In strongly worded public comments, R-CALF USA criticized the plan by the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) to relax United States’ border protections to allow the importation of fresh beef from 14 Brazilian states, even though Brazil is not a country free of foot-and-mouth disease (FMD).
While APHIS recommends that the U.S. begin importing fresh beef from Brazil based on its characterization that the risk of introducing FMD into the United States is “low,” the agency admits the consequences of an FMD outbreak would be “extremely high,” costing the U.S. cattle industry and related businesses upwards of $42 billion.
But, R-CALF USA states that because APHIS’ proposal uses a “dizzying array” of adjectives such as “low” and “extremely unlikely” to describe the increased risk of introducing FMD into the United States, the agency’s characterizations of risk are “meaningless, unscientific, and uninformative.” The group further argues that because APHIS admits that the risk it characterizes as “low” nevertheless harbors a high probability of causing a catastrophic event, the agency should withdraw its rule.
“APHIS’ Proposed Rule and supporting documents read more like a cheerleader’s playbook than a scientific analysis of the impact of relaxing the United States’ crucial disease-prevention border controls,” R-CALF USA wrote.
The group added: “APHIS’ documents suggest that no risk is too great and the agency is willing to write virtually anything to win support for its cause, even if there is absolutely no basis for its boisterous claims.”
The group included numerous arguments to refute APHIS’ claim that the risk of introducing FMD would be adequately mitigated under the proposed rule. Such arguments include:
• Brazil has a history of failing to notify the U.S. of animal disease outbreaks.
• Brazil’s food safety system for meat is currently under intense scrutiny by the USDA Food Safety and Inspection Service (FSIS) because Brazil does not appear to meet all the meat safety protocols required by the United States.
• Brazil does not always man its border inspection posts to prevent cattle from entering Brazil from neighboring FMD-affected countries.
• APHIS failed to meaningfully address the risk associated with Brazil’s vaccination practices particularly since contaminated vaccines and accidents associated with the production of vaccines were found in a study to be the second-leading cause of FMD outbreaks throughout the world.
• When dismissing the possibility of the transmission of FMD via wildlife, APHIS failed to consider that wildlife in Brazil have likely developed a natural immunity to FMD over the many generations that FMD was widely circulating in the country. But, neither U.S. wildlife nor U.S. livestock would have any natural immunity and FMD would likely spread quickly in the U.S. as a result.
• APHIS failed to give any meaningful consideration to the risk that contaminated meat trim from fresh Brazilian beef, if discarded in U.S. landfills, could be consumed by the rapidly growing population of feral hogs in the U.S. that could then transmit the disease to U.S. livestock.
• APHIS has a historically poor track record when it comes to claiming that countries are “unlikely” to experience FMD outbreaks as the countries of Argentina, Uruguay, South Africa, South Korea and Japan all experienced outbreaks soon after APHIS claimed they each had all the necessary mitigation measures in place to prevent an outbreak.
• APHIS’ proposal is in conflict with Congress’ mandate that the agency prevent the introduction of foreign animal disease into the United States. In its conclusion, the group accused APHIS of “pursuing a despicable, politically motivated campaign to cause the introduction of FMD into the United States, presumably for the purpose of leveling the global trade arena by pulling the United States down to the lower standards of developing countries.” ❖