April 23, 2014
Docket No. APHIS 2013-0105
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238
RE: Docket No. APHIS 2013-0105, Notice of Availability of Evaluations of the Foot-and-Mouth Disease and Rinderpest Status of a Region of Patagonia, Argentina
To Whom it May Concern:
The North Dakota Stockmen’s Association (NDSA) is an 85-year-old beef cattle trade organization, which is proud to represent nearly 3,000 North Dakota cattlemen and cattlewomen. Our organization works to unite, protect, promote, educate and serve our state’s beef cattle industry, and our members are committed to ensuring the health and well-being of the domestic cattle herd. 
Thank you for the opportunity to comment on the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service’s (APHIS) evaluation of the foot-and-mouth disease (FMD) and rinderpest status of the Patagonia region of Argentina. As an affiliate member of the National Cattlemen’s Beef Association (NCBA), we also support the comments submitted by NCBA, including the findings of a team of third-party risk assessors from the University of Minnesota College of Veterinary Medicine’s Centers for Animal Health and Food Safety and Veterinary Population Medicine and NCBA’s request for a comment extension, considering that several Freedom of Information Act (FOIA) and Spanish-to-English translation requests pertinent for the critical review of this evaluation were not honored by the time this comment period closed.
Generally, the NDSA supports free trade based upon scientifically sound principles consistent with the World Organization of Animal Health’s (OIE) guidelines. However, we cannot support action that could endanger the health and well-being of the U.S. cattle herd. We share NCBA’s concerns about the weaknesses identified in APHIS’ risk analysis regarding the FMD risk through the importation of susceptible species and products from Patagonia, including the following: 1) Limited or lacking methodological approaches in performing the risk assessment; 2) Poorly defined scope regarding the specific animal types and products for the risk assessment; 3) Incomplete analysis of the hazard identification; 4) Inconsistent terminology for the risk analysis based on current OIE guidelines; 5) Insufficient information in the release assessment; 6) Incomplete information contained in the exposure assessment; 7) Lack of a defined matrix for establishing the risk scale in the risk estimation; 8) Lack of sufficient detail for geographical landmarks outlining the Patagonia region and maps in the risk analysis to be useful; and 9) The overly subjective qualitative format used for the risk assessment that fails to objectively quantify the probability of risk and adequately assess the magnitude of the consequences.
Argentina’s track record of diminishing compliance with the regulatory requirements of the Federal Meat, Poultry Products and Egg Products Inspection Acts, as attested to in the U.S. Department of Agriculture’s Food Safety Inspection Service’s audits, raises our level of concern over the country’s ability to successfully and consistently employ mitigation strategies to prevent FMD introduction into the United States. Significant deficiencies were recorded from 2005 to 2009 in areas such as sanitation standard operation procedures and performance standards; Hazard Analysis and Critical Control Point Systems and implementation; and specified risk material removal equipment and/or procedures.
Similarly, a review of 2009-2012 audit findings of Argentina’s FMD and related certification procedures for bovine and ovine fresh meat intended for export identified by the European Commission’s Food and Veterinary Office identified points of concern related to border controls, animal identification and registration, vaccination controls, FMD surveillance measures and wildlife management plans. A 2012 audit revealed less-than-satisfactory enforcement of sheep identification and movement registration requirements in the Patagonia region, as well as weak official controls along the Bolivian border. It is our assessment that these deficiencies would likewise be replicated here, in the United States, and could put the domestic beef industry and other animal agriculture sectors at risk for FMD.
As you know, FMD, which affects cloven-hooved animals such as cattle, sheep, bison, goats and many wildlife species, is considered one of the most contagious viral diseases. Since FMD is so transmissible, it is also considered to be the most economically devastating livestock disease in the world, according to “The Economic Impacts of a Foot-and-Mouth Disease Outbreak: A Regional Analysis, Journal of Agriculture and Applied Economics.” Depending on the magnitude of the outbreak of FMD in the United States and the eradication strategies employed to address it, direct impacts, consumer impacts and trade losses are estimated to range from $37 billion to $42 billion over a 25-year period, according to APHIS’ own risk analysis accompanying the proposed rule regarding the importation of fresh, maturated, deboned beef from a region in Brazil. That is a price we cannot afford to pay.
Fortunately, the United States has not had a case of FMD since 1929, which, incidentally, was traced back to infected meat delivered by steamship from Buenos Aires, Argentina. On the other, Argentina has had FMD cases as recent as 2006, and, in the Patagonia region, which is the focus of this evaluation, as recent as 1994, when six outbreaks were reported.
The best line of defense against the introduction of FMD is to have adequate import controls and quarantine measures for live animals in place and to properly assess the hazards associated with the importation of products from FMD-affected areas of the world. We are not confident that those necessary defenses are in place and, therefore, have significant concerns about the risk that importation from regions in close proximity to FMD-affected areas, such as the Patagonia region of Argentina, could pose to the U.S. livestock industry.
Thank you for the consideration of our comments on this important issue. If you have any questions, please call our office at (701) 223-2522.
Jason Zahn
North Dakota Stockmen’s Association