EICR ASF Dog Import Justification Letter

Marketing and
Regulatory Programs
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Avenue SW
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TO:

Brenda Aguilar
Office of Management and Budget Branch Chief

THROUGH:

Ruth Brown
Department Clearance Officer

FROM:

Mae Wu
USDA Deputy Under Secretary
Kevin Shea
APHIS Administrator

Katherine
Zenk

ANTHONY
SHEA

Digitally signed by
Katherine Zenk
Date: 2021.07.22
17:07:35 -04'00'

Digitally signed by ANTHONY
SHEA
Date: 2021.07.22 16:04:19
-04'00'

Burke Healey
Veterinary Services Deputy Administrator BURKE HEALEY

Digitally signed by BURKE HEALEY
Date: 2021.07.22 12:15:01 -06'00'

SUBJECT: Request for Emergency Approval of a New Information Collection for
Import of Dogs from Countries Affected with African Swine Fever
SUMMARY: The Animal and Plant Health Inspection Service (APHIS) is

submitting to the Office of Management and Budget (OMB) an information collection
request for an emergency 6-month approval for information collection activities
connected to the prevention of African swine fever (ASF), in particular, conditions for
import of dogs from countries or regions affected with ASF.
APHIS’ primary mission is to protect the health of U.S. agriculture and natural
resources against invasive pests and diseases. This includes the prevention, control,
and eradication of animal diseases to safeguard animal, plant, and human health.
Disease prevention is the most effective method for maintaining a healthy animal and
plant population and for enhancing the United States’ ability to compete globally in
animal and animal product trade. In situations where a disease risk is sufficiently
severe and fast-moving so that the regular regulatory process cannot provide adequate
relief, APHIS employs Federal Orders to set trade restrictions quickly to control,
eradicate, or prevent a disease threat. On June 21, to help prevent the entry of ASF into
the United States, APHIS issued a Federal Order setting restrictive conditions for the
import of dogs from countries or regions affected with ASF.

BACKGROUND: ASF is a contagious hemorrhagic disease of wild and domestic
pigs. It is often characterized by high morbidity and mortality rates. Some isolates can
cause animal death as quickly as a week after infection. There is no effective treatment
for ASF-infected swine and no vaccine. The disease can be spread not only by contact
with other affected animals, even animals of different species (such as dogs), but also
via materials such as bedding or packing materials. ASF is a notifiable disease to the
World Organisation for Animal Health (OIE). The disease does not pose a risk to
human health or food safety. ASF is a critical threat; the disease has spread globally in
recent years, and the United States has millions of susceptible swine, including feral
swine.

ASF is currently widespread and endemic in sub-Saharan Africa, parts of West Africa,
and Sardinia. In the last decade, ASF has spread through Eastern Europe and the
Caucasus. In the last few years, the disease has continued to spread in the European
Union, primarily in wild boar. (Notably, APHIS has identified feral swine – of which
there are currently between 5 million and 9 million spread in all areas of the United
States – as a significant possible vector in an outbreak here, as it has been in the
European Union.) In August 2018, China reported the first ASF detections in its
domestic swine population. ASF continued spreading widely throughout Asian
countries in 2019 with additional outbreaks reported between 2020 and 2021.
As of December 1, 2020, the USDA National Agricultural Statistics Service identified
an inventory of 77.5 million hogs and pigs in the United States. According to the
USDA National Animal Health Monitoring System, the U.S. swine industry is worth
more than $22.5 billion, which without proper preparation could be put at risk if ASF
was introduced into the United States.
An ASF outbreak of any size or type, particularly a multistate outbreak, would likely
have an immediate, sizeable, and lingering economic impact for an extended period. An
outbreak would instantly disrupt international exports of meat, meat products, and
swine byproducts. The value of lost exports would be a substantial detriment to the
economy and would also affect interstate commerce. Farms would shut down, causing
unemployment and costs both on-farm and in related sectors such as feed production
and supply. In addition, an ASF response effort would involve direct costs for
depopulation, indemnity payments, animal disposal, disinfection, and movement
control measures. Consumers would sustain additional indirect costs and potentially
suffer food insecurity. The lack of a vaccine makes prevention of disease entry of
utmost importance, and thorough preparation for an emergency response crucial. If
ASF were to be detected in the United States, there would be severe economic impacts
on U.S. livestock producers, their communities, and the economy.
In the past few years, APHIS has seen an increase in the number of dog import permits
APHIS has issued, rising from 568 in fiscal year (FY) 2018 to 2,669 in FY 2020 with
numbers on track to hit 3,500 in FY 2021. Of the currently received permits, 1,465
originated in ASF-affected countries, accounting for 7,085 dogs entering the United
States from these countries. APHIS has determined that dogs imported from ASFaffected countries for resale purposes (along with their bedding) represent a possible
pathway for the introduction of disease. APHIS is requiring all dogs imported into the
United States for resale from a region in which ASF exists, or is reasonably believed to
exist, to meet the import requirements outlined below. Importers must obtain an import
permit and submit written documentation verifying completion of the requirements,
including disposal of animal bedding, microchip identification, and post-entry bath:
•
•
•

The dogs and their shipping crate/container must be free of dirt, wood shavings,
hay, straw, or any other organic/natural bedding material.
All bedding that accompanies the dogs during transit must be properly disposed
of at the U.S. post-entry points of concentration.
Each dog must have an ISO-compliant microchip implanted, and the individual
microchip number must be verified immediately before each animal is bathed.

An Equal Opportunity Provider and Employer

•

Each dog must be bathed at the U.S. post entry point of concentration within 2
calendar days of arrival in the United States. Bathing must be documented in the
VS Dog Import record, along with information about the dog, the importer, the
country of origin, U.S. port of entry and post-entry points of concentration, and
date of arrival,

Delays in obtaining approval of this information collection could have significant
repercussions on the Agency’s ability to respond efficiently and effectively as events
unfold early in an outbreak. APHIS will collect information using a new Dog Import
Form as well as existing permit forms. As multiple pathways for infection are possible,
all likely sources of virus introduction should be mitigated, and producers should work
to minimize the risk of spread from imported animals.
Thank you for your time and consideration.

An Equal Opportunity Provider and Employer