R-CALF USA on Dec. 4, 2009, filed formal comments with the U.S. Department of Agriculture (USDA) regarding the agency's proposal to revamp the United States' bovine tuberculosis (TB) program, a program that has significantly reduced the prevalence of TB in U.S. livestock since 1917.
The group praised USDA's proposals to impose new restrictions on the importation of cattle from Mexico, enhance efforts to mitigate TB risks with wildlife, develop new diagnostic tests and develop alternative strategies for whole-herd depopulation. However, the group strenuously objected to USDA's plan to adopt the internationally-devised "zoning" plan that would ignore the geopolitical boundaries of states. R-CALFUSA believes such a proposal would infringe upon the sovereign rights of the 50 states and weaken U.S. disease eradication efforts. In addition, the group objected to USDA's plans to adopt a mandatory national animal identification system (NAIS) and its plans to exclude the public from agency decision-making by granting USDA authority to take actions without providing the public with notice and opportunity for comment, as required under USDA rule-making responsibilities.
"We are pleased USDA has responded favorably to our member policy by proposing to increase TB testing of Mexican cattle imports," said R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group's animal health committee. "It's been known for several years that 75 percent of TB-infected cattle detected at U.S. slaughtering plants originate from Mexico. And, while USDA plans to require certain classes of Mexican cattle to be quarantined upon entering the U.S., we will continue working to expand this to include all Mexican cattle until Mexico takes steps to eradicate this dangerous human and animal disease in its native cattle herd."
In addition, the group's comments called for TB restrictions on Canadian cattle and noted that the U.S. imported two TB-positive heifers from the Canadian province of British Columbia in 2008.
"If we're serious about eradicating TB, we must prevent its continued reintroduction from both Canada and Mexico," Thornsberry said.
The comments also hailed USDA's plan to emphasize TB eradication efforts in wildlife populations, where the disease is known to persist in several areas in the United States.
However, R-CALFUSA called USDA's plan to adopt the World Organization for Animal Health's (OIE's) zoning plan counterproductive and unacceptable. The comments note that the U.S. has evidence proving that the international zoning concept is inadequate to control disease spread. R-CALF USA provided the example in Uruguay where, in 2000, USDA tried to zone Uruguay, claiming that foot-and-mouth disease (FMD) was limited to a single state or department in the country, but by 2001, widespread FMD outbreaks (1,596 new cases) were reported in 18 Uruguayan states.
The zoning concept ignores the geopolitical boundaries of states within a country and, instead, imposes federal jurisdiction over zones that may include land in multiple states.
"This is an attempt by USDA to impose federal jurisdiction over multiple states and will weaken TB eradication efforts because such federal intervention would completely ignore and usurp the intrinsic synergies created when states individually and collectively seek excellence in protecting their respective boundaries from the introduction and spread of disease," Thornsberry pointed out.
Thornsberry also said USDA is inappropriately attempting to force the international zoning concept in the U.S. so it can expand its efforts to force zoning in other parts of the world.
This is contrary to the interests of U.S. cattle producers and in direct contradiction to legislation recently introduced in Congress by Sen. Tim Johnson, D-S.D., and Sen. Mike Enzi, R-Wyo., along with Rep. Stephanie Herseth Sandlin, D-S.D., and Rep. Cynthia Lummis, R-Wyo., titled "Foot and Mouth Disease Protection Act" (S. 337 and H.R. 1226, respectively) that would prevent USDA from zoning Argentina. This legislation is in response to USDA's proposal to impose zoning on Argentina to facilitate imports of fresh and frozen meat into the U.S. from Argentina, even though Argentina is known to have a continuing problem with FMD, the most contagious disease known to cattle.
R-CALF USA's comments also object to USDA's insistence that a new national animal identification system is needed to eradicate TB.
"We continue to push USDA to improve upon our existing, time-proven identification systems rather than to impose a costly, unproven mandatory National Animal Identification System," said Thornsberry. "USDA provides no evidence to support a need for any new form of animal identification other than what has been used successfully for decades to control TB.
"We are generally pleased with USDA's plan to strengthen our disease eradication efforts, but will aggressively insist that the plan must fully respect the geopolitical boundaries of the 50 states, as well as preserve and protect the rights and privileges of U.S. cattle producers," he concluded.
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