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January 14,
2005 Hon.
Ann Veneman, Secretary
United States Department of Agriculture
Administration
Building
1400 Independence Ave., SW
Washington DC 20250 Dear
Secretary Veneman: The
National Grange strongly opposes the recent final rule announced by USDA to resume
imports of live cattle and other meat products from countries with known outbreaks
of, or otherwise considered at high risk for outbreak of, bovine spongiform encephalopathy
(BSE), including areas with active BSE cases. Under this new rule, Canada will
be the first country recognized as a minimal-risk country. The National Grange
strongly urges USDA to withdraw the final rule.
Founded in 1867, the National Grange is the nation's oldest rural advocacy organization.
It has grassroots units in 3,000 local communities in 38 states. It serves farm,
non-farm, rural families, and communities on a wide variety of economic, educational,
legislative and family issues. At
the 138th annual convention of the National Grange, held last November in Rochester,
New York the Grange delegates from across the nation adopted the following policy
on imported products from nations with known outbreaks of BSE.
"The National Grange asks that imports of animals, meat and meat by-products into
the United States from any country having Bovine Spongiform Encephalopathy (BSE)
be stopped until scientific data shows otherwise."
The
USDA final rule fails to protect the interests of the public or the farming and
ranching community. The regulatory approach used by USDA to justify this decision
fails to keep pace with current scientific knowledge about BSE. Furthermore, USDA's
regulatory approach is inconsistent with country of origin labeling programs established
in the 2002 Farm Bill. USDA's final rule is inconsistent with current scientific
knowledge about BSE. First and foremost, after USDA announced the new rule, Canada
disclosed that it had discovered two additional cases of BSE in cattle. While
the Canadian government has active theories regarding the exposure and development
of BSE in these animals, those theories are factually unproven. At the very least,
importation of cattle and meat from Canada into the U.S. should be delayed until
the Canadian government can complete their investigation into how these two animals
contracted of BSE. Canadian
officials currently believe that the animals became infected through consumption
of tainted feed prior to the imposition of the ban on ruminant-to-ruminant feed.
If true, the amount of tainted feed consumed by these animals would have been
small, given the publicly disclosed ages of these animals. This raises new questions
about the current scientific consensus regarding the exposure that is necessary
for an animal (and possibly a human) to contract BSE. A scientific review of the
effectiveness of U.S. and Canadian regulations regarding prohibition on consumption
of potentially BSE contaminated materials, by both animals and humans, would clearly
be warranted if Canadian agriculture officials are correct about their theories
on how the most recent animals were exposed to BSE. If
it turns out, instead, that the Canadian animals consumed BSE contaminated materials
after the ban on those feeds was put in place, then an complete audit of the Canadian
feed regulation program should be conducted. Necessary reforms of the regulatory
infrastructure that enforce the ban on ruminant-to ruminant feeding should be
completed before Canadian meat and animals are allowed to enter the United States.
In any case, the questions of science and policy enforcement employed by the Canadian
government to control and eliminate BSE from its cattle herds that are raised
by the two most recent BSE cases in Canada were clearly not taken into account
by USDA when it announced the rule on importation of animals and meat from "minimal
risk" countries. Further
questions regarding best available science are also raised by USDA's negotiations
with the Government of Japan to reopen that market to U.S. beef exports. As recent
press reports indicate, the Japanese have insisted that meat products entering
their country come from animals that are no more than 21 months old at the time
of slaughter. The Japanese have had more experience with BSE cases than the US
and Canada combined. The Japanese officials claim that their study of BSE contaminated
animals suggests that the disease can manifest itself as early as 21 months of
age. The USDA rule for importation of meat and animals into the U.S. from minimal
risk nations allows for animals of up to 30 months of age. It is clear that despite
the assurances by USDA that the 30 month age limit requirement meets international
scientific standards set out by the World Organization for Animal Health, these
standards are not yet accepted by all of our major trading partners. USDA's position
on the appropriate scientific standard for the minimum age when BSE can manifest
itself in cattle should be consistent for imports as well as exports of beef cattle.
USDA
assures the nation that meat and live cattle imported from Canada under the final
rule will be subject to nearly 500 pages of regulations designed to segregate
and separate the imported cattle from the rest of the U.S. meat and cattle marketing
system in order to guarantee that they are slaughtered by the time they reach
30 months of age. However these extensive segregation requirements do not carry
forward to the end consumer. At the 138th Annual Convention of the National Grange,
the Grange's delegates reaffirmed the following policy positions related to country
of origin labeling regulations in the U.S.: "The
National Grange supports Country of Origin Labeling and strongly urges the implementation
of the program on all food products by the USDA as provided in the 2002 farm bill."
The
Grange strongly supports country of origin labeling as a tool to allow consumers
to make informed decisions about the food they purchase. Reopening the boarder
to cattle and meat imports from Canada and elsewhere is an opportunity to begin
implementing country of origin labeling. USDA's decision not to institute country
of origin labeling for imported cattle and meat products is a fatal flaw of the
program. Ultimately the National Grange believes that the collective commercial
judgments of U.S. consumers should be the arbiter of what constitutes "minimal
risk." For
the reasons outlined in this letter, the National Grange strongly opposes the
resumption of importation of live cattle and other meat products derived from
Canada, as well as other countries, with known outbreaks of or otherwise considered
at high risk for outbreak of BSE. The USDA final rule fails to protect the interests
of both the public and the farming and ranching community. The existence of two
more active cases of BSE in Canada raises important new scientific questions about
this disease and its transmission that should be answered before imports are allowed
to resume. Furthermore, USDA's regulatory approach is inconsistent with country
of origin labeling programs established in the 2002 Farm Bill. I
appreciate your consideration of the views of the National Grange. I would appreciate
learning your views on this important issue so that we could share those views
with our grassroots members across the nation.
Sincerely, William
Steel, President
National Grange of the Order of Patrons of Husbandry
cc. Hon Mike Johanns, Secretary-Designate | 
