OC submits comments on CDC import requirements

[Laura Bies]

The Ornithological Council submitted comments to the Centers for Disease Control, regarding the agency’s requirements for import permits. The CDC currently requires that an import permit be secured for birds carcasses or specimens, if the specimen or sample to be imported is known or reasonably expected to contain an infectious biological agent. If a permit is not secured, the agency is proposing a new Importer Certification Statement, which will require the importer to attest that they are importing only noninfectious biological agent(s) or biological substance(s).

The OC explained that, since virtually all animals can harbor one or more pathogens capable of causing human illness and infected animals may be asymptomatic, it is extremely difficult for a field biologist to determine the presence or absence of all potential zoonotic pathogens. This is made even more difficult by the fact that the  CDC has not provided a list of pathogens of interest. Thus, even if the scientist were able to have the blood or tissues analyzed prior to import, there could be microbes present for which the potential to cause human disease is unknown. Without knowing which infectious biological agents the CDC is monitoring and which might be contained in an importer’s sample it is impossible know if a permit is required.

Furthermore, the proposed certification statement would require a detailed description of how the material was rendered noninfectious. To enable compliance with this, we ask the CDC to provide a list of acceptable treatment methods. It is easy to certify that the animal or animal product has been rendered noninfectious if the importer knows what methods are considered by the CDC to be effective. The importer should not have to guess at the methods the CDC (or agents at U.S. ports of entry) will accept, only to arrive at the port and determine that they have guessed incorrectly.

Finally, the OC also notes that the CDC import permit itself is duplicative. Imports of ornithological samples and specimens are already subject to review and permitting by the USDA’s Animal and Plant Health Inspection Service. Requiring an additional permit from the CDC for the same materials does nothing to further protect our country from potentially harmful imports and it unnecessarily increases the burden on importers.

Read the OC’s letter to the CDC here. 

 

About the Ornithological Council

The Ornithological Council is a consortium of scientific societies of ornithologists; these societies span the Western Hemisphere and the research conducted by their members spans the globe. Their cumulative expertise comprises the knowledge that is fundamental and essential to science-based bird conservation and management.  The Ornithological Council is financially supported by our member societies and the individual ornithologists who value our work. If the OC’s resources are valuable to you, please consider joining one of our member societies or donating directly at Birdnet.org. Thank you for your support!