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Bill
Hawks
Undersecretary for Marketing and Regulatory Programs
Regulatory Analysis and Development, PPD
APHIS, U.S. Department of Agriculture
Station 3C71
4700 River Road Unit 118
Riverdale MD 20737-1238
U.S.A.
Monday, January 5, 2004
RE: Government of Canada Comments on Proposed U.S Rule –
Docket No. 03-080-1: "Bovine Spongiform Encephalopathy;
Minimal Risk Regions and Importation of Commodities"
Dear
Mr. Hawks,
The Canadian Sheep Federation is a national, non-profit organization that
represents all Canadian sheep producers. Its mission is to work closely
and cooperatively with all levels of government and industry related organizations,
both domestic and foreign, to further the viability, expansion and prosperity
of the Canadian sheep and wool industry.
On behalf of the Canadian Sheep Federation, I am writing to submit our
comments to you in response to the proposed U.S. Rule, "Bovine
Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities."
The Canadian Sheep Federation Board of Directors has reviewed the response
submitted by the Government of Canada. Overall, we support our government’s
comments and recommendations. Specifically, we are supportive of the recommendations
made to allow the importation of sheep and lambs: destined for immediate
slaughter or entry into a feedlot in the U.S. and for fresh meat from
animals slaughtered in Canada; and live animals. Here, our federal government
has recommended that any animal within these categories be permitted to
enter the United States upon certification by the Government of Canada
that the animal:
• was born after the implementation of the feed ban in 1997; and
• was not known to have been fed ruminant proteins prohibited under
the feed ban during its lifetime.
An additional requirement was recommended for the category of live animals
that would allow an animal to enter the United States if it is identified
by a permanent identification system enabling them to be traced back to
the dam and flock of origin. On January 1st, 2004, the Canadian Sheep
Federation implemented its mandatory identification program that requires
all sheep and lambs to be tagged with an approved ear tag before they
leave any premises. We feel it is necessary, therefore, to establish a
basis for the acceptance and recognition by the USDA of our program and
programs developed by other commodities.
In addition to expressing our support for the Government of Canada’s
comments, the Canadian Sheep Federation wishes to voice our position that
the import ban was unjustly placed on sheep and should be lifted immediately.
We feel that our industry has been unnecessarily affected by the discovery
of BSE in one Canadian cow. Sheep do not carry or transmit BSE, and do
not pose any animal or human health risk. We request that separate consideration
for restoring full trade with the US for sheep be given. Should this request
be granted, sheep would not be subject to the terms and conditions outlined
in the newly proposed rule.
In the Proposed US Rule, references are made to the fact that sheep have
become infected with BSE in experimental settings. But, under the section
entitled "Source Species", the statement is clearly
made that "no natural infections with BSE have yet been confirmed
in sheep...". Based on this admission, the Canadian Sheep Federation
urges the USDA to lift the import ban for our commodity immediately. We
applaud the USDA for its efforts to base its decisions and actions on
sound science. We urge you to extend that practice to our industry. The
distinct lack of scientific evidence proving that BSE is a disease of
sheep should be a primary consideration in removing sheep from the import
ban.
Similarly, we applaud the USDA’s attempt to abide by, and consider
international trade standards throughout the rule-making process. We ask
that you remain consistent with the international standards for the ovine
species. We urge the USDA to revise its import policies to reflect the
standards established by the International Office of Epizootics (OIE).
These standards do not prohibit the importation of sheep from countries
where BSE has been discovered.
Although BSE is not a disease of sheep, the Canadian Sheep Federation
does recognize the need to develop programs that address the presence
of scrapie in sheep. We are currently working with the American Sheep
Industry to develop and implement effective surveillance, eradication
and flock certification programs for scrapie that are mutually recognized
by our countries and internationally.
On behalf of the Canadian Sheep Federation, I would like to thank the
United States Department of Agriculture for the opportunity to submit
comments on the proposed rule. We look forward to restoring our trade
relations with you as quickly as possible.
Sincerely,
Randy Eros,
Chair
on behalf of the Canadian Sheep Federation Board of Directors
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