Greetings,
here are comments from a few people ;
Comment from Shawn Helmie, Canadian food inspection agency 02/02/2007 PUBLIC SUBMISSIONS
Comment Info: =================
General Comment:I applaud the Usda's decision to continue with rule 2. I have read all the comments
on the page and people seem to forget that the USA has had cases of BSE as
well not just Canada, internatinally we have the same risk category. I would also
like to remind people that the first case of bse in America had to be retested to
find the positive, how many others should have been? The other underlying
argument seems to be economical, nothing like an american monopoly to inflate
the price instead of relying on quality mcool is the same idea. The Usda is leading
the way in the fact that bse trade should be based on science not just public
rhetoric and protectionism and Rule 2 should be implemented as soon as possible
to show the world how beef trade should be handled in a world where bse risks are
mitigated.
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Washington Cattlemenis Association
February 2,2007
Docket No. APHIS 2006-0041
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 1 18
Riverdale, MD 20737-1 238
RE: Comments Regarding Docket No. APHIS 2006-0041; Bovine
Spongiform Encephalopathy; Minimal-Risk Regions: Importations of Live
Bovines and Products Derived From Bovines
9 CFR Parts 93,94,95, & 96
To Whom It May Concern:
The Washington Cattlemen's Association (WCA) is a grass- roots based
organization that represents over 1500 members state wide on a wide variety of
issues that face cattlemen and private property owners every day. The WCA
office is located in Ellensburg Washington. The WCA has several concerns
about the APHIS'S proposed rule to allow Over Thirty Month (OTM) Cattle and
Beef and Beef Products to be imported from Canada as it is currently written.
The WCA would like to offer the following suggestions:
The WCA believes that the USDNAPHIS must clearly demonstrate how they
intend to track imported Canadian beef and beef products that are over thirty
months of age. The USDNAPHIS must also contact of the United States
(US) beef industry export trading countries and get assurances from them that
implementation of this rule will not impair the US beef industry from regaining full
unrestricted access into their markets.
The WCA has concerns in the following areas:
1. How will the Canadian Food Inspection Agency (CFIA) and the USDA
accurately determine the age of imported beef and beef products? The
Canadian national cattle ID program didn't become mandatory until 2002;
and, it is still not mandatory to enter birthdate information into the
database. Therefore, how can age be verified? The WCA is also
concerned about the accuracy of dentition in older cattle since accuracy
tends to drop off after four years of age.
2. What system is the USDA planning to use to trace these beef products
from OTM cattle?
3. The WCA believes it is unacceptable to allow OTM beef and beef
products to be imported from Canada into the USA without any age
requirements or restrictions. This demonstrates USDNPHIS blatant
disregard for market impacts that implementation of this rule will have on
United States Cattlemen.
The WCA strongly recommends that the USDA immediately implement
Mandatory Country of Origin Labeling (COOL) to allow consumers the ability to
determine the origin of their food. Without full and immediate implantation of
Mandatory COOL the WCA will not support any form of the USDA's rule that
allows for Canadian OTM live cattle, beef, and beef products to be imported.
The WCA insists that the USDA require the PERMANENT MARK of the "CAN"
hot iron brand and a low frequency IS0 compliant Radio Frequency Tag (RFID)
be placed in the left ear of every live animal that is not being sent directly to
slaughter. The USDNAPHIS must conduct more stringent brand inspection in
Canada prior to allowing cattle to be imported into the United States to ensure
that the hot iron brands are properly applied to each and every animal. "Hair
brands" are unacceptable and shall not be tolerated by the USDAIAPHIS. The
WCA also insists the CFlA and the USDA provide to the State Veterinarian in the
state that is receiving imported Canadian cattle all animal health and
identification documentation prior to importation. The WCA strongly
recommends that the USDA grant each State Veterinarian and Director of
Agriculture complete authority to ensure that even/ animal health and animal
identification regulation is followed. In the event that a State Veterinarian or
Director of Agriculture finds an issue of noncompliance, the USDA will
COMPLETELY support the actions of the State officials as they take
enforcement measures. The USDA must have strict penalties in place that will
act as a strong deterrent to violating this rule. The USDA must bring criminal
charges against anyone that violates the rules. The WCA believes that in the
event of non-compliance the entire shipment of live animals must be returned to
Canada immediately. Importers and exporters that are found to be in violation of
the rule must permanently lose their licenses and pay substantial fiscal penalties.
Such fines will be paid to animal health department of the state where the
violations occurred.
The WCA strongly believes that USDAlAPHlS must require every head of
Canadian cattle to meet flof Washington State's animal health requirements.
The WCA also believes that importers of OTM Canadian Cattle must report all
animal movements to the Washington State Department of Agriculture prior to
importation to or through Washington State.
The WCA believes that March I, 1999 is an unacceptable birth date for
Canadian cattle eligible for importation since there have been positive cases of
BSE confirmed in cattle born after March 1, 1999. IF OTM Cattle are allowed to
be imported; the WCA strongly recommends the USDAIAPHIS use of the
following age model:
March 13,2007 - allow import of 30-month or younger live cattle (which
includes breeding cattle).
Following a 24-month probationary period the age can be raised by 12 months
March 13, 2009 - allow 42-month old live cattle, beef cattle and beef products
(which includes breeding cattle).
Following a 24-month probationary period the age can be raised by 12 months
March 13, 201 1 - allow import of 54-month and younger live cattle, beef cattle
and beef products (which includes breeding cattle).
Following a 24-month probationary period the age can be raised to 5 years
After 6 years of importing live cattle over thirty months of age without any animal
health or food safety issues, the USDA may then allow all cattle born on or after
March 13,2007 to be imported into the U.S..
Thank you for considering these comments the Washington Cattlemen's Association
hopes that the USDNAPHIS will incorporate each of these recommendations to improve
the proposed rule.
-Executive Vice President
Washington ~~ttlemen's Association
PO ~ 0 x 9 6
Ellensburg, WA. 98926
(509) 925-9871
Email
[email protected],elltel.net
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Comment Info: =================
General Comment:February 16, 2007
Docket No. APHIS 2006?0041
Regulatory Analysis and Development PPD
APHIS, Station 3A?03.8, 4700
River Road Unit 118
Riverdale, MD 20737?1238.
RE: Docket No. APHIS 2006?0041
To Whom It May Concern:
On behalf of the more than 2,400 members of the Colorado Cattlemen?s
Association (CCA), I would like to take this opportunity to comment on expanding
the age restrictions, beyond 30 months of age and younger, for bovine and select
bovine products from minimal risk defined countries for Bovine Spongiform
Encephalopathy (BSE). CCA has concerns over the recent detection of an
additional BSE positive ?mature? bovine in Canada. Additionally, the association
believes that this publication is premature previous to the World Organization for
Animal Health (OIE) General Assembly?s ruling on reevaluating the United States?
risk status for BSE.
CCA supports scientific-based approaches to disease management but concerns
must be addressed to assure that no retaliatory measures will be taken by our
trading partners in relation to the U.S. expanding trade with Canada. The U.S.
can not act unilaterally in expanding trade with Canada, but rather should include
all of Canada?s and the U.S.?s beef trading partners to collectively establish a
protocol that does not create a trade barrier and cast any doubt on the safety of
the U.S. beef supply. The OIE ruling due in May of 2007 is critical to that
assurance.
To date, the U.S. has taken necessary steps to reduce the prevalence of BSE in
the U.S., along with ensuring the highest level of food safety. By coupling our
enhanced BSE testing protocol and strict adherence to our feed ban, the U.S. has
become a leader in BSE disease management. CCA is concerned that Canada
has not adhered as closely to their feed ban. The most recent case of BSE
reaffirms our concerns. In-depth review of this adherence by the U.S., OIE, and
our trading partners must be implemented previous to our organization?s support
for reopening trade of bovine and bovine products from cattle over 30 months of
age from Canada.
In closing, the CCA respectfully requests that the United States Department of
Agriculture table consideration of Docket No. APHIS 2006?0041 until the
processes mentioned in this letter have been completed and formally reported on.
Thank you for your consideration of our comments.
Sincerely,
Mark Roeber
President
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EITHER these USA cattle producers and there partners are oblivious to the USDA, FSIS, APHIS, FDA,s FAILURES of the BSE/TSE firewalls of safeguards, or they are all in it together to conceal and cover up. I just cannot believe they are ALL that stupid. ...TSS