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• Modified Policy: Changes to Canada’s Bluetongue Policy

Consultation Paper

Reviewing the Canadian Food Inspection Agency's import policy for bluetongue [and anaplasmosis] for ruminant animals imported from the United States

May 19, 2006

Purpose

The Canadian Food Inspection Agency (CFIA) is conducting a review of import conditions for bluetongue and anaplasmosis for cattle and other ruminant animals from the United States (US). Apart from the Okanagan Valley in British Columbia where infrequent incursions of bluetongue have been reported, Canada is free of these diseases. To prevent their introduction from the US, import restrictions have been in place for several decades. Changes to these restrictions have been made a number of times as scientific knowledge has grown. In addition to considering the relevant scientific information, it is also important to take account of any unwarranted effects restrictions may be having on trade. Together with some recent scientific developments, which have enabled the risks to be reassessed and ongoing concerns about trade impacts, the CFIA has initiated this review and is proposing further changes to its import policy. As a result, the CFIA is seeking comments accordingly.

Background

Restrictions associated with bluetongue and anaplasmosis for ruminant animals imported from the US have been in place for several decades. As the scientific communities' knowledge has grown, the risks associated with these diseases have been reassessed a number of times and changes to the import policy have been made following consultation with stakeholders across Canada. For example, restrictions for feeder cattle have been reassessed and eased on a number of occasions. Beginning in 1995, feeder cattle were able to be imported under the North West Pilot Project without testing during the winter months from a handful of states determined by the CFIA to be either free or to have a low incidence of bluetongue. In 2003 the CFIA concluded that a vector capable of transmitting bluetongue does not exit in eastern Canada from Ontario to the Atlantic Provinces. As a result, all classes of cattle are now eligible for importation from any state in the US at any time of the year without bluetongue related restrictions into this region of Canada. Based on preliminary findings from a three year study in southern Alberta from 2002 to 2004, which indicated that the capacity of midges found in this area to transmit bluetongue was poor, feeder cattle restrictions have been further eased. Under the year round restricted feeder program, cattle can be imported into all of Canada, except for the Okanagan Valley, from an expanded list of states (now 39) at any time of the year without testing for either bluetongue or anaplasmosis. They are, however, subject to certain conditions which require that the feedlot be approved by the CFIA and that it establish a vector control and sentinel animal program.

Reviewing import policy

In developing or reviewing an import policy the CFIA's goal is to ensure that it is based on relevant and up to date scientific information and that it takes account of relevant international standards and stakeholders concerns. In addition, if restrictions are to be applied, a number of guiding principles are considered: the restrictions should only be applied to the extent that is necessary to mitigate risk; restrictions should be technically, operationally and economically feasible; and, negative effects on trade should be minimized.

It is the CFIA's intention in reviewing the import conditions for bluetongue and anaplasmosis to consider them separately. At this time, since an analysis has been completed for bluetongue, it is appropriate to move forward and invite stakeholder comment on the CFIA's proposal for this disease.

Anaplamosis

A risk assessment for Anaplasmosis is underway and once it is finalized the CFIA will also release a consultation paper for comment. At this stage it is likely that it will be available by late spring although the timing may be influenced by the availability and quality of prevalence data to be provided by US authorities. Included in the scope of the assessment is the development of a pilot program based on a zoned approach that would facilitate the importation of all classes of cattle, including breeders, without testing or other restrictions from states considered to be either free or that present a low risk of anaplasmosis. Although a number of ruminant species, such as cattle, bison, deer and sheep, may be infected with the organism that causes anaplasmosis, cattle are the only species in which significant clinical disease may arise. As a result, if anaplasmosis were introduced its impact would be most acutely expressed in the cattle industry. Representatives from the beef cattle industry believe that the disease risks are likely to be minimal and certainly no worse than those experienced in the northern tier states where it has come to be regarded as an unimportant disease.

Canada's current import conditions for bluetongue

Considering that a competent insect vector, which is needed to spread bluetongue, does not exist in eastern Canada from Ontario to the Atlantic Provinces, the current import policy allows all classes of cattle and other ruminant animals to be imported into this region from any state in the US without bluetongue related restrictions. On the other hand, because of concerns that a competent vector may exist in western Canada, certain restrictions are imposed depending on time of the year that cattle and other ruminants are imported and whether they are destined to enter a feedlot or a breeding herd.

The year round restricted feeder program enables cattle to be imported from the US into approved feedlots in the western provinces (Manitoba and west) without testing from 39 states recognized by the CFIA as having low or medium bluetongue incidence. For feedlots located in the Okanagan Valley cattle can only be imported without testing during the winter months except for those that originate in Alaska or Hawaii, which the CFIA recognizes to be bluetongue free. Each feedlot is required to establish vector control and sentinel animal programs during the summer months. All other classes of cattle and other ruminants can be imported into the western provinces from any state subject to certain testing requirements, which depend on whether the state is classified by the CFIA as either having a low, medium or high incidence of bluetongue or is a low or high risk state.

A summary of the scientific findings for bluetongue

In recent years some important new information on the capacity of local populations of the insect vector, Culicoides sonorensis, to spread bluetongue has arisen. This insect is responsible for spreading bluetongue south of the border across a broad diagonal band extending from the west coast to the south eastern states. It is found along the southern fringes of the Prairie Provinces and British Columbia, which lie within the northernmost limits of its distribution in North America. The results from a field based study undertaken in southern Alberta from 2002 to 2004 strongly indicate that the capacity of local strains of this insect to transmit bluetongue is very poor. These findings are consistent with observations that some insect populations do not have the ability to spread bluetongue even though other members of the same species found in other areas can. This phenomenon is usually seen in those areas at the limits of the natural distribution of the vector where environmental and climatic conditions for both the vector and the virus are marginal.

Together with these observations, the CFIA considered a number of other relevant scientific factors when estimating the likelihood of bluetongue being introduced, spreading and becoming established in Canada. Based on a consideration that:

• a competent insect vector, which is needed to spread bluetongue, does not exist in eastern Canada from Ontario to the Atlantic Provinces;
• bluetongue restrictions had not been in place for ruminant animals imported from the US prior to 1975 without incursions being observed;
• the southern fringes of the Prairie Provinces and British Columbia lie within the northernmost limits of the distribution of the bluetongue vector, C. sonorensis;
• local strains of C. sonorensis found in southern Alberta and northern Montana appear to have a very poor capacity to spread bluetongue virus;
• any expansion in the range of bluetongue from the US into Canada as a consequence of climate change would be likely to occur regardless of Canada's import policy for ruminant animals. Experience elsewhere in the world indicates that windborne transfer of competent vectors is a more probable means of spread than through the movement of viraemic animals.
• historical and epidemiological evidence from the US clearly demonstrate a north-south gradient in the prevalence of bluetongue with much lower levels in the northern tier states compared with states further to the south;
• there is little bluetongue activity in the northern reaches of the Prairie States;
• bluetongue has only ever been detected four times since it was first discovered in the Okanagan Valley, BC in 1975;
• the Okanagan valley is a distinct geographic region separated from the rest of Canada by mountains to the north, east and west and extending into Washington State to the south;
• there have never been reports of significant clinical disease or death losses attributable to bluetongue in either domestic or wildlife species in the Okanagan Valley;
• even in the Okanagan Valley, where conditions are likely to be the most favourable of any area in Canada, bluetongue transmission has been limited to mid summer to late fall in some years;
• bluetongue incursions into the Okanagan Valley are thought to arise from infected vectors periodically moving north on high winds up the valley from Washington State or through the cross border movement of infected wildlife;
• bluetongue has never become established beyond a single vector season in the Okanagan Valley;
• extensive surveillance efforts conducted over many years in Canada have not detected any evidence of bluetongue transmission outside the Okanagan Valley;
• bluetongue is a seasonal disease with suitable conditions for potential bluetongue transmission only likely to exist in western Canada for several weeks in mid to late summer and perhaps into the fall;

the CFIA has concluded that there may be only very limited opportunities for bluetongue to spread in some years in the southernmost border regions of the Prairie Provinces and British Columbia. If transmission were to occur it would be limited to a narrow window of perhaps just a few weeks towards the end of the vector season in mid to late summer and perhaps early fall in some years. In all likelihood there may be very little impact on susceptible species such as sheep and white-tailed deer. In addition, the likelihood of bluetongue becoming established beyond a single limited vector season is considered to be negligible under the existing climatic conditions.

Stakeholder Views

Despite the easing of bluetongue and anaplamosis restrictions over the years, they remain contentious. Some stakeholders on both sides of the Canadian-US border continue to claim that the disease risks are minimal and that the import conditions are unnecessarily impeding trade by imposing additional transaction costs that erode competitiveness with the US cattle industry. It is further claimed that these restrictions adversely impact on an integrated North American market and have a negative effect on bilateral relations. This is considered to be a critical issue by the beef cattle industry in Canada, particularly as the United States Department of Agriculture (USDA) moves forward with its rule making process in relation to BSE and the restoration of market access for a number of commodities not covered by the "Minimal Risk Rule" that was announced in January 2005. These commodities include breeding cattle older than thirty months and beef or other products derived from these animals. It is firmly believed by the industry that if Canada continues to maintain restrictions for bluetongue and anaplasmosis, there will be opposition from within the US cattle industry for the USDA's proposed rule, which is expected to be released for public consultation within the next few months. This will be followed by a final rule, possibly towards the end of the year. The Canadian cattle industry has estimated that it will lose over one million dollars for each day that the final rule is delayed if there is opposition within the US cattle industry. Losses would arise from the continued prohibition on exports of purebred beef cattle, milking heifers and cull cows and bulls as well as the additional certification costs imposed for age verification and pregnancy testing.

Apart from concerns about bilateral relations, the beef cattle industry in Canada considers that a continuous supply of competitively priced feeder and breeder cattle is necessary to sustain current market growth and to support the ongoing expansion occurring in the beef slaughter sector. As more export markets are secured it is inevitable that a stable supply of cattle will be required to ensure ongoing success. Following on from the serious disruption to trade that arose with the discovery of BSE in North America in 2003, Canada's slaughter industry has expanded significantly. A recent analysis by the Government of Alberta indicates that a net increase of 950,000 slaughter cattle will be required over the next year to achieve ninety percent capacity as the build up of cattle and cull cows that occurred during the BSE crisis declines and new slaughter plants come on stream. Part of this increased demand could come from drawing off up to 400,000 feeder and/or slaughter cattle from western Canada that would otherwise be exported to the US. The balance of 550,000 would need to come from imported US cattle as the domestic cow-calf sector is not expected to expand rapidly enough to satisfy the increased demand.

The Government of Alberta's analysis further indicated that reducing or eliminating the transaction costs associated with bluetongue and anaplasmosis would ensure that the cattle industries in both countries are on a more level playing field and help to ensure that bids for domestic as well as imported cattle are competitive. While this should, in turn, facilitate a significant net increase in imports, the actual number of cattle imported would be influenced by other economic drivers such as the exchange rate and costs associated with production and transportation.

In addition to the increased net returns for feedlot operations arising from a reduction in transaction costs for imported cattle, the Government of Alberta's analysis indicates that net returns for slaughter plants, manufacturers and other sectors across the beef value chain can be expected to increase significantly.

The CFIA's proposal for bluetongue

After carefully weighing the relevant scientific information the CFIA is proposing, that in addition to eastern Canada, bluetongue restrictions be lifted for all classes of cattle, deer, goats, sheep and other ruminants imported year round into western Canada from any state in the US. In addition, it is proposed that bluetongue be changed from being a reportable disease to immediately notifiable. This means that movement controls would no longer apply. Rather, the CFIA would not intervene beyond an investigation into death losses in domestic ruminants such as deer and sheep in the event of a bluetongue incursion. Easing restrictions would also mean that movement controls for animals moving out of the Okanagan Valley to other areas in Canada would no longer apply even if bluetongue activity is detected.

By making bluetongue immediately notifiable the CFIA would still be able to fulfill its international reporting obligations to trading partners and the World Organisation for Animal Health, commonly referred to as the OIE. Under OIE guidelines a country is required to immediately report the first detection of bluetongue and/or the introduction of new serotypes.

Although the Canadian Cattlemen's Association (CCA) consider that the likelihood of bluetongue incursions are negligible, they have indicated that they will establish an indemnity fund for five years to offset any death losses should they arise in sheep flocks in western Canada. After this time CCA consider that sufficient experience would have been gained to finally conclude that the likelihood of bluetongue incursions and any associated impact is negligible.

Surveillance activities for bluetongue are currently undertaken every three to four years outside the Okanagan Valley. Within this area the CFIA conducts a sentinel monitoring program in which pre-selected animals are tested every three weeks from June until the middle of October each year. With the easing of bluetongue restrictions the CFIA proposes to enhance its surveillance activities by moving to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.

While bluetongue is an important disease in international trade affecting live ruminant animals and their semen and embryos, potential impacts arising from the CFIA easing import restrictions for animals imported from the US are likely to be limited:

• The vast majority of live animal exports are to the US where bluetongue is an unregulated disease federally and where only a handful of states (Alaska, Illinois, New York, Rhode Island and Vermont) apply movement controls in the form of a negative test for ruminants originating from elsewhere in the US. Historically, trade with these states has been limited, for example, an average of 367 cattle were exported in each of the years 1998 to 2002 from western Canada to these destinations.
• Although some countries outside the US may no longer recognize Canada as bluetongue free, they should at least recognize eastern Canada from Ontario to the Atlantic Provinces as a free zone. As a result, there should be no bluetongue related restrictions for ruminant animals or their semen or embryos originating from this region of Canada. Initially, the Prairie Provinces and British Columbia may be treated as a seasonally free zone with associated restrictions on live ruminants and their semen and embryos. From 1998 to 2002 the average export value of these commodities to countries other than the US from these provinces was $5.1 million. While a complete ban on these commodities would be highly unlikely, there may be some restrictions applied. For example, the export of live animals or the collection of semen could be restricted to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen collected during the vector season tests may be required.
• It is likely that enhanced surveillance activities together with ongoing research on the capacity of the potential vector to transmit bluetongue virus will provide evidence that bluetongue is either not a risk in Canada outside the Okanagan Valley in British Columbia or that transmission cycles are limited to a very narrow window in mid to late summer and perhaps the early fall in some years.

The following analysis provides the scientific details supporting this proposal together with further details on the CFIA's proposal, the significance of bluetongue in international trade and how trading partners, including the US, might respond.

Invitation to comment

The CFIA invites comments on this discussion paper. Comments should address scientific issues and should, where possible, be supported by scientific data or published information. Unless otherwise directed by the author of the submission, the CFIA will place all submissions on the public record and will release them to stakeholders if requested.

Comments should be submitted in writing by May 31^st, 2006 and should be addressed to:

Dr. Francine Lord
A/Director, Animal Health and Production Division
Canadian Food inspection Agency
59 Camelot Drive
Ottawa, ON, K1A 0Y9

Technical questions may be addressed to:

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