In the Federal Register of January 9, 2007, USDA APHIS published a proposed amendment to the regulations regarding the importation of animal and animal products from Bovine Spongiform Encephalopathy (BSE) Minimal-Risk regions. This would allow importation of live bovines for any use born on or after the effective enforcement of a ruminant-to-ruminant feed ban in the region of export; blood and blood products derived from bovines; and casings and part of the small intestine derived from bovines.

The American Veterinary Medical Association commented on the proposed rule amendment in a letter dated April 6, 2007. The letter states that the AVMA is concerned with the gap between USDA's proposal to allow additional imports from bovine spongiform encephalopathy (BSE) minimal risk countries and the USDA's position on the National Animal Identification System. The AVMA believes that implementation of the minimal risk rule can only proceed after a comprehensive and viable animal health identification system is in place. Such a system must support the measurement of disease status among livestock populations, traceability of the movements of at-risk animals, and provide for national integration of the data.

The AVMA acknowledges the scientific approach to the assessment of BSE risks associated with expanded importation but feels that the USDA must consider the following issues:

1. The risk assessment overlooks the need for a functional National Animal Identification System.
2. The inability to identify the source of an infected animal reduces the confidence in the U.S. animal health structure and may be sufficient reason for trade partners to impose movement barriers for the species involved.