Below you will find comments on the areas that I feel are important for the CWD Herd Certification Program and the Chronic Wasting Disease - Program Standards. You don't have to comment on all of them. Please feel free to add whatever comment or concerns you might have (if I missed something please let me know). Try to put these into your own words or explain how they will adversely affect your personal operation (short bullet points are fine, a line or two is all that is needed but the more information and facts you can give the better). Keep the comments professional as they are screened.
You may submit comments on the internet by August 13th, 11 PM CST - http://www.regulations.gov/#!submitComment;D=APHIS-2006-0118-0199 you may type your comments into the comment box, paste them from a word program, or attach them as a file.
Comments may be viewed at http://www.regulations.gov/#!docketDetail;rpp=250;so=ASC;sb=postedDate;po=0;D=APHIS-2006-0118 I would suggest everyone read the comments that are dated 2012 to get a better idea of what we are up against. I like to wait until the afternoon to post my comments so they don't appear online until after the comment time closes so it doesn't turn into a "chat room/public forum" where people can comment on my comments.
If you have questions or troubles commenting, you can give me a call at 651-212-1315.
Shawn Schafer
Comments on Docket No. 00-108-8 CWD Herd Certification Program
I support the right to traverse all states in-route to the receiving state as long as all interstate transportation regulations have been met.
Herd Certification should be linked to the premise or herd, not to the owner. It is undue regulation to require an owner to submit a sample from an animal that is no longer on the inventory of the certified herd.
A sample should be considered "complete" if any of the required tissues (obex or lymph node) are testable. To call a sample "incomplete if one of the two tissues is not testable, is too restrictive of regulation.
There should be relief when a herd attains certification status. After 5 years of monitoring all deaths the test age should be increased from 12 months to 16 months of age.
Certified Herds should not have to test healthy animals slaughtered under State or Federal meat inspection. This additional testing over the required natural mortalities will cause a financial hardship for the venison market.
Certified Herds should not be required to submit 100 % of all deaths. The requirement to sacrifice 2 healthy certified animals when a sample is missed is unwarranted. This is excessive regulation when a herd has been monitoring all deaths for 5 or more years (most herds will have over a decade of monitoring).
The requirement of a physical inventory just to read an ear tag without some form of CWD vaccination or CWD test, is over burdensome. All farmed cervid States currently have inventory systems that are verified and reconciled, and have been proven and accepted by the cervid industry for decades.
The CWD Herd Certification Program is important to rural America. USDA needs to request sufficient funding for the CWD-HCP to support administration, research, and most importantly indemnification!
Reindeer have not been proven to be susceptible by natural routes and should not be added to the list of program species.
Relocation of wild cervids should not be allowed until a live test is approved for the CWD Program or APHIS can define what level of surveillance is needed to document the source population to be low risk for CWD (this level should mirror the statistical level of monitoring required of the CWD-HCP for farmed cervids). Federal restrictions should be implemented to stop the translocation of wild cervid carcasses and to regulate the disposal of taxidermy waste.
You may submit comments on the internet by August 13th, 11 PM CST - http://www.regulations.gov/#!submitComment;D=APHIS-2006-0118-0199 you may type your comments into the comment box, paste them from a word program, or attach them as a file.
Comments may be viewed at http://www.regulations.gov/#!docketDetail;rpp=250;so=ASC;sb=postedDate;po=0;D=APHIS-2006-0118 I would suggest everyone read the comments that are dated 2012 to get a better idea of what we are up against. I like to wait until the afternoon to post my comments so they don't appear online until after the comment time closes so it doesn't turn into a "chat room/public forum" where people can comment on my comments.
If you have questions or troubles commenting, you can give me a call at 651-212-1315.
Shawn Schafer
Comments on Docket No. 00-108-8 CWD Herd Certification Program
I support the right to traverse all states in-route to the receiving state as long as all interstate transportation regulations have been met.
Herd Certification should be linked to the premise or herd, not to the owner. It is undue regulation to require an owner to submit a sample from an animal that is no longer on the inventory of the certified herd.
A sample should be considered "complete" if any of the required tissues (obex or lymph node) are testable. To call a sample "incomplete if one of the two tissues is not testable, is too restrictive of regulation.
There should be relief when a herd attains certification status. After 5 years of monitoring all deaths the test age should be increased from 12 months to 16 months of age.
Certified Herds should not have to test healthy animals slaughtered under State or Federal meat inspection. This additional testing over the required natural mortalities will cause a financial hardship for the venison market.
Certified Herds should not be required to submit 100 % of all deaths. The requirement to sacrifice 2 healthy certified animals when a sample is missed is unwarranted. This is excessive regulation when a herd has been monitoring all deaths for 5 or more years (most herds will have over a decade of monitoring).
The requirement of a physical inventory just to read an ear tag without some form of CWD vaccination or CWD test, is over burdensome. All farmed cervid States currently have inventory systems that are verified and reconciled, and have been proven and accepted by the cervid industry for decades.
The CWD Herd Certification Program is important to rural America. USDA needs to request sufficient funding for the CWD-HCP to support administration, research, and most importantly indemnification!
Reindeer have not been proven to be susceptible by natural routes and should not be added to the list of program species.
Relocation of wild cervids should not be allowed until a live test is approved for the CWD Program or APHIS can define what level of surveillance is needed to document the source population to be low risk for CWD (this level should mirror the statistical level of monitoring required of the CWD-HCP for farmed cervids). Federal restrictions should be implemented to stop the translocation of wild cervid carcasses and to regulate the disposal of taxidermy waste.
