Comment from Lee Jan, DVM, Texas Animal Health Commission

APHIS is proposing to add the Czech Republic, Latvia, Lithuania and Poland to the list of regions recognized as free of Classical Swine Fever (CSF) and Swine Vesicular Disease (SVD). APHIS' risk analyses concluded EC legislation imposes less stringent restrictions on sourcing of imported ruminants and swine than do APHIS requirements, resulting in some risk of introducing CSF, SVD, or Foot and Mouth Disease (FMD) into the Czech Republic, Latvia, Lithuania, Poland or other EU Member States via imported animals or animal products. The proposal states this risk is substantially mitigated by factors such as veterinary inspection of live animals prior to shipment. However, this same document states that some forms of CSF, SVD, and FMD are difficult to detect in live animals or on post-mortem examination. Therefore, it seems that the main mitigating factor as presented in this document is ineffective in some instances. How can we be sure that the animals imported to that region will not come in contact with animals to be exported to the U.S. or that some of those animals imported to that region would not then be included in an export to the U.S.? APHIS also proposes to add Latvia and Lithuania to the list of regions recognized as free of FMD and rinderpest, yet subjects those countries' ruminant and swine meat products for export to the U.S., to certain restrictions to prevent the introduction of FMD and rinderpest into the U.S. Due to the proximenty of FMD affected or potentially affected regions, APHIS' risk analysis concluded that the potential exists for introduction of FMD into Latvia or Lithuania via wild animals, incoming vehicular or human traffic, smuggled animal products, or other routes. Neither country has active disease control programs in place for FMD. Biosecurity measures, according to the proposed rule preamble, on ruminant operations, are generally not sufficient to prevent direct and/or indirect contact with wildlife or contact with live virus on clothing or vehicles. We urge that this rule change not be implemented.