# ![](media/image1.jpeg){width="0.9in" height="0.4666666666666667in"}National Pork Board

P.O. Box 9114 Des Moines, Iowa 50306 USA Phone: 515-223-2600 Fax:
515-223-2646

Regarding Docket no. APHIS-2006-0186

These comments are submitted on behalf of the National Pork Board. The
National Pork Board was established by an act of Congress in 1985 and is
responsible for the collection, distribution, and program accountability
for the money generated by the pork checkoff. A Board led by 15 pork
producers creates programs in the areas of promotion, research, and
consumer information. These programs support producers by providing them
with information on many areas including swine health and pork safety.

After seeking input from subject matter experts and reviewing applicable
scientific materials the National Pork Board poses the following
questions to USDA on the proposed amendment to 9 CFR Part 94, Docket no.
APHIS-2006-0186 which would allow the importation of uncooked pork
products from regions of Mexico where classical swine fever (CSF) is
considered to exist if the uncooked pork and pork products originate in
a region free of CSF and meet certain other conditions with respect to
processing and shipping. National Pork Board looks forward to any
answers, clarifications, or results from risk assessments conducted that
USDA can provide.

Our research into the basis for the proposed rule shows that a risk
assessment that is specific to the processing plant to measuring the
risk of introducing CSF into the United States and US swine herd by the
proposed change in the regulations has not been completed by USDA and
communicated to the US swine industry. After consulting with experts in
CSF, the following questions were posed:

a.  What is the risk of external contamination of fresh pork and
    processed pork products by plant employees through normal production
    practices and critical control points?

> A science based assessment to determine the risk of external
> contamination of fresh pork and processed pork products from plants
> located in CSF positive areas is needed to identify and mitigate
> vulnerabilities in processing chain that could contribute to an
> increased risk of introduction of CSF to the US pork industry.

b.  What reviews have been done to assess the plants compliance with
    on-site biosecurity practices?

> A review of plants' biosecurity practices will help identify and
> correct deficits that could lead to product contamination and increase
> the risk of CSF introduction to the U.S. swine industry.

c.  What reviews have been done to assess the plants compliance with
    regulations required by APHIS, FSIS and the country's competent
    animal health and food safety authorities?

> The review of the plant(s) compliance history with the safeguards
> required by USDA, FSIS and the country's competent authorities will
> identify and help correct compliance issues that could contribute to
> an increase risk of CSF introduction to the U.S. swine industry.

d.  What reviews have been done to assess the risk of transmission of
    classical swine fever into the US swine herd from the external
    contamination of vehicles and containers used to ship fresh and
    processed pork product from the plants in areas considered positive
    for classical swine fever?

> External contamination of shipping containers and vehicles with
> biologic materials from transportation through a CSF positive region
> presents a risk to the U.S. swine industry. The review of
> transportation biosecurity practices will help identify and correct
> deficits and protect the US swine herd.

e.  Is there any need for sampling fresh pork and processed pork that
    originates from processing facilities located in CSF positive
    regions to determine compliance with the safeguarding steps outlined
    in this proposed rule?

> If a risk assessment shows value to additional product monitoring, the
> sampling of fresh and processed pork from plants in regions that are
> positive for CSF might be used to provide additional information to
> assess the success of safeguards in place to prevent the introduction
> of CSF into the US swine industry.

f.  As stated in the proposed rule;

> "the proposal would, however, also allow uncooked pork and pork
> products that originate in another CSF-free region to be processed in
> a region where CSF is considered to exist and then be shipped to the
> United States."
>
> Can the assumption be made that the reference to "region" is
> consistent with the definition in the 2006 terrestrial animal health
> code? If so, has USDA defined the science-based criteria to evaluate
> whether or not a region should be considered to be free of CSF?
>
> Decisions to allow the processing of fresh pork and pork products from
> free regions in countries that are not free of CSF should be based on
> a risk assessment which includes identifying and evaluating the
> science-based standards being used to define a CSF free region or
> compartment. This includes, but is not limited to, review of the
> necessary standard operating procedures for disease surveillance,
> biosecurity and disease control that prevent introduction and allows
> for early detection of CSF in swine located in free regions or
> compartments.

The National Pork Board appreciates the opportunity to comment on this
proposed rule and looks forward to further opportunities to provide
information about the U.S. pork industry that USDA can use to protect
the U.S. swine herd from the introduction of foreign animal disease.

Sincerely,

Patrick Webb, DVM

Director Swine Health Programs

National Pork Board