ASI Submits Trade Restriction Comments
April 25, 2014

The American Sheep Industry Association (ASI) submitted comments this week regarding a proposed rule and a risk assessment notice issued by the United States Department of Agriculture's Animal Plant Health Inspection Services (APHIS). The notices include a proposed rule to allow fresh beef to be imported from a region in Brazil and a notice of disease risk assessment for the Patagonia region of Argentina pertaining to Foot and Mouth Disease (FMD) and Rinderpest. ASI commented on both the proposed rule and risk assessment notice.

ASI industry believes that serious voids in the risk assessment of the Argentina package should be addressed with appropriate notice and comment before any further steps are taken. Some of these include:

"The specific methodology and measurements used during the site visits to support the qualitative risk assessment conclusions are not available for review.
  • Over half of the sheep in Argentina reside in the Patagonia region. They are generally raised in extensive management systems and since FMD clinical signs are relatively subtle in sheep, it is important that data be collected and shared for public review on the specific FMD diagnostic practices and what risk-mitigation measures are in place at border crossings to prevent FMD from entering Patagonia.
  • We believe it is APHIS' responsibility to provide the public with all of the documentation for these proposed rules in officially-translated English. Since many of the documents are in a foreign language, we urge APHIS to provide this information for public review and analysis.
  • We urge that a new, updated economic impact analysis for animals and animal products be completed and published for public review and comment for the Patagonia South and North B region if a proposed rule to allow sheep products to be imported from this region to the United States is published.
  • Finally, it is our view that in addition to monitoring processing operational systems and sampling, the responsible government agencies of the exporting region should be required to submit data and status review information regularly as is done in the United States between APHIS and state animal health regulatory agencies.
ASI has also reviewed the proposal for importing beef from a region in Brazil. While this proposed rule is specific to beef, FMD disease risk is everyone's concern. Many of the concerns stated for Argentina also translate to importing beef from Brazil.

ASI believes that the proposal to import beef from Brazil into the United States is premature.