Importation of Meat that Originates in an FMD Region and Is Cured or Cooked in Another Region

Regulatory Analysis and Development, PPD APHIS, Station 3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238 RE: Docket No. 02-083-1 We have carefully reviewed the proposed rule ?Importation of Meat That Originates in an FMD Region and Is Cured or Cooked in Another Region, Docket No. 02-083- 1, published in the Federal Register on October 25, 2005. The National Cattlemen?s Beef Association (NCBA) is the largest organization representing America?s cattle industry. Initiated in 1898, the NCBA is the industry leader in providing education and in influencing the development and implementation of science and risk analysis-based public policy to protect the health of the U.S. cattle population, provide safe and wholesome food and improve producer profitability. In this regard, the NCBA also strives to preserve the industry?s heritage and ensure our future. We appreciate this opportunity to share with the United States Department of Agriculture, Animal and Plant Health Inspection Service (APHIS) our perspectives on the proposed rule. In addition, this proposed rule also impacts the responsibilities of the Food Safety and Inspection Service (FSIS), in terms of their role in approving plants that process livestock or meat products for export to the United States. The FSIS is also responsible for establishing residue monitoring and surveillance programs and re-inspection of imported meat products at ports of entry. Therefore, we will also include in our comments issues to be considered by FSIS in carrying out their responsibilities as authorized by legislation and regulation. The NCBA closely monitors all advanced notices of proposed rule-making (ANPRM) proposed rules and final rules published by the nearly 50 Federal agencies that regulate one facet or another of our industry. In particular, there are several previously published proposed rules or final rules that are related to this proposal. On May 22, 2002 APHIS published a proposed rule: ?Importation of Cooked Meat and Meat Products.? In the proposed rule APHIS, proposed to amend the regulations governing the importation of certain animals, meat, and other animal products to allow meat cooked in plastic in processing establishments located in regions where rinderpest or foot-and-mouth disease exists to be further processed after cooking and before importation. Additionally, APHIS proposed to allow the pink juice test to be used in determining whether ground meat cooked in such establishments has been adequately cooked. APHIS stated these regulations were proposed to ??provide foreign meat processing establishments with additional processing options while continuing to protect against the introduction of rinderpest and foot-and-mouth disease into the United States.? The final Rule regarding ?Importation of Cooked Meat and Meat Products? was published April 2, 2003 (Volume 68, Number 63). The rule allowed for the use of the pink juice test or a temperature indicating device (TID) to be used to determine compliance with cooking temperature requirements. The proper cooking of beef from countries where Foot and Mouth Disease (FMD) exists is virtually the ONLY mitigating measure that prevents the potential introduction of FMD virus into the United States. In our comments submitted to APHIS on July 17, 2002 we stated: ?We also want to be on record stating the USDA-FSIS has long been on record challenging the validity of the ?pink juice test? as a reliable means of documenting proper cooking of ground beef from a food safety perspective. There have been numerous studies documenting conditions where premature browning occurs and for which the pink juice test would fail to indicate proper cooking. USDA-FSIS has moved to recommend actual temperature of the product as the only reliable means of assuring proper cooking. This fact leads us to believe the use of TID?s in all cooked products sent to the U.S., coupled with statistically…