animal health issues impacting the U.S. cattle industry, specifically the FMD component of the proposed regulation.

"The implications of this proposed regulation can be better understood by examining current events taking place right now in Japan," noted Jon Wooster, USCA President, San Lucas, California. "A FMD outbreak in Japan that began in April of this year has resulted in more than 150 cases of the disease and the loss of 200,000 head of livestock. While the source of the outbreak is still being investigated, it is believed to have entered Japan through either Hong Kong or Korea. Japan is a well-developed nation, with sophisticated biosecurity measures in place, yet these systems were overwhelmed. This should be of great concern to nations like the United States."

Japan is not alone in recurring FMD outbreaks. South Korea confirmed new cases of FMD earlier this year, and the United Kingdom did so in 2007. USCA believes there is a real concern that if such "developed countries" cannot effectively control and eliminate the disease then it is not reasonable to expect a third world country like Brazil to be able to contain the disease to certain regions.

In its formal comments, USCA raised concerns with the USDA-APHIS risk assessment, saying that it is important to note the issues that developed nations like Japan and South Korea are experiencing with FMD outbreaks. While Brazil claims developing country status at the World Trade Organization (WTO) level, throughout WTO negotiations Brazil continues to maintain that it lacks the infrastructure and financial stability to compete in a global trade market with developed countries like Japan, the European Union and the United States.

"USCA believes it is important for USDA to take into consideration Brazil’s self-imposed identity as a developing country," said Wooster. "Brazil’s disease management plans deserve additional scrutiny. If developed countries are struggling to contain FMD, it would appear Brazil faces even greater obstacles in controlling and eradicating FMD."

Wooster also noted, "In the past, USDA has looked at lifting or regionalizing FMD restrictions in other South American countries like Argentina and Uruguay only to have FMD outbreaks recur within months of such rules being formalized. Related to lifting FMD restrictions with South American countries the track record for past risk assessments and liberalizations is not good."

USCA’s concerns include the economic impact to the U.S. livestock industry as well as the overall U.S. economy if FMD were to find its way into the U.S. "Considering the consequences to animal health, food security, the economy and the environment there is simply no positive gain that justifies taking such a risk," explained Wooster. "The concept of regionalization, particularly between countries that are not close in terms of animal health practices, standards and disease prevalence, would be an extreme risk for the U.S. to engage in."

USCA listed several concerns with USDA’s assessment process for the region of Santa Catarina including inadequate assessments or failure to look at food waste handling as well as the improved markets that would result in Brazil which would encourage illegal livestock movement. USCA also noted that the risk assessment fails to include wildlife. "This is a crucial gap in USDA’s eleven point plan," explained Wooster. "Wildlife do not respect country or regional boundaries or biosecurity infrastructure practices."

"The health and well-being of the U.S. cattle herd is heavily dependent on our disease prevention efforts, which begin at the border," continued Wooster. With FMD outbreaks on the increase globally, this is no time to liberalize our health standards. Rather, we should be enhancing them."

"Brazil originally requested this rule making process, much like the one Argentina requested a few years ago," added Jess Peterson, USCA Executive Vice-President. "USCA spent considerable time and resources defeating the Argentina proposed rule and we will continue to meet with both USDA and elected officials to see that this rule making process with Brazil is abandoned."

Established in March 2007, USCA is committed to concentrating its efforts in Washington, DC to enhance and expand the cattle industry’s voice on Capitol Hill. USCA has a full-time presence in Washington, giving cattle producers across the country a strong influence on policy development. For more information go to www.uscattlemen.org.