Comment from Paul R Frischknecht, American Sheep Industry Association

October 5, 2006 Regulatory Analysis and Development PPD, APHIS Station 3A-03.8 4700 River Rd, Unit 118 Riverdale, MD 20737-1238 Re: Docket No. APHIS-2006-0120 (Importation of Sheep and Goat Semen) We are writing on behalf of the American Sheep Industry Association, Inc. (ASI). ASI is the national trade association for the United States sheep industry representing approximately 68,000 producers through our 43 state affiliates. We appreciate the opportunity to provide comments on this proposed rule. ASI appreciates the Agency?s diligence in reviewing the import regulations for semen in light of current science and OIE guidelines. The U.S. sheep industry is very committed to eradicating scrapie and has expended a great deal of resources over the past several years in partnership with USDA/APHIS and State animal health authorities toward this end. It is also very important to the U.S. sheep industry that we complete the eradication process in the shortest time possible. At the same time, trade interest should be accommodated to the extent low-risk products can be identified, appropriate risk-mitigation measures put into place with international acceptance of these measures and no reduction in the recognized disease-risk status of the U.S. sheep flock because of trade in these products. ASI believes that for the most part, the proposed amendment to 9 CFR Part 98 is appropriate and that the amendment would relieve the restrictions on sheep semen while continuing to provide safeguards against the introduction and dissemination of scrapie and conform to international (OIE) standards. The proposed provisions provide that: Imported semen be accompanied by an international veterinary certificate stating that in the region of origin, scrapie is a compulsorily notifiable disease; there is an effective surveillance and monitoring system plus other related provisions including ID of the donors; destruction of scrapie affected sheep; an effective ruminant to ruminant feeding ban and the assurance that the donor animals were not affected with scrapie or the progeny of scrapie affected animals. However, we believe that the proposal can and should be made more uniform with fewer burdens on importers and less costly to APHIS. Due to the high compliance rate of flock premises registration through the National Scrapie Eradication Program, the vast majority of sheep operations are listed in the Scrapie National Database and there are continuing industry, State and federal efforts to list those that are not currently listed. ASI believes that when semen is imported from any country that it should be distributed only to a flock that is listed in the Scrapie Page 2 Docket No. APHIS-2006-0120 (Importation of Sheep and Goat Semen) October 5, 2006 National Database. This should provide for better traceability and enhance the overall scrapie eradication effort. Additionally, we recommend that the requirement that all first generation (F1) progeny resulting from imported semen be permanently identified and records of sale kept for five years can be accomplished in a more cost-effective and less onerous manner by making the requirement a condition of the import permit rather than requiring a formal agreement between the importer and APHIS. We also recommend that APHIS distribute special ear tags to the importer for the purpose of identifying the F1 progeny when the permit is approved. The collective experience of industry along with our State and federal partners demonstrates that traceability is augmented when animals carry identification. In the proposed rule, APHIS states: ?While the risk of scrapie transmission from sheep semen is believed to be minimal, no studies have been done regarding the transmissibility through semen of other animal TSEs and certain other diseases in small ruminants. For this reason, traceback of progeny is essential.? ASI certainly concurs with these statements and we believe this makes a strong case for uniformly requiring importers of semen from all countries to meet the requirements as listed in the proposed rule and as discussed above whether they are recognized as being scrapie-free or not. In summary, the U.S. sheep industry, along with the public sector, is investing heavily in and committed to eradicating scrapie from the U.S. Trade in sheep semen should be accommodated where disease risk is demonstrated to be at an acceptably low level and where risk mitigation measures and verification/traceability systems are put into place and enforced with uniformity and consistency. Sincerely, Paul R. Frischknecht President