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CPA letter to USDA re: BSE, Cattle and Trade |
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Written by Stumo
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Tuesday, 17 November 2009 |
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One of CPA's major concerns is that trade policy has trumped food and product safety. We allow importation of food and manufactured goods that do not meet U.S. quality standards, because trade flows are deemed more important than safety.
In the animal health world, the U.S. historically banned imports of cattle, pigs and sheep from countries that have known cases of foot and mouth disease, blue tongue and Bovine Spongiform Encephalopathy (BSE or mad cow disease).
But when BSE was discovered in Canada, our U.S. Department of Agriculture decided that trade was more important than U.S. animal health. The multinational meatpackers successfully persuaded USDA to keep the border to Canada open, to a large degree. The U.S. had three BSE cases starting in 2003, with cattle originating in Canada. Other countries cut off our export sales, but we allowed Canada to ship cattle to us. The U.S. beef and cattle market has suffered drastically because our borders are open to imports, but other doors are not open to our exports.
Thus, we are a major net importer of cattle and beef.
CPA agreed to sign on to a letter to the USDA protesting this policy. R-CALF USA, a major U.S. cattle producer organization and CPA member, initiated the letter. It is below the fold.
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November 17, 2009
The Honorable Tom Vilsack
Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, D.C. 20250
Re: Serious Concerns Regarding APHIS October 5, 2009 Status Report
in R-CALF USA, et al. vs. USDA, et al.
Dear Secretary Vilsack:
On Oct. 5, 2009, the U.S. Department of Agriculture (USDA) provided notice to the United States District Court, District of South Dakota, Northern Division, that states the agency is preparing a docket to initiate rulemaking to amend its bovine spongiform encephalopathy (BSE) regulations regarding the importation of bovines and bovine products. The notice specifically states, The proposed criteria for country classification and commodity import would be closely aligned with those of the World Organization for Animal Health.
We, the undersigned organizations, are deeply concerned with this proposed action and believe USDA is exhibiting a serious lack of judgment by attempting to align U.S. safety measures with the incessantly weak and demonstrably ineffective BSE standards established by the international World Organization for Animal Health (OIE). This proposed action would, if taken, abrogate your agencys responsibility under the Animal Health Protection Act to protect U.S. livestock and the people of the United States from the introduction into and spread within the United States of animal diseases, particularly from such a pernicious animal disease as BSE that is invariably fatal and that also afflict humans. Your Administration must reverse, not perpetuate, the previous Administrations dangerous policy of preempting sound animal health and human health protections to facilitate trade a policy that not only has increased domestic health hazards, but also has caused serious economic harm to domestic industries.
USDAs own risk assessment predicts, with a high level of certainty, that current regulations will cause the introduction and spread of fatal BSE within the United States. The risk assessment further predicts that the people of the United States will be exposed to additional risk for the disease. These regulations, implemented by the prior Administration, defy USDAs animal health protection mandate while stating, throughout their respective preambles, that the U.S. and Canada, as well as the rules themselves, are in conformity to OIE standards. The OIE standards cannot reasonably be expected to protect U.S. livestock and the people of the United States from the introduction and spread of BSE as required by the Animal Health Protection Act.
The OIE standards are not deemed credible. They have not been followed by any of the United States major export customers with which the United States maintains a positive trade balance. This situation has not changed in the past six years. Current trade policy is losing support, in large part, because food and product safety standards are negated by government efforts to facilitate cross-border trade at all costs. The trade-trumping-safety policy problem includes, but also goes beyond, cattle and beef. Because of USDAs past and current persistence in adopting unproven and inapt international standards rather than continuing pre-BSE disease standards proven to protect consumers of U.S. beef and U.S. citizens, including U.S. cattle producers and their livestock the U.S. cattle industry is unnecessarily burdened by a flood of unsafe imports. The result is a large trade deficit in cattle and beef that is forcing thousands upon thousands of independent cattle producers out of business each year.
The only countries that have scientifically demonstrated a reduction in the incidence of BSE are those that continue to require more BSE testing, stricter feed bans, and more stringent specified risk materials removal practices than the OIE requires. Canada, on the other hand, is the only BSE-affected country with multiple cases of BSE detected in animals born after a feed ban that does not require standards far more stringent than those established by the OIE. It is not surprising, therefore, that OIE reports show that Canada is the only BSE-affected country other than Portugal to have experienced an increased incidence of BSE between 2007 and 2008.
President Barack Obama and Vice President Joseph Biden, Jr., have previously demonstrated their strong opposition to USDAs final rule that reopened our borders to Canadian cattle and beef after BSE was detected in Canada. Then-Senators Obama and Biden voted in favor of a Senate Resolution of Disapproval declaring that USDAs rule shall have no force or effect. The BSE problem in Canada has grown substantially worse since that Senate Resolution. At the time of their votes, only four cases of BSE had been detected in Canadian-born cattle, and no post-feed ban BSE cases were discovered. Since that time, seventeen (17) cases of BSE have been discovered in Canadian-born cattle. Eleven (11) of these seventeen (17) BSE-infected cattle were born after Canadas 1997 feed ban. Ten (10) of these eleven (11) infected post-feed ban cattle were eligible, under USDAs current rules, for export to the United States because they were born after March 1, 1999.
The proper policy is to bring United States BSE regulations in line with past standards, which were more closely aligned to the current standards of our trading partners. Animal health, as well as food and product safety, should be held in higher regard by your Administration than trade facilitation. Public support for such a change is clear. The industry need is clear. Consumer confidence would increase. The United States current trade imbalances would become more balanced. Risks to animal and human health would be drastically reduced.
The U.S. is the largest beef consuming market in the world and the largest beef producing country in the world. You have inherited the weakest, most ineffective and liberal BSE import policies when compared to every other major beef consuming market in the world. President Obama and Vice President Biden previously objected to the very rules that exist now.
We respectfully request that you promulgate BSE rules that restore for U.S. livestock, livestock producers, and the people of the United States the highest possible level of protection against the introduction and spread of animal diseases. Valid science, consumer confidence, and sound economics require the BSE import rules to be tightened according to pre-outbreak norms. This departure from the past Administrations destructive policies will improve consumer confidence in the beef supply, balance trade flows, remedy the severe financial destruction of the U.S. cattle industry, and substantially decrease the risk of livestock and human disease exposure.
Sincerely,
National Organizations: American Grassfed Association
Coalition for a Prosperous America
Consumer Federation of America
CJD Foundation
Farm and Ranch Freedom Alliance
Food & Water Watch
Freedom21, Inc.
International Texas Longhorn Association
National Association of Farm Animal Welfare
National Farmers Union
Organic Consumers Association
Organization for Competitive Markets
R-CALF USA
Sovereignty International, Inc.
The Cornucopia Institute
Western Organization of Resource Councils
State, Regional and County Organizations:
Buckeye Quality Beef Association (Ohio)
Cattle Producers of Washington
Citizens for Private Property Rights, Missouri
Colorado Independent CattleGrower's Association
Independent Cattlemen of Nebraska
Independent Beef Association of North Dakota
Independent Cattlemen of Wyoming
Kansas Cattlemens Association
Kansas Farmers Union
Mississippi Livestock Markets Association
Missouri Farmers Union
Nebraska Farmers Union
Nevada Live Stock Association
New England Farmers Union
Northeast Organic Farming Association/Massachusetts Chapter, Inc.
Ohio Farmers Union
Oregon Livestock Producers Association
Ozarks Property Rights Congress, Missouri
PCC Natural Markets (Puget Consumers Co-op)
SmallHolders of Massachusetts
South Dakota Farmers Union
South Dakota Stockgrowers Association
Spokane County Cattlemen, Washington
Stevens County Cattlemen, Washington
For More information or to contact individual organizations, please contact R-CALF USA at 406-252-2516 or
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cc: Members of Congress
U.S. Centers for Disease Control and Prevention
State Animal Health Officials
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March 2-4, The Coalition for a Prosperous America
Legislative Fly-In
CPA will hold its Second Annual Legislative Fly-In on
March 2-4, 2010. This is a powerful opportunity for us to work
together to advance trade reform in the halls of Congress. We need to
bring the concerns of the grass roots to our legislators.
This is efficient advocacy, well worth your time. We make all the
meeting arrangements with legislators or their staff, we put together
materials, we plan a message, and we pack meetings together in a
concentrated period of time. You make a bigger impact with your time
using only three of the 365 days in the year.
Click here to sign up for the CPA Fly In.
CPA has a special offer--limited time only: the first 50 registrants
get a free copy of Ian Fletcher's new book: Free Trade Doesn't Work.
This is a highly acclaimed book about trade policy and the needed
changes therein.
Agenda:
March 2, 2010: 2p to 6p - Group meeting for training, talking points and team assignments
March 3-4, 2010: Hill visits
Place: Capitol Skyline Hotel, 10 I ("Eye") Street SW, Washington, DC 20024
Once you sign up with CPA, reserve your room at the Capitol Skyline
Hotel by calling 202.488.7500. You should book for the evenings of
March 2 and March 3.
If you have questions about the events, please call Sara Haimowitz,
Development Coordinator, at 413-203-1410 or email at
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