Comment from Lucy Garcia

Research suggests improvements are needed to the APHIS' screening process of foreign applications for the importation of animals; however, the rules proposed by the APHIS continue to exceed what’s currently underway or absent from the other regulatory agencies. In addition, the APHIS has implemented the Veterinary Services Strategic Plan of the APHIS, which intends by 2015 to expand the APHIS mission by addressing zoonotic disease and other animal types. Though APHIS is streamlining the application of the importation of animals into the US from eleven factors to eight, the changes do not appear to compromise current operations. Furthermore, by adding the OEI recommendation for regions historically clear of disease, (based on scientific evidence from the OEI), the APHIS is taking positive steps toward further preventing disease from animal imports. A commitment to continued collaboration with regulatory agencies and wildlife groups should be a continued focus of the APHIS. Some would suggest the ongoing threat of animal disease outbreaks should be cause alone NOT to reduce/change the APHIS’ existing evaluation criteria; however, because the importation of animals is a multijurisdictional approach, there is no evidence the proposed changes will have any negative impact on the current work of the APHIS’ and its prevention and control management of animal disease. A better consideration by the APHIS over the proposed rule should be to expand the APHIS’ oversight of other animals including rodents capable of communicating disease; the prioritizing of objectives, roles an activities in conjunction with the other regulatory agencies so that there is no overlap; and improved communications/data collection and data sharing among the regulators so that disease-related information in animals is available to all the regulatory agencies. As a final yet important consideration, APHIS should facilitate for the health certifications of ALL imported animals.