USDA's Proposed Rule for Brazil Lacks Science and Sense

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In evaluating USDA's Proposed Rule to import beef from Brazil, it is important to keep certain principles and factors in mind. I favor free trade. I favor scientific evidence in facilitating that trade, and I oppose catastrophic risk.

There is another psychological effect. That is the damage done by the BSE episode, which even now, more than a decade later, limits our access to world markets, colors our trade relations with other nations and took hundreds of millions of dollars out of the nation’s beef production chain. No one’s ever offered a refund.

All of that said, evaluating the proposed rule has seemed somewhat disconcerting, like any time it seemed someone should pop up and yell, “April Fool! We’re just kidding!” or, given the hard lessons taught to us by this administration – some whistleblower explaining the real, political motive behind this proposal that no one outside government had deciphered. Yet.

One has to remember this proposal is to import fresh or chilled beef into this country from Brazil, not to import live cattle or the virus. But try as I might, I found it is impossible because of the nature of this particular virus to completely separate the two because this virus can be so contagious. It travels in and on animals, on equipment, wrapping, vehicles and wind currents (30-70 miles) and causes both mortality and severe morbidity, that one can't entirely separate the meat and meat processing from the virus threat.

There is a reason Brazil has a team of professionals that descend at the first reports of this disease and slaughter every cloven-hoofed animal in sight, or more technically, any critter that could have been in contact with the stricken ones. It is a serious problem for the producer involved, for the surrounding countryside, the nation and surrounding nations. For a country with export customers, it is a bomb.

One factor getting minimal attention is the frightening prospect of foot and mouth disease (FMD) in North American wildlife. How could we become free of this virus ever again should our continent’s deer and elk population become infected with FMD? Hogs produce copious amounts of aerosol virus. Can you imagine FMD raging through the hordes of wild hogs roaming through the southern United States?

What we learned about applying science to trade under the threat of BSE only underlines the differences in this case. BSE is not a contagious disease, has a limited source of infection (feed contaminated with certain tissues) and has limited geographic scope compared to FMD. While all the science we would have preferred wasn’t available then, there was a considerable body of evidence. Most folks weren't aware of it because it wasn't necessary.

That isn't analogous to the FMD situation. While we know quite a bit about the virus, its effects on animals, how it travels and how to dispose of sick animals, there are critical things we do not know about the key question – how it could be transmitted through the import of meat.

The World Organization for Animal Health (OIE) did as thorough an examination of that question as could be done with the available evidence and research results.* We do not know two critical things: how much infective virus it would take on meat or meat wrappings, boxes, containers, etc. to infect an animal; and how much lymphatic or bone residue remains in deboned beef that could potentially carry the virus.

Those are key reasons the OIE study concluded it was impossible at this time to conclude that the risk of bringing FMD in through deboned beef was "negligible" through applying strict slaughter procedures. A "negligible" risk could only be attained if certain practices used to reduce the risk of presenting FMD infected animals for slaughter were combined with key slaughter and processing procedures.

To be fair, Brazil has shipped fresh beef to other countries in the world, mostly European Union countries and, to this point, no one has tied any FMD outbreak to that source. The OIE report attributes this mainly to proper slaughter procedures and to a very low percentage of cattle being slaughtered while infected with FMD. But there is no way to quantify the risk because there is no data on how many infected animals have been slaughtered and shipped.

FMD vaccination entails its own problems. The OIE report shows recommendations for twice a year vaccination, the necessity of matching which of the seven serotypes and 60 strains one needs to vaccinate for, less than 100 percent vaccination rates and possible less than optimal vaccination due to possible potency problems, short or long periods before challenge or single doses. Brazil does not regularly vaccinate pigs.

The USDA proposed rule has two gaping holes. While Brazil surveys and monitors strains of the virus active in the “export” states of Brazil, it does not do so in the non-export area states and it does not do so in the surrounding countries, some with “FMD-free with vaccination” ratings and some classified as unknown risks. This is critical because there is no cross protection among different serotypes and variable cross protection among strains. The other blunder – the OIE recommendation is a three-week quarantine period for all animals to be slaughtered for export to allow for most of any infected animals to show signs and eliminate the group for eligibility. Even the quarantine is not failsafe, as occasional animals show no visible symptoms. In the absence of a quarantine requirement, USDA does not discuss a blood test component.

Bottom line: do we want to swap nearly no risk for “low risk”?

The opinions expressed in this commentary are solely those of Steve Dittmer, a veteran in agricultural policy and commentator. 

*Qualitative Assessment of the Commodity Risk Factor for Spread of Foot-and-mouth Disease Associated with International Trade in Deboned Beef, " OIE ad hoc Group on


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