Below is an outline for those that have not yet commented on the CWD Rule.
I cannot stress how important this is for the industry!!! Please pass this on to producers that you think will step up to the plate and speak up for the industry. This does not take a lot of time, you can use my bullet points below or you can come up with comments of your own based off of them or go to this link http://www.aphis.usda.gov/newsroom/2012/06/cwd_program.shtml and address any concerns you find. We all have different view and opinions concerning CWD and the need for a program, but, that is not the issue at hand, this is the rule that is coming and we need to use this time to start the process to fix the areas that affect us the most.
This must be completed by midnight Eastern or 11 pm Central. I have just got done reading the comments submitted so far and it is shameful that there are so few from the industry. Thanks to those that did take the time to respond. I sent out the rule and how to comment 30 days ago, so no one has an excuse that they didn't know this was coming. Please comment, it will only take 5 minutes!
You can submit comments by clicking on this link http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0199 and then click on comment. Please keep your comments professional!
You can type your comments in a Word program and enter them as an attachment or quickly type them in the comment box. If you can navigate your way to this thread on deerfarmer.com then you will have no problem commenting.
The areas I feel that we need to hit on are -
1. We support States Rights, but we also support the right to travel across a state to do interstate commerce.
2. We should not have to test animals from Certified herds when they are slaughtered under State or Federal Meat Inspection.
3. When a new species is added such as Sika, they need to find a way to bring them in slowly, such as only needing 3 years from non-CWD states.
4. Two forms of ID is too much.
5. A physical inventory is over burdensome upon the industry and also could be a welfare issue.
6. There is no relief or benefit for certification!
7. There needs to be an established protocol for a herd to mitigate their risk and still do business when they are in a state or area with CWD in wild cervids.
8. Wild cervids should not be able to move unless there is a live test.
9. There needs to be carcass transportation restrictions for wild cervids.
10. We support a voluntary program.
11. If you compare the infection rate of states with a 12 month age requirement for testing to those states that only test 16 month or older you will find that the lower age has never resulted in finding a CWD positive herd earlier. Lowering the required age will only add cost to the producer and program with no benefit.
I cannot stress how important this is for the industry!!! Please pass this on to producers that you think will step up to the plate and speak up for the industry. This does not take a lot of time, you can use my bullet points below or you can come up with comments of your own based off of them or go to this link http://www.aphis.usda.gov/newsroom/2012/06/cwd_program.shtml and address any concerns you find. We all have different view and opinions concerning CWD and the need for a program, but, that is not the issue at hand, this is the rule that is coming and we need to use this time to start the process to fix the areas that affect us the most.
This must be completed by midnight Eastern or 11 pm Central. I have just got done reading the comments submitted so far and it is shameful that there are so few from the industry. Thanks to those that did take the time to respond. I sent out the rule and how to comment 30 days ago, so no one has an excuse that they didn't know this was coming. Please comment, it will only take 5 minutes!
You can submit comments by clicking on this link http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0199 and then click on comment. Please keep your comments professional!
You can type your comments in a Word program and enter them as an attachment or quickly type them in the comment box. If you can navigate your way to this thread on deerfarmer.com then you will have no problem commenting.
The areas I feel that we need to hit on are -
1. We support States Rights, but we also support the right to travel across a state to do interstate commerce.
2. We should not have to test animals from Certified herds when they are slaughtered under State or Federal Meat Inspection.
3. When a new species is added such as Sika, they need to find a way to bring them in slowly, such as only needing 3 years from non-CWD states.
4. Two forms of ID is too much.
5. A physical inventory is over burdensome upon the industry and also could be a welfare issue.
6. There is no relief or benefit for certification!
7. There needs to be an established protocol for a herd to mitigate their risk and still do business when they are in a state or area with CWD in wild cervids.
8. Wild cervids should not be able to move unless there is a live test.
9. There needs to be carcass transportation restrictions for wild cervids.
10. We support a voluntary program.
11. If you compare the infection rate of states with a 12 month age requirement for testing to those states that only test 16 month or older you will find that the lower age has never resulted in finding a CWD positive herd earlier. Lowering the required age will only add cost to the producer and program with no benefit.
