Several countries that have not had countrywide Foot-and- Mouth Disease (FMD) freedom have used a combination of measures to (1) reduce the likelihood of infected animals being presented for slaughter at export [slaughterhouses], and to (2) minimize FMDV (FMD virus) survival during the slaughter process and the preparation of deboned beef. This combination of measures has proved extremely successful in eliminating the risk associated with trading deboned beef.
Deboned beef is a very low risk commodity with respect to spread of FMD. However, neither data on the safety of trade in the commodity to date nor a risk assessment of the survival of FMD during the preparation of the commodity under currently recommended procedures provide conclusive evidence that the risk is negligible without measures that reduce the likelihood of infected cattle being presented for slaughter.
There is no agreed threshold level for safe FMDV contamination for deboned beef. Information was not found on the amount of residual blood clot, lymph node and bone tissue within deboned beef. Nor was information found on the survival of FMDV in deboned beef from carcasses where the normal acidification of skeletal muscle had not occurred nor on FMDV survival in fat tissues.
Even with recommended quarantine measures, “more specific guidance” should be developed on mitigation measures to ensure infected animals are not slaughtered—especially animals in early stages of infection or incubation.
There should be procedures to survey the antigenic variants (serotypes and strains) that are circulating in the vicinity, including neighboring regions, in order to validate the protective immunity likely from particular FMD vaccines.
Agribusiness Freedom Foundation (AFF) sees the USDA proposal as seriously deficient because of these omissions: • Serotype and strain surveys in surrounding countries and Brazilian states outside the export zone; • Lack of quarantine; • Inability to guarantee separation zone with airborne potential and lack of geographic separation from known sources; and • Consideration should be given to a blood test requirement for export animals, at least until above research information becomes available.
This Proposed Rule shouldn’t have even been presented before significant questions regarding the production of deboned beef are answered with research.
The organization that sets the world’s scientific standards for trading in agricultural commodities—the World Organization for Animal Health (OIE)—had this to say about trading in deboned beef. In a 2009 30-plus page report, the OIE said, “It is clear that a combination of pre-slaughter [surveillance, quarantine and vaccination] and slaughterhouse measures has resulted in a commodity (deboned beef-DB) with a negligible risk of transmitting FMD. However, it is concluded that the current evidence does not provide absolute assurance that [slaughter] procedures for producing deboned beef can on their own result in a commodity with a negligible risk of transmitting FMDV (FMD Virus) without complementary measures to reduce the likelihood of slaughtering infected cattle.
“The main areas of uncertainty are the amounts of residual FMDV-harboring tissues with deboned beef and our understanding of what constitutes a safe level of contamination.”
The report also suggests more research on what amounts of residual lymph node and bone marrow tissues are within deboned beef.
AFF sees holes like Swiss cheese in this rule. Brazil appears to being making a good effort to control a disease they have, but the emphasis in the APHIS Risk Analysis is on control, detection, inspection and a history of “outbreaks.” And that’s in the export region. It’s certainly not reassuring, nor does it inspire confidence that they are anywhere close to shutting down the virus in Brazil.
The risk analysis gives us the “can’t see the forest for the trees” feel of how APHIS approached their risk analysis—detailed inspections and evaluations of labs, plans, inspection points, etc.—but little recognition of the huge problem, which requires a significant infrastructure and firefighting force.
We don’t want to be thinking about setting up “control” programs, “detection and notification” networks, inspection systems from coast to coast in the U.S. We do not want any preventable chance of importing this disease. We do not want a calculated risk. We want NO preventable risk.
This is like being pregnant. Either you are or you are not.
Brazil is pregnant. We are not. But this is not like turning the bulls out in the pasture next to the heifers. This disease can infect through the air for miles, especially from pigs. Twothousand-pound bulls on the prod are slugs by comparison.
Brazil’s cattlemen have no choice. They have to deal with this very contagious virus as best they can. America’s ranchers should have the choice not to jeopardize their industry.
If Brazil’s cattlemen had the chance to swap with us and not have neighboring states and countries with FMD threatening their herds, don´t you think they´d swap in a heartbeat?
— Steve Dittmer, Agribusiness Freedom Foundation [This is the conclusion of a four-part series originally published in the AFF Sentinel, an e-newsletter published by Agribusiness Freedom Foundation. Reprinted here with permission. Contact the author at firstname.lastname@example.org.