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Acts and Regulations > Regulatory Initiatives REGULATORY IMPACT ANALYSIS STATEMENT DESCRIPTION The purposes of the Health of Animals Act and Regulations are: to prevent the introduction of animal diseases into Canada; to control and eliminate diseases in animals that either affect human health or could significantly affect the Canadian economy; and, to provide for the humane treatment of animals during transport. Requirements for the importation of live animals and germplasm are based upon categories of animal health risk and the import documentation required for each of these categories. The animal health risk categories allow the documentation requirements to be reduced for importations originating in areas that have been evaluated as having a health status equivalent or superior to Canada for all reportable diseases in a particular species. Individual states in the U.S. or other countries may apply to Canada and be assessed as equivalent to Canada for all reportable diseases affecting a particular species. The categories are (i) equivalent risk area and (ii) low risk area. Anything that does not fall into either of these two categories (undesignated) must be imported under an import permit or must meet the requirements outlined in the Import Reference Document referenced in the Regulations. If not, it is not permitted entry to Canada. In general, the Import Reference Document contains requirements for dogs and cats from anywhere in the world, and for other animals from the U.S. The purpose of this amendment is to modify the definition for "Import Reference Document " to reflect the publication of a new version of this document. Since the Import Reference Document is incorporated into regulation by reference, any time this document is amended the definition for import reference document must be amended to reflect the new version. The current version of the Import Reference Document, published on June 20, 2003 is changed as follows: i) The tuberculosis requirements for importing bovines have been modified to reflect the addition of "modified accredited advanced " areas in both the Canadian and U.S. livestock regulatory regimes. ii) The post entry bluetongue test requirement for bison has been removed. This brings the bison requirements for bluetongue in line with the requirements for cattle following research that concluded that the risk for bison was in line with that for cattle. iii) People wishing to bring pet dogs or cats into Canada now have the option of having a blood test performed to show that previous rabies vaccinations are still active rather than re-vaccinating animals. iv) The rabies vaccination requirements for pet cats and ferrets are now brought in line with the requirements for dogs in that an inspector may now order that an unvaccinated animal be vaccinated rather than refusing to allow it to enter Canada. v) The trade name and serial number of rabies vaccines must now be included in the rabies certificate for dogs. vi) The time between inspection and importation of unaccompanied puppies has been extended from 36 to 72 hours to allow for weekend travel. vii) Permits will be required for the importation of elephants and of non-human primates due to the human health risks posed by these animals. The importation of pet monkeys from the U.S. will no longer be allowed. Their importation from any other country was already prohibited. There is evidence that there is a risk of tuberculosis with elephants imported into Canada from the U.S. According to an internal USDA memo dated August 28, 1996, four Hawthorn elephants tested positive for tuberculosis. On September 16, 1997, the U.S. Department of Labor Occupational Safety and Health Administration informed Hawthorn that an inspection "disclosed the following potential hazard: Employees were exposed to the Mycobacterium tuberculosis when they worked around elephants infected with tuberculosis. This letter serves as notification of the likelihood of transmission of tuberculosis from elephants to employees." Hawthorn leases animals to facilities and circuses around the world. Non-human primates, as well, are known to pose a risk for disease transmission to the human population. The proposed permitting requirements are consistent with the standards of the World Organisation for Animal Heath (OIE). viii) Testing requirements for bovines and equines are updated to reflect the latest testing technology. ix) The Import Reference Document now specifies the border evaluation requirements for animals imported from the United States for which no specific requirements are currently set out, and clarifies that permits are not required to import these animals. It also now clarifies when import permits are mandatory for imports from the U.S. x) A new section has been added to clarify what actions may be taken in the case of non-compliance with the provisions of the Import Reference Document. This section does not create new sanctions, but rather outlines the sanction possibilities under the existing enforcement regime. xi) Extra wording and headings are added to help clarify what animals are covered and how the requirements apply. As well, some terminology has been updated for the sake of consistency and ease of understanding. ALTERNATIVES CONSIDERED Option 1. Maintain current regulations without changes This option was rejected since it will prevent the CFIA from implementing the most current import requirements. Failure to address the new tuberculosis areas defined for bovines in Canada and the US would allow an unacceptable disease risk to Canadian livestock from U.S. imports. Failure to implement the new permitting requirements for elephants and non-human primates would mean not addressing a potential risk to human health. Option 2. Amend the definition of Import Reference Document This will permit the CFIA to implement the latest import requirements. BENEFITS AND COSTS Proposed Permit Requirements for Elephants and non-Human Primates The changes to the permit requirements for elephants and non-human primates are being considered in order to protect the animal base industry, worth billions of dollars in Canada, and also to protect valuable human lives. Although the risk of tuberculosis is relatively low, based on the number of animals presented for import and the lack of evidence of transmission of tuberculosis from those animals, elephants are known to be susceptible to a form of tuberculosis that can be spread to the human population. Based on the expected number of applications for permits to import elephants and non-human primates per year, it is expected that the annual revenue would be $3,885. The costs to the Agency of processing these extra permit requests is expected to be $4,015. Other Proposed Changes The changes to the tuberculosis requirements for imports of cattle should not impose a significant extra burden; but, in responding to the changes in zoning for tuberculosis status both in Canada and the United States, these new provisions should help protect the health of the Canadian cattle industry. The changes to the bluetongue testing requirements for farmed bison should result in a small cost savings for the industry without compromising on safety. It is anticipated that the wording changes to the Import Reference document aimed at clarifying the requirements should result in a small reduction in the regulatory burden on importers. These changes should also slightly decrease the workload of Agency staff who would otherwise be called upon to deal with misunderstandings. The changes in the area of rabies requirements for cats, dogs and ferrets will offer a greater range of options for importers without compromising on safety standards. Overall, this option should result in positive benefits to consumers, our trading partners, industry and significant parts of the Canadian animal industry. This option provides the most opportunities for an efficient and responsive system. CONSULTATION Initial consultations included the consultations that took place when these regulations were amended to incorporate the first version of the Import Reference Document. That amendment was to address the regulatory structure. This amendment addresses content issues that were raised by staff and industry at that time but which could not be addressed at that time. New items are the results of requests from field staff and the public for clarification of certain sections and requests from other government departments such as Health Canada (for the new permit requirements for non-human primates). Health Canada and the CFIA jointly identified and addressed the problems with the current, extremely liberal, requirements for the import of non-human primates and issues surrounding the possibility of elephants playing a role in the transmission of tuberculosis to humans. Alberta Agriculture and Alberta Wildlife have also expressed concerns with our current requirements for non-human primates. Other problems were identified over the course of the last eighteen months. As people used the Import Reference Document it became clear that there were areas where clarification was required. This was communicated both orally and in writing by field staff and industry members. COMPLIANCE AND ENFORCEMENT The proposed changes to the Import Reference Document do not affect the CFIA’s compliance and enforcement capabilities. Regulatory infractions will continue to be identified by field staff and addressed in accordance with their regulatory inspection authorities or forwarded to Enforcement and Investigation Services for consideration and enforcement action. ENVIRONMENTAL IMPACT As the changes proposed for the regulations do not significantly change the patterns of importation of live animals and germplasm into Canada, there is no effect on the environment from this regulatory amendment. CONTACT Dr. D. Barr |
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