QUESTIONS AND ANSWERS
The Importation of Certain Ruminant Products from Canada
August 2003
USDA Permitting Process
Q. What is a ruminant?
A. Ruminants are animals that have multiple stomachs, such as cattle,
sheep, goats, bison, deer, elk, caribou, moose, camels, etc.
Q. Which ruminant products that were banned on May 20, 2003, can
now be imported from Canada?
A. The following ruminant products from Canada will be allowed
to enter with a permit:
· Hunter-harvested wild ruminant products that are intended for
personal use;
· Caribou and Musk ox meat from the Canadian province of Nunavut
for commercial use;
· Veal (meat) from calves that were 36 weeks of age or younger
at slaughter;
· Boneless meat from sheep or goats that were 12 months of age
or younger at slaughter;
· Meat from farm-raised cervids (cervids include deer and elk);
· Boneless bovine meat from cattle that were 30 months of age or
younger at slaughter;
· Fresh or frozen bovine liver;
· Finished pet chews that are made from bone, ligaments, hides
or hooves; and
· Calf milk replacer, pet food, and feed ingredients that contain
processed animal protein and tallow of non-ruminant sources when produced
in facilities with dedicated manufacturing lines.
Q. How can a hunter import wild ruminant meat?
A. In order to import hunter-harvested wild ruminant products, the hunter
must obtain a “Veterinary Services Special Permit for the Importation
of Hunter-Harvested Wild Ruminant Meat.” Importers in the United
States can download and print this document directly from APHIS’
homepage at: http://www.aphis.usda.gov/lpa/issues/bse/bse.html.
Importers can also contact APHIS’ National Center for Import and
Export by telephone at (301) 734-3277 to obtain the Special Permit or
to ask questions.
Q. Can I re-enter the United States at any land border crossing
with hunter-harvested meat?
A. No. Only certain ports can be utilized. Visit www.usda.aphis.gov
for a list.
Q. What documentation must the hunter present to officials at
the port of entry upon their return to the United States from their hunting
expedition in Canada?
A. The hunter must have a “Veterinary Services Special
Permit for the Importation of Hunter-Harvested Wild Ruminant Meat.”
The hunter must also have either a valid Canadian Export Certificate for
game meat or a valid hunting license or hunting tag. These documents must
be presented at the U.S. port of entry and will be reviewed and approved
by an inspector with the Department of Homeland Security, Customs and
Border Protection.
Q. How do I import the other ruminant products listed above?
A. The importer in the United States must apply for and receive a “United
States Veterinary Permit for Importation and Transportation of Controlled
Material.” There are three ways to apply:
1. You can apply on-line at the following address: http://www.aphis.usda.gov/vs/import_export.htm.
Click on “IMPORT AUTHORIZATION SYSTEM” and follow the directions
to apply;
2. You can download and print an application (VS Form 16-3) at the following
address <<www.aphis.usda.gov/vs/ncie>>;
or
3. You can contact APHIS’ National Center for Import and Export
by telephone at (301)734-3277 to have the application faxed or mailed
to you.
Q. What is the definition of a “commercial importation?”
A. A commercial importation is an importation of a product that will be
sold and/or further distributed.
Q. What is the definition of an importation that is for “personal
use?”
A. Importations that are for personal use include meat and trophies from
legally hunted wild ruminants that are imported strictly for the use of
the hunter.
Q. What is the definition of a “dedicated facility?”
A. A dedicated facility is an exporting processing facility that does
not receive, store, or process ruminant material from any region that
USDA designates as being affected with BSE.
Q. Are there any products that do not require a United States
Veterinary Import Permit?
A. Yes, there are certain products that require a Canadian Government
Certificate rather than a United States Veterinary Import Permit. They
include fresh and frozen bovine liver and finished pet chews that are
made from ligaments and bone.
Q. How will I know what the Canadian Government Certificate needs
to say?
A. Contact APHIS’ National Center for Import and Export at (301)
734-3277 for more information.
Q. What will happen if an importer does not have the required
documentation?
A. The product will be refused entry into the United States.
Q. If I am a commercial importer of edible ruminant meat, does
the exporting processing facility need to be dedicated?
A. No. However, the permit restrictions will differ depending
on whether the facility is dedicated or non-dedicated.
Q. Can meat and cattle that originate in the United States be
processed in Canada and then returned to the United States?
A. Yes, if certain requirements are met.
Q. What are the requirements to process U.S. origin meat in
Canada and then return it to the United States?
A. The requirements will be based on whether the Canadian facility
in which the U.S. origin meat is processed is dedicated or non-dedicated.
Contact APHIS’ National Center for Import and Export at (301) 734-3277
for specific requirements.
Q. Can any live ruminants be imported from Canada into the United
States at this time?
A. No. The rulemaking process will begin immediately for the
importation of live ruminants and ruminant products.
Q. What is the legal authority for the permitting process? Is
there a need for rulemaking?
A. The Department has regulatory authority to issue permits allowing
ruminants and ruminant products to enter the United States from Canada,
under prescribed conditions, if doing so will not endanger U.S. livestock
or poultry (9 C.F.R. § 93.401(a)).
If the Department decides to make changes to the underlying regulation,
we will follow the regulatory process, including the opportunity for public
comment. Before we take action, the Department will ensure that there
is a strong scientific justification for doing so. All actions taken by
the Department will be based on sound science.
Q. Are other countries besides Canada with BSE cases going to
be allowed to import to the United States too?
If a country believes that they have the same status as Canada,
they then can apply to export to the United States. Since Canada has requested
that we open the border to low risk materials, the United States has reassessed
the systems in place in Canada for reducing risk from BSE. Certain actions,
including but not limited to the following, led us to conclude that Canada
presents a minimal risk of BSE: A history of stringent import control
measures, a strong surveillance system, a feed ban that has been in place
for several years and appropriate additional mitigation actions taken
as necessary. If another BSE-restricted country requested recognition
of a similar status from to the United States, we would assess the preventive
systems in place in that country and evaluate the slaughter and processing
systems to determine their equivalence with the United States system.
Trade Issues
Q. Will the import of certain products from Canada impact U.S.
export markets?
A. We have been in close communication with our export partners
regarding these actions. After failing to implement appropriate BSE preventative
measures---measures that have been in place in Canada and the United States
since 1989---Japan has had seven reported cases of BSE. The Japanese consumer
received mixed messages about BSE and consumer confidence fell. Japan’s
government responded by requesting an identification process from all
beef suppliers----and this was being discussed prior to BSE in Canada.
We do not feel that the Japanese government is justified in its decision
to exclude Canadian beef from our beef and beef products exported to Japan.
Although the United States does not believe such steps are necessary,
we are working to provide the industry a system that can be used to verify
U.S. beef exports.
Q. Why is a certification process needed if Canadian beef is
safe?
A. We do not feel that it is needed. Japan is basing its identification
requirement on commercial marketing factors and not on science-based principles.
However, in order to maintain an important export market for U.S. beef,
we are working to provide a requested measure that meets Japan’s
current marketing expectations. Other foreign suppliers to Japan had already
agreed to the Japanese demands.
A process verification system for beef exports to Japan is voluntary.
It is a proven marketing tool that is currently used by many different
sectors of the U.S. beef industry at all levels of marketing, but it has
nothing to do with food safety.
We will continue to work to convince Japan to remove this unnecessary
requirement.
Safety
Q. How does the permitting process change the risk of BSE occurring
in the United States?
A. Our experts have thoroughly reviewed the scientific evidence and determined
that the risk to public health is extremely low. We feel that the Canadian
system of beef production and processing has been and continues to be
based on a strong foundation of preventive measures to keep BSE from spreading.
Canada has also taken numerous actions, including an effective feed ban
in the 1990's, an aggressive surveillance program, and a heightened awareness
at ante-mortem inspection for central nervous system disorders to minimize
the risk of BSE.
In addition, the U. S. has had a strong system of preventive measures
in place since 1997. We have had a feed ban in place since 1997 that,
according to a Harvard Risk Assessment, has been the U.S.’s most
effective means of BSE prevention. The U.S. has continued to expand the
BSE surveillance program as well as strengthen efforts on feed ban compliance.
We are currently evaluating all of our safeguards to ensure that they
reflect the most recent science.
Other countries such as Japan that have found recurring cases of BSE
did not effective preventive programs in place until after a case of BSE
was found.
Q. Should the United States take any additional preventive actions?
A. Canada announced additional steps that are appropriate for a country
that has had a case of BSE. The U.S. has already taken aggressive action
to provide multiple firewalls against BSE, including prohibiting certain
specified risk material in ground beef products and has an active surveillance
program in place to ensure risk material is not present. Although we feel
confident that safeguards currently in place provide ample safety, we
will continue to reassess our safeguard measures using science based principles.
We have asked Harvard to re-evaluate its BSE risk assessment in light
of the single case of BSE in Canada.
Q. Can you explain the justification for allowing such products
as boxed beef in from Canada?
The USDA Transmissable Spongiform Encephalopathy (TSE) Working
Group continues to reassess the information that they had been working
on for some time prior to the Canadian case regarding the identification
of products that present low risk for carrying the BSE-infectious agent.
Based on peer-reviewed research, muscle cuts do not appear to transmit
infection. Whole muscle boneless cuts of beef from countries in the same
risk category as Canada do not contain the types of nervous system tissues
that could carry the BSE-infectious agent.
Boneless beef containing whole muscle cuts are very low risk, do not
contain central nervous system tissues and will be allowed to be imported
only from cattle younger than 30-months of age.
The U.S. is taking a measured approach to allowing low risk materials
from Canada into the U.S. The U.S. believes that Canada, like the U.S.,
has had an effective prevention system in place for many years in order
to reduce the likelihood that the BSE-infective agent was present. We
believe that the Canadian system of beef production and processing has
been and continues to be based on a strong foundation of BSE prevention
measures. The combination of an effective feed ban in the 1990's, an aggressive
surveillance program, and a heightened awareness at ante-mortem inspection
for CNS disorders has been effective in reducing the risk of BSE in Canada.
In addition, Canada has had a regulatory system for beef slaughter and
processing that has been deemed equivalent to the U.S. system. Since the
identification of the BSE case in Canada, the U. S. government has sent
delegations of scientists to Canada to further improve the preventive
and compliance measures employed by Canada to ensure that the on-going
systems are sound and effective.
Q. Are you confident that the single Canadian cow is an isolated
case?
A. Canada conducted an extensive investigation into the case of BSE including
the trace back and trace forward of the suspected animals of origin. Canada
depopulated over 2700 animals that could have been associated with the
case animal and tested them for BSE. No other cases were found. In addition,
Canada had an international expert panel review their investigation and
found it to be scientifically valid.
Canada had strong mitigation steps in place, including a ruminant feed
ban, to prevent the spread of BSE should a case been found--mitigation
steps not present in other BSE countries such as Japan. As noted in the
2001 Harvard Risk Assessment, this type of ban is an important measure
to prevent the spread of the animal disease. Canada has implemented additional
measures as necessary in response to the finding of the case of BSE.
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