Letter to Shaun Donovan, Director the Office of Budget and Management - Repeal of Wasteful Catfish Program

Letter

The Honorable Shaun Donovan
The Office of Management and Budget
725 Seventeenth Street, N.W.
Washington, D.C. 20503

Dear Director Donovan:

We are writing to express our concerns about the proposed catfish program final rule currently pending before the Office of Information and Regulatory Affairs (OIRA) for interagency review. This is a program that the President requested that Congress eliminate in his FY 2014 budget request and that is opposed by a wide bipartisan coalition in both the House and Senate. The proposed catfish program would be extremely detrimental to Illinois seafood processors, farmers and exporters.

If implemented, the catfish program would shift jurisdiction of catfish from the Food and Drug Administration (FDA) to the Department of Agriculture (USDA). FDA is the agency that currently regulates all seafood and includes the country's leading seafood scientists. USDA currently only regulates livestock, poultry and processed eggs and has no seafood experience, and therefore would have to stand up an entirely new government program for catfish from scratch. Meanwhile, FDA's seafood experts would continue to oversee all other seafood.

This duplication is our first concern. By putting the program into place, the Administration will subject Illinois seafood processors to two inconsistent, incompatible and duplicative sets of regulations depending on the species of fish. The same facility will be regulated by USDA when it is processing catfish and by FDA when it is conducting the same processing function to any other species of seafood. The President highlighted this duplication in his budget request to Congress stating "Catfish inspection is already conducted by the Food and Drug Administration and the National Marine Fisheries Service. By freeing FSIS of this funding requirement the agency will be better able to focus on its core mission of ensuring the safety of the Nation's meat and poultry supply." The duplicative program is a complete waste of Illinois taxpayer funds, which we were elected to protect. The Government Accountability Office (GAO) has concluded in six separate reports that the catfish program will result in waste, fraud, and abuse, and will cost taxpayers $165 million over 10 years. GAO concluded last year that implementing the USDA catfish program would fracture the Federal food safety oversight of seafood and diminish the capability to ensure a safe food supply.[1] According to GAO, repealing the USDA catfish program "would avoid duplication of federal programs and could save taxpayers millions of dollars annually without affecting the safety of catfish intended for human consumption."[2]

In addition, Illinois farmers and exporters will be negatively impacted by this program. Once phased in, the program would block all imported catfish from entering the U.S. for years, as USDA conducts an "equivalency" process with foreign agricultural regulators. Given that USDA itself has concluded that there is no food safety basis for this program, this would violate our World Trade Organization (WTO) obligations and subject our exports to retaliation. Our trade partners would then be able to retaliate against Illinois soybean, pork, beef, and dairy producers.[3]

We agree with the Administration's position that the catfish program detracts from USDA's core food safety efforts, duplicates existing Federal regulation of seafood, and squanders Federal tax dollars and therefore should be eliminated. As you conduct your review of the proposed final rule, we urge you to fully consider these issues.

Sincerely,

Source