Billings, Mont. -- On May 15, the day the Bovine Spongiform Encephalopathy (BSE) Proposed Rule comment period closed, R-CALF USA sent a letter to the United States Department of Agriculture (USDA) requesting an extension of time for the USDA to receive comments on the proposed rule. This is the second extension request made by the group. The first request, made by approximately 30 organizations in an April 24, 2012 letter, has not yet been answered.
The second request states, "Although our [first] request was timely, and although we provided you with two legitimate reasons in support of our joint request (i.e. first, the Proposed Rule is voluminous in size and exceedingly complex in its rationale; second, the Proposed Rule represents a sweeping change to U.S. standards regarding the prevention of BSE in U.S. cattle and vCJD in U.S. citizens), your agency has not responded to our timely and reasonable request."
In addition to the reasons listed above, the second request includes another reason USDA should grant an extension. R-CALF USA learned from a Taiwanese article that the recent "California BSE case was an atypical L-strain BSE case, which scientific literature indicates is a far more virulent strain and potentially more readily transmissible to humans than were the two atypical H-strain BSE cases detected previously in the United States." Because USDA did not officially announce this information, R-CALF USA was only able to confirm this report by calling Dr. John Clifford, USDA's chief veterinarian. Dr. Clifford said USDA knew the particular strain of the California BSE case at the time of initial detection.
Without timely and transparent information on the California BSE case, comments submitted on the Proposed Rule will be incomplete "and necessarily void of pertinent information crucial for a thorough and thoughtful evaluation of the likely impacts the Proposed Rule will have on the health of the U.S. cattle herd and safety of U.S. citizens" states the letter.
Given the reasons listed above, R-CALF USA believes it is irresponsible for USDA to continue in the rule-making process without extending the comment period for the Proposed Rule for at least 60 days following the completion of the epidemiological investigation of the California BSE case.
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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit www.r-calfusa.com or, call 406-252-2516.
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