Comment from Monica Engebretson, Animal Protection Institute

February 15, 2007 Docket No. APHIS-2006-018 Regulatory Analysis and Development PPD, APHIS, Station 3A 03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238 RE: Importation of Uncooked Pork and Pork Products To Whom It May Concern: On behalf of the Animal Protection Institute (API), a national animal advocacy organization, I urge the APHIS to evaluate the impact of the proposed rule on human and animal welfare. While the costs associated with pig mortality and loss of meat quality are likely more than compensated by the ability to take advantage of low wages paid to laborers in Mexican slaughterhouses, this proposed rule has the potential to increase costs terms of human and animal welfare. This is especially true if the proposed rule results in an increase in live pig exports to Mexico plants and increase in production pressure on Mexican plant workers. In 2005, API and the UK-based Compassion in World Farming documented pigs being transported over the U.S.?Mexico border on crowded trucks through many hours of baking desert heat without food, water, or rest, en route to Mexican slaughterhouses. Conversations between investigators and pig dealers in the U.S. revealed that low labor costs and the lack of government oversight in Mexico are considered the primary (if not the only) benefits of sending live pigs to Mexico for slaughter. Indeed, labor costs in pork-processing plants are nine times lower in Mexico than the U.S. (Reynolds 2007). On average, production workers in Mexico make $2.24 per hour compared with $18.61 per hour in the United States (Reynolds 2007). Time spent in transit is stressful both physically and mentally for farmed animals. Transported animals are subjected to social challenges from unfamiliar animals, handling by people who are sometimes untrained and unskilled, loading onto and off vehicles, exposure to vibration, noise, unfamiliar surroundings, long journeys, and deprivation of food and water. Other problems during transport include overcrowding, lack of bedding and lack of opportunities for rest, and exposure to extreme heat or cold (Warriss 1998). Pigs are especially sensitive to transport stress. According to data from a survey of packer members of the National Institute of Animal Agriculture (Bowling Green, KY), approximately 80,000 hogs die annually during the transit process in the United States (Grandin 1992). Seventy percent of these losses occur on the truck during transportation, and 30 percent occur shortly after arrival and are directly attributable to the transportation process (Grandin 1992). Estimates from the Agriculture Department?s Food Safety and Inspection Service (FSIS) report a higher death rate ? 0.26 percent, which translates to 260,000 pigs per year. It has also been estimated that 0.08 percent of pigs taken to market in the U.S. arrive as ?fatigued? ? out of breath and unable to get off the truck on their own. This would translate to approximately 82,400 ?fatigued? pigs in 2005 (Kelley 2005). It is reasonable to assume that loss and fatigue rates are much higher in pigs transported to Mexico. It is also well documented that animals fare poorly in U.S. slaughterhouses. A 2004 report prepared by the United States General Accounting Office (GAO) on the frequency of Humane Methods of Slaughter Act violations found that ?the most prevalent noncompliance documented was the ineffective stunning of animals, in many cases resulting in a conscious animal reaching slaughter? (GAO 2004). The GAO also found that USDA inspectors charged with enforcing the Humane Slaughter Act frequently fail to take enforcement action for violations of the Act (GAO 2004). Again, one can assume that animals fare even more poorly when even a pretext of the humane slaughter act is absent as is the case in Mexico. In addition, injury rates for workers in U.S. slaughterhouses have been estimated to be three times higher than in a typical American factory (Schlosser 2001). Pressure to move and process animals quickly, improper equipment, slippery environments, and inadequate training contribute to this high injury rate (Schlosser 2001). APHIS should consider the impact the proposed rule may have on injury rates and worker health in Mexican pork slaughter and processing plants as a result of any increase in production following approval of pending rule change. Consumer research shows that customers place a high value on locally-produced products and that they associate the term ?local? with reduced transport distance from farm to store. Moreover, customers are typically willing to pay 5 to 15 percent more for locally-raised meat items than for similar items that are not locally produced. Pork producers can increase profits by targeting such markets rather than taking advantage of poor labor and animal protection laws across our southern boarder. I thank you for your attention to this matter that is of great importance to API, our members, and to many Americans concerned about the welfare of animals and the ethical treatment of human workers. Sincerely, Monica Engebretson Project Director Animal Protection Institute Citations: General Accounting Office 2004. Humane Methods of Slaughter Act: USDA Has Addressed Some Problems but Still Faces Enforcement Challenges. GAO-04-247. Grandin T 1992. Livestock trucking guide: Livestock management practices that reduce injuries to livestock during transport. In: Livestock Conservation Institute, Bowling Green KY. Reynolds G. 2007. Regulator proposes re-opening border to Mexican pork. Truth about Trade and Technology http://www.truthabouttrade.org/print.asp?id=6859 Schlosser E 2001. Fast Food Nation: The Dark Side of the All-American Meal (New York: Houghton Mifflin Company). Warriss 1998b. Choosing Appropriate Space Allowances for Slaughter Pigs Transported by Road: A Review. Veterinary Record, 142, 449-454.