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The new US military role in the European Union's import program: strategic implications ensuring safe food for the European theater.

It is known across the Department of Defense (DoD) that the Secretary of the Army is the Executive Agent for DoD Veterinary Public and Animal Health Services, the functional responsibilities for which are assigned to US Army Veterinary Services. (1, 2) A critical component of the Veterinary Services mission is the assurance of safe food and water for DoD personnel and their dependents assigned throughout the world, even extending to some US embassies and consulates in the most austere environments.

However, much less is known about the behind-the-scenes, complex mechanisms required to provide those safe food and water sources, achieved only by the consistent and elaborate coordination among military and civilian public health authorities, medical and veterinary personnel, logistics personnel, and foreign customs authorities. It is probably safe to say that the average consumer at an overseas Defense Commissary Agency commissary or an Army and Air Force Exchange Service facility is only vaguely aware of the intensive efforts made on their behalf to ensure constant availability of US food items.

The US European Command (USEUCOM) area of responsibility is a prime example of the enormous complexities involved with exporting and shipping foodstuffs to DoD's multiple locations around the world. As DoD locations span Europe, US government-owned subsistence transits the breadth of the continent, crossing many borders before reaching outlying installations. To support that mission, the processes involved have historically required sound logistics, communication, and teamwork across multiple services. In recent years, however, it has also required strategic diplomacy to integrate those processes into compliance with the European Union (EU) Trade Control and Expert System (TRACES), designed to track animal and animal origin product EU imports.

This article highlights the progression of US military's incorporation into and compliance with TRACES. It outlines the broader strategic implications of United States engagement in that program to ensure food safety and quality assurance of public health for DoD personnel assigned throughout USEUCOM while, at the same time, ensuring, and even strengthening, diplomatic ties and trust with European partners.

As the EU was coming together as a fully functioning regulatory and authoritative body representing its member states, around the year 2000 the European Commission Directorate General for Health and Consumers began to pay attention to animal origin products from the US that were entering the EU bound for US military installations. Movement of such products had been ongoing decades, but the backdrop of a number of high impact, economically costly animal disease outbreaks in the EU, combined with emerging awareness of and concerns about the use of growth hormones, antibiotics, and genetically modified organisms by the US agricultural industry, served to elevate attention even further.

The first of these animal disease outbreaks in the EU began in 1996 with cases of bovine spongiform encephalopathy (BSE), otherwise known as "mad cow disease," occurring in Britain. The scientific community associated human cases of the variant form of Creutzfeld-Jakob disease with the consumption of BSE-contaminated beef, and the resultant economic loss to the United Kingdom (UK) reached an estimated $6.4 billion by early 2001. (3) The BSE outbreak was quickly followed by an epidemic of classical swine fever which began with the first case reported from Germany in January, 1997 and presumably spreading from there to the Netherlands, then on to Italy, Spain and eventually to Belgium. (4) In 2001, the UK's livestock industry was again hit, this time by a foot-and-mouth disease outbreak which crippled exports and cost the UK an estimated 8 [pounds sterling] to 8.6 billion [pounds sterling] ($12 to $13 billion at current exchange rates) to resolve. (5, 6) Collectively, these diseases resulted in devastating effects on health, economic, and consumer confidence. It had become obvious that there was enormous potential economic risk posed by the introduction of foreign animal diseases into the EU. This awareness, undoubtedly, contributed to shaping the comprehensive import regulations currently being developed and implemented.

There was, however, another significant change as a result of the 1996 association of human disease with the consumption of potentially BSE-contaminated beef. Historically, the US military had procured beef for the European theater's needs predominantly from US approved European sources (primarily from the UK as it was economically the most competitively priced). But once the protection of human health was at risk according to the best scientific information available, the US military categorically shifted to exclusively procuring beef from US sources via import, as the US beef industry largely escaped infection with BSE and was considered safe. This monumental change of sourcing was to have far-reaching effects approximately a decade later when EU attention focused on US military meat importation.

By 2008, the EU community's internal implementation and compliance with import regulation had reached maturity and the spotlight shifted to US military animal origin imports which were not in compliance with existing regulations. Historically, US military importation had been permitted with the recognition that its purpose was to supply military forces outside the European economy, so installations were treated as "foreign soil" versus host nation. But that "exemption" was coming under increasing scrutiny, and the United States was approached to initiate an effort to comply with new EU requirements. Initial meetings, panels, working groups, and senior leader engagements failed to make progress toward this end, however, and US representatives gradually concluded that the problem would be more difficult to solve than originally anticipated, despite the best intentions.

Preventing the construction of a solution framework was a significant legal hurdle. From the inception of the issue, legal experts in multiple organizations insisted that no governmental organization outside of the Office of the Secretary of Defense (OSD) or the Department of State had the authority to initiate any such agreement. Over many years, multiple legal opinions were issued that effectively prevented any work toward an achievable solution. The chief legal concern was that while the United States and each of the individual member states in the EU are themselves sovereign nations, the EU itself, while a legislative body, is not recognized as a sovereign body and thus has no standing from which to negotiate.

By 2011, with multiple initials attempts failed and no traction toward compliance in sight, the EU's patience was wearing thin and US animal origin product imports were being threatened with refusal at ports of entry. It was clear that the US military had not responded rapidly enough and that EUCOM had to step in to reach a resolution. Finally, in the fall of 2012, senior leaders from EUCOM and other agencies including the Principal Deputy Assistant Secretary of Defense for Logistics and Materiel Readiness and the Joint Staff's J4 and J5 met and concluded that this problem required urgent solution as product procurement was in imminent jeopardy. Ultimately, the OSD determined that because this issue primarily affected forces serving in the EUCOM area of responsibility, the EUCOM Directorate of Logistics could serve as the lead agency to develop and implement policy governing a successful solution.

POINT OF ENTRY: EU BORDER INSPECTION POSTS

First, and most critically, a successful solution was required to address the arrival and acceptance of shipments at EU Border Inspection Posts (BIPs), the importation entry points located at ports, certain borders, and airports. Then, the EU required that US military shipments be tracked from entry to receipt at destination using the EU's electronic tracking database, TRACES. This system is used, along with the information provided in accompanying animal health certificates and other import documents, to produce the EU transit health certificate called a Common Veterinary Entry Document (CVED) which accompanies a shipment. Upon receipt at destination, a shipment is either processed by an exit BIP as having left the EU in the case of transiting goods or, in the case of goods bound for retail operations with consumer sales, its status updated to reflect arrival at its final tracking destination. Thirty days are allowed from the time a shipment is logged at the entry point until it must be closed out. Failure to meet requirements potentially jeopardizes future shipments for a specific importer as compliance history is monitored and a poor track record can result in subsequent refusals of entry.

PROGRESS TOWARDS SOLUTION

Once authority was granted for the involved players to engage with the EU toward constructing a workable framework for US compliance, progress was slow, but at least there was movement. While the US would no longer be permitted to import goods with an entirely free rein, it was recognized that shipments intended for US installations were, in fact, not freely entering the EU food economy as were most other imported goods. So, despite the fact that US military imported animal origin products that often do not meet EU standards (eg, are not from EU approved sources, are not antibiotic free or may contain unapproved growth hormone), the EU level veterinary authority made the determination that US import shipments would be considered to be transiting the EU until they arrived at designated US installations which were to be considered "non-EU" destinations. This decision took advantage of the existing allowances in EU regulations that permitted the legal transit of goods bound for actual non-EU countries, such as from EU ports through the EU, then out via an EU exit BIP where the shipment is closed out of the TRACES tracking system. This decision, however, did require the official designation of US installations as exit BIPs and the identification and training of personnel at these locations to be able to perform this function.

As the oversight and authority for importation of animal origin products falls under the purview of EU veterinarians and the DoD veterinary mission belongs to the US Army, the US Army Public Health Command Region-Europe (PHCR-E) was delegated authority by USEUCOM to provide direct support and program implementation. The PHCR-E controlled most veterinary assets in Europe and its deputy (the senior veterinary officer) was appointed the Competent Veterinary Authority and granted limited authority to engage the EU directly regarding the importation program, thus ensuring appropriate professional engagement with the European veterinary authorities.

A decision was also made regarding prime vendor warehouse facilities located in the EU which could not technically be considered US military installations. They were assessed and categorized as nonconforming warehouses (permitted under EU legislation). They could function to process transiting goods provided they maintained US government owned goods strictly isolated from goods intended for the EU, and they shipped only to final destinations that included ships' supply, US military installations, or other locations actually outside the EU, such as those under the US Central Command or Africa Command. European Union veterinarians continued to be involved with these facilities which function as both entry and exit BIPs as subsequent shipments are moved on EU generated transit paperwork ("daughter CVEDs" based on the original CVED), then closed out when they reach their ultimate destinations at US installations.

US INTERAGENCY COOPERATION

Before an export shipment of animal origin product leaves the United States, the Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) * certifies the goods and issues health certificates confirming their quality. The FSIS is the public health agency within the USDA responsible for ensuring the nation's commercial supply of meat, poultry, and egg products is safe, wholesome, and correctly labeled and packaged--in other words, safe for human consumption per US standards. Once approved by USDA, a shipment can be loaded at a supplier's location, then transported to the east coast for transoceanic movement to European BIPs.

The USDA Foreign Agricultural Service (FAS) [dagger] links US agriculture to the world, enhancing export opportunities and global food security, as well as expanding and maintaining access to foreign markets for US agricultural products by removing trade barriers and ensuring US rights under existing trade agreements. The FAS also works with foreign governments, international organizations, and the Office of the US Trade Representative to establish international standards and rules to improve accountability and predictability for agricultural trade. For the DoD, the US Foreign Agricultural Service Mission to the EU, headquartered in Brussels, Belgium, has played an absolutely key role in assisting with issues related to importation of animal origin products to the EU. They were critical in overcoming challenges with the implementation of TRACES and continue to assist with ongoing and emerging situations.

APPROACHING A STABLE END STATE

In 2013, the multiyear-long process of US military integration into the EU import program culminated with the release of USEUCOM European Command Instruction 4506.01: USEUCOM Guidance Regarding the EU TRACES, which codified the rules of engagement for the working levels of all service components and affected agencies to participate in the European import program. This guidance serves as the cornerstone for ensuring animal origin products including fresh meat and meat products from the US are available at commissaries, dining halls, food courts, schools, day care centers, and other installation food sources.

Combatant commands such as EUCOM are organized and structured for strategic military oversight and direction. As such, it is unusual that EUCOM was designated as the lead to pull together multiple service components and both DoD and non-DoD agencies to safeguard the US European theater's access to US animal origin products. Although progress remains ongoing, it is far enough along to be assessed and considered a success story.

* http://www.fsis.usda.gov/About_FSIS/index.asp

[dagger] http://www.fas.usda.gov/aboutfas.asp

ACKNOWLEDGEMENT

The research involved in the preparation of this article was supported in part by an appointment to the Knowledge Preservation Program at the US Army Public Health Command administered by the Oak Ridge Institute for Science and Education through an interagency agreement between the US Department of Energy and the Army Public Health Command.

REFERENCES

(1.) Department of Defense Directive 6400.04E: DoD Veterinary Public and Animal Health Services. Washington, DC: US Dept of Defense; 2013.

(2.) Army Regulation 40-905: Veterinary Health Services. Washington, DC: US Dept of the Army; 2006.

(3.) Regmi A, ed. Changing Structure of Global Food Consumption and Trade. Washington, DC: US Dept of Argiculture Economic Research Service; 2001:60. Agriculture and Trade Report WRS-01-1. Available at: http://www.ers.usda.gov/media/293645/wrs011_1_.pdf. Accessed April 13, 2015.

(4.) Greiser-Wilke I, Fritzemeier J, Koenen F, et al. Molecular epidemiology of a large classical swine fever epidemic in the European Union in 1997-1998. Vet Microbiol. 2000;77(1-2):17-27.

(5.) Donaldson A, Lee R, Ward N, Wilkinson K. Five Years On: The Legacy of the 2001 Foot and Mouth Disease Crisis for Farming and the British Countryside. Newcastle, England: Centre for Rural Economy; February 2006:4. Centre for Rural Economy Discussion Paper Series No. 6. Available at: http://www.ncl.ac.uk/cre/publish/discussionpapers /pdfs/dp6.pdf. Accessed April 22, 2015.

(6.) National Cattlemen's Beef Association. Fact Sheet: Industry Economics. FootAndMouthDiseaseInfo.org web site. Available at: http://www.footand -mouthdiseaseinfo.org/factsheetindustryeconomics.aspx. Accessed April 22, 2015.

MAJ Michael McCown, VC, USA

Jacob L. Hall, II

Megan McCormick, DVM, MPH

Lt Col Henry H. Triplett, III, USAF

AUTHORS

MAJ McCown is Chief, Veterinary Services Division, US Army Public Health Command Region-Europe, Landstuhl, Germany.

Mr Hall is a Traffic Management Specialist, Air Force Security Assistance and Cooperation Directorate, Wright-Patterson Air Force Base, Ohio.

Dr McCormick is the EU TRACES Specialist, US Army Public Health Command Region-Europe, Landstuhl, Germany.

Lt Col Triplett is assigned to Headquarters, US European Command, Stuttgart, Germany.
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Author:McCown, Michael; Hall, Jacob L., II; McCormick, Megan; Triplett, Henry H., III
Publication:U.S. Army Medical Department Journal
Date:Jul 1, 2015
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