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Yes I got the email yesterday.........
News*Release - April 3rd, 2013
**
The working group to rewrite the CWD Program Standards has made some huge strides in removing or relaxing language that was overly burdensome and clarifying language that was being misinterpreted. While we have came a long ways in shorting up the document and reaching consensus as a group, below are still some areas that we need to work our way through.
Number one on my list is the lack of relief in the rule once we attain certification. I would like to see relief for certification built into the Program Standards, but I am receiving pushback from the Federal regulators saying that the Rule language prohibits this not the Program Standards. USDA still must respond to our comment we submitted on the Federal Rule so I am going to continue to push for some type of relief or relaxation upon reaching certified status. Keep in mind that there is not one State CWD program that has any relief built into it as well.
The decrease in test age from 16 to 12 months of age. This is also in the rule and not the Standards, but is an area that I am concentrating on for future relief for certified herds to be able to drop back to 16 months of age for testing of certified animals. If we fight to throw out these program standards the Rule language will still require 12 months of age. Most State CWD Programs also required testing after 12 months of age.
Not allowing a reduction of testing for certified herds when they send animals to slaughter. We did clarify that if you sell your animals first and remove them from your inventory that you are no longer required to test them as they are not part of your certified herd. This is another issue that if we were to throw out the Standards the state program would kick in, and all state programs required cervids to be tested at slaughter.
"Requiring" both obex and lymph nodes to be submitted for CWD testing. We are still working on changing this to read that it is "recommended". We did gain in this area as the original Standards stated that if one of the tissues was not testable then both would not be counted. We also added language that explains that the State Official can make allowances for one tissue only.
We need more defined protocols for Trace Forwards and Trace Backs, so the State Animal Health Officials will have something to reference when they are dealing with exposed herds and animals that have died and were not tested. Trace Forwards and Trace Backs have always been a part of every epidemiological investigation and always will be. If we scrap these Standards the Epi investigation and quarantines will still take place, but without any type of guidance or standards to use as a baseline. These Standards should give us a vehicle to deliver the most current science and information to all states. The quarantines and traces from Iowa and Pennsylvania last year were implemented by their State programs not the Federal Rule or Standards.
*
Some of the positive attributes and changes of the Program Standards that I would hate to lose include-
Correcting the language that the physical inventory every three years does not have to be a "hands on" inventory.
These revised Standards offer other options for quarantined herds other than depopulation, such as moving under permit to terminal facilities and hunt ranches.
Exemptions during times of mass losses, such as during EHD outbreaks, to allow only 2 samples to be submitted instead of every animal that dies.
Specifies that this is a voluntary program. Producers that do not want to sell out of state and terminal facilities such as hunt ranches do not have to be on the program.
These Standards also clarify that when an animal is sold or moved and no longer on the inventory of your certified herd, it is not required to be CWD tested.
While I think the Trace forward and back can still use some tweaking, there have been some great changes already such as limiting the trace back to 5 years (in PA they went back 7 years) and these Standards also direct the states to conduct a risk evaluation based on time of exposure and they also direct that your time in the monitoring program should count from the time you sold the animal or the date that it died and not be an automatic 5 years from when the positive animal is found. This would have been a major help in PA and I think could help currently in NY as well.
The Standard also allows the use of microchips, tattoos, and other tag options.
The standards have been changed to allow additions to quarantined herds such as hunt ranches and from quarantined herds to slaughter or a quarantined hunt ranch, to allow continuity of business (interstate travel is only allowed for slaughter at this time).
These Standards also allow the State Official to grant exemptions for missed or poor samples and "removed" the confusing language about testing 2 to make up for 1 missed sample.
These standards specify that a producer or an accredited vet can take their own samples if they become a certified sample collector.
The removal of the language that took away certified status for herds that moved into endemic areas.
The allowance to take exposed animals to slaughter instead of a landfill if they are depopulated.
The fencing requirements in these Standards specify that 8 foot fencing is adequate and that double fencing is not needed.
These standards clarify the DNA testing protocol to prove an animal that you may have sold years earlier is the same as the sample being tested.
Interstate travel and transiting across all states is allowed in the Program Standards and the Rule. We have fought for this for years, why would we want to give this up now. What would happen to commerce if more states shut down travel across their state? This was a change made in the Rule at the request of the industry.
Another major change in the rule at the request of the industry was extending out the physical inventory from annually to every three years (and now is further clarified that it does "not" have to be a hands on inventory).
Another major change in the Rule was the removal of the 25 mile parameter as there was no science to back it up and the addition of allowing animals to move from CWD areas if the producer mitigates their risks.
I like that these Standards reference Taxidermy and hunting as a possible source of spreading CWD.
Lastly we have added language to the program standards to hold the wildlife agencies to a higher standard than in the past if they want Trans-locate wild cervids. Without these standards the wildlife groups are free to bounce animals all across this nation. Under these program standards they would have to certify the animals came from a source population that has been documented to be of low risk for CWD based on a CWD surveillance program in wild cervids and that program must be approved by the receiving state and APHIS. The certificate should include a summary of the surveillance data on the source population including population size and statistical parameters used to assess prevalence. While I would have liked to see the exact parameter spelled out, this is still a major increase over the free rein they have had up until this point. This is a huge step forward and is something that we can use in the future to build relief into our certification program to test at a statistical parameter based on prevalence in place of 100%. Do we want to scrap these standards and turn the wildlife agencies loose again?
I am sure there are more positives and negatives to these Standards and I will be combing through them before our next call on April 8th. I would ask everyone to please go through them as well and send me any comments you might have.
*
Shawn Schafer
**
News*Release - April 3rd, 2013
**
The working group to rewrite the CWD Program Standards has made some huge strides in removing or relaxing language that was overly burdensome and clarifying language that was being misinterpreted. While we have came a long ways in shorting up the document and reaching consensus as a group, below are still some areas that we need to work our way through.
Number one on my list is the lack of relief in the rule once we attain certification. I would like to see relief for certification built into the Program Standards, but I am receiving pushback from the Federal regulators saying that the Rule language prohibits this not the Program Standards. USDA still must respond to our comment we submitted on the Federal Rule so I am going to continue to push for some type of relief or relaxation upon reaching certified status. Keep in mind that there is not one State CWD program that has any relief built into it as well.
The decrease in test age from 16 to 12 months of age. This is also in the rule and not the Standards, but is an area that I am concentrating on for future relief for certified herds to be able to drop back to 16 months of age for testing of certified animals. If we fight to throw out these program standards the Rule language will still require 12 months of age. Most State CWD Programs also required testing after 12 months of age.
Not allowing a reduction of testing for certified herds when they send animals to slaughter. We did clarify that if you sell your animals first and remove them from your inventory that you are no longer required to test them as they are not part of your certified herd. This is another issue that if we were to throw out the Standards the state program would kick in, and all state programs required cervids to be tested at slaughter.
"Requiring" both obex and lymph nodes to be submitted for CWD testing. We are still working on changing this to read that it is "recommended". We did gain in this area as the original Standards stated that if one of the tissues was not testable then both would not be counted. We also added language that explains that the State Official can make allowances for one tissue only.
We need more defined protocols for Trace Forwards and Trace Backs, so the State Animal Health Officials will have something to reference when they are dealing with exposed herds and animals that have died and were not tested. Trace Forwards and Trace Backs have always been a part of every epidemiological investigation and always will be. If we scrap these Standards the Epi investigation and quarantines will still take place, but without any type of guidance or standards to use as a baseline. These Standards should give us a vehicle to deliver the most current science and information to all states. The quarantines and traces from Iowa and Pennsylvania last year were implemented by their State programs not the Federal Rule or Standards.
*
Some of the positive attributes and changes of the Program Standards that I would hate to lose include-
Correcting the language that the physical inventory every three years does not have to be a "hands on" inventory.
These revised Standards offer other options for quarantined herds other than depopulation, such as moving under permit to terminal facilities and hunt ranches.
Exemptions during times of mass losses, such as during EHD outbreaks, to allow only 2 samples to be submitted instead of every animal that dies.
Specifies that this is a voluntary program. Producers that do not want to sell out of state and terminal facilities such as hunt ranches do not have to be on the program.
These Standards also clarify that when an animal is sold or moved and no longer on the inventory of your certified herd, it is not required to be CWD tested.
While I think the Trace forward and back can still use some tweaking, there have been some great changes already such as limiting the trace back to 5 years (in PA they went back 7 years) and these Standards also direct the states to conduct a risk evaluation based on time of exposure and they also direct that your time in the monitoring program should count from the time you sold the animal or the date that it died and not be an automatic 5 years from when the positive animal is found. This would have been a major help in PA and I think could help currently in NY as well.
The Standard also allows the use of microchips, tattoos, and other tag options.
The standards have been changed to allow additions to quarantined herds such as hunt ranches and from quarantined herds to slaughter or a quarantined hunt ranch, to allow continuity of business (interstate travel is only allowed for slaughter at this time).
These Standards also allow the State Official to grant exemptions for missed or poor samples and "removed" the confusing language about testing 2 to make up for 1 missed sample.
These standards specify that a producer or an accredited vet can take their own samples if they become a certified sample collector.
The removal of the language that took away certified status for herds that moved into endemic areas.
The allowance to take exposed animals to slaughter instead of a landfill if they are depopulated.
The fencing requirements in these Standards specify that 8 foot fencing is adequate and that double fencing is not needed.
These standards clarify the DNA testing protocol to prove an animal that you may have sold years earlier is the same as the sample being tested.
Interstate travel and transiting across all states is allowed in the Program Standards and the Rule. We have fought for this for years, why would we want to give this up now. What would happen to commerce if more states shut down travel across their state? This was a change made in the Rule at the request of the industry.
Another major change in the rule at the request of the industry was extending out the physical inventory from annually to every three years (and now is further clarified that it does "not" have to be a hands on inventory).
Another major change in the Rule was the removal of the 25 mile parameter as there was no science to back it up and the addition of allowing animals to move from CWD areas if the producer mitigates their risks.
I like that these Standards reference Taxidermy and hunting as a possible source of spreading CWD.
Lastly we have added language to the program standards to hold the wildlife agencies to a higher standard than in the past if they want Trans-locate wild cervids. Without these standards the wildlife groups are free to bounce animals all across this nation. Under these program standards they would have to certify the animals came from a source population that has been documented to be of low risk for CWD based on a CWD surveillance program in wild cervids and that program must be approved by the receiving state and APHIS. The certificate should include a summary of the surveillance data on the source population including population size and statistical parameters used to assess prevalence. While I would have liked to see the exact parameter spelled out, this is still a major increase over the free rein they have had up until this point. This is a huge step forward and is something that we can use in the future to build relief into our certification program to test at a statistical parameter based on prevalence in place of 100%. Do we want to scrap these standards and turn the wildlife agencies loose again?
I am sure there are more positives and negatives to these Standards and I will be combing through them before our next call on April 8th. I would ask everyone to please go through them as well and send me any comments you might have.
*
Shawn Schafer
**
