16pt 12pxFrom the American Cervid Alliance Newsroom
American Cervid Alliance Outlines Major Concerns of Proposed
Federal Chronic Wasting Disease Program Standards
15pt;'Franklin Gothic Book', ''Deer & Elk Farmers Asked to Submit Comments to USDA by March 31, 2014
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AYR, NE- The Chronic Wasting Disease Program Standards public comment period will end Monday, March 31, 2014. This is the final step of the process before the USDA officially unveils their suggested guidelines for Federal Chronic Wasting Disease policy.
It is vital that all deer and elk farmers submit at least one comment voicing their opinion of the proposed document, while citing specific concerns. The ACA has thoroughly examined Version 23 and outlined lingering concerns. ACA Leaders ask you to reflect on the concerns listed and determine how it could impact your farm and home state. Although the Program Standards are intended to be optional suggestions to state agencies from the USDA, any official suggestion written by the USDA needs to be based on sound science and not detrimental to our ability to grow the industry. It is important to take in consideration how both your current and future state program administrators could interpret the language.
Please make articulate comments, citing specific examples of language as it pertains to the Program Standards Version 23. We are not commenting on the Federal Rule at this time.
For example, with mention of double fencing on Page 22- Part A, Section 4; as Missouri elk and deer farmers work tirelessly to keep Missouri farmers and ranchers from having to double fence their high fence operations, it would defy logic for our industry to accept any language of the same theme from the USDA/APHIS in our federal program.
The American Cervid Alliance Leadership Council appreciates everyone's attention to this matter. The ACA asks these bullet points not be copy and pasted but make your comments clear about the issue while citing the area of the document and possible consequences they may have. We would also encourage you to thoroughly read the entire document and make comments pertaining to other parts of the Standards that you feel will have a negative impact to your state or operation. Also, please mention any positive comments you have as well.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifConcerns for Version 23 on the proposed Federal Standards document are as follows:
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifMention of Double Fencing 10pt;Cambria, serif: Very important for deer and elk farmers that do not want to be required to double fence their farm in the future. State wildlife agencies are using the USDA approved suggestions against the industry.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifPart B, Section 1.1 (pg 37) "In areas where CWD is not known to be present in free-ranging wild cervids, a second barrier is recommended that is adequate to prevent fence line contact of wild cervids with a CWD-exposed farmed cervid herd. Examples of barriers are described in Appendix II.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serif Part A, Section 4 (pg 22) "Therefore, the risk of CWD transmission between farmed cervid and free-ranging cervid populations should be assessed by individual States and addressed by additional barrier requirements as necessary. Appendix II (pg 46) Fence types in Colorado included a single woven-wire fence (2.4 m high), double woven-wire fences separated by 1 to 4 m (2.4 m high), and a single woven-wire fence (2.4 m high) plus a 3-strand offset electric fence either inside or outside the woven-wire fence. The study recorded only two direct naso-oral contacts between wild and farmed deer in Michigan during more than 77,000 hours of camera monitoring. Conversely, 77 interactions were documented between wild and farmed elk involving naso-oral contact. No direct contacts were observed through double woven-wire fences. Risk of direct contact was about 3.5 times greater for single woven-wire fences compared to an offset electric fence attached to the single woven-wire fence.
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifHunt Facility Language 10pt;Cambria, serif - Part A, Section 5.4 (pg 24). Section 5.4 dealing with testing of animals harvested in hunting ranches is not included in the Federal Rule and should be removed.
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifTop Soil Requirements: 10pt;Cambria, serifVery important protocol in the event a deer or elk farmer finds CWD.The language of "close confinement" is very vague and is up for interpretation. This is inappropriate for federal policy.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifAppendix IV- Section B, (pg 55) 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.
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifCleaning Requirements for Sale Barns 10pt;Cambria, serif: Very important to livestock markets, such as Lolli Bros in Missouri. This was not included in the Federal Rule.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifDefinition of "Limited Contact" on pg 8 "Pens at fairs, livestock auctions, sales, shows, and exhibitions should be thoroughly cleaned and all organic material removed after use and before holding another animal."
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifMention of Ten Foot Fencing: 10pt;Cambria, serif The Federal Program does not require or suggest ten foot fencing, therefore there should be no mention of speculation of the effectiveness of ten foot fence. State wildlife agencies can use this language against the industry.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifAppendix II of Version 23 (pg 37) VerCauteren, et al. (2007a and b) also measured behaviors and contacts through game-farm fences between farmed and wild white-tailed deer in Michigan and between farmed elk and wild elk and mule deer in Colorado. All sites in Michigan employed a single 3 m high woven-wire fence.
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifNotifying every state travel through transporting deer and elk: 10pt;Cambria, serif There is no requirement to notify every state in the Federal Rule, therefore it is unreasonable to suggest people call every state they travel through. In many cases, this idea would mean people calling at least six separate states.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifPart A, Section 8.4 (pg 33) "While it is not required, APHIS recommends producers and transporters provide a courtesy notification to any State through which they may transit en route to their final destination. This may be a benefit should emergencies arise and State assistance is needed."
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifCreation of a "Hold Order" that is used to prevent movement: 10pt;Cambria, serif This definition was not in the Federal Rule. This will just give states more power to hold animals.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifOn Page 8, "Hold Order- A temporary order issued by a State prohibiting movement of animals from or into a premises for a given period of time."
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifRemoving Semen Commingling as Part of the Definition of Limited Contact": 10pt;Cambria, serifThe definition of "commingling" was amended in Version 23 to say "Commingling includes contact with bodily fluids (blood, saliva, urine), or excrement from other farmed animals." However, the same exception was not made in the definition of "Limited Contact" on page 8. Semen is considered a bodily fluid. Clarification is needed.
'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal;margin-left:1in 10pt;Cambria, serifOn page 8, "Limited Contact- Any brief contact with a farmed animal such as occurs in sale or show rings and alleyways at fairs, livestock auctions, sales, shows, and exhibitions. Limited contact does not include penned animals having less than 10 feet of physical separation or contact through a fence; or any activity where uninhibited contact occurs such as sharing an enclosure, a section of a transport vehicle, sharing equipment, food, or water sources; or contact with bodily fluids or excrement. Pens at fairs, livestock auctions, sales, shows, and exhibitions should be thoroughly cleaned and all organic material removed after use and before holding another animal.
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'Times-New-Roman';000090;text-align:left;font-style:normal;font-weight:normal 10pt;Cambria, serifSanitary Precautions for Vehicles: 10pt;Cambria, serif This language is in addition to requirements listed in the Federal Rule.
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10pt;Cambria, serifPart B, Section 5 (pg 42) "Any third-party vehicle used to transport cervids should be cleaned and disinfected before and after transporting CWD-susceptible cervids. The owner should require the transporter to provide a statement that the truck or trailer was cleaned and disinfected, and should keep a copy of the statement. Producer-owned vehicles such as cars, pickup trucks, and tractors only may be shared among herds or premises under common ownership. Producer-owned equipment for transport of animals should be cleaned and disinfected if it is to be used for multiple herds managed by the same producer. Other farm equipment that tends to be heavily contaminated with soil or feces, such as manure spreaders and drags, should not be shared among herds or premises unless it is cleaned and disinfected with each use. Producers should keep records of these activities which involve commingling of animals in those herds.
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