G/SPS/GEN/1330  
8 May 2014  
(14-2844) Page: 1/4  
Committee on Sanitary and Phytosanitary Measures  Original: Spanish  
 
  ANALYSIS OF THE SANITARY RE GULATIONS FOR THE IMPORTATION 
OF BRAZILIAN MEAT INTO  THE UNITED STATES 
COMMUNICATION FROM NICARAGUA 
The following communication, dated 3 April 2014, is being circulated at the request 
of the delegation of Nicaragua. 
 
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  1.   In its animal health management system, the United States has placed great emphasis 
on maintaining biosecurity through prevention. One means of fulfilling this precept is by keeping 
out any possible risk of acquiring foot and mouth disease (FMD) by prohibiting imports of bovine 
animals and meat products from countries where FMD exists. 
2.   On this basis, United States policy has been to permit imports of bovine meat only 
from countries listed by the OIE as FMD free without  use of vaccination, or from countries 
declared to be wholly  (at national level) FMD free with vaccination. There is only one country 
in the world in this category, namely Uruguay, from which fresh or frozen bovine meat 
can be imported to the United States. 
3.   In Brazil, the OIE recognizes only the state of Santa Catarina as being FMD free without 
vaccination. There are also five separate zones declared by the OIE as being free of the disease 
with vaccination. It is a fact that all the northern zone of Brazil is not FMD free, as may be seen 
from the OIE map for 2013 (official status of FMD in South America). 
4.   The disease does not follow borders nor does it respect them, especially when it exists inside 
a country's borders as in the case of Brazil, which also has borders with other South American 
countries where FMD is prevalent. 
5.   Brazil has an FMD containment zone in the north of the country, but this is not a sufficient 
guarantee that the disease will not spread to neighbouring states from which the proposed 
regulations permit fresh/frozen me at to be imported from Brazil. 
6.   It is common knowledge that FMD is caused by a highly contagious virus that can 
be transmitted via inanimate objects and may also be spread by wind. 
7.   The various simulation exercises carried ou t in the United States have shown that 
it is essential to have an excellent capacity to track infected animals within 48 hours of an outbreak in order to be able to rapidly eliminate and contain the incipient onset 
of the disease. 
8.   The experience and results of simulation exer cises for FMD outbreaks show the importance 
of identification and isolation of potentially infected animals, which requires a comprehensive 
and excellent system of bovine traceability. A comprehensive traceability programme 
is a sine qua non condition to be able to respond rapidly to animal health emergencies, as occurred 
in the eradication programmes for tuberculosis and brucellosis, especially if zones where FMD is prevalent still exist in the meat-exporting country. G/SPS/GEN/1330 
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  9.   Thus, it is only possible to respond effectively to an FMD outbreak when one knows which 
animals are affected, where they are located, with what other animals they have been in contact, where these animals are located, and whether they  in turn have had contact with other animals 
that may potentially spread the disease. 
10.   In Brazil the Bovine Traceability Programme is voluntary. It applies only to livestock whose 
meat is destined for countries that require traceability of the animal from birth (European Union, for example). Other countries have similar systems. However, it should be borne in mind that only 
some areas in Brazil are considered FMD free with vaccination, and therefore the absence 
of a generalized traceability system could affect the monitoring, detection and response capability 
in the face of FMD emergent events. 
11.   For many years Nicaragua has been working hand in hand with the United States sanitary 
authorities in joint programmes aimed at preventing the entry of FMD into Central America. 
12.   Efforts have been devoted to campaigns for prevention, training and market restriction 
through controls on the entry of animal produc ts and byproducts that could represent a risk 
for the sanitary status of Central America. These restrictions have applied not only to countries 
of South America but also to the rest of the world considered not FMD free. 
13.   Nicaragua has forgone importing semen from Brazil for genetic improvement, in order 
to remain consistent with these control programmes carried out together with the United States. 
14.   The damage caused by FMD has led nearly all developed countries to adopt measures firstly 
to eradicate it and subsequently to remain free of it over time through prevention programmes. 
15.   This has led to the creation of two major groupings of countries with exportable production 
surpluses: the so-called "FMD free circuits" (United States, Australia, New Zealand, 
Central America etc.), and those that are not FMD free, known as the "FMD circuits". 
16.   The FMD virus has enormous variation potential, and eradicating it through the use of natural 
or synthetic vaccines seems difficult since none of the genomic regions of the virus is invariant. 
COVERAGE OF VACCINATION PROGRAMMES  
 
17.   Concerns of a technical nature are based on considerations about the lack of confidence 
on the part of the countries using vaccination as regards circulation of the virus. Those countries are not sufficiently confident that their own vaccination coverage is stopping the virus from circulating; since they have not obtained the evidence to be sure that the virus is not circulating, 
their campaigns remain active in most of their national territory, as in the case of Brazil. 
18.   In view of the above, the containment of FMD with vaccination  cannot be a sufficient 
guarantee for the United States of America, inter alia  due to: 
(a) The rapid mutation of the virus, especially when the country in question still has zones 
where the virus is prevalent; 
(b) Differences in susceptibility of organisms, as not all animal organisms react in the 
same way; 
(c) There are different vaccines and fragility in the manufacture of vaccines and serotypes; 
(d) The immunological protection provided by vaccination remains scientifically moot. 
19.   Many simulations of FMD outbreaks have been made in the United States, such as the one 
in March 2005, and the total value of losses under various scenarios have been calculated, ranging 
from a small outbreak, successfully contained within one state, to a major multi-state outbreak, resulting in the loss of up to 30% of the national cattle herd. The value of losses from these 
simulations have ranged from between US$37 billion (0.15% of 2006 GDP) to US$228 billion 
(0.92% of 2006 GDP), the greatest impact comi ng from the wholesale destruction of animals 
and the economic impact in curbing livestock supply. G/SPS/GEN/1330 
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  20.   Given the large-scale movement of bovine animals and products among NAFTA countries, the 
r i s k  o f  t h e  i m p a c t  o f  a n  o u t b r e a k  m u s t  b e  m i n i m i z e d .  A f t e r  a l l  t h e  e f f o r t s  m a d e  t o  k e e p  F M D  outside the borders of the United States and NAFTA countries, there is no room for complacency. 
21.   FMD has a devastating impact on the economy of affected countries. The process 
of containing the disease requires major resources in vaccination and monitoring as well as trade 
restrictions, and historically the destruction of  millions of animals. In Great Britain the 2001 
epidemic led to the slaughter of 7 million animals and had an estimated economic impact 
of between US$12-18.5 billion from direct and indirect losses. 
22.   The importation of fresh and frozen meat creates a serious risk for the herds of 
the United States, Canada, Mexico and Central America. 
23.  Like the other Central American countri es, Nicaragua is not economically prepared 
to cope with the catastrophe that an outb reak of FMD would represent in the country, 
since its bovine livestock sector and in dustries are its main economic pillar.  
24.   Given the high economic risk that modifying the current regulations represents, 
has the United States given thought to the amounts of compensation for livestock farmers 
of the United States and other countries affected by the change in the regulations in order to allow imports of meat from Brazil? 
ANTIGENIC VARIATION  
 25.   The variation of the FMD virus is a serious obstacle for control and eradication campaigns, 
and the capacity for antigenic variation of the FMD virus seems far from exhausted. 
26.   There is a latent biological risk from the inherent variation capacity of antigenic properties 
of the FMD virus, which is precisely why it has not been possible to eradicate the disease from large parts of the affected countries. It is a virus with a heterogeneous structure whose 
evolution is unpredictable. 
27.   The dynamic, constantly evolving world of riboviruses and in particular the FMD virus 
contrasts with the new vaccine design technologies whose criteria are those of a static world: 
they are constructions obtained from fixed sequen ces by molecular cloning or chemical synthesis, 
which instead are unwittingly promoting the accelerated selection of new variants of the virus. 
28.   Little is known about the control procedures for the antigenic variants of the FMD virus 
circulating in the immediate surroundings, includin g neighbouring regions, in order to validate 
the probable immunoprotection conferred by specific vaccines. 
PRESENCE IN MEAT PRODUCTS 
 
29.   More specific guidelines should be given concerning risk abatement measures required 
in slaughterhouses so as to be able to visualize the minimization of virus survival during slaughter and the preparation of boned meat, where risk elimination is very difficult. 
30.   Furthermore, as regards the presence of the virus in animal products, focusing on inactivation 
treatments, there is a clear absence of an established threshold of viral contamination below which a product may be considered safe. 
31.   The data obtained so far on meat trade safety do not guarantee that the risk assessment 
of survival of the virus using the currently reco mmended procedures can establish an insignificant 
risk of contagion. 
32.   Again, there is a lack of data on survival of the virus in boned bovine meat from carcasses 
where the acidification process has not been carried out properly for the skeletal muscles. 
Information is also lacking on survival of the virus in fatty tissue, apart from bone marrow and infected blood splashed on carcass surfaces. G/SPS/GEN/1330 
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  33.   Therefore, on sanitary grounds, Nicaragua considers that the importation of bovine 
meat products from countries that are FMD free with vaccination into countries that are FMD free without vaccination represents a high sanitary risk for the livestock assets of the importing country and of its neighbours and the region(s) having a similar 
sanitary status (FMD free without vaccination). 
34.    Thus: 
(a) Circulation of the virus in susceptible wild mammals represents a high risk for a zone 
that is FMD free without vaccination. 
(b) The review of the historical data for zone s recognized as FMD free with vaccination 
in some countries shows that they have been very unstable. 
(c) The immunological protection provided by strains of attenuated virus vaccines remains 
a matter of scientific debate. 
(d) The systems of bovine traceability in many countries that are FMD free with vaccination 
have not proved sufficiently strong to guarantee that the disease will not spread. 
35.    Nicaragua is seriously concerned by the APHIS proposal to amend the relevant United States 
regulations on FMD in order to allow imports of fresh and/or frozen bovine meat into the United States from 14 of the 17 states of Br azil, or zones of those states included in the 
above-mentioned five zones that are FMD free with vaccination. 
NB: Countries that place these agricultural assets at risk should provide compensation. 
 
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