Comment from Francisco Muzio

The Ministry of Livestock, Agriculture and Fisheries of Uruguay (MGAP) expresses its satisfaction for this public consultation.. The possibility of exporting ovine meat to the American market will open new opportunities for our “family farms” . But it will not cause any loss to American farmers, due to the reduced volume of Uruguayan production. American consumers will get a direct benefit having access to a very high quality product with all the guarantees of health and safety required by a highly demanding market. However, the conditions proposed by APHIS in this rule imply changes in the current conditions required for the import of beef from Uruguay. Since that may disturb, in the future, a well established commercial flow of common interest, the MGAP means necessary to carry out the following remarks, on the basis of norms and standards of the OIE. As a condition to export fresh beef, the current rule requires that "Foot and mouth disease have not been diagnosed in Uruguay within the previous 12 months." In the proposed rule, APHIS establishes ( paragraph 94.22 point "b") that "if Foot-and-Mouth Disease is detected anywhere in Uruguay, the export of beef and ovine meat from all of Uruguay to the United States is prohibited until at least 12 months have elapsed since the depopulation, cleaning, and disinfection of the last infected premises." The new rule provides that if FMD is diagnosed “anywhere in Uruguay“ the exports of fresh beef and ovine meat shall be prohibited from “all of Uruguay”. This provision should be in accordance with the principle of regionalization established in the WTO-SPS Agreement and the OIE standards. Furthermore, the proposed 12 month period to resume exports in the event of an outbreak of FMD should also comply with the established term (6 months) of the Animal Health Code of the OIE. Last but not least, it is understood that the proposed depopulation process means the sanitary sacrifice of infected animals in the outb