--- The ACA distributed the following information to the council members last week, but I have received several requests to list them on the forums. These are just a starting point of concerns from the standards document version 22. The ACA is asking everyone that has additional concerns to please give them to us or your councilman. The ACA will have a running list in preparation to the comment period.
Thank you.
Initial Concerns Regarding CWD Standards Document- Version 22
The American Cervid Alliance is asking all council members to please review these initial concerns with the Version 22 Standards Document. These are bullets are just the starting point. Please share these with the leadership of your respective associations and bring any additional concerns you find. The council will discuss these during the next ACA meeting.
• Optional Language- Pertaining to page 3 of the Version 22 Standards document draft. The optional and guidance document language was intended to match the introductory sentences for both Part A and Part B but it has been removed for Part B on Version 22. Part B is the most restrictive and onerous of the entire document therefore it is imperative the there is consistency for Part A and Part B. Instead, the first sentence in Version 22 states these “describe minimum requirements.” This clearly contradicts the intent of the document.
• Wild Cervid Movement Exemption. Pertaining to Part A-8.1 of the Version 22 Standards document draft. Version 22 exempts wildlife agencies from re-location/movement requirements of wild cervids from the same certification requirements forced on farmed cervids. The document states, “Wild cervids can move under the authority of APHIS as long as they come from a low risk herd.” If USDA is truly concerned about the public and animal health relating to CWD, then all movement should be subject to the same rules even though the wild cervids are not part of the herd certification plan. Farmed cervids that are not enrolled in herd certification programs are prohibited to move interstate. There must be parity in movement regulations.
• 5 Year Quarantines. Pertaining to Part B-Paragraph B, of the Version 22 Standards document draft. The document states, all quarantines may require 5 years. This should be based on sound epidemiological evaluation of herd risk.
• Semen. Pertaining to Part A-2.6 of the Version 22 Standards document draft. The document states, “At this time there is no scientific evidence that germplasm (embryos or semen) may transmit CWD.” Language concerning germplasm and semen needs to be eliminated until science proves otherwise. The document specifically states there is no scientific evidence to connect CWD with semen therefore it should not be included in the document.
• 100% Testing for all Harvested Cervids in Preserves. Pertaining to the definitions on page 6 under the heading of “Hunt or Shooter Facility” of the Version 22 Standards document draft. In the last sentence of the definition of “Hunt or Shooter Facility,” Version 22 features the suggested idea of 100% testing for all harvested cervids in preserves by stating “States also may have CWD testing requirements of all cervids harvested from these facilities.”
• 5 Year Trace Backs and Trace Forwards. Pertaining to Part A-2.8 of the Version 22 Standards document draft. The document defines “Trace Forwards” under the definitions on page 8 as, “Trace Forward Herd- A herd that has received exposed animals from a CWD positive herd within 5 years before the diagnosis of CWD in the positive herd or from the identified point of entry of CWD into the positive herd.” Therefore, if someone is considered a trace forward herd within 60 months, their herd status would be suspended according to the language on page 14, If a herd is designated a CWD suspect herd, a trace back herd, or a trace forward herd, it will immediately be placed in suspended status pending an epidemiological investigation by the State animal health agency. A herd may remain in suspended status until the epidemiological investigation ends and appropriate actions are taken.”
If the trace forward herd to found to be “commingled” with the exposed herd within 60 months, then the trace forward herd will be designated as an exposed herd too. This is according to page 15, “If the epidemiological investigation determines that the herd was commingled with a CWD positive animal, the herd loses its program status and is designated a CWD exposed herd.” If a herd loses its status the five years of monitoring is void and reverts back to zero. This should be based on a sound epidemiological evaluation of herd risk. This is very important a
• 10 Foot Fencing. Pertaining to Appendix II of Version 22 the Standards document draft. The document states, “in at least one study (VerCauteren, et.al 2010) recommends fence height greater than 2.4 meters (at least 10 feet) to ensure 100 percent containment.” However, 8 feet is the requirement in the standards and rule. Theories of surveys suggesting anything otherwise is speculation and inappropriate to be included in the document. The document already states in Part A-4 and the Rule 9 CFR 55.23 “For herds established after the effective date of the CWD rule, the fence must be a minimum of 2.4 meters (8 feet) high and must comply with any other existing State regulations or requirements. In either case, the fence must be structurally sound, maintained in good repair, and of sufficient construction to contain the animals.” This language goes far above the intent of the federal rule.
• Definition of “Commingling” to allow AI Program to Lower Your Herd Status. Pertaining to Part B-2.4 item 6, under heading of “Limited Contact” of the Version 22 Standards document draft. The document states on page 12, “Commingling includes contact with bodily fluids or excrement from other farmed animals. Farmed cervids commingled with other farmed cervids assume the status of the lowest program status animal in the group.” Semen is considered a “bodily fluid.” This could offer the possible interpretation that if “bodily fluids” enters your herd via artificial insemination it could lower your herds’ status to the level of the AI herd. This theory is justified by the document already stating the warning about germsplasm (semen) in Part A-2.6 of Version 22 Standards document draft.
• Requiring Notification for Every State Traveled Through to Destination for Interstate Transport. Pertaining to Part A-8.4 of the Version 22 Standards document draft. The federal rule, located in 9 CFR 81.5, allows interstate transit to destination. It is stated again in the standards by stating, “Cervids eligible to move interstate in accordance with the CWD rule, and meeting the conditions specified in Part 81.5, can transit States enroute to their destination.” However, the standards then go on to require notification for every state during transit by stating, “Although the CWD rule does not require such transport permits, APHIS intends to advise producers and transporters to provide prior notification to any state through which they may transit en-route to their final destination ” This additional language is unnecessary and should be removed. The federal rule does not require this therefore the standards go above the requirements.
• Top Soil Removal Requirements. Pertaining to Appendix IV- Section B, under heading of “Dry lot Where CWD positive animals have been held in close confinement (this includes but is not limited to corrals, pens, stalls, and alleyways or pathways),” of the Version 22 Standards document draft. The document states, “In addition, removal of the top 1 to 2 inches of soil may help to reduce surface contamination. The soil removed may be buried deeply or incinerated.” There is no instruction of what state or federal agency will be responsible for soil removal cost therefore it would fall on the producer. Moreover, the language “Dry lot Where CWD positive animals have been held in close confinement (this includes but is not limited to corrals, pens, stalls, and alleyways or pathways)” is very vague and could incorporate dozens to hundreds of acres requiring the removal depending on the speculation. This is highly inappropriate.
• HCP with No State Participation. Pertaining to Part A-1 of the Version 22 Standards document draft. States without an HCP will only be allowed to participate in the program if funds are available. The document states, “subject to the availability of appropriated funds, in States that do not have an approved State CWD HCP.” There must be federal funds available if a state does not have an HCP or the producer will not be able to participate. Since this is a federal mandate, it is imperative the funding is provided.
• Quarantine for Commingled Animals for Five Years. Pertaining to Part B of the Version 22 Standards document draft. For 5 years even if herds have been commingled for any length of time. This should be based sound epidemiological evaluation of herd risk. Standard requirements of 5 years are inappropriate.
• Sale Barns. Pertaining to Part B under heading of “Limited Contact” of the Version 22 Standards document draft. The document states, “Pens at fairs, livestock auctions, sales, shows, and exhibitions must be thoroughly cleaned and all organic material removed after use and before holding another animal.” This ensures sale barns involving cervids must have total disinfection if there is limited contact with susceptible species. This will severely damage states with live animal auctions involving deer or elk. For example, Lolli Bros in Missouri.
• Definition of Hunt or Shooter Facility. Pertaining to the definitions on page 6 under the heading of “Hunt or Shooter Facility” of the Version 22 Standards document draft. Version 22 has now included the new definition of “Hunter or Shooter Facility” as “A privately owned ranch or other premises that operates to sell commercial hunts. These facilities should have fenced enclosures maintained to prevent ingress and egress of cervids. They may participate in an Approved State CWD HCP if they can comply with all minimum requirements of Approved State CWD HCP as set forth in the federal rule. States also may have CWD testing requirements of all cervids harvested from these facilities.” The word “Shooter” must be removed from the definition. The added language in the last sentence suggesting 100% testing is also inappropriate.
Thank you.
Initial Concerns Regarding CWD Standards Document- Version 22
The American Cervid Alliance is asking all council members to please review these initial concerns with the Version 22 Standards Document. These are bullets are just the starting point. Please share these with the leadership of your respective associations and bring any additional concerns you find. The council will discuss these during the next ACA meeting.
• Optional Language- Pertaining to page 3 of the Version 22 Standards document draft. The optional and guidance document language was intended to match the introductory sentences for both Part A and Part B but it has been removed for Part B on Version 22. Part B is the most restrictive and onerous of the entire document therefore it is imperative the there is consistency for Part A and Part B. Instead, the first sentence in Version 22 states these “describe minimum requirements.” This clearly contradicts the intent of the document.
• Wild Cervid Movement Exemption. Pertaining to Part A-8.1 of the Version 22 Standards document draft. Version 22 exempts wildlife agencies from re-location/movement requirements of wild cervids from the same certification requirements forced on farmed cervids. The document states, “Wild cervids can move under the authority of APHIS as long as they come from a low risk herd.” If USDA is truly concerned about the public and animal health relating to CWD, then all movement should be subject to the same rules even though the wild cervids are not part of the herd certification plan. Farmed cervids that are not enrolled in herd certification programs are prohibited to move interstate. There must be parity in movement regulations.
• 5 Year Quarantines. Pertaining to Part B-Paragraph B, of the Version 22 Standards document draft. The document states, all quarantines may require 5 years. This should be based on sound epidemiological evaluation of herd risk.
• Semen. Pertaining to Part A-2.6 of the Version 22 Standards document draft. The document states, “At this time there is no scientific evidence that germplasm (embryos or semen) may transmit CWD.” Language concerning germplasm and semen needs to be eliminated until science proves otherwise. The document specifically states there is no scientific evidence to connect CWD with semen therefore it should not be included in the document.
• 100% Testing for all Harvested Cervids in Preserves. Pertaining to the definitions on page 6 under the heading of “Hunt or Shooter Facility” of the Version 22 Standards document draft. In the last sentence of the definition of “Hunt or Shooter Facility,” Version 22 features the suggested idea of 100% testing for all harvested cervids in preserves by stating “States also may have CWD testing requirements of all cervids harvested from these facilities.”
• 5 Year Trace Backs and Trace Forwards. Pertaining to Part A-2.8 of the Version 22 Standards document draft. The document defines “Trace Forwards” under the definitions on page 8 as, “Trace Forward Herd- A herd that has received exposed animals from a CWD positive herd within 5 years before the diagnosis of CWD in the positive herd or from the identified point of entry of CWD into the positive herd.” Therefore, if someone is considered a trace forward herd within 60 months, their herd status would be suspended according to the language on page 14, If a herd is designated a CWD suspect herd, a trace back herd, or a trace forward herd, it will immediately be placed in suspended status pending an epidemiological investigation by the State animal health agency. A herd may remain in suspended status until the epidemiological investigation ends and appropriate actions are taken.”
If the trace forward herd to found to be “commingled” with the exposed herd within 60 months, then the trace forward herd will be designated as an exposed herd too. This is according to page 15, “If the epidemiological investigation determines that the herd was commingled with a CWD positive animal, the herd loses its program status and is designated a CWD exposed herd.” If a herd loses its status the five years of monitoring is void and reverts back to zero. This should be based on a sound epidemiological evaluation of herd risk. This is very important a
• 10 Foot Fencing. Pertaining to Appendix II of Version 22 the Standards document draft. The document states, “in at least one study (VerCauteren, et.al 2010) recommends fence height greater than 2.4 meters (at least 10 feet) to ensure 100 percent containment.” However, 8 feet is the requirement in the standards and rule. Theories of surveys suggesting anything otherwise is speculation and inappropriate to be included in the document. The document already states in Part A-4 and the Rule 9 CFR 55.23 “For herds established after the effective date of the CWD rule, the fence must be a minimum of 2.4 meters (8 feet) high and must comply with any other existing State regulations or requirements. In either case, the fence must be structurally sound, maintained in good repair, and of sufficient construction to contain the animals.” This language goes far above the intent of the federal rule.
• Definition of “Commingling” to allow AI Program to Lower Your Herd Status. Pertaining to Part B-2.4 item 6, under heading of “Limited Contact” of the Version 22 Standards document draft. The document states on page 12, “Commingling includes contact with bodily fluids or excrement from other farmed animals. Farmed cervids commingled with other farmed cervids assume the status of the lowest program status animal in the group.” Semen is considered a “bodily fluid.” This could offer the possible interpretation that if “bodily fluids” enters your herd via artificial insemination it could lower your herds’ status to the level of the AI herd. This theory is justified by the document already stating the warning about germsplasm (semen) in Part A-2.6 of Version 22 Standards document draft.
• Requiring Notification for Every State Traveled Through to Destination for Interstate Transport. Pertaining to Part A-8.4 of the Version 22 Standards document draft. The federal rule, located in 9 CFR 81.5, allows interstate transit to destination. It is stated again in the standards by stating, “Cervids eligible to move interstate in accordance with the CWD rule, and meeting the conditions specified in Part 81.5, can transit States enroute to their destination.” However, the standards then go on to require notification for every state during transit by stating, “Although the CWD rule does not require such transport permits, APHIS intends to advise producers and transporters to provide prior notification to any state through which they may transit en-route to their final destination ” This additional language is unnecessary and should be removed. The federal rule does not require this therefore the standards go above the requirements.
• Top Soil Removal Requirements. Pertaining to Appendix IV- Section B, under heading of “Dry lot Where CWD positive animals have been held in close confinement (this includes but is not limited to corrals, pens, stalls, and alleyways or pathways),” of the Version 22 Standards document draft. The document states, “In addition, removal of the top 1 to 2 inches of soil may help to reduce surface contamination. The soil removed may be buried deeply or incinerated.” There is no instruction of what state or federal agency will be responsible for soil removal cost therefore it would fall on the producer. Moreover, the language “Dry lot Where CWD positive animals have been held in close confinement (this includes but is not limited to corrals, pens, stalls, and alleyways or pathways)” is very vague and could incorporate dozens to hundreds of acres requiring the removal depending on the speculation. This is highly inappropriate.
• HCP with No State Participation. Pertaining to Part A-1 of the Version 22 Standards document draft. States without an HCP will only be allowed to participate in the program if funds are available. The document states, “subject to the availability of appropriated funds, in States that do not have an approved State CWD HCP.” There must be federal funds available if a state does not have an HCP or the producer will not be able to participate. Since this is a federal mandate, it is imperative the funding is provided.
• Quarantine for Commingled Animals for Five Years. Pertaining to Part B of the Version 22 Standards document draft. For 5 years even if herds have been commingled for any length of time. This should be based sound epidemiological evaluation of herd risk. Standard requirements of 5 years are inappropriate.
• Sale Barns. Pertaining to Part B under heading of “Limited Contact” of the Version 22 Standards document draft. The document states, “Pens at fairs, livestock auctions, sales, shows, and exhibitions must be thoroughly cleaned and all organic material removed after use and before holding another animal.” This ensures sale barns involving cervids must have total disinfection if there is limited contact with susceptible species. This will severely damage states with live animal auctions involving deer or elk. For example, Lolli Bros in Missouri.
• Definition of Hunt or Shooter Facility. Pertaining to the definitions on page 6 under the heading of “Hunt or Shooter Facility” of the Version 22 Standards document draft. Version 22 has now included the new definition of “Hunter or Shooter Facility” as “A privately owned ranch or other premises that operates to sell commercial hunts. These facilities should have fenced enclosures maintained to prevent ingress and egress of cervids. They may participate in an Approved State CWD HCP if they can comply with all minimum requirements of Approved State CWD HCP as set forth in the federal rule. States also may have CWD testing requirements of all cervids harvested from these facilities.” The word “Shooter” must be removed from the definition. The added language in the last sentence suggesting 100% testing is also inappropriate.
