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Review: Version 23 of Chronic Wasting Disease Program Standards “Better than Version 22, but still Burdensome to Industry”

Joined Nov 2012
183 Posts | 0+
Garnett, Kansas
From the American Cervid Alliance News Room


January 7, 2014


 


18pxReview: Version 23 of Chronic Wasting Disease Program Standards

“Better than Version 22, but still Burdensome to Industry�



18pxACA Creates Comparison Chart to Show New Changes


 


 


Please click link for comparison chart between Version 22 and Version 23.


AYR, NE- The long anticipated 23rd version of the Chronic Wasting Disease CWD Program Standards was published last week, marking the end of formal negotiations with USDA/APHIS and the start of the public comment period. The public comment period will last until March 31, 2014, and is the final step of the process before the USDA officially unveils their suggested guidelines for Federal Chronic Wasting Disease policy.


After several cervid industry leaders compared Version 23 to Version 22, there have been a few positive changes but several problems referred to as “deal breakers� still exist. The comparison shows language suggesting 100% testing of harvested trophy animals as been removed. Version 23 also removed language for restrictive physical inventories.


Version 23, however, still has major language concerns such as the suggestion of double fencing and mention of 10’ fences.  Containment procedures noted in Version 23 mirror Version 22, including language calling for the removal of 4â€� of top soil on farms with CWD.  Cleaning requirements for sale barns are also still in the document.  On page 34, the USDA recommends producers and transporters contact every state prior to traveling through with deer or elk.


“This is still a document that will cause unnecessary hardship for our members,â€� said Eric Mohlman, Moderator of the ACA.  “If the USDA has 8’ foot fences as the minimum requirement, then it’s inappropriate to even mention 10’ fencing in the standards; which it still does on page 46. These are suggestions that some wildlife agencies will use to over regulate our industry.â€�


The American Cervid Alliance leaders meet this week to discuss the Program Standards and the Chronic Wasting Disease Federal Rule.


 
 
Without a fight, it will be shoved down your throat just as in the past. They will give you a few crumbs but they have left enough in the wording to choke the industry. The comment phase is just a front to make it appear they are being fair to the industry but they have no intention of helping the industry.
 
There are big improvements between the two. There are still wording in there like 10ft and double fencing that should not be there.   Maybe its time to go back and get them all thrown out. There is only one positive route at this time and that is..Do whatever it takes to get a live blood test funded!!!
 
Deerchaser895851389145142



We don't have to adopt it do we?




 


Deerchaser,


If we want a Federal Rule, we have to have a set of standards. Version 23 is better than Version 22, but I think each version has been better than the last. Version 23 still has major problems though, that you'd think if the USDA wanted them removed they would have done so by now. We can all make comments for the record during the comment period, but the comment period is not a place where miracles occur, because the comment period in July 2012 went very bad for us.


 


If you look at the brand new ACA update from last night's meeting, these standards and the rule itself was a major topic. We had discussion about whether this industry evened wanted a rule. No person of the dozens in attendance could point to one benefit we gain by it,.  The rule itself has added an extra layer of regulations on top of the state, which are not necessary, and wouldnt otherwise be there. The Rule is already in place, but there are a couple options the indsutry could utilize IF the industry wants to stand together. Member associations are going back to their boards right now.


 


Angie, you are correct, the CWD blood test would be a great benefit to the industry and its good to see so many folks working together on this...


 


Travis
 
Travis is right.


The comment session is not likely to solve the industry problems since government does not want to promote this industry. The comment session is mainly for show. They put all these deal breaker regulations in the wording, that will choke the industry, and then after the comment period, they remove a few of them to lead people to believe they have negotiated in good faith knowing full well there is still plenty left in the proposed regulations to accomplish their goal which is to kill this industry.
 
Autry895961389195326



Travis is right.


The comment session is not likely to solve the industry problems since government does not want to promote this industry. The comment session is mainly for show. They put all these deal breaker regulations in the wording, that will choke the industry, and then after the comment period, they remove a few of them to lead people to believe they have negotiated in good faith knowing full well there is still plenty left in the proposed regulations to accomplish their goal which is to kill this industry.




As we just found out ourselves. A comment period means.Squat. The decision has been made before anyone walks in the room or a piece of paper has been read. 


 After going through what we just did i now believe that everyone should get together and have any standards or rules thrown out and then work within the states.  If the state can go above anything...and if you read the words they are asking the states to be more strict..any rule or standard then what good is it?


 


Our state would not work with us reguardless of any rule but some states out there still have vets and those in charge that will use their heads and are dealing with cwd for what it is.  Like i wrote above in my opinion i believe we need to do whatever it takes to get a live blood test funded at all costs. Thats the only thing they hold over our heads to use as power to get their other agenda completed.  I also believe that there should be something implemented into this industry that a certin percent of every deer or semen sale that goes thru any auction service should be taken out and used for just this kind of need.  It worked for the beef guys and i had to pay it years ago when we had cattle. No choice to not pay it!  If we need just over 100 grand to fund this testing for a year then we would have it no problem!
 
I also have been in the rule making process in Montana.  Fact is I was the lead person for the industry in Montana.  The involvement of the industry in Montana really was just for show.  When you take people that want to help the industry and they believe these agencies are working in good faith you lose.  When we as an industry figured out we were pawns and started to put in our own requirements for the industry the State closed down rule making process.  The State DOL and Fish and Game got most of what they wanted then they used the new rules with a different agenda and direction than talked about in rule making just shut down the growth of the industry in Montana.  The public comment process is also just a joke as it will add items that were not thought of during the rule making process.  I don't care how friendly the Fish and Game is to your face they really all have the same agenda to shut down the game farm industry.   I'm sorry to say but CWD rules all looks to me like the same program agenda to shut down the industry without compensation.  We will get a few crumbs out of this but the rules have left us with a mess.  No consistancy from State to State, what business can be run like this?  If anyone believes these agencies only want to bring safety from CWD to wild animals and yet not hurt this industry you are not seeing the whole picture.  That picture is to shut down the deer industry.  It's time to wake up and stop bending over.  If we as an industry don't get a live test soon and continue to let these agencies run us over  with excess rules this industry is over.  God help this industry but remember God helps those that help themselves.
 
Jack,


When Dr Clifford gets back to Laurie we will know more on what it will take for the number of animals on the blood test research.


There is a CWD herd in Canada that can be used and possible 2 in the US. Beyond that we may have to have volunteer animals depending on the number the government will want to verify the validity of the test.  Slaughter facilities would be great to collect additional data if we could get blood before they are killed.  I would be willing to donate some of my time to help with something like that. We have a processor down the road that is in the deer business that I'm sure would work with us.
 
jerrilee cave896021389208501



Jack,


When Dr Clifford gets back to Laurie we will know more on what it will take for the number of animals on the blood test research.


There is a CWD herd in Canada that can be used and possible 2 in the US. Beyond that we may have to have volunteer animals depending on the number the government will want to verify the validity of the test.  Slaughter facilities would be great to collect additional data if we could get blood before they are killed.  I would be willing to donate some of my time to help with something like that. We have a processor down the road that is in the deer business that I'm sure would work with us.




 


Jerrilee,


The blood test research effort is great and I am a proponent of the industry raising funds to support it, but is not a solution regarding whether we need a  Federal CWD Rule and Standards. We, as the industry, need to determine if we want this extra layer of government regulation. We can work toward the CWD blood test and vaccine concurrently but we can't forget the question at hand regarding the rule and standards.


 


Travis
 
Travis896041389210162



Jerrilee,


The blood test research effort is great and I am a proponent of the industry raising funds to support it, but is not a solution regarding whether we need a  Federal CWD Rule and Standards. We, as the industry, need to determine if we want this extra layer of government regulation. We can work toward the CWD blood test and vaccine concurrently but we can't forget the question at hand regarding the rule and standards.


 


Travis




I believe the standards and rules should be done away with.  Even if states want to do what Ny did, they will do it above any federal anything.  We will lose what little bit of federal money there is but would we see any of that anyway.


 I think now- Yesterday!!!  Is the time to start finding a way to fund the live test research.  I also feel that just asking for peoples/states help is not going to cut it.         At least i can tell you it wont up here. To many along for the ride without giving/doing anything!
 
It appears that the majority of the industry cannot live with the proposed regulations. The working group did not accomplish a set of regulations that's fair to the industry. If ACA could have kept the wildlife agencies out of the rule making process, as they had promised, there may have been a chance of fair regulations. These wildlife agencies are never going to agree with anything that is reasonable for the industry. They demand strict unreasonable regulations for the industry but they are unwilling to abide by those same regulations when it comes to their agencies wanting to relocate animals for restocking free range animals.
 
Guys this industry has allowed all this extra testing trying to prove we have healthy animals and our testing works in our private herds and will protect wildlife just to stay in business.  Well how has this worked for us?  As far as I'm concerned all we have done is allow them to kill our industry while they sneak out of any responcialty for this disease and any compensation for putting this industry out of business.  Our leaders have always went with if we just take this extra testing we can have a working industry and stay in business.  Wake up people we have proved nothing to anyone and the testing will not save us.  I personally would take testing if it was the same all over the US but the way States work this minimum standard and go way above with over regulation is stupid.  If we don't take some kind of stance united on this we will just be over regulated out of business in time.


 


I do want to personally thank all those working to save this industry giving their time and money and I know from personal experience it is a hard job with all the quarter backs that are not working on this problem with you.  But I really feel the time for just getting along with Fish and Game and other government agencies is over.  We need to change our method of working with people that want to regulate the industry out of business.
 
Even with all the hard working people that have tried to solve this industry's problems this past year, this industry is in the worst shape it has ever been in. We can sugar coat it and brag on this accomplishment or that accomplishment but the fact remains, this industry is in serious trouble and we're in no better shape now than we were over a year ago.


 


Writing letters has not worked. Having dozens of meetings has not solved the industry problems. Giving funds to individuals that were fighting government agencies did not change the outcome. The working group was not able get us reasonable regulations. Nothing that was done, this past year, changed the condition of this industry.


 


Thanks to all those that made sacrifices of both time and funds to try and solve this industry's problems but the ship is still sinking.
 
I agree that the standards are designed to put us out of business


If we can it where will that leave us?  Will we be in worse shape than we are now?


If we don't can it, are we better off?


These are questions we as an industry must answer.


 


Autry,


I think it is unfair to say nothing was accomplished.


I'm sure that Travis, Laurie, Charlie, and Eric can get on here and tell you about the head way that has been made.Most may not visibly be able to see it, but they did.



Jack,


I think that if we get a live test we must help develop a program that is not going to TEST US OUT OF BUSINESS.


For one dropping the brucellosis sounds like will be in the works. 


We dont suggest we test for CWD every year.Why do we need to do that when we test heads and have such a low rate of infection.  That doesn't make sense.


Do we suggest we test every 3 years????


My thought is that we test heads as we do now and test animals that are moving across state lines.


If a farm has a positive then test the whole herd.  Then we would have to decide how often we would retest.


If and when we get a live test lets not start out making this any more difficult for ourselves than need be. 


Have we not shown for 10-11 years than our surveilance is working?


Positive herds should be able to move an animal to a terminal facility to be hunted. 


CWD is only a threat to cervids so lets not make it overkill.
 
Autry896101389217776



Even with all the hard working people that have tried to solve this industry's problems this past year, this industry is in the worst shape it has ever been in. We can sugar coat it and brag on this accomplishment or that accomplishment but the fact remains, this industry is in serious trouble and we're in no better shape now than we were over a year ago.


 


Writing letters has not worked. Having dozens of meetings has not solved the industry problems. Giving funds to individuals that were fighting government agencies did not change the outcome. The working group was not able get us reasonable regulations. Nothing that was done, this past year, changed the condition of this industry.


 


Thanks to all those that made sacrifices of both time and funds to try and solve this industry's problems but the ship is still sinking.




WOW Really!  Autry i think you are going a little overboard here.  I mean yes things are a changing but you coming on here slamming every single good positive that may help with something like the..skip is sinking..is a bit much.   They are still pulling the same **** they have for years and we now finally may have an out to prove what our animals are...Thats a blood test!!!!    I see your name on all these emails i get about the elk industry on them. Do you think you have the power to get every one of those elk farms you represent to donate $5.00 per head that they own on their farm to donate to the 125 grand we need to research this testing for the next year?


If not just wish us good luck and move on!


 Mike!!!!
 
Jerrilee,


Yes I believe a live test will help the industry.  But I've said for 14 years being TB certified, Bangs Certified and CWD monitered really hasn't done anything to prove to the public we were a healthy industry.  Sure we all know that but it has been a secret to the general public.  It has kept some doors open and some officals have worked with us but most didn't.  I very much resent being in the CWD program and still be looked on as the industry that started CWD and spread CWD to the wild deer.  I also very much hate the fact that I have had to pay for CWD testing in my State with CWD testing cost from 125 to 300 a test because we  have a Vet do our work in collecting and sending in samples.  Just do the math for those 14 years and take an average of 150.00 for testing times 1500 head submitted.  In my case thats 225000 spent/wasted on this testing.  I'm sorry but between cost of production and testing on slaughter animals very little profit was made.  I can think of many other ways to spend money that would given me more pleasure.  I think all deer and elk farmers feel they should have gotten credit from their State health officals but my State never did stand up for the health of the deer industry and I'm sure most of the other States didn't get health support from their Dept of Livestock either.


I'm sure the ACA will get collection going for a live test and even though we are cutting back on animals I will support that cause.
 
jerrilee,


 


I know that there have been a few accomplishments this past year but none of them has helped the industry yet. Like I said in another post, maybe in a year or two, these accomplishments will help the industry but I'm not sure how many will still be around to benefit from what's been done this far.