Hodges pointed out that the disruption of cattle and beef trade between the U.S. and Canada that has followed the diagnosis of the first case of BSE in Canada has resulted in substantial economic hardship for U.S. beef processors. “Fully restoring cattle and beef trade in North America is a critical step to preventing further equity losses in the industry, enhancing our competitiveness in an increasingly global market, and protecting jobs in the U.S.,” he noted.

AMI urged USDA to amend the proposed rule and allow cattle of any age to be imported if they were going directly to slaughter, noting that doing so is consistent with World Organization for Animal Health (OIE) guidelines and poses no health risk to the cattle population. “The extensive array of risk mitigation measures implemented in both Canada and the United States over the past three decades dictates an expansion of the proposal,” he said, adding that a “statistically based testing and surveillance program in both countries provides a high degree of confidence that animal health is protected.”

Hodges pointed out that imposing a birth date for cattle moving directly to slaughter is not consistent with the treatment APHIS afforded beef and beef products in its final rule published in the Federal Register on Jan. 4, 2005, which provides for the importation of beef derived from cattle of any age if requirements for the removal of specified risk material (SRM) are met. “Allowing the import of cattle of all ages for slaughter does not increase the likelihood of BSE occurring in U.S. cattle because a ban on feeding ruminant proteins to ruminants effectively protects the U.S. cattle herd,” he said, noting that oral ingestion of feed contaminated with the BSE agent is the only documented route of field transmission of BSE.

OIE guidelines permit trade in all beef and beef products from which SRM have been hygienically removed. Because SRM would be removed from any beef or beef product derived from imported Canadian cattle that are sent directly to slaughter in the U.S., it would be inconsistent to impose a birth date on such animals when no such limitation applies to imported beef.

Hodges applauded the agency for publishing the rule, but again urged their consideration of an amendment that would permit the importation of cattle of all ages for slaughter. "No food safety or animal health reasons exist to exclude the importation of Canadian cattle born before March 1, 1999 for slaughter," he added.

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