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Regulatory Cooperation Council – Foreign Animal Disease Zoning Recognition

Response to Comments Received: External Consultation on the Framework for Implementing and Maintaining the Arrangement between Canadian Food Inspection Agency and United States Department of Agriculture for the Recognition of Foreign Animal Disease Control and Eradication Zones

Introduction

Foreign Animal Disease (FAD) Zoning Recognition is an initiative under the United States (U.S.) - Canada Regulatory Cooperation Council (RCC). President Obama and then Prime Minister Harper created the RCC in 2011 to promote regulatory cooperation and facilitate trade, with resulting benefits for industry and consumers.

The first step in the FAD Zoning Recognition initiative was reciprocal evaluations of each country's veterinary infrastructure and emergency response capabilities, focusing on zoning to control FAD outbreaks. Based on the favorable outcome of these evaluations, the Animal and Plant Health Inspection Service (APHIS) and the Canadian Food Inspection Agency (CFIA) entered into an ArrangementFootnote 1 to recognize each other's zoning decisions in the event of a highly contagious (HCFAD) outbreak (note, the scope was limited to those FADs that have the ability to spread in an extremely rapid manner). The intent of the Arrangement was to facilitate trade between zones that remain free of the disease, while safeguarding animal health in both countries.

The CFIA and APHIS subsequently developed a frameworkFootnote 2 to implement and maintain the Arrangement over time. The agencies conducted an external consultation process for this framework over the spring and summer of 2014. APHIS published the Framework and associated documents on May 13, 2014, for a 60-day public comment period. The CFIA published the same documents for comment from June 11, 2014, to August 31, 2014.

APHIS received 11 unique comments during, and subsequent to, the public comment period, including recommendations from the Secretary of Agriculture's Advisory Committee on Animal Health. One comment consisted of 19,062 form letters opposing both Framework and Arrangement received from a citizen health advocacy group. The remainder were received from national and State livestock, meat, and dairy organizations and a national veterinary group.

The CFIA received 17 comments: two from individuals, five from national and provincial poultry organizations, seven from national swine, beef, dairy and meat organizations and a provincial sheep association, one from a packer/exporter, one from a consumer group, one from a provincial representative, and one from a farmers union.

General

The comments received by CFIA ranged from highly supportive to neutral. Although no commenters opposed the Arrangement or Framework, many raised concerns over the potential impact of zoning recognition on international markets. Poultry organizations recommended the recognition of compartments as well as zones, and asked for assurances that the Framework and Arrangement would not interfere with the emergency preparedness work previously completed with the CFIA.

The comments received by APHIS were primarily supportive, but some were opposed to the Arrangement and Framework, stating that they would undermine U.S. notice and public comment procedures and unnecessarily endanger U.S. livestock producers and herds.

Industry groups on both sides of the border highlighted the importance of cross-border trade and supported the development of tools such as the Arrangement and Framework for minimising trade restrictions during outbreaks. Most groups expressed their support for continued stakeholder engagement and desire to participate in cross-border working groups to foster relationships. Some groups raised industry-specific questions and/or offered suggestions for improving the Framework.

The CFIA and APHIS have grouped the comments into seven categories, namely international acceptance, emerging diseases, traceability, political pressures, communications and stakeholder engagement, vaccination zones, and other topics. The comments within each category are discussed in greater detail below.

1. International Acceptance

2. Emerging Diseases

3. Traceability

4. Political Pressures/States versus Provinces

5. Communications/Stakeholder Engagement

6. Vaccination Zones

7. Other

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