ANIMAL HEALTH PROTECTION AND DISEASE
CONTROL
(February 23, 2004)
1.1 Introduction
The need for basic and applied animal health protection and disease
control research continues to demand attention. There is a critical
need to strengthen integrated animal health management programs to
facilitate the transfer of information and technology from laboratory
to the producer/consumer. Research is needed to prevent introductions
of pathogens into the food chain by developing methods to reduce
or eliminate them from animals during production.
Currently not enough scientifically-based information is available
to define what constitutes a state of well-being in animals. Behavioral,
physiological, health, and production parameters need to be incorporated
into animal health research. This will lead to improved management
practices and systems which will ensure the psychological and physical
well-being of animals while maintaining affordability and competitiveness
for producers.
1.2 Foreign And Domestic Animal Health Issues
Homeland Security and Agriculture — NASDA strongly supports the
Department of Homeland Security ("DHS") in its efforts to
protect the nation against threats to the homeland, especially after
the events of September 11, 2001, and the anthrax incidents that followed.
The agriculture quarantine inspection staff and functions from USDA
APHIS were transferred to the Department of Homeland Security, Customs
and Border Protection. The stated priority for the DHS is preventing
terrorists and terrorist weapons from entering the United States. Introductions
of foreign animal diseases, such as Exotic Newcastle Disease and emerging
diseases, such as West Nile Virus, Avian Influenza and Chronic Wasting
Disease are of great concern to the U.S. agricultural economy, and
to the nation’s livestock, and animal resources.
While the prevention of terrorists and terrorist weapons from entering
the United States is vital to the security of the nation, so too, is
the protection of the nation's food supply, our agricultural economy,
and animal health. It is essential that the relationship between the
DHS and APHIS offers the greatest reduction in risks, establishes a
consistent and clear communication structure, and provides for problem
resolution with built-in accountability. NASDA urges increased emphasis
be placed by DHS on the mission of safeguarding agriculture.
Animal Disease Eradication
and Control — The completion of several
disease control programs of significance to the economic viability
of livestock production agriculture in the United States is nearing.
Bovine tuberculosis, bovine brucellosis, swine brucellosis and pseudorabies
are examples of diseases that will likely be eradicated from domestic
livestock. Funding cuts and other resource constraints threaten the
ability of USDA, specifically the Animal and Plant Health Inspection
Service (APHIS), to complete these important programs.
As international trade has increased, the threat of an outbreak of
a foreign animal disease in the United States has also increased. Such
an outbreak would disrupt production of food animals, interrupt the
domestic meat and poultry supply, adversely affect food processing,
marketing and the distribution chain, and cause the loss of export
markets for United States livestock and livestock products. The loss
to the United States would be billions of dollars in trade of agricultural
products.
NASDA believes that disease control programs are essential if eradication
of animal and poultry diseases and the prevention of the introduction
or outbreak of foreign or domestic diseases is to be successful. Priority
should be given to programs whose efforts are aimed at preventing the
outbreak of animal health diseases and protecting our nation’s
domestic livestock from foreign diseases. Valid tests should also be
developed to properly detect diseases that pose a risk to animal health.
Some animal health diseases that require specific attention are:
Sufficient resources should be made available for such programs so
that the appropriate agencies can provide indemnity to owners of diseased
livestock, which will encourage the elimination of remaining infected
herds, and maintain an adequate number of animal health professionals
able to respond to animal health issues.
NASDA believes that any comprehensive program to control or eradicate
disease from domestic livestock should include provisions for testing,
quarantining exposed animals, and indemnifying diseased animals. All
susceptible species should be included in regulations addressing disease
control. Moreover, consideration should be given to industry funded
insurance initiatives that provide indemnification for disease exposed
domestic livestock.
APHIS has published a proposed rule that would codify a standardized
cost sharing formula for animal disease and plant pest and disease
emergency eradication programs that are conducted cooperatively with
states. Unfortunately, expanding world trade and the threat ofbioterrorism
have increased the risk of destructive pests and diseases being introduced
into the United States. The United States Department of Agriculture
(USDA) is the federal agency statutorily charged with preventing the
introduction, spread and establishment of plant pests and diseases,
noxious weeds and pests and diseases of livestock in the United States.
States are not federally mandated to partner with USDA in this endeavor
yet have historically done so with great success. Developing a plan
on how the United States Department of Agriculture should respond to
emergencies is not without merit. In fact, NASDA's Animal Health Safeguarding
Review and the Safeguarding American Plant Resources Review conducted
by the National Plant Board contain recommendations that would facilitate
the kind of out year planning envisioned in the proposed rule.
Emergency programs relating to animal and plant health by their very
nature, however, do not accommodate a "one size fits all" approach.
While some suggest a cost share formula would yield savings to the
Federal Government in future years, it will actually result in quite
the opposite for states, who are already bearing significant costs
associated with plant and animal pest and diseases that are not detected
at the border.
NASDA urges USDA to withdraw the proposed rule and work with states
toward the development of a joint system for the early detection and
eradication of plant and animal pests and diseases. NASDA's Animal
Health Safeguarding Review and the Safeguarding American Plant Resources
Review would provide a sound footing for the development of a science
based rule that combines the unique abilities of each partner. NASDA
discourages attempts to construct meaningful eradication programs around
budgetary decisions.
Bovine Spongiform
Encephalopathy —This current policy section
(approved September 23, 2003) has been suspended because of the major
changes proposed in federal policy, as a result of the identification
of a single cow infected with BSE in Washington State in December 2003.
NASDA’s BSE Working Group is currently rewriting the section.
Emergency Disease
Preparedness/Response — Government infrastructure
for emergency animal disease preparedness has decreased significantly
at both the state and national levels. This has led to serious concerns
regarding our ability to control and eradicate foreign animal and poultry
diseases in the United States. The economic and trade implications
are enormous.
Successful strategies for emergency disease preparedness will require
the combined cooperative effort of industry, government, and academia.
USDA, the states, and regional groups must work in concert to improve
communications and to prepare for dealing with emergencies involving
the introduction of foreign animal or poultry diseases. NASDA supports
the Animal Health Protection Act (AHPA) introduced in Congress in 2000.
The AHPA would be a powerful tool for safeguarding the United States
from dangerous incursions by granting the USDA broader authority.
Appropriate funding must be available to carry out an effective emergency
disease response program. The National Veterinary Services Laboratory
(NVSL) provides vital support for the animal health programs of the
Animal & Plant Health Inspection Service (APHIS). The NVSL plays
a crucial role in safeguarding the agriculture of the United States
from harmful disease events. Because of its importance in protecting
American agriculture, NASDA supports funding for necessary upgrades
to the NVSL Ames, Iowa, facility.
The heightened awareness of foreign animal diseases due to natural
events as well as intentional introductions has been met with like
attention to the needs of appropriate funding and infrastructure to
implement an effective emergency disease response program.
Although the threat for introducing any
foreign animal disease into the US is high, the spread of Chronic Wasting
Disease (CWD) poses the most immediate threat in the US, as well as
multifaceted challenges that impact State Departments of Agriculture,
Natural Resources, animal diagnostic laboratories, the farmed cervid
industry, deer processors and hunters:
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The health of captive herds must
be carefully monitored to protect the economic future of the
captive cervid industry
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Surveillance of the free
roaming cervid population must be conducted to determine the prevalence
and spread of the disease.
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Hunters must have a means of determining
whether the animals they harvest are free of disease.
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The annual
deer harvest must be sufficient to control population.
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Licensed
deer processors require assurance of the disease status of
hunter-killed deer in order to protect conditions in their facilities.
Central to the challenges is the need for reliable, rapid diagnostic
testing for CWD. Current restrictions on state testing do not promote
the broad-based, rapid testing necessary to meet potential demand.
USDA’s National Veterinary Services Laboratory (NVSL) conducts
CWD surveillance, but is not equipped to provide the fast-turn around
testing service required by hunters and processors and necessary to
support programs of the Departments of Agriculture and Natural Resources.
The current timetable for CWD results at NVSL is two to four weeks.
State laboratories must be able to provide CWD testing service. The
majority of state-run diagnostic laboratories are prohibited from possessing
reagents necessary to run the tests. A limited number of laboratories
recently authorized under contract with NVSL are required to use specific
equipment (Ventana) and protocols established by NVSL.
Non-contract laboratories that own and use quality immunohistochemistry
stainers capable of producing accurate CWD test results must purchase
a $45,000 Ventana immunohistochemistry stainer and a host of expensive
commodities to be recognized by NVSL.
NASDA acknowledges that prevention, containment and eradication of
foreign animal diseases will require cooperative efforts of federal
and state governments, industry, and academia. Further, NASDA urges
USDA to:
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Expand the authorities of state-run diagnostic
labs to conduct tests for foreign animal diseases, including CWD.
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Implementation
of appropriate protocols to enhance the nation’s
infrastructure to address foreign animal diseases, including accepting
test results from laboratories that utilize systems other than Ventana,
which produce accurate foreign animal disease test results.
Significant animal mortalities from natural disasters as well as recent
outbreaks of infectious animal diseases such as Avian influenza demand
expeditious and appropriate disposal of animal carcasses in a manner
that will prevent disease spread, prevent excessive air emissions and
prevent ground water and environmental contamination by infectious
agents or by the byproducts of decomposition. State and federal agencies
must have protocols, authorities and approvals in place for appropriate
animal carcass disposal prior to, and not after, emergency disease
or emergency mortality events.
Accurate identification of animals and products, traceability, and
documentation of events is essential to ensure appropriate measures.
In addition, adequate laboratory and diagnostic capabilities as well
as essential interagency real time communication of critical information
are important elements for animal carcass disposal. States must have
necessary statutory authorities to deal with proper disposal of affected
agricultural materials from either disease or other disaster incidences
whether from imported or domestic animal production,
NASDA will work to formulate and gain approval from all agriculture
and environmental agencies of appropriate protocols for permit sanitary
carcass disposal; to provide effective systems of identification; to
promulgate needed authority in model language; to authorize needed
resources and laboratory and diagnostics capacities; and to effectively
incorporate interagency communication agreements.
Wild and Exotic Animals — The unregulated, or inadequately regulated
importation, commercialization, interstate movement and reintroduction
of wild and exotic animals, including cervidae and other wild and exotic
ungulate species, poses a disease risk to domestic livestock. Even
the barter and sale of surplus animals from quarantined zoos could
result in the dissemination of diseases presently foreign to the domestic
livestock. There is a need within the United States to address all
susceptible animal species in disease control regulations. The failure
to do so will jeopardize the success of national disease eradication
programs.
Non-indigenous ticks are entering the United States with imported “wildlife” such
as lizards, snakes and tortoises, which are imported for the pet trade.
These ticks threaten cattle and wildlife by possible transmission of
diseases that could cause great economic hardships to agriculture and
inhibit foreign trade. Apparently no federal agency has responsibility
for the inspection and control of these invasive pests as they arrive
on “wildlife” from countries with known infestations of
dangerous foreign diseases. Few acaricides have been approved for treatment
inside the United States of these “wildlife” for the pests.
NASDA encourages the USDA and all other agencies to work closely with
foreign governments, with frequent interchanges of information and
technical assistance between countries, so that the prevention/eradication
efforts and elimination from all animals being exported can be coordinated
with prevention/eradication of these pests in the United States. NASDA
urges that APHIS and the U.S. Fish and Wildlife Service take all necessary
measures to prevent the introduction of non-indigenous ticks into the
United States.
Uniform Disease Testing — Uniformity in livestock disease quarantine
protocols between the United States, Canada and Mexico demands some
attention. In some cases, the United States’ requirements are
unnecessary and, perhaps, redundant, while in other cases, compliance
with those import requirements is not being met. Disease testing requirements
that are applied by all three countries would assure that protocols
are being met and that each country’s animal and public health
is adequately protected.
NASDA believes that the United States, Canada, and Mexico should work
together to develop disease testing protocols which are based on the
assessment of risk of disease introduction and to develop uniformity
and transparency in disease control programs.
Rights of States — NASDA diligently supported the Animal Health
Protection Act (AHPA), the purpose of which was to modernize this nation’s
ability to safeguard animal health. State animal health officials were
careful to ensure that AHPA language did not appear to preclude states
from enacting and administering laws and regulations more stringent
than federal requirements in order to safeguard an individual state’s
animal industries.
To the surprise of state officials, APHIS
administrators in April 2003 reported that enforcement of state
animal health requirements which are more restrictive than federal
policy could be legally challenged.
Federal officials cited legal interpretation of the new AHPA language
as their authority for federal
preemption of state regulations. From a state perspective, lack of
enforcement of state requirements could
result in state officials being in violation of their own state statutes.
The long and successful history of major
federal disease control programs (e.g. brucellosis, tuberculosis,
pseudorabies) have historically relied upon preceded actions at the
state level for successful eradication, in collaboration with the private
sector. The Livestock and Horticulture Subcommittee of the United States
House of Representatives Agriculture Committee is considering a hearing
to address the implementation status and areas of concerns of the AHPA.
NASDA defends the rights of states to adopt and enforce statutes,
regulations, policies that may be more restrictive than federal requirements
in order to have necessary protections of animal health and animal
industries in their state.
Regional Equine Event
Permits — The movement of equine between
states in the southern region for special events (e.g. exhibition,
trail rides, horse fairs) has become increasingly popular. All states
require a Certificate of Veterinary Inspection (CVI) issued within
the previous 30 days and evidence of a negative equine infectious anemia
test for a specified length of time (typically 12 months) in order
for equine to enter their states. Georgia, Alabama, and Florida have
had a mutual agreement for approximately 15 years that allows movement
of equine for special events for a six month period through the issuance
of an Equine Event Permit issued by the state of origin. An additional
agreement with South Carolina has been in place for approximately one
year. Such permit is not valid for change of ownership.
The Southern Animal Health Association
is currently pursuing a Memorandum of Agreement between the southern
states for a Regional Equine Event Permit. The southern state veterinarians
agree that such a
permit for this type of equine movement presents minimal risk for the
introduction of disease and facilitates movement of equine throughout
the southern region. NASDA supports efforts to implement a Regional
Equine Event Permit and encourages each member to approve its use in
their state.
Infectious Disease
Concerns of Poultry and Other Birds — Outbreaks
of Exotic Newcastle disease (END) and avian influenza (AI) are costly
and disruptive events for many Americans and significant threats to
the U.S. food supply. There is a 30-year-history of repeated outbreaks
of END and AI, and other dangerous avian diseases. The danger of these
diseases is significantly magnified when they spread
into and among backyard and barnyard flocks of poultry, game birds,
game fowl, waterfowl and other avian species. Thousands of these types
of flocks exist in many states, often in close proximity to commercial
poultry operations. The composition, management and exact locations
of these critically important flocks are often unknown. Therefore,
mitigation of this dangerous situation by education and, when needed,
regulatory action first requires the identification of the addresses
and geographical
locations of these flocks. Such identification would benefit from assistance
from various grassroot county and township agencies. NASDA encourages
states to give high priority to the formation of pilot studies, in
cooperation with grassroot agencies, to find locally appropriate ways
and means to precisely locate backyard and barnyard flocks, and other
birds. In addition, states are encouraged to explore a national strategy
to advance the identification and biosecurity of backyard and barnyard
flocks, and other birds.
NASDA will survey states to learn of their policies, activities and
concerns related to regulation of backyard and barnyard flocks, and
other birds.
Cost-Share Criteria
for APHIS Emergency Programs — APHIS has
published a proposed rule that would codify a standardized cost-sharing
formula for animal disease and plant pest and disease emergency eradication
programs that are conducted cooperatively with states. Unfortunately,
expanding world trade and the threat of bio-terrorism have increased
the risk of destructive pests and diseases being introduced into the
United States. The United States Department of Agriculture (USDA) is
the federal agency statutorily charged with preventing the introduction,
spread and establishment of plant pests and
diseases, noxious weeds and pests and diseases of livestock in the
United States. States are not federally mandated to partner with USDA
in this endeavor yet have historically done so with great success.
Developing a plan on how the USDA should respond to emergencies is
not without merit. In fact, NASDA's Animal Health Safeguarding Review
and the Safeguarding American Plant Resources Review conducted by the
National Plant Board contain recommendations that would facilitate
the kind of out year planning envisioned in the proposed rule.
Emergency programs relating to animal and plant health by their very
nature, however, do not accommodate a "one size fits all" approach.
While some suggest a cost-share formula would yield savings to the
Federal Government in future years, it will actually result in quite
the opposite for states, who are already bearing significant costs
associated with plant and animal pest and diseases that are not detected
at the border.
NASDA urges USDA to withdraw the proposed rule and work with states
toward the development of a joint system for the early detection and
eradication of plant and animal pests and diseases. NASDA's Animal
Health Safeguarding Review and the Safeguarding American Plant Resources
Review would provide a sound footing for the development of a science-based
rule that combines the unique abilities of each partner. NASDA discourages
attempts to construct meaningful eradication programs around budgetary
decisions.
1.3 APHIS Reorganization And Consolidation
USDA’s Animal and Plant Health Inspection Service (APHIS) consolidated
the following offices — Veterinary Services (VS), Plant Protection
and Quarantine (PPQ), Wildlife Services, Animal Care, and Investigations
and Enforcement Services — into two regional offices. The consolidation
streamlined the administration of programs, permitted cross utilization
of personnel, and made the agency more responsive to the needs of the
states and their constituencies. NASDA commends APHIS for its efforts
to seek efficiency within the federal government and to improve satisfaction
of its constituencies. We recognize the importance of the consolidation
of APHIS programs into eastern and western regional offices as a cost
savings measure, while maintaining accessibility by customers and partners.
NASDA recommends that, to prevent negative impacts on services, costs
for future reorganizations should not be taken from operational programs,
but from agency overhead savings.
Further, NASDA recognizes that plant and animal health issues may
not be similar within the consolidated regions and that current funding
levels of programs in a particular region may be diminished due to
priority setting as a result of the regional consolidation. NASDA urges
APHIS to consider the plant and animal health needs of the states within
the current regional composition when allocating program funding.
NASDA strongly supports increasing funding to PPQ Unit for the purpose
of interception of illegal and smuggled food products that pose a direct
threat to the food security of the United States of America and to
homeland security. NASDA also strongly supports increasing APHIS’s
ability to fine and prosecute offenders of United States’ agricultural
import laws. NASDA also recognizes that the 48 inspectors that the
PPQ Smuggling and Interdiction Program has for inspection of all imported
food and agricultural products into the United States is severely inadequate
and further poses a direct flaw in the United States’ ability
to ensure food security and homeland security.
1.4 Animal Damage Control
USDA’s Wildlife Services program (formerly the Animal Damage
Control program) provides leadership in managing problems caused by
wildlife. Managing wildlife is important to reduce damage to agriculture
and natural resources, to minimize potential threats to public health
and safety, and to protect other species. Strategies are implemented
that are environmentally, socially and biologically sound. NASDA supports
the efforts of the USDA to manage wildlife and to protect American
agriculture and other aspects of human life.
The emergence and demonstrated spread of rabies in the United States
has overwhelmed state rabies control and prevention programs. NASDA
supports the appropriation of federal funds to support rabies control
and vaccination programs.
1.5 Animal Drugs
Livestock Tampering at Exhibitions — Livestock tampering and
the use of illegal drugs at exhibitions around the nation have become
prevalent. Some states have passed laws or have considered legislation
making it a felony to administer illegal or unapproved drugs to livestock,
or otherwise illegally tamper with livestock before or during exhibition.
Valid tests have been developed to detect the use of drugs in livestock
exhibitions.
Several implications exist if action is not taken on this issue. First,
public safety and health issues exist regarding the wholesomeness of
meat and dairy products. Second, the use of illegal, unapproved, or
off-label drugs in exhibition livestock jeopardizes consumer confidence
in the safety of meat and the integrity of our inspection system. And,
third, the “win at all cost” attitude of some exhibitors
and fitters encourages unethical practices.
NASDA denounces tampering and other unethical practices at livestock
exhibitions and encourages states to aggressively survey and test at
exhibitions to ensure that food safety, consumer confidence and ethical
standards are upheld. The federal government should provide aid in
combating the administration of illegal drugs to exhibition livestock.
Further, a national code of conduct/practices for showing exhibition
livestock should be developed by the National Association of Agricultural
Fair Agencies.
1.6 Animal Welfare
Quality animal care is at the heart of farm animal production in an
age when science and technology have moved farming from horsepower
to computer power. Farmers and ranchers devote their lives to providing
a safe, ample supply of food and fiber for the nation and many beyond
our borders.
Farming is a business and farm animals are not pets. Because the margin
between costs of production and marketing products is so small, today's
producers recognize that poor or inhumane management is never profitable.
Our nation's farmers and ranchers must use the highest quality, most
nutritious feeds, provide safe, clean stress free environments coupled
with a love for their animals to obtain even small margins of profit.
However, there is a clear distinction
between animal welfare and animal rights:
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Animal Welfare is the proper
care and management of animals. Farmers and ranchers believe animals
raised under humane conditions and practices will be productive
and profitable.
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Animal Rights philosophy goes beyond the
promise of protecting the physical well-being of animals and
seeks to establish that animals have inherent legal and ethical
rights that are equal to those of humans. Adhering to this philosophy
would mean the complete elimination of all uses of animals
for food, clothing, leisure or research. This would lead to the
total abolition of animal agriculture.
A healthy diet is based upon moderation and animal food products are
an excellent source of essential dietary nutrients. Fat is necessary
for hormone production and healthy skin and enables the body to absorb
fat-soluble vitamins such as A, D, E, and K as well as providing calories
for energy.
Advances in modern medicine, as well as agriculture production, have
been made possible as a result of research involving the use of animals.
We support the humane and judicious use of animals in research carried
out under good laboratory practices.
There is a growing need for adding animal welfare, which will include
information on the value of farm animals, to the curriculum for elementary,
middle and junior high schools. Youth programs should provide appropriate
developmental and learning opportunities through working with farm,
companion or when appropriate, research animals.
Public concern about animal welfare continues to increase. The industry
should address such concerns including the increasing need for both
consumer and industry education about the welfare of animals and their
value to the nation, new techniques to assure and improve the welfare
of animals, national voluntary standards for animal husbandry practices,
mechanisms to assure fair and proper enforcement of animal welfare
regulations, government funding for this increased regulatory burden,
and stronger laws and regulations to end threats, harassment, destruction
and disruptive actions by animal rights activists.
Animal welfare regulations and guidelines should be developed and
promoted by the appropriate industry segment. These regulations should
include guidelines about animals used in biomedical research; standards
of practice for all livestock species, both for production and marketing
including transportation; the handling of downer animals; and animal
care including a protocol for farmers and ranchers to use to evaluate
the welfare of animals on their farms and ranches. NASDA also encourages
the dairy industry to adopt voluntary guidelines for the care of dairy
cattle, and to urge that any requirements regarding the treatment of
animals be based on science.
We support the humane and compassionate care of all animals and encourages
the development of educational programs and activities that communicate
factual information on food and fiber production to the public. Research
should be conducted that evaluates and develops production systems
that insure an optimum environment for animals while simultaneously
providing an economic and wholesome food and fiber supply for the nation's
consumers.
We believe that the goal of all persons involved in production animal
agriculture should be to produce a quality food or fiber product for
consumers. In order to accomplish this goal, producers and all other
components of the marketing chain must operate in a profitable manner.
Maintaining the health, welfare and value of animals as they are raised,
marketed, transported and processed is of central importance.
1.7 Domestic Bee Protection
The continued production of high quality food and fiber crops in the
United States depends on the ability of the American beekeeping industry
to provide pollination services. Research initiatives conducted by
the U.S. Department of Agriculture-Agriculture Research Service (USDA-ARS)
to protect and improve pollination resources have allowed the American
beekeeping industry to become the finest in the world.
International trade agreements such as GATT and NAFTA were intended
to lower international trade barriers, the effect of which may have
contributed to the increase in the recent introduction of undesirable
honey bee diseases, parasites, pests, and/or genetic strains of bees
into the United States. These recent introductions of bee diseases
and pests have increased the burden on American beekeepers to maintain
a healthy domestic supply of bees. An example is the Africanized honey
bee. The Africanized honey bee (AHB) has characteristics that pose
a threat to the United States beekeeping industry and the general public.
It is essential to maintain a healthy domestic bee stock to pollinate
crops, and for the production of honey. NASDA encourages the USDA to
vigorously enforce the Federal Honey Bee Act in order to protect the
beekeeping industry from introductions of undesirable honey bee diseases,
parasites, pests, or genetic strains of bees in the United States.
Pollinator and bee disease research programs should also continue to
receive adequate funding.
New regulations are being established for the importation of honeybees
and related articles. It is therefore important that APHIS has data
of the current status and risks of honeybee diseases and pests available
so that informed decisions may be made regarding future import requests.
NASDA requests that APHIS provide a mechanism similar to the Cooperative
Agricultural Pest Survey (CAPS) for the purpose of establishing an
ongoing, coordinated, nationwide survey to document the presence and/or
absence of pests and pathogens which affect honeybees.
1.8 Brucellosis In Yellowstone Bison
Brucellosis has been known to exist in the bison of Yellowstone National
Park (YNP) since 1917 and in the elk of the Greater Yellowstone Area
(GYA) since the 1930s. Numerous intermittent efforts during the time
between 1935 and the 1970s have been made by USDA and state animal
health officials to gain cooperation of the National Park Service
(NPS) to control and eradicate brucellosis from YNP bison. More diligent
efforts have been continuous since 1988.
Until 1967, NPS officials conducted population controls of both bison
and elk in YNP to maintain the population of bison and elk within the "carrying
capacity" of the park (425 bison and 3,500 elk). These controls
included capture and slaughter of bison, and the shooting of bison
and elk. In addition, bison were tested periodically and reactors removed.
YNP officials removed bison from the park and transferred ownership
of YNP bison to other federal agencies and to private citizens. Some
of these transfers were made without regard to the disease status of
the bison.
In 1967, NPS initiated a policy of "natural regulation" (hands
off management) within YNP. The bison population in YNP was 397 head
in 1967. The bison population in YNP has been reduced from an estimated
3,500 head in 1996 to approximately 1,700 head as a result of the destruction
of approximately 1100 head and the starvation of approximately 1000
head in YNP during the winter of 1996/1997. The current population
in GYA consists of 2,5000 bison and 120,000 elk. The Grand Teton National
Park contains 250 bison.
Brucellosis infection in cattle, resulting from exposure to brucellosis-infected
wildlife, may not be discernible for many months after the exposure
occurred. The end result could be transmission of brucellosis to herds
in a number of states. Without brucellosis eradication, efforts to
set aside additional lands outside YNP are deceiving to the public
and dangerous to domestic livestock and should be discouraged.
The President should delegate authority and responsibility for animal
disease control over livestock, and animals carrying disease which
may affect livestock, to APHIS, the agency specifically established
for that responsibility. APHIS should be involved in the effort of
eradicating brucellosis from the wild populations of bison and elk
living within the Greater Yellowstone Area (GYA).
The NPS should take responsibility for managing the wildlife, implementing
a brucellosis management plan for bison and other species located in
Yellowstone-Teton National Parks, and other parks in the system, and
maintaining numerically, biologically, and genetically viable bison
populations in the parks that will maintain the brucellosis Class Free
status of Wyoming, Montana, and Idaho, thus protecting the ability
of livestock producers to freely market and buy livestock, eliminating
brucellosis-related risks to public health.
NASDA urges the Administration to direct Agriculture and Interior
to collaborate with state agencies to address Brucellosis in wildlife
in the GYA and to provide sufficient resources to control and elminiate
Brucellosis from wildlife of the GYA.
1.9 Aquaculture
Aquaculture — the business of farming aquatic plants and animals — is
the fastest growing segment of U.S. agriculture. Aquaculture is based
on sustained production of renewable resources, promotes a healthy
environment and provides an economically viable form of
agriculture. As phenomenal as the growth of aquaculture has been over
the past three decades, there remains significant constraints to realizing
its full potential as a major force in American agriculture.
NASDA believes aquaculture should be considered a form of agriculture
in the broadest sense and aquaculture products should be viewed and
treated as agricultural commodities. This means that the aquaculture
industry should have access to USDA financing, crop insurance, soil
and water conservation, commodity grading and other marketing services
and be subject to USDA’s inspection and regulatory requirements
comparable to those currently applicable to meat and poultry. Development
of the aquaculture industry would be enhanced if the Department of
Agriculture’s (USDA) leadership role in aquaculture was reaffirmed.
Furthermore, we encourage USDA to work with other federal agencies
including established Sea Grant and National Marine Fisheries Service
(NMFS) programs in the Department of Commerce and U.S. Fish and Wildlife
Service (FWS) programs within the Department of the Interior in order
to enhance the role of the aquaculture industry in agriculture.
NASDA believes regulatory constraints imposed upon the aquaculture
industry should be clarified, streamlined, and consolidated. The treatment
of aquaculture as a form of agriculture by local, state and federal
regulatory agencies should enhance development of the industry from
a regulatory standpoint and provide a positive climate for development.
Water Quality standards and regulation need to be based on science
and reasonable risk assessment procedures. The US Environmental Protection
Agency should rely strongly on the expertise within USDA and the aquaculture
organizations in evaluating new technologies and best management practices
for aquaculture, which can be utilized to improve water quality.
We believe the development of sound marketing strategies is crucial
to the orderly and progressive development of the U.S. aquaculture
industry. The research, extension and market development infrastructure
utilized for other agricultural commodities has not adequately addressed
opportunities for aquaculture. There is a need for collaborative research
and education (with industry participation) to better identify consumption
trends, market structure, market access, market elasticity, regional
preferences, product form and demand equations from a regional, national,
and international perspective. The opportunity for new international
markets and the rise in competition from abroad increases the need
for continued and expanded evaluation of foreign markets, trade constraints
and markets potentials.
Further, there is a need for improved crop and marketing reports and
a better definition of market relationships among domestic and foreign
aquaculture products and traditional fisheries products. We support
strong marketing education of producers and processors as well as consumers
such as home processing, preparation and the nutritional quality of
aquaculture products.
NASDA urges the Office of Management and Budget to approve USDA’s
National Agricultural Statistics Service funding for an annual aquaculture
census which would provide statistics on the number of aquaculture
farms, number of units sold, total sales, and average price per unit
for most species for places which have or normally have $1,000 or more
in agricultural sales. The census would provide data for the major
species under the following categories: food fish, baitfish, ornamental
fish, sport or game fish, crustaceans, and mollusks. Aggregated information
for other fish and aquaculture products would also be published. Estimates
would be published for each of the 50 states and the United States,
except where prohibited by confidentiality laws. The estimated cost
of conducting a census of this scope is $213,240 per year. The first
annual census would update the information published in the 1998 Census
of Aquaculture. This is the only source of aquaculture information
for all 50 states and the United States.
NASDA believes the development of improved processing technologies
and new products development represent important opportunities for
the aquaculture industry. New value -added products can contribute
to both domestic and export markets. NASDA endorses the HACCP principles
for aquaculture processing and encourages USDA and FDA to provide on-going
training for the industry that is both cost effective and focused.
Adoption of uniform quality standards throughout the aquaculture industry
and assurance of product safety and high quality could assure a competitive
edge for aquaculture products over the traditional capture fisheries
or imported aquaculture products.
NASDA believes the process of development of minimum health standards
by USDA should be with the direct involvement of the major aquaculture
organizations, insuring coverage of all species groups and uses for
the interstate and international movement of aquatic animals and plants.
This is critical to the continued viability and growth of the aquaculture
industry, domestically and abroad. The recognition of these standards
will facilitate the movement of aquaculture products in commerce and
protect the industry from losses due to disease outbreaks and adverse
public opinion. Further, there is need for the development of rapid,
non-lethal sampling and testing techniques for the diagnosis of aquatic
diseases as well as state and national surveillance systems to identify
disease early in its course. Regulatory constraints utilizing new identification
methods and testing protocols should have nationally accepted validation
and interpretation prior to adoption.
The development of the U.S. aquaculture industry is severely constrained
by a lack of federally approved chemicals, vaccines, and therapeutic
compounds that could contribute to increased production efficiency
and offset annual losses of millions of dollars to disease and parasites.
The process of certifying shipments of live fish and aquaculture products
for export needs to be streamlined in the areas of jurisdiction as
well as the use of therapeutants and disease free status. There is
opportunity to facilitate the process of clearance and approval of
desirable and safe therapeutants through research to provide necessary
information, through improved communications among government agencies
and the industry, and through increased understanding of the aquaculture
industry by regulatory agencies. We encourage the enhancement of the
role of the National Research Support Program - 7 (NRSP-7), formerly
IR-4 Program, in order to provide further assistance to aquaculture
for development of minor use drugs.
World trade is increasing, and therefore the threat of the introduction
of new pests and diseases of honeybees is also increasing. 2. Soybean
Rust
1.10 Animal Identification
The number of animals officially identified in the United States has
been decreasing rapidly over the last few years due to the successes
of disease eradication programs that have historically provided the
foundation for animal identification. The ability to efficiently
track animals from birth to slaughter is vital to safeguarding animal
health, protecting the safety of the U.S. food supply and promoting
the economic vitality of animal agriculture.
An industry-state-federal partnership, aided by the National Institute
for Animal Agriculture, was formed in 2002 to more uniformly coordinate
a national animal identification plan. The resulting plan, requested
by the US Animal Health Association and facilitated by USDA’s
Animal and Plant Health Inspection Service, built upon previously established
and successful animal health and animal identification programs involving
many animal industries. More than 100 animal industry and state-federal
government professionals representing more than 70 allied associations/organizations
collectively assessed the plan to meet future U. S. animal identification
needs.
The U.S. Animal Identification Plan (USAIP) calls for federal standards
and oversight that will enable states and industry organizations to
develop a flexible network of linked databases to trace diseased animals
within 48 hours, a goal established as necessary if animal diseases
are to be properly responded to. Linked databases will be needed to:
-
Identify where animals are kept
(premises registration)
-
Identify individual (or groups/lots)
of animals (animal identification)
-
Track movements of individuals
or groups/lots of animals from premise to premise (animal tracking)
While the USAIP initially supports eleven animal industries with species-specific
standards applying to all animals within the represented industries,
the plan is flexible enough to accommodate modifications. The USAIP
provides a practical framework for continued planning and implementation
of a workable national animal identification program that provides
states and industry organizations with flexibility to develop premises
registration and animal identification systems that meet their own
unique needs while providing standards that will enable national interoperability.
The costs associated with USAIP will be substantial and the plan will
continue to evolve over time.
NASDA supports using the USAIP as the model plan to establish state
and national programs of animal identification. NASDA supports funding
the program to incrementally implement premises registration and animal
identification consistent with the USAIP, recognizing that incremental
development of premises registration and animal identification systems
will provide immediate benefits in terms of safeguarding animal health
and provide necessary infrastructure for implementation of 48 hour
animal tracking. NASDA also supports the long-term state and federal
investment that must be made to maintain an animal identification component
of safeguarding animal health.
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