CNGF letter that was submitted to the Canadian Food Inspection Agency in regards to the Proposed Import Policy for Small Ruminants: The Canadian National Goat Federation (CNGF) would like to take this opportunity to thank the Canadian Government and specifically the Canadian Food Inspection Agency for the opportunity to comment on the proposed “Requirements for Small Ruminants Imported From the United States for Breeding, Domestic or Captive Purposes” [TAHD-DSAT-IE-2007-5-6]. The CNGF can NOT support the proposed “Requirements for Small Ruminants Imported From the United States for Breeding, Domestic or Captive Purposes” [TAHD-DSAT-IE-2007-5-6] and the restrictions it would impose on the imports of bucks from the United States. The reasons CNGF is not in support of changes are outlined below. Prematurity of Changes In light of the fact that a Scrapie Eradication Steering Committee is currently in place and actively working towards an eradication plan for the small ruminant industry in Canada, changes to import policy from the U.S. is felt to be premature. Development of the plan is expected to be complete by March 2014, and we would hope that any changes in import policy would only be made if they align with the plan developed by this committee. Furthermore, changes to the USDA SFCP are still open for public comment, and US producers have until September of 2013 to make decisions regarding their program participation. The CNGF would suggest that Canadian requirements based on the USDA SFCP cannot reasonably be considered until the full depth of the impact of the US changes are understood and realized. Policy Changes Must Reflect True Risk The more restrictive nature of the proposed policy needs to be more reflective of the true risk that bucks pose for introducing scrapie into the national goat herd. Current research supports that PrPSc can accumulate in various tissues other than the nervous tissue and the transmission of TSE can be achieved by ingestion or injection of infected organ or tissue . However, in 2008 Sarradin et al. concluded that even the most highly infected scrapie positive males cannot transmit infectivity and that natural mating has a very low to negligible potential for transmitting scrapie. The CFIA also needs to take into consideration advances made by the USDA in disease eradication decreasing scrapie prevalence in the US to a mere 0.005%, down 96% since 2003. Limited Access and Success of Artificial Insemination The Canadian goat industry does not enjoy the same access to germplasm as do other livestock commodities and Artificial Insemination is not readily available to Canadian goat producers, as it is to cattle producers. The AI success rate in goats is considerably lower than that of cattle, restrictions on semen collection and handling make the process cost-prohibitive and the amount of US semen that meets Canadian import requirements is negligible. The Canadian goat industry relies heavily on the trade of live animals, a genetic source to which it requires continued access. Loss of Genetics and Erosion of Rare Breeds in Canada More than 230 dairy bucks alone have been imported from the US over the last 4 years; 48 in 2009, 65 in 2010, 51 in 2011 and 70 in 2012. These figures do not include bucks of meat, angora, dwarf or other breeds. The proposed import policy changes would severely restrict access to these valuable genetics necessary for the continued growth and ultimate success of the Canadian goat industry. Losing the current level of access to US genetics and eliminating the existing level of imports compromise the industry’s genetic base for generations to come. Rare breeds of goats will find it nearly impossible to import from the US and improve their herds, both in terms of numbers and genetics. Canada still has an open herdbook for some rare breeds of dairy goats. For example, currently there are fewer than 10 Canadian producers raising Oberhasli dairy goats, with only 25 purebred animals in the country and very few of them are bucks. There are no Oberhasli goat breeders enrolled in the USDA SFCP. The proposed policy will limit the access to breeding animals required for Canada to build and expand a genetically sound herdbook. Under the proposed changes, while one option of importing excludes bucks from import, the other option is excessive and impractical with regards to the importation of breeding bucks. As it stands, fewer than 30 US farms meet the proposed criteria for exporting to Canada. Despite the fact that the pending changes to the USDA SFCP are expected to result in a larger number of farms entering the Export Monitored program, this proposed policy does not accept the automatic grandfathering of program participation as outlined by the USDA and as such, farms moving from Complete Monitored to the Export Monitored program may not meet Canada’s proposed import criteria for another 4 years. The proposed import policy changes would severely restrict access to valuable genetics necessary for the continued growth and ultimate success of the Canadian goat industry. Losing the current level of access to US genetics and eliminating the existing level of imports compromise the industry’s genetic base for generations to come. Moving Forward The CNGF suggests more risk-appropriate requirements for importing bucks and encourages the CFIA to work with the national goat industry to explore alternative solutions in an effort to mitigate the possible risk of introducing scrapie positive animals into Canada without introducing measure that are damaging to the industry. The CNGF is open to and requests discussions with the CFIA regarding a number of potential solutions to this issue, including: A RAMALT biopsy testing of males destined for import. A RAMALT testing scheme was explored during the first round of policy comments and continues to be supported by the CNGF. The MAF Biosecurity New Zealand scrapie risk assessment, the government of New Zealand recognized an enzyme immunoassay applicable to biopsy samples obtained from rectal mucosa developed by Gonzalez et al in 2008, as detecting scrapie in 95% of infected animals when animals were sampled once but 100% when they were sampled on two occasions . ‘limited contact’ protocol as outlined recently by the CFIA as an option for dealing with rams and bucks. While the CNGF supports scrapie eradication in principle, it is not in support of actions that it views as detrimental to the long-term sustainability and profitability of the industry.
Posted on: Mon, 17 Jun 2013 20:05:40 +0000
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