February 10, 2003 

The Honorable Ann M. Veneman
Secretary, U.S. Department of Agriculture
1400 Independence Avenue, SW
Washington, DC 20250 

Dear Madam Secretary: 

In the 1980’s, at the first signs that Bovine Spongiform Encephalopathy (BSE) in the United Kingdom might be a threat to the United States, the U.S. Department of Agriculture, the Food and Drug Administration and all of our industry sectors took very proactive and science-based actions to develop a formidable barrier to the introduction, amplification or spread of the BSE. 

These decisions have effectively prevented BSE in the United States. In this regard the USDA/APHIS has listed at Title 9 Code of Federal Regulations, Section 94.18, restrictions on importation of meat and edible products from ruminants due to BSE by country. This listing has been determined following OIE guidelines as well as information relating to the potential risk of the introduction of the agent, surveillance practices, etc., and is broken down between countries where the following pertain: 1) BSE exists, 2) regions that have inadequate surveillance, as well as import requirements less restrictive than those that would be acceptable for import into the U.S. 

Even though the United States, in concert with the OIE, has set the global standard for BSE risk analysis, we are concerned with the actions of the European Union (EU) which continue to disrupt the global BSE risk analysis and prevention methodology. The recent regulation (EC) No. 1774/2002 of the European Parliament and of the Council, passed on October 3, 2002 and effective May 1, 2003 is an example of why we are concerned. In addition, the EU is in the process of implementing a Geographical Risk of Bovine Spongiform Encephalopathy (GBR) assessment system for other countries, including the United States. 

We have let the EU “tail” wag “the dog” of world BSE policy long enough. It must be understood that in Europe, where BSE problems emanate, they only produce about 13 percent of the world’s rendered products. Yet their regulations are being used to determine the “regulatory landscape” for the remaining 87 percent of global production where the USDA has already made determinations of risk and taken appropriate actions. This is not right and we would greatly appreciate your assistance in developing a U.S. “GBR categorization system” and/or working closely with the OIE to ensure there is a globally accepted, science and risk-based system, rather than an EU politically driven process. 

We request the USDA seriously consider our options for developing, in concert with the OIE, a rational “GBR classification” system with a minimum of four categories. This should then be publicized and used immediately to achieve the following: 

a) Refute EU GBR categorization as needed;
b) Educate other countries as to the U.S. interpretation utilizing OIE guidelines; and
c) Set a world standard. 

Thank you for your consideration. Please feel free to call on us if we can be of any assistance. Please contact Tom Cook at the National Renderers Association. 


American Farm Bureau Federation
American Feed Industry Association
American Meat Institute
American Sheep Industry Association
Fats and Proteins Research Foundation
Livestock Marketing Association
National Cattlemen’s Beef Association
National Grain and Feed Association
National Institute for Animal Agriculture
National Meat Association
National Milk Producers Federation
National Renderers Association
Pet Food Institute

cc: The Honorable Bill T. Hawks
cc: Mr. Bobby Acord
cc: Dr. Ron DeHaven
cc: Mr. David Hegwood