ATTN: Cervid Industry
January 14, 2016
The USDA’s Proposed Brucellosis & TB Rule May Impact Your Interstate Movement
The American Cervid Alliance (ACA) is notifying all cervid producers on the possible changes to interstate movement requirements. Last month, the United States Department of Agriculture published its proposed rule for TB and Brucellosis for cervids, bison and cattle. Because of the proposed changes to the rule, you may want to consider whole herd testing for Brucellosis and TB as soon as possible if you are not already Brucellosis certified and TB accredited.
Several ACA councilmen have had an opportunity to go through the document and several major problems have been identified. The most notable concern is the whole herd Brucellosis testing mandates for non-certified herds to move interstate. Currently, each state handles their own import requirements by requiring individual testing on animals with a certain amount of days prior to movement. Instead, this proposed rule) § 76.16 2(a) states “The cervids originate from a herd that was subjected to a herd test using an official test for brucellosis and an official test for bovine tuberculosis no more than 1 year and no less than 120 days prior to movement, with negative results; and (B) The cervids are additionally tested for brucellosis and bovine tuberculosis using an individual official test no more than 60 days prior to movement, with negative results.” This proposed change will not affect herds that are currently both TB accredited and Brucellosis certified.
Therefore, if this proposed rule is unchanged, herds that are currently not Brucellosis certified and TB accredited would have to do a whole herd test before 120 days of movement AND an individual animal test prior to movement.
The elk industry and several species of deer other than whitetail, as a whole, have very few Brucellosis certified herds. It is the hope of the ACA and other associations that this language can be amended because of the great disturbance it would have on interstate movement. If these herds are not able to move animals as a result of this new rule, particularly by breeding season, the ACA estimates the 2016 economic impact to be in the millions of dollars.
The ACA will be discussing this concern, among many others, early next month. Please make sure your association attends that conference call. We will be finalizing a complete list of concerns to be emailed to all of you by the end of February. It is essential for all cervid producers to submit a comment to the USDA at the appropriate time urging them to delete the language in 76.16 2(A). The comment period ends March 15 and the ACA will instruct you how to post your comments.
We will work to change this proposed requirement but for those of you who are skeptical of the government making the change and want to be proactive, you may want to consider becoming brucellosis certified and TB accredited as soon as possible.
Thank you and please let us know if you have any questions.
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