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FDA Comment Period on Feed Ban Starts April 9 – Ends April 16 April 8, 2009 Alert Sample letter (doc 36K) April 9, 2009 Alert Sample letter (PDF 12K) Online submission instructions April 8 Alert: On March 25, 2009, R-CALF USA sent a letter to each congressional member serving on the House Agriculture Committee and to the Acting FDA Commissioner urging them not to delay implementation of the Final Feed Ban Rule so long as the USDA continues to expose the U.S. to a heightened BSE risk through the OTM Rule. Though FDA did not outright scrap its plan to delay the Final Feed Ban Rule as R-CALF USA requested, it did substantially modify its plans by announcing today that it will publish a “Special Filing” in the Federal Register on Thursday, April 9, 2009. This Special Filing will provide the public with a 7-day period – from April 9 through April 16, to comment solely on whether the FDA should delay the April 27, 2009 implementation of the Final Feed Ban Rule for 60 days – until June 26, 2009. Action: This is our opportunity to highlight the danger of USDA’s totally irresponsible OTM Rule by telling FDA in no uncertain terms that unless USDA immediately rescinds the OTM Rule, the U.S. has absolutely no choice but to immediately implement the Final Feed Ban Rule in order to mitigate our increased exposure to BSE caused by imported OTM Canadian cattle. We need as many written comments from as many cattle producers and consumers as possible within the 7-day window that starts April 9 and ends April 16. The clear message to FDA should be that: Any delay of the Final Feed Ban Rule would expose the U.S. cattle herd and U.S. consumers to an unacceptable, unnecessary and entirely avoidable risk of BSE. Unless USDA immediately rescinds the OTM Rule, the U.S. has absolutely no choice but to immediately implement the Final Feed Ban Rule in order to mitigate our increased exposure to BSE caused by imported OTM Canadian cattle. April 9 Alert: Please consider commenting on FDA’s plan to delay the scheduled April 27, 2009, implementation of the BSE feed ban needed to address the heighted risk of BSE we already have assumed by allowing high-risk Canadian cattle into the United States. Below is a short background, instructions on how to submit comments, and a sample letter you can use to submit your comments. We need thousands of comments on this issue! Background: Our April 7 Member Alert provided more background on this issue but today the U.S. Food and Drug Administration (FDA) has opened a 7-day public comment period to solicit public comments on whether the FDA should delay implementation of its upgraded bovine spongiform encephalopathy (BSE) feed ban. The U.S. Department of Agriculture (USDA) and the FDA have purposely positioned the cattle industry between a rock and a hard place. There is no doubt that cattle producers who rely on rendering services to pick up deadstock will experience a hardship if the FDA’s new BSE feed ban rule takes effect. The government is banking on cattle producers to support this last minute delay for this very reason. But, the government has purposely backed our cattle industry into a corner and we should not kowtow to its manipulation. The fact is that the government, through USDA, purposely exposed U.S. consumers and the U.S. cattle herd to an unacceptable risk of BSE by allowing Canada’s highest-risk cattle – cattle over 30 months (OTM) of age – to freely enter the U.S. food supply, feed supply, and cattle herd. USDA should not have allowed these higher-risk cattle into the U.S. until after it determined if it was feasible to assume the additional costs necessary to mitigate this increased risk – the cost of upgrading the U.S. feed ban. But this is exactly what has happened and this is what we are now faced with. We now have a choice: We can either do what is right to protect the health and safety of our cattle herd and our consumers or we can kowtow to the government and follow the path that they have devised for us. R-CALF USA chooses to do what is right! We must force the government to do what is right as well. So, must change-up this debate and instead of capitulating to the government’s manipulative tactics, we should give them a choice: Either eliminate the source of our higher BSE risk by closing the border to OTM Canadian cattle or immediately implement the upgraded feed ban needed to minimize this higher risk. There are no responsible alternatives. Below is a sample letter you can use to submit your comments to the FDA. We need thousands of comments submitted within the next 7 days, so please circulate this Alert as widely as possible and encourage as many people as possible to submit comments as well.
How to
submit your written comments (Deadline April 16, 2009):
By Internet:
1. Go
to:
www.regulations.gov |
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