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R-CALF USA’s Opposition to USDA’s Proposed Mandatory Animal Identification Rule: Part I of VIII-Part Series

Thursday, December 15th, 2011

R-CALF United Stockgrowers of America

“Fighting for the U.S. Cattle Producer”

For Immediate Release                                                                                                                                                                                      Contact: R-CALF USA CEO Bill Bullard

December 14, 2011                                                                                                                                                                                             Phone: 406-252-2516; r-calfusa@r-calfusa.com

R-CALF USA’s Opposition to USDA’s Proposed Mandatory Animal Identification Rule:  Part I of VIII-Part Series

Billings, Mont. – As promised, R-CALF USA today launches an 8-day series of news releases to explain in detail many of the reasons our members vehemently oppose the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s (APHIS’) proposed mandatory animal identification rule titled, Traceability for Livestock Moving Interstate (proposed rule).

With this effort, R-CALF USA hopes to bring to light many of the dangerous aspects associated with the proposed rule that R-CALF USA described in its voluminous comments submitted to APHIS on Dec. 9, 2011. Click here to view the entire 41-page comment submitted by R-CALF USA, which includes all of the group’s citations to specific references that are removed from this news release to save space.

Part I:  By Shirking its Responsibility Under the U.S. Animal Health Protection Act to Prevent the Introduction and Spread of Foreign Animal Diseases, APHIS Is now a Leading Cause, if not the Leading Cause, of Livestock Disease Problems Experienced in the United States

  1. APHIS’ Failure and Refusal to Properly Prevent the Introduction and Spread of Foreign Animal Diseases Belies APHIS’ Claim that the Proposed Rule Is Needed to Support Efforts by U.S. Cattle Producers to Protect their Herds from Disease

APHIS’ ongoing policy of willfully and knowingly allowing the perpetual and extensive introduction and reintroduction and subsequent spread of the very diseases APHIS identifies as justification for the proposed rule, e.g., bovine spongiform encephalopathy (BSE), bovine tuberculosis (TB), and bovine brucellosis (brucellosis), is indefensible, unconscionable, and constitutes outright defiance of the agency’s statutory obligation to protect U.S. livestock from the introduction and spread of foreign animal disease.

Further, APHIS’ ongoing policy of willfully and knowingly exposing U.S. livestock to an increased risk of foreign animal disease introduction, e.g., the risk of introduction of foot-and-mouth disease (FMD), is equally indefensible, unconscionable, and likewise constitutes outright defiance of the agency’s statutory obligation to protect U.S. livestock from the introduction and spread of foreign animal disease.

Specific examples of APHIS’ failure and refusal to prevent the introduction and spread of foreign animal diseases, along with examples of its actions to expose U.S. livestock to a heightened risk for disease, are enumerated below.  The following list clearly demonstrates that APHIS is a leading cause, if not the leading cause, of livestock disease problems experienced in the United States. Because APHIS is a leading cause, if not the leading cause, for ongoing animal disease outbreaks in the United States, its claimed intent within the proposed rule to protect the safety of U.S. livestock is both baseless and absurd.

Despite having conducted a 2006 quantitative risk evaluation for BSE that predicts the U.S. would import 19 to 105 BSE-infected Canadian cattle, resulting in 2 to 75 infections of U.S.-born cattle over the next 20 years pursuant to USDA’s over-30-month rule (OTM Rule) (EXHIBIT 1, p. 53347); and, despite a July 2008 court-ordered injunction directing APHIS to reopen the OTM Rule and “revise any provision of the OTM Rule it deems necessary (EXHIBIT 2, p. 21); and, despite the detection of 12 BSE infected Canadian cattle that meet the OTM Rule’s age requirement for importation into the United States (including the February 2011 case of BSE detected in a Canadian cow), APHIS continues to ignore the fully expected, continual reintroduction of Canadian BSE into the United States.

Despite having full and complete knowledge of a 2006 report by USDA’s Office of Inspector General (OIG) that states 75 percent of bovine TB cases detected in U.S. slaughtering plants originated in Mexico (EXHIBIT 3, pp. 19, 20); and, despite the OIG’s other findings that, “These infected animals were identified in 12 different States” and “animals of Mexican origin spent up to 14 months at U.S. farms before going to slaughter, with each case potentially spreading the disease” (EXHIBIT 3, pp. iii); and, despite APHIS’ own report that states, “From 2001 through February 2009, 236 out of 329 slaughter cases were traced to Mexico,” which means nearly 72 percent of all TB cases detected at slaughter were caused by APHIS’ inadequate import restrictions for Mexican cattle imports (EXHIBIT 4, p. 62); and, despite APHIS’ own finding that states, “Each year 1-2 infected animals per 100,000 animals imported from Mexico are identified [as bovine TB-infected] through slaughter detection or epidemiologic investigations (EXHIBIT 4, p. 1);” and, despite repeated requests by R-CALF USA for immediate action to address this willful introduction of bovine TB into the U.S. cattle herd, APHIS continues to cause the annual introduction and spread of bovine TB by failing to implement adequate import restrictions for Mexican cattle.

Despite having full and complete knowledge that Canadian cattle imports introduce bovine TB into the U.S. as evidence by three bovine TB-infected cattle imported into the U.S. from Canada in 2008, with a total of five TB-infected Canadian cattle detected in the U.S. during the past seven years (EXHIBIT 4, pp. 61, 62), and, despite R-CALF USA’s request that APHIS address this known disease source, APHIS continues to cause the introduction of bovine TB from Canadian cattle by failing and refusing to adequately strengthen U.S. import restrictions for Canadian cattle.

Despite having full and complete knowledge that the 11 factors used by the agency to determine the potential risk for foot-and-mouth disease (FMD) outbreaks in both entire countries and regions within a country are wholly incapable of predicting actual FMD risks (as was definitively proven following APHIS’ FMD risk evaluations for Uruguay, Argentina, the Republic of South Africa, and South Korea.), APHIS nevertheless persists in its efforts to apply the same, failed 11 factors to facilitate imports into the United States of beef and cattle from FMD-affected countries, notably from the Patagonia South Region of Argentina and Santa Catarina, Brazil.

Despite having full and complete knowledge that the relocation of the Plum Island, N.Y., research facility to Manhattan, Kansas, will increase the risk of FMD exposure for U.S. livestock, APHIS, in cooperation with the U.S. Department of Homeland Security (DHS), proposes to transfer live FMD viruses and research on live FMD viruses to the U.S. mainland.  APHIS and DHS propose this relocation despite full knowledge that: 1) there is no support for the contention that FMD research can be done as safely at Manhattan, Kansas, as at Plum Island, N.Y. (EXHIBIT 5, p. 46); 2) Plum Island is the only location determined to be of low risk with respect to the likelihood of FMD infection (EXHIBIT 5, p. 42); 3) “Plum Island’s lack of animals placed it at an advantage with respect to the likelihood that FMD virus would become established after being released and spread from the site (EXHIBIT 5, p. 42);” 4) Manhattan, Kansas, is in an area “where the virus would have ample opportunity to spread rapidly after release because of the presence of susceptible livestock and wildlife (EXHIBIT 5, p. 42); and, 5) “for all sites except Plum Island, the wind could potentially transport viral pathogens significant distances and that this pathway is not limited for them, as it is on Plum Island” (EXHIBIT 5, p. 42).

The foregoing discussion reveals and documents that APHIS is a leading cause, if not the leading cause, for the continual introductions and spread of foreign animal diseases by failing and refusing to comply with its statutory responsibility to prevent the introduction and spread of foreign animal diseases. The diseases APHIS is causing to be introduced and spread in the United States include the very diseases claimed as justification for its proposed rule. APHIS’ proposed rule would burden each and every U.S. cattle producer that moves cattle interstate by mandating the individual identification of their cattle. APHIS could not be more disingenuous in its claim that the proposed rule is intended to support U.S. cattle producers in their effort to protect their cattle herds from disease when APHIS itself is actively facilitating the introduction of dangerous foreign animal diseases

APHIS’ actions are akin to the hideous and unlawful scheme of organized crime to rob business owners of their money and then offer to mitigate the affect of their robberies in exchange for regular payments from the business owners, while making no commitment to prevent others from continually robbing their businesses. Like those victimized business owners, U.S. cattle producers have no moral or ethical obligation to pay the cost of mitigating diseases in the United States that are directly caused by APHIS’ recalcitrance, and they should have no legal obligation either.

If APHIS proceeds in any way other than to immediately withdraw it proposed rule, it must thoroughly and comprehensively explain to U.S. livestock producers why it is planning to burden them with the cost of a mandatory animal identification system to control diseases that APHIS is willfully and knowingly allowing into the United States each year in direct defiance of its statutory responsibility under the AHPA.

R-CALF USA encourages readers to share this information with their neighbors, state animal health officials, and their members of Congress.

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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.