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Docket No. 03-080-2
Regulatory Analysis and Development
PPD APHIS, Station 3C71
4700 River Road Unit 18
Riverdale, MD 20737-1238
RE: Proposed Rule to open US-Canadian border to allow live cattle from Canada
Docket No. 03-080-2
Dear APHIS,
The South Dakota Stockgrowers Association represents over 1470 grassroots cattle producers, nearly all of whom derive the major portion of their income from cattle. The Animal Health Committee specializes on livestock well being and disease concerns, and provides insight to our organization regarding those issues. As the chairman of the Animal Health Committee, I thank you for this opportunity to comment on the new proposed rule for opening the US-Canadian border to live cattle and other animal products that are currently banned. Please consider the following comments from the South Dakota Stockgrowers Association Animal Health Committee.
We strongly oppose the US-Canadian border opening because of health risks to the US human population as well as the US live cattle industry. Since May of 2003, Canada has had 2 known cases of BSE. Because the BSE infected cow found in Washington State came from the same area in Canada as the BSE infected cow found in Canada in May, it is evident that Canada has a serious problem.
Canada was reluctant to report the first case of a BSE infected cow in a timely manner. It took Canada nearly 100 days to confirm and report he first BSE case. Therefore, we cannot trust Canada to admit to any other cases they may have found since then. This leads us to believe that Canada may still have BSE infected cattle and that all live cattle of any age and other animal products should remain banned. According to the OIE rules relating to countries with BSE, the country or countries must stop feeding ruminant protein to ruminant animals for eight years before they can be considered "minimal risk."
The South Dakota Stockgrowers Association Animal Health Committee believes that the US-Canadian border should remain closed for at least two years, as Canada’s feed ban has only been in place for six years. Plus, Canada has produced two cows known to be infected with BSE.
We urge USDA to keep the Canadian border closed to live cattle and other animal products, including the boxed beef currently allowed into the United States, at the very least until Country of Origin Labeling is implemented. This would satisfy America’s number one export market for US beef, Japan, and create a better market for US cattle producers.
Canada should not be considered a "minimal risk country" because the evidence thus far doesn’t warrant this status. A country such as Canada with two cases of BSE in six months certainly is high risk and should be treated as such.
If Canada is allowed to export live cattle and other animal products to the US, the action jeopardizes the US export markets and causes the US to lose credibility with its trading partners, creates a dumping ground for the rest of the world to send their BSE-infected cattle and forces the American consumer to eat beef that comes from a potentially BSE-infected animal.
The US has never had BSE in our domestic herd and we do not want to invite BSE from Canada or any other country.
In summation, for the reasons stated above, again we strongly urge USDA to:
- Keep the US-Canadian border closed to live cattle and other animal products for at least two years, and;
- Fund and implement Country of Origin Labeling immediately.
The South Dakota Stockgrowers Association Animal Health Committee also supports the comments submitted by our national organization, R-CALF USA.
Respectfully,
Kenny Fox
Chairman, Animal Health Committee
South Dakota Stockgrowers Association