Interactive mapping application showing harvest locations of all deer tested including 
those with positive test results.
CWD sampling areas for 2012 
[PDF]The DNR will focus statewide 
surveillance in Dodge, Grant, Juneau, and Adams counties for the 2012 season. In 
the CWD Management Zone, the department will continue to sample in the 
monitoring areas, Devils Lake, and Racine, Kenosha, Richmond, and Sauk counties. 
In addition, an intense sampling effort will take place around the Washburn 
positive.
Prevalence of CWD in the CWD Zones 
[PDF]This map displays the 
estimated prevalence of CWD per square mile within the CWD management zone. It 
is based on testing data collected from 2002-2009.
CWD positive deer locations 
[PDF] Updated 
4/3/2013.
Wisconsin/Illinois Positive Locations 
[PDF] Updated 
4/12/2013.
 
http://dnr.wi.gov/topic/wildlifehabitat/prevalence.html
 
 
 
 
 
 
 
 
CWD detected in Washburn county in northwest Wisconsin 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Why fawns are not routinely tested for CWD 
 
 
 
The department highly discourages the testing of any fawns regardless of 
where they were harvested. Of the more than 15,800 fawns from the CWD-MZ that 
have been tested, only 27 tested positive, and most of those were nearly one 
year old. 
 
 
 
 
 
 
 
 
 
 
 
 
 
Saturday, February 04, 2012 
 
 
 
 
Wisconsin 16 MONTH age limit on testing dead deer Game Farm CWD Testing 
Protocol Needs To Be Revised 
 
 
 
 
 
 
 
 
 
 
 
 
 
Deer trustee report implementationHerd Health/Chronic Wasting Disease 
Action Team 
 
 
 
 
 
 
 
 
 
 
 
yep, while the Texas deer czar dr. dough was off to Wisconsin pushing the 
privately owned shooting pen industry (livestock cervids industry), Texas fell 
to CWD, and just reported 4 more CWD postives. ... 
 
 
 
 
for your information... 
 
 
 
 
 
 
According to Wisconsin’s White-Tailed Deer Trustee Dr. James Kroll, people 
who call for more public hunting opportunities are “pining for socialism.” He 
further states, “(Public) Game management is the last bastion of communism.” 
“Game Management,” says James Kroll, driving to his high-fenced, 
two-hundred-acre spread near Nacogdoches, “is the last bastion of communism.” 
Kroll, also known as Dr. Deer, is the director of the Forestry Resources 
Institute of Texas at Stephen F. Austin State University, and the “management” 
he is referring to is the sort practiced by the State of Texas. The 55-year-old 
Kroll is the leading light in the field of private deer management as a means to 
add value to the land. His belief is so absolute that some detractors refer to 
him as Dr. Dough, implying that his eye is on the bottom line more than on the 
natural world. Kroll, who has been the foremost proponent of deer ranching in 
Texas for more than thirty years, doesn’t mind the controversy and certainly 
doesn’t fade in the heat. People who call for more public lands are “cocktail 
conservationists,” he says, who are really pining for socialism. He calls 
national parks “wildlife ghettos” and flatly accuses the government of gross 
mismanagement. He argues that his relatively tiny acreage, marked by eight-foot 
fences and posted signs warning off would-be poachers, is a better model for 
keeping what’s natural natural while making money off the land. 
 
 
 
 
 
 
 
Tuesday, July 10, 2012 
 
Dr. James C. Kroll Texas deer czar final report on Wisconsin 
 
 
 
 
 
 
 
 
 
 
Friday, June 01, 2012 
 
*** TEXAS DEER CZAR TO WISCONSIN ASK TO EXPLAIN COMMENTS 
 
 
 
 
 
 
 
 
Thursday, March 29, 2012 
 
TEXAS DEER CZAR SAYS WISCONSIN DNR NOT DOING ENOUGH ABOUT CWD LIKE POT 
CALLING KETTLE BLACK 
 
 
 
 
 
 
 
 
 
 
Tuesday, July 10, 2012 
 
Chronic Wasting Disease Detected in Far West Texas 
 
 
 
 
 
 
 
 
 
 
 
Monday, February 11, 2013 
 
TEXAS CHRONIC WASTING DISEASE CWD Four New Positives Found in Trans Pecos 
 
 
 
 
 
 
 
 
 
 
 
Thursday, May 02, 2013 
 
Chronic Wasting Disease (CWD) Texas Important Update on OBEX ONLY TEXTING 
 
 
 
 
 
 
 
 
 
 
Tuesday, November 02, 2010 
 
IN CONFIDENCE 
 
The information contained herein should not be disseminated further except 
on the basis of "NEED TO KNOW". 
 
BSE - ATYPICAL LESION DISTRIBUTION (RBSE 92-21367) statutory (obex only) 
diagnostic criteria CVL 1992 
 
 
 
 
 
 
 
 
 
 
 
Chronic Wasting Disease CWD, and other TSE prion disease, these TSE prions 
know no borders. 
 
these TSE prions know no age restrictions.
 
The TSE prion disease survives ashing to 600 degrees celsius, that’s around 
1112 degrees farenheit. 
 
you cannot cook the TSE prion disease out of meat. 
 
you can take the ash and mix it with saline and inject that ash into a 
mouse, and the mouse will go down with TSE. 
 
Prion Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel 
Production as well. 
 
the TSE prion agent also survives Simulated Wastewater Treatment Processes. 
 
IN fact, you should also know that the TSE Prion agent will survive in the 
environment for years, if not decades. 
 
you can bury it and it will not go away. 
 
The TSE agent is capable of infected your water table i.e. Detection of 
protease-resistant cervid prion protein in water from a CWD-endemic area. 
 
it’s not your ordinary pathogen you can just cook it out and be done with. 
that’s what’s so worrisome about Iatrogenic mode of transmission, a simple 
autoclave will not kill this TSE prion agent. 
 
I go from state to state trying to warn of the CWD and other TSE prion 
disease in other species, I just made a promise to mom. back then, there was no 
information. 
 
so, I submit this to you all in good faith, and hope that you take the time 
to read my research of the _sound_, peer review science, not the junk science 
that goes with the politics $$$ 
 
right or left or teaparty or independent, you cannot escape the TSE prion 
disease. 
 
there is a lot of science here to digest, but better digesting this _sound_ 
science, instead of the junk political science you will hear from the shooting 
pen industry. 
 
 
 
snip... 
 
 
 
see full text of my submission here ; 
 
 
 
 
 
 
 
 
 
 
 
please see what the U.K. DEFRA recently said ABOUT CWD RISK FACTORS ; 
 
 
 
 
 
 
 
Friday, December 14, 2012 
 
 
 
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
 
 
 
snip... 
 
 
 
In the USA, under the Food and Drug Administration’s BSE Feed Regulation 
(21 CFR 589.2000) most material (exceptions include milk, tallow, and gelatin) 
from deer and elk is prohibited for use in feed for ruminant animals. With 
regards to feed for non-ruminant animals, under FDA law, CWD positive deer may 
not be used for any animal feed or feed ingredients. For elk and deer considered 
at high risk for CWD, the FDA recommends that these animals do not enter the 
animal feed system. However, this recommendation is guidance and not a 
requirement by law. 
 
 
 
Animals considered at high risk for CWD include: 
 
 
 
1) animals from areas declared to be endemic for CWD and/or to be CWD 
eradication zones and 
 
 
 
2) deer and elk that at some time during the 60-month period prior to 
slaughter were in a captive herd that contained a CWD-positive animal. 
 
 
 
Therefore, in the USA, materials from cervids other than CWD positive 
animals may be used in animal feed and feed ingredients for non-ruminants. 
 
 
The amount of animal PAP that is of deer and/or elk origin imported from 
the USA to GB can not be determined, however, as it is not specified in TRACES. 
It may constitute a small percentage of the 8412 kilos of non-fish origin 
processed animal proteins that were imported from US into GB in 2011. 
 
 
 
Overall, therefore, it is considered there is a __greater than negligible 
risk___ that (nonruminant) animal feed and pet food containing deer and/or elk 
protein is imported into GB. 
 
 
 
There is uncertainty associated with this estimate given the lack of data 
on the amount of deer and/or elk protein possibly being imported in these 
products. 
 
 
 
snip... 
 
 
 
36% in 2007 (Almberg et al., 2011). In such areas, population declines of 
deer of up to 30 to 50% have been observed (Almberg et al., 2011). In areas of 
Colorado, the prevalence can be as high as 30% (EFSA, 2011). 
 
 
 
The clinical signs of CWD in affected adults are weight loss and 
behavioural changes that can span weeks or months (Williams, 2005). In addition, 
signs might include excessive salivation, behavioural alterations including a 
fixed stare and changes in interaction with other animals in the herd, and an 
altered stance (Williams, 2005). These signs are indistinguishable from cervids 
experimentally infected with bovine spongiform encephalopathy (BSE). 
 
 
 
Given this, if CWD was to be introduced into countries with BSE such as GB, 
for example, infected deer populations would need to be tested to differentiate 
if they were infected with CWD or BSE to minimise the risk of BSE entering the 
human food-chain via affected venison. 
 
 
 
snip... 
 
 
 
The rate of transmission of CWD has been reported to be as high as 30% and 
can approach 100% among captive animals in endemic areas (Safar et al., 2008). 
 
 
 
snip... 
 
 
 
In summary, in endemic areas, there is a medium probability that the soil 
and surrounding environment is contaminated with CWD prions and in a 
bioavailable form. In rural areas where CWD has not been reported and deer are 
present, there is a greater than negligible risk the soil is contaminated with 
CWD prion. 
 
 
 
snip... 
 
 
 
In summary, given the volume of tourists, hunters and servicemen moving 
between GB and North America, the probability of at least one person travelling 
to/from a CWD affected area and, in doing so, contaminating their clothing, 
footwear and/or equipment prior to arriving in GB is greater than negligible. 
For deer hunters, specifically, the risk is likely to be greater given the 
increased contact with deer and their environment. However, there is significant 
uncertainty associated with these estimates. 
 
 
 
snip... 
 
 
 
Therefore, it is considered that farmed and park deer may have a higher 
probability of exposure to CWD transferred to the environment than wild deer 
given the restricted habitat range and higher frequency of contact with tourists 
and returning GB residents. 
 
 
 
 
 
snip... 
 
 
 
 
see full text report here ; 
 
 
 
 
 
Friday, December 14, 2012 
 
 
 
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
 
 
 
 
 
 
 
 
 
 
how many states have $465,000., and can quarantine and purchase there from, 
each cwd said infected farm, but how many states can afford this for all the cwd 
infected cervid game ranch type farms ??? 
 
 
 
 
 
Tuesday, December 20, 2011 
 
CHRONIC WASTING DISEASE CWD WISCONSIN Almond Deer (Buckhorn Flats) Farm 
Update DECEMBER 2011 
 
The CWD infection rate was nearly 80%, the highest ever in a North American 
captive herd. 
 
RECOMMENDATION: That the Board approve the purchase of 80 acres of land for 
$465,000 for the Statewide Wildlife Habitat Program in Portage County and 
approve the restrictions on public use of the site. 
 
SUMMARY: 
 
 
 
snip... 
 
 
 
C. The DNR will begin timber removal from outside the fence this winter. 
Timber removal from inside the fence has begun with hazardous trees removed. The 
construction of a second fence 10 – 12 feet outside the present fence will begin 
in the spring. This will add an additional level of security for keeping wild 
deer from entering the farm and maintain the integrity of the perimeter (see 
attachment). 
 
 
 
 
D. The DNR plans to use the Almond Farm as a CWD research facility. Because 
the question of how long a contaminated site is a risk to deer is of national 
and international interest, there may be opportunities for research and funding 
at this facility. One way to potentially assess whether there is a risk to deer 
from the Almond Farm is to conduct bioassays focusing on prions persisting in 
soil and what role environmental contamination plays in disease transmission. A 
proposal is pending from the University of Wisconsin – Stevens Point that 
concerns prion degradation via composting. The group is seeking additional 
funding from the University of Wisconsin – Madison and representatives in 
Canada. USGS is also contemplating a proposal contingent on funding from their 
pending federal budget. Any proposed research that includes bringing captive 
cervids onto the property will be thoroughly reviewed by the CWD Research 
Committee consisting of the Wildlife Health Team, the Wildlife Policy Team, and 
Department administration as well as external CWD experts prior to permission 
being granted to ensure that the health of the wild deer herd will not be 
endangered. The double fencing described above will be critical to minimize the 
risk of ingress of free-ranging and egress of any experimental captive cervids. 
E. The house is rented and currently occupied by a Northeast district wildlife 
employee. The Lessee agrees to perform weekly fence inspections to insure that 
the fence integrity has not been compromised. The Lessee also pays for all 
utilities, and will provide lawn care, snow removal, gutter cleaning, and other 
miscellaneous maintenance as needed. In exchange for these services the monthly 
rental fee has been waived. It is agreed that the Lessor and the Lessee shall 
review said waiver of the monthly rental charge at the end of every twelve 
months that this lease is in effect (see attachment). 
 
 
 
 
snip... 
 
 
 
 
Despite the five year premise plan and site decontamination, The WI DNR has 
concerns over the bioavailability of infectious prions at this site to wild 
white-tail deer should these fences be removed. Current research indicates that 
prions can persist in soil for a minimum of 3 years. However, Georgsson et al. 
(2006) concluded that prions that produced scrapie disease in sheep remained 
bioavailable and infectious for at least 16 years in natural Icelandic 
environments, most likely in contaminated soil. Additionally, the authors 
reported that from 1978-2004, scrapie recurred on 33 sheep farms, of which 9 
recurrences occurred 14-21 years after initial culling and subsequent restocking 
efforts; these findings further emphasize the effect of environmental 
contamination on sustaining TSE infectivity and that long-term persistence of 
prions in soils may be substantially greater than previously thought. Evidence 
of environmental transmission also was documented in a Colorado research 
facility where mule deer became infected with CWD in two of three paddocks where 
infected deer carcasses had decomposed on site 1.8 years earlier, and in one of 
three paddocks where infected deer had last resided 2.2 years earlier (Miller et 
al. 2004). 
 
 
 
 
snip... 
 
 
 
 
Environmental contamination has been identified as a possible cause of 
recurrence of CWD-infection on elk farms in Canada, when elk were reintroduced 
one year after depopulation, clean up and disinfection. To date, 8 CWD infected 
farms remain under CFIA (government of Canada) quarantine indefinitely and will 
not be allowed to repopulate with cervids until there is additional research on 
detection of prions in soils and better understanding of the duration of 
persistence of disease-causing prion post depopulation of CWD-infected cervid 
farms (Douglas, CFIA, pers. comm.). 
 
 
 
Furthermore, the likely transmission of CWD via soil is corroborated by 
recent studies showing long-term persistence of prions in soil, that prion binds 
to soil components with high affinity and is not easily removed by water, and 
that oral prion disease transmission may be enhanced when bound to soil (Johnson 
et al. 2006, Schramm et al. 2006, Johnson et al. 2007). These findings suggest 
that soil may harbor more TSE infectivity and contribute more significantly to 
TSE transmission than previously recognized. These studies highlight the 
concerns about the risk of transmission via environmental contamination beyond 
five years and that efforts should be made to prevent freeranging deer from 
coming into contact with these contaminated facilities. 
 
 
 
SNIP... 
 
 
 
 
CHAPTER TWO 
 
OBJECTIVE FOR PROPERTY 
 
Maintain the Perimeter Deer Fence 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wednesday, November 16, 2011
 
Wisconsin Creutzfeldt Jakob Disease, CWD, TSE, PRION REPORTING 2011 
 
 
 
 
 
 
 
 
 
 
Monday, January 16, 2012 
 
9 GAME FARMS IN WISCONSIN TEST POSITIVE FOR CWD 
 
 
 
 
 
 
 
 
 
Tuesday, April 16, 2013 
 
Cervid Industry Unites To Set Direction for CWD Reform and seem to ignore 
their ignorance and denial in their role in spreading Chronic Wasting 
Disease
 
 
 
 
 
 
 
 
 
 
Tuesday, December 18, 2012 
 
A Growing Threat How deer breeding could put public trust wildlife at risk 
 
 
 
 
 
 
 
 
 
 
*** Cumulative Distribution of CWD among Farmed Cervid Herds October 2012, 
2013, and depopulation maps
 
 
 
 
 
 
 
 
 
 
see full text and more here ; 
 
 
 
 
 
 
 
 
 
 
 
 
Thursday, February 09, 2012 
 
50 GAME FARMS IN USA INFECTED WITH CHRONIC WASTING DISEASE 
 
 
 
 
 
 
 
 
 
pens, pens, PENS ??? 
 
 *** Spraker suggested an interesting explanation for the occurrence of 
CWD. The deer pens at the Foot Hills Campus were built some 30-40 years ago by a 
Dr. Bob Davis. At or abut that time, allegedly, some scrapie work was conducted 
at this site. When deer were introduced to the pens they occupied ground that 
had previously been occupied by sheep. 
 
 
 
 
 
 
 
 
 
now, decades later ; 
 
 
 
 
 
The most widely accepted hypothesis at this time is that CWD may have 
originated from an interspecies transmission of scrapie. It is worth noting that 
experimental transmission of scrapie into elk via IC inoculation is clinically 
and neuropathologically indistinguishable from CWD with currently available 
experimental methods.44 
 
 
 
 
 
 
 
 
 
 
 
snip...see much more here ; 
 
 
 
 
Thursday, June 13, 2013 
 
Experimental interspecies transmission studies of the transmissible 
spongiform encephalopathies to cattle: comparison to bovine spongiform 
encephalopathy in cattle
 
 
 
 
 
 
 
 
 
 
2012 
 
PO-039: A comparison of scrapie and chronic wasting disease in white-tailed 
deer 
 
snip... 
 
After a natural route of exposure, 100% of WTD were susceptible to scrapie. 
Deer developed clinical signs of wasting and mental depression and were 
necropsied from 28 to 33 months PI. Tissues from these deer were positive for 
PrPSc by IHC and WB. Similar to IC inoculated deer, samples from these deer 
exhibited two different molecular profiles: samples from obex resembled CWD 
whereas those from cerebrum were similar to the original scrapie inoculum. On 
further examination by WB using a panel of antibodies, the tissues from deer 
with scrapie exhibit properties differing from tissues either from sheep with 
scrapie or WTD with CWD. Samples from WTD with CWD or sheep with scrapie are 
strongly immunoreactive when probed with mAb P4, however, samples from WTD with 
scrapie are only weakly immunoreactive. In contrast, when probed with mAb’s 6H4 
or SAF 84, samples from sheep with scrapie and WTD with CWD are weakly 
immunoreactive and samples from WTD with scrapie are strongly positive. This 
work demonstrates that WTD are highly susceptible to sheep scrapie, but on first 
passage, scrapie in WTD is differentiable from CWD. 
 
 
 
 
 
 
 
 
 
2011 
 
*** After a natural route of exposure, 100% of white-tailed deer were 
susceptible to scrapie. 
 
 
 
 
 
 
 
 
 
Scrapie in Deer: Comparisons and Contrasts to Chronic Wasting Disease (CWD) 
 
Justin J. Greenlee of the Virus and Prion Diseases Research Unit, National 
Animal Disease Center, ARS, USDA, Ames, IA provided a presentation on scrapie 
and CWD in inoculated deer. Interspecies transmission studies afford the 
opportunity 
 
After a natural route of exposure, 100% of white-tailed deer were 
susceptible to scrapie. Deer developed clinical signs of wasting and mental 
depression and were necropsied from 28 to 33 months PI. Tissues from these deer 
were positive for scrapie by IHC and WB. Tissues with PrPSc immunoreactivity 
included brain, tonsil, retropharyngeal and mesenteric lymph nodes, hemal node, 
Peyer’s patches, and spleen. While two WB patterns have been detected in brain 
regions of deer inoculated by the natural route, unlike the IC inoculated deer, 
the pattern similar to the scrapie inoculum predominates. 
 
 
 
 
 
 
 
 
2011 Annual Report 
 
Research Project: TRANSMISSION, DIFFERENTIATION, AND PATHOBIOLOGY OF 
TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES Location: Virus and Prion Research 
Unit 2011 Annual Report 
 
In Objective 1, Assess cross-species transmissibility of transmissible 
spongiform encephalopathies (TSEs) in livestock and wildlife, numerous 
experiments assessing the susceptibility of various TSEs in different host 
species were conducted. Most notable is deer inoculated with scrapie, which 
exhibits similarities to chronic wasting disease (CWD) in deer suggestive of 
sheep scrapie as an origin of CWD. 
 
snip... 
 
4.Accomplishments 1. Deer inoculated with domestic isolates of sheep 
scrapie. Scrapie-affected deer exhibit 2 different patterns of disease 
associated prion protein. In some regions of the brain the pattern is much like 
that observed for scrapie, while in others it is more like chronic wasting 
disease (CWD), the transmissible spongiform encephalopathy typically associated 
with deer. This work conducted by ARS scientists at the National Animal Disease 
Center, Ames, IA suggests that an interspecies transmission of sheep scrapie to 
deer may have been the origin of CWD. This is important for husbandry practices 
with both captive deer, elk and sheep for farmers and ranchers attempting to 
keep their herds and flocks free of CWD and scrapie. 
 
 
 
 
 
 
 
 
 
White-tailed Deer are Susceptible to Scrapie by Natural Route of Infection 
 
snip... 
 
This work demonstrates for the first time that white-tailed deer are 
susceptible to sheep scrapie by potential natural routes of inoculation. 
In-depth analysis of tissues will be done to determine similarities between 
scrapie in deer after intracranial and oral/intranasal inoculation and chronic 
wasting disease resulting from similar routes of inoculation. 
 
see full text ; 
 
 
 
 
 
 
 
 
 
 
 
UPDATED DATA ON 2ND CWD STRAIN
 
Wednesday, September 08, 2010
 
CWD PRION CONGRESS SEPTEMBER 8-11 2010 
 
 
 
 
 
 
 
 
 
 
 
*** The potential impact of prion diseases on human health was greatly 
magnified by the recognition that interspecies transfer of BSE to humans by beef 
ingestion resulted in vCJD. While changes in animal feed constituents and 
slaughter practices appear to have curtailed vCJD, there is concern that CWD of 
free-ranging deer and elk in the U.S. might also cross the species barrier. 
Thus, consuming venison could be a source of human prion disease. Whether BSE 
and CWD represent interspecies scrapie transfer or are newly arisen prion 
diseases is unknown. Therefore, the possibility of transmission of prion disease 
through other food animals cannot be ruled out. There is evidence that vCJD can 
be transmitted through blood transfusion. There is likely a pool of unknown size 
of asymptomatic individuals infected with vCJD, and there may be asymptomatic 
individuals infected with the CWD equivalent. These circumstances represent a 
potential threat to blood, blood products, and plasma supplies. 
 
 
 
 
 
 
 
 
 
The chances of a person or domestic animal contracting CWD are “extremely 
remote,” Richards said. The possibility can’t be ruled out, however. “One could 
look at it like a game of chance,” he explained. “The odds (of infection) 
increase over time because of repeated exposure. That’s one of the downsides of 
having CWD in free-ranging herds: We’ve got this infectious agent out there that 
we can never say never to in terms of (infecting) people and domestic 
livestock.” 
 
 
 
 
 
 
 
 
 
P35 
 
ADAPTATION OF CHRONIC WASTING DISEASE (CWD) INTO HAMSTERS, EVIDENCE OF A 
WISCONSIN STRAIN OF CWD 
 
Chad Johnson1, Judd Aiken2,3,4 and Debbie McKenzie4,5 1 Department of 
Comparative Biosciences, University of Wisconsin, Madison WI, USA 53706 2 
Department of Agriculture, Food and Nutritional Sciences, 3 Alberta Veterinary 
Research Institute, 4.Center for Prions and Protein Folding Diseases, 5 
Department of Biological Sciences, University of Alberta, Edmonton AB, Canada 
T6G 2P5
 
The identification and characterization of prion strains is increasingly 
important for the diagnosis and biological definition of these infectious 
pathogens. Although well-established in scrapie and, more recently, in BSE, 
comparatively little is known about the possibility of prion strains in chronic 
wasting disease (CWD), a disease affecting free ranging and captive cervids, 
primarily in North America. We have identified prion protein variants in the 
white-tailed deer population and demonstrated that Prnp genotype affects the 
susceptibility/disease progression of white-tailed deer to CWD agent. The 
existence of cervid prion protein variants raises the likelihood of distinct CWD 
strains. Small rodent models are a useful means of identifying prion strains. We 
intracerebrally inoculated hamsters with brain homogenates and phosphotungstate 
concentrated preparations from CWD positive hunter-harvested (Wisconsin CWD 
endemic area) and experimentally infected deer of known Prnp genotypes. These 
transmission studies resulted in clinical presentation in primary passage of 
concentrated CWD prions. Subclinical infection was established with the other 
primary passages based on the detection of PrPCWD in the brains of hamsters and 
the successful disease transmission upon second passage. Second and third 
passage data, when compared to transmission studies using different CWD inocula 
(Raymond et al., 2007) indicate that the CWD agent present in the Wisconsin 
white-tailed deer population is different than the strain(s) present in elk, 
mule-deer and white-tailed deer from the western United States endemic region. 
 
 
 
 
 
 
 
 
 
PPo3-7:
 
Prion Transmission from Cervids to Humans is Strain-dependent
 
Qingzhong Kong, Shenghai Huang,*Fusong Chen, Michael Payne, Pierluigi 
Gambetti and Liuting Qing Department of Pathology; Case western Reserve 
University; Cleveland, OH USA *Current address: Nursing Informatics; Memorial 
Sloan-Kettering Cancer Center; New York, NY USA
 
Key words: CWD, strain, human transmission
 
Chronic wasting disease (CWD) is a widespread prion disease in cervids 
(deer and elk) in North America where significant human exposure to CWD is 
likely and zoonotic transmission of CWD is a concern. Current evidence indicates 
a strong barrier for transmission of the classical CWD strain to humans with the 
PrP-129MM genotype. A few recent reports suggest the presence of two or more CWD 
strains. What remain unknown is whether individuals with the PrP-129VV/MV 
genotypes are also resistant to the classical CWD strain and whether humans are 
resistant to all natural or adapted cervid prion strains. Here we report that a 
human prion strain that had adopted the cervid prion protein (PrP) sequence 
through passage in cervidized transgenic mice efficiently infected transgenic 
mice expressing human PrP, indicating that the species barrier from cervid to 
humans is prion strain-dependent and humans can be vulnerable to novel cervid 
prion strains. Preliminary results on CWD transmission in transgenic mice 
expressing human PrP-129V will also be discussed.
 
Acknowledgement Supported by NINDS NS052319 and NIA AG14359. 
 
 
 
 
 
PPo2-27:
 
Generation of a Novel form of Human PrPSc by Inter-species Transmission of 
Cervid Prions
 
Marcelo A. Barria,1 Glenn C. Telling,2 Pierluigi Gambetti,3 James A. 
Mastrianni4 and Claudio Soto1 1Mitchell Center for Alzheimer's disease and 
related Brain disorders; Dept of Neurology; University of Texas Houston Medical 
School; Houston, TX USA; 2Dept of Microbiology, Immunology & Molecular 
Genetics and Neurology; Sanders Brown Center on Aging; University of Kentucky 
Medical Center; Lexington, KY USA; 3Institute of Pathology; Case western Reserve 
University; Cleveland, OH USA; 4Dept of Neurology; University of Chicago; 
Chicago, IL USA
 
Prion diseases are infectious neurodegenerative disorders affecting humans 
and animals that result from the conversion of normal prion protein (PrPC) into 
the misfolded and infectious prion (PrPSc). Chronic wasting disease (CWD) of 
cervids is a prion disorder of increasing prevalence within the United States 
that affects a large population of wild and captive deer and elk. CWD is highly 
contagious and its origin, mechanism of transmission and exact prevalence are 
currently unclear. The risk of transmission of CWD to humans is unknown. 
Defining that risk is of utmost importance, considering that people have been 
infected by animal prions, resulting in new fatal diseases. To study the 
possibility that human PrPC can be converted into the infectious form by CWD 
PrPSc we performed experiments using the Protein Misfolding Cyclic Amplification 
(PMCA) technique, which mimic in vitro the process of prion replication. Our 
results show that cervid PrPSc can induce the pathological conversion of human 
PrPC, but only after the CWD prion strain has been stabilized by successive 
passages in vitro or in vivo. Interestingly, this newly generated human PrPSc 
exhibits a distinct biochemical pattern that differs from any of the currently 
known forms of human PrPSc, indicating that it corresponds to a novel human 
prion strain. Our findings suggest that CWD prions have the capability to infect 
humans, and that this ability depends on CWD strain adaptation, implying that 
the risk for human health progressively increases with the spread of CWD among 
cervids. 
 
 
 
 
 
PPo2-7:
 
Biochemical and Biophysical Characterization of Different CWD 
Isolates
 
Martin L. Daus and Michael Beekes Robert Koch Institute; Berlin, 
Germany
 
Key words: CWD, strains, FT-IR, AFM
 
Chronic wasting disease (CWD) is one of three naturally occurring forms of 
prion disease. The other two are Creutzfeldt-Jakob disease in humans and scrapie 
in sheep. CWD is contagious and affects captive as well as free ranging cervids. 
As long as there is no definite answer of whether CWD can breach the species 
barrier to humans precautionary measures especially for the protection of 
consumers need to be considered. In principle, different strains of CWD may be 
associated with different risks of transmission to humans. Sophisticated strain 
differentiation as accomplished for other prion diseases has not yet been 
established for CWD. However, several different findings indicate that there 
exists more than one strain of CWD agent in cervids. We have analysed a set of 
CWD isolates from white-tailed deer and could detect at least two biochemically 
different forms of disease-associated prion protein PrPTSE. Limited proteolysis 
with different concentrations of proteinase K and/or after exposure of PrPTSE to 
different pH-values or concentrations of Guanidinium hydrochloride resulted in 
distinct isolate-specific digestion patterns. Our CWD isolates were also 
examined in protein misfolding cyclic amplification studies. This showed 
different conversion activities for those isolates that had displayed 
significantly different sensitivities to limited proteolysis by PK in the 
biochemical experiments described above. We further applied Fourier transform 
infrared spectroscopy in combination with atomic force microscopy. This 
confirmed structural differences in the PrPTSE of at least two disinct CWD 
isolates. The data presented here substantiate and expand previous reports on 
the existence of different CWD strains. 
 
 
 
 
 
 
 
 
 
 
2012 
 
 
 
 
 
Envt.06: 
 
Zoonotic Potential of CWD: Experimental Transmissions to Non-Human Primates 
 
Emmanuel Comoy,1,† Valérie Durand,1 Evelyne Correia,1 Aru Balachandran,2 
Jürgen Richt,3 Vincent Beringue,4 Juan-Maria Torres,5 Paul Brown,1 Bob Hills6 
and Jean-Philippe Deslys1 
 
1Atomic Energy Commission; Fontenay-aux-Roses, France; 2Canadian Food 
Inspection Agency; Ottawa, ON Canada; 3Kansas State University; Manhattan, KS 
USA; 4INRA; Jouy-en-Josas, France; 5INIA; Madrid, Spain; 6Health Canada; Ottawa, 
ON Canada
 
†Presenting author; Email: emmanuel.comoy@cea.fr 
 
The constant increase of chronic wasting disease (CWD) incidence in North 
America raises a question about their zoonotic potential. A recent publication 
showed their transmissibility to new-world monkeys, but no transmission to 
old-world monkeys, which are phylogenetically closer to humans, has so far been 
reported. Moreover, several studies have failed to transmit CWD to transgenic 
mice overexpressing human PrP. Bovine spongiform encephalopathy (BSE) is the 
only animal prion disease for which a zoonotic potential has been proven. We 
described the transmission of the atypical BSE-L strain of BSE to cynomolgus 
monkeys, suggesting a weak cattle-to-primate species barrier. We observed the 
same phenomenon with a cattleadapted strain of TME (Transmissible Mink 
Encephalopathy). Since cattle experimentally exposed to CWD strains have also 
developed spongiform encephalopathies, we inoculated brain tissue from 
CWD-infected cattle to three cynomolgus macaques as well as to transgenic mice 
overexpressing bovine or human PrP. Since CWD prion strains are highly 
lymphotropic, suggesting an adaptation of these agents after peripheral 
exposure, a parallel set of four monkeys was inoculated with CWD-infected cervid 
brains using the oral route. Nearly four years post-exposure, monkeys exposed to 
CWD-related prion strains remain asymptomatic. In contrast, bovinized and 
humanized transgenic mice showed signs of infection, suggesting that CWD-related 
prion strains may be capable of crossing the cattle-to-primate species barrier. 
Comparisons with transmission results and incubation periods obtained after 
exposure to other cattle prion strains (c-BSE, BSE-L, BSE-H and cattle-adapted 
TME) will also be presented, in order to evaluate the respective risks of each 
strain. 
 
 
 
 
 
Envt.07: 
 
Pathological Prion Protein (PrPTSE) in Skeletal Muscles of Farmed and Free 
Ranging White-Tailed Deer Infected with Chronic Wasting Disease 
 
Martin L. Daus,1,† Johanna Breyer,2 Katjs Wagenfuehr,1 Wiebke Wemheuer,2 
Achim Thomzig,1 Walter Schulz-Schaeffer2 and Michael Beekes1 1Robert Koch 
Institut; P24 TSE; Berlin, Germany; 2Department of Neuropathology, Prion and 
Dementia Research Unit, University Medical Center Göttingen; Göttingen, Germany 
†Presenting author; Email: dausm@rki.de 
 
Chronic wasting disease (CWD) is a contagious, rapidly spreading 
transmissible spongiform encephalopathy (TSE) occurring in cervids in North 
America. Despite efficient horizontal transmission of CWD among cervids natural 
transmission of the disease to other species has not yet been observed. Here, we 
report a direct biochemical demonstration of pathological prion protein PrPTSE 
and of PrPTSE-associated seeding activity in skeletal muscles of CWD-infected 
cervids. The presence of PrPTSE was detected by Western- and postfixed frozen 
tissue blotting, while the seeding activity of PrPTSE was revealed by protein 
misfolding cyclic amplification (PMCA). The concentration of PrPTSE in skeletal 
muscles of CWD-infected WTD was estimated to be approximately 2000- to 
10000-fold lower than in brain tissue. Tissue-blot-analyses revealed that PrPTSE 
was located in muscle- associated nerve fascicles but not, in detectable 
amounts, in myocytes. The presence and seeding activity of PrPTSE in skeletal 
muscle from CWD-infected cervids suggests prevention of such tissue in the human 
diet as a precautionary measure for food safety, pending on further 
clarification of whether CWD may be transmissible to humans. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Thursday, April 03, 2008
 
 
 
A prion disease of cervids: Chronic wasting disease
 
 
 
2008 1: Vet Res. 2008 Apr 3;39(4):41
 
 
 
A prion disease of cervids: Chronic wasting disease
 
 
 
Sigurdson CJ.
 
 
 
snip...
 
 
 
*** twenty-seven CJD patients who regularly consumed venison were reported 
to the Surveillance Center***,
 
 
 
snip...
 
 
 
full text ;
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Monday, November 14, 2011 
 
WYOMING Creutzfeldt Jakob Disease, CWD, TSE, PRION REPORTING 2011 
 
 
 
 
 
 
 
 
 
 
 
Sunday, November 13, 2011 
 
COLORADO CWD CJD TSE PRION REPORTING 2011 
 
 
 
 
 
 
 
 
 
 
Friday, November 09, 2012
 
*** Chronic Wasting Disease CWD in cervidae and transmission to other 
species
 
 
 
 
 
 
 
 
 
 
 
Sunday, November 11, 2012
 
*** Susceptibilities of Nonhuman Primates to Chronic Wasting Disease 
November 2012
 
 
 
 
 
 
 
 
 
 
 
Friday, December 14, 2012
 
*** Susceptibility Chronic Wasting Disease (CWD) in wild cervids to Humans 
2005 - December 14, 2012
 
 
 
 
 
 
 
 
 
 
 
Saturday, March 09, 2013 
 
Chronic Wasting Disease in Bank Voles: Characterisation of the Shortest 
Incubation Time Model for Prion Diseases 
 
 
 
 
 
 
 
 
 
 
CJD9/10022
 
 
October 1994
 
 
Mr R.N. Elmhirst Chairman British Deer Farmers Association Holly Lodge 
Spencers Lane BerksWell Coventry CV7 7BZ
 
 
Dear Mr Elmhirst,
 
 
CREUTZFELDT-JAKOB DISEASE (CJD) SURVEILLANCE UNIT REPORT
 
 
Thank you for your recent letter concerning the publication of the third 
annual report from the CJD Surveillance Unit. I am sorry that you are 
dissatisfied with the way in which this report was published.
 
 
The Surveillance Unit is a completely independant outside body and the 
Department of Health is committed to publishing their reports as soon as they 
become available. In the circumstances it is not the practice to circulate the 
report for comment since the findings of the report would not be amended. In 
future we can ensure that the British Deer Farmers Association receives a copy 
of the report in advance of publication.
 
 
The Chief Medical Officer has undertaken to keep the public fully informed 
of the results of any research in respect of CJD. This report was entirely the 
work of the unit and was produced completely independantly of the the 
Department.
 
 
The statistical results reqarding the consumption of venison was put into 
perspective in the body of the report and was not mentioned at all in the press 
release. Media attention regarding this report was low key but gave a realistic 
presentation of the statistical findings of the Unit. This approach to 
publication was successful in that consumption of venison was highlighted only 
once by the media ie. in the News at one television proqramme.
 
 
I believe that a further statement about the report, or indeed statistical 
links between CJD and consumption of venison, would increase, and quite possibly 
give damaging credence, to the whole issue. From the low key media reports of 
which I am aware it seems unlikely that venison consumption will suffer 
adversely, if at all.
 
 
 
 
 
 
 
 
 
 
 
 
PLUS, THE CDC DID NOT PUT THIS WARNING OUT FOR THE WELL BEING OF THE DEER 
AND ELK ; 
 
 
 
 
 
Thursday, May 26, 2011 
 
 
Travel History, Hunting, and Venison Consumption Related to Prion Disease 
Exposure, 2006-2007 FoodNet Population Survey 
 
 
Journal of the American Dietetic Association Volume 111, Issue 6 , Pages 
858-863, June 2011. 
 
 
 
 
 
 
 
 
 
 
 
NOR IS THE FDA recalling this CWD positive elk meat for the well being of 
the dead elk ; 
 
 
 
 
 
Wednesday, March 18, 2009 
 
 
Noah's Ark Holding, LLC, Dawson, MN RECALL Elk products contain meat 
derived from an elk confirmed to have CWD NV, CA, TX, CO, NY, UT, FL, OK RECALLS 
AND FIELD CORRECTIONS: FOODS CLASS II 
 
 
 
 
 
 
 
 
 
 
 
 
 
Tuesday, May 28, 2013 
 
Chronic Wasting Disease CWD quarantine Louisiana via CWD index herd 
Pennsylvania Update May 28, 2013 
 
6 doe from Pennsylvania CWD index herd still on the loose in Louisiana, 
quarantine began on October 18, 2012, still ongoing, Lake Charles premises. 
 
 
 
 
 
 
 
 
 
 
Wednesday, June 12, 2013 
 
CWD now waltzing into Texas from Pennsylvania CWD index herd, via 
Louisiana, or Missouri now ? 
 
 
 
 
 
 
 
 
 
 
Sunday, June 09, 2013 
 
Missouri House forms 13-member Interim Committee on the Cause and Spread of 
Chronic Wasting Disease CWD 
 
 
 
 
 
 
 
 
 
 
 
Tuesday, June 11, 2013 
 
CWD GONE WILD, More cervid escapees from more shooting pens on the loose in 
Pennsylvania
 
 
 
 
 
 
 
 
 
PAUL BROWN SCRAPIE SOIL TEST
 
 
 
 
 
 
 
 
 
 
 
Friday, December 14, 2012 
 
 
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
 
 
 
In summary, given the volume of tourists, hunters and servicemen moving 
between GB and North America, the probability of at least one person travelling 
to/from a CWD affected area and, in doing so, contaminating their clothing, 
footwear and/or equipment prior to arriving in GB is greater than negligible. 
For deer hunters, specifically, the risk is likely to be greater given the 
increased contact with deer and their environment. However, there is significant 
uncertainty associated with these estimates. 
 
 
 
Probable amount of CWD prions on contaminated boots and equipment 
 
 
 
SNIP... 
 
 
 
Given that a hunter or tourist walks in areas which are contaminated with 
CWD, it is possible that they will collect soil on their boots and other 
equipment. This likelihood will increase if the hunter has shot and handled a 
CWD infected deer resulting in contamination of the hunting equipment (e.g. 
knives) and their clothing and they subsequently arrive in GB with this 
equipment, footwear and clothing. Further, the soles of hiking boots tend to 
retain more soil than those of normal shoes. Wilkinson (2010), for example, 
removed 0.1 g of soil from hiking boots after returning to GB from a 2-month 
research visit to Canada. The amount of CWD prion in this amount of soil will 
depend upon the density of CWD infected animals excreting prions into the 
environment and the type of soil; CWD prion binds to clay soil, for example. 
Animal mortality sites could also be hotspots of CWD prion given the highly 
infectious nervous system matter entering into the environment and soil 
(Saunders et al., 2010). 
 
 
 
 
 
 
 
 
 
 
 
Friday, December 14, 2012 
 
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
 
 
 
 
 
 
 
 
 
 
Research Article 
 
Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) with 
Lyophilized Chronic Wasting Disease Prion Particulate Complexed to 
Montmorillonite Clay 
 
Tracy A. Nichols mail, Terry R. Spraker, Tara D. Rigg, Crystal 
Meyerett-Reid, Clare Hoover, Brady Michel, Jifeng Bian, Edward Hoover, Thomas 
Gidlewski, Aru Balachandran, Katherine O'Rourke, Glenn C. Telling, Richard 
Bowen, [ ... ], Kurt C. VerCauteren equal contributor 
 
Abstract 
 
Chronic wasting disease (CWD), the only known prion disease endemic in 
wildlife, is a persistent problem in both wild and captive North American cervid 
populations. This disease continues to spread and cases are found in new areas 
each year. Indirect transmission can occur via the environment and is thought to 
occur by the oral and/or intranasal route. Oral transmission has been 
experimentally demonstrated and although intranasal transmission has been 
postulated, it has not been tested in a natural host until recently. Prions have 
been shown to adsorb strongly to clay particles and upon oral inoculation the 
prion/clay combination exhibits increased infectivity in rodent models. Deer and 
elk undoubtedly and chronically inhale dust particles routinely while living in 
the landscape while foraging and rutting. We therefore hypothesized that dust 
represents a viable vehicle for intranasal CWD prion exposure. To test this 
hypothesis, CWD-positive brain homogenate was mixed with montmorillonite clay 
(Mte), lyophilized, pulverized and inoculated intranasally into white-tailed 
deer once a week for 6 weeks. Deer were euthanized at 95, 105, 120 and 175 days 
post final inoculation and tissues examined for CWD-associated prion proteins by 
immunohistochemistry. Our results demonstrate that CWD can be efficiently 
transmitted utilizing Mte particles as a prion carrier and intranasal exposure. 
 
snip... 
 
The results of this study confirm that CWD can be successfully transmitted 
IN as a lyophilized prion particulate adsorbed to Mte and that genotype at codon 
96 affects the lymphoid distribution of CWD within the body. Additionally, two 
novel intranasal tracking methods were employed that provided insight into CWD 
translocation within the nasal cavity. The data collected in this study may also 
shed light on why there is a higher prevalence of CWD in males, as males 
participate in more behaviors that generate dust. We propose chronic, long-term 
exposure to CWD prions adsorbed to dust particles to be a natural CWD infection 
route in addition to chronic oral and nasal contact exposure. 
 
Citation: Nichols TA, Spraker TR, Rigg TD, Meyerett-Reid C, Hoover C, et 
al. (2013) Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) 
with Lyophilized Chronic Wasting Disease Prion Particulate Complexed to 
Montmorillonite Clay. PLoS ONE 8(5): e62455. 
doi:10.1371/journal.pone.0062455
 
Editor: Anthony E. Kincaid, Creighton University, United States of America 
 
Received: November 30, 2012; Accepted: March 21, 2013; Published: May 9, 
2013
 
This is an open-access article, free of all copyright, and may be freely 
reproduced, distributed, transmitted, modified, built upon, or otherwise used by 
anyone for any lawful purpose. The work is made available under the Creative 
Commons CC0 public domain dedication.
 
Funding: Funding was provided by U.S. Department of Agriculture, Animal and 
Plant Health Inspection Service, Veterinary Services (VS). The funders had no 
role in study design, data collection and analysis, decision to publish, or 
preparation of the manuscript.
 
Competing interests: The authors have declared that no competing interests 
exist. 
 
 
 
see full text ; 
 
 
 
 
 
 
 
 
Thanks again to PLOS et al for full text access to this scientific research 
on the CWD TSE prion disease...tss 
 
 
 
 
see more here ; 
 
 
 
Wednesday, May 15, 2013 
 
Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) with 
Lyophilized Chronic Wasting Disease Prion Particulate Complexed to 
Montmorillonite Clay 
 
Research Article
 
 
 
 
 
 
 
 
 
Friday, February 08, 2013
 
*** Behavior of Prions in the Environment: Implications for Prion Biology 
 
 
 
 
 
 
 
 
Friday, February 25, 2011 
 
Soil clay content underlies prion infection odds Soil clay content 
underlies prion infection odds 
 
 
 
 
 
 
 
 
 
 
Greetings TAHC, Carol Pivonka, et al, 
 
 
 
I kindly wish to comment on the proposed rule making for “Chronic Wasting 
Disease (CWD)”. 
 
 
 
AS a layperson, and since the confirmed death of my mother to the 
Heidenhain Variant of Creutzfeldt Jakob Disease, I have followed the mad cow 
debacle/blunder, the CWD blunder, the scrapie blunder, and the human CJD 
science, daily since that day December 14, 1997 MOM DOD hvCJD. I made a promise 
to her about the fact I would not let this die with her. back then there was no 
information, and I made a promise I would my best to find this information, make 
it public, for everyone to know. 
 
 
 
 
There is much science out there, updated peer review science, and 
transmission studies, that dispute some of the things said by TAHC, and other 
government agencies, I wish to kindly submit this science. I hope that my 
submission is made available to the public, and especially the members of the 
meeting that is to be held on September 18, 2012 meeting, to amend Chapter 40, 
entitled “Chronic Wasting Disease (CWD)”. 
 
 
 
 
My submission is as follows, and I will comment after each key point 
separately ; 
 
 
 
 
 
Below are key points of the proposed rules to Chapter 40: 
 
• Require additional cervid species such as North American Elk or Wapiti, 
red deer and Sika deer to participate in surveillance for CWD if they are being 
moved or transported within the state. 
 
• Provide enrollment requirements for the TAHC Complete Monitored Herd 
Program for CWD, based in large part on the USDA interim final rule on CWD. 
 
o Complete physical inventory of the herd every three years 
 
o Fences must be 8 feet in height for herds enrolling after the rule is 
effective 
 
o Require 30 feet of separation between herds, with no shared working 
facilities 
 
o Requires reporting of all CWD suspicious animals and testing of all death 
losses in animals 12 months of age or older (changed from 16 months). 
 
• Delegates authority to the Executive Director to issue an order to 
declare a CWD high risk area or county based on sound epidemiological principles 
for disease detection, control and eradication. 
 
 
 
 
 
>>> • Require additional cervid species such as North American Elk 
or Wapiti, red deer and Sika deer to participate in surveillance for CWD if they 
are being moved or transported within the state. 
 
 
 
 
 
1st and foremost, any voluntary cwd program will fail. 
 
BY only requiring this, ONLY ‘if these cervids are being moved or 
transported within state’, and NOT in general, this is a mistake. Elk or Wapiti, 
red deer and Sika that are not moved within state, will not be in the 
surveillance program, and these animals could potentially risk CWD to other herd 
mates, that might be transported within state. 
 
ALSO, these same cervids, once traded within state, could potentially be 
subclinically infected with CWD (considering cwd testing protocols, age limits 
etc.), and once traded within state, could it not be possible to then trade them 
out of state? 
 
 
 
 
*** I propose this proposal should be that all cervids, should be in this 
CWD surveillance program, and this program should be MANDATORY, if the state is 
going to license ANY game farm or fenced in game farm/ranch. ...TSS 
 
 
 
 
 
 
Monday, June 18, 2012 
 
natural cases of CWD in eight Sika deer (Cervus nippon) and five Sika/red 
deer crossbreeds captive Korea and Experimental oral transmission to red deer 
(Cervus elaphus elaphus) 
 
 
 
 
 
 
 
 
 
Tuesday, June 19, 2012 
 
Experimental Oral Transmission of Chronic Wasting Disease to Reindeer 
(Rangifer tarandus tarandus) 
 
 
 
 
 
 
 
 
 
==================================== 
 
 
 
 
 
>>> • Provide enrollment requirements for the TAHC Complete 
Monitored Herd Program for CWD, based in large part on the USDA interim final 
rule on CWD. 
 
o Complete physical inventory of the herd every three years 
 
o Fences must be 8 feet in height for herds enrolling after the rule is 
effective 
 
o Require 30 feet of separation between herds, with no shared working 
facilities 
 
o Requires reporting of all CWD suspicious animals and testing of all death 
losses in animals 12 months of age or older (changed from 16 months). 
 
 
 
 
 
 
 
FIRST LET’S look at the USDA interim final rule on CWD and my submission ; 
 
 
 
 
Comment from Terry Singeltary Document ID: APHIS-2011-0032-0002Document 
Type: Public Submission This is comment on Notice: Agency Information Collection 
Activities; Proposals, Submissions, and Approvals: Chronic Wasting Disease Herd 
Certification Program Docket ID: APHIS-2011-0032RIN: Topics: No Topics 
associated with this document 
 
 
 
 
View Document: Show Details 
 
 
 
 
Document Subtype: Public Comment Status: Posted Received Date: January 24 
2012, at 12:00 AM Eastern Standard Time Date Posted: January 25 2012, at 12:00 
AM Eastern Standard Time Comment Start Date: January 24 2012, at 12:00 AM 
Eastern Standard Time Comment Due Date: March 26 2012, at 11:59 PM Eastern 
Daylight Time Tracking Number: 80fa2c68 First Name: Terry Middle Name: S. Last 
Name: Singeltary City: Bacliff Country: United States State or Province: TX 
Organization Name: LAYPERSON Submitter's Representative: CJD TSE PRION VICTIMS 
 
 
 
 
Comment: 
 
 
 
 
Agency Information Collection Activities; Proposals, Submissions, and 
Approvals: Chronic Wasting Disease Herd Certification Program (Document ID 
APHIS-2011-0032-0001) I believe that any voluntary program for CWD free herd 
certification from game farms will be futile, as was the partial and voluntary 
mad cow feed ban of August 4, 1997. That failed terribly, with some 10,000,000 
of banned blood laced MBM being fed out in 2007, a decade post August 4, 1997 
partial and voluntary ban. Game farms are a petri dish for CWD TSE Prion 
disease, with Wisconsin having documented 9 CWD infected game farms, with one 
having the highest CWD infection rate in the world, 80% CWD infection rate. I 
believe that all game farms should be SHUT DOWN PERMANENTLY. CWD TSE prion 
disease survives ashing to 600 degrees celsius, that’s around 1112 degrees 
farenheit. you cannot cook the CWD TSE prion disease out of meat. you can take 
the ash and mix it with saline and inject that ash into a mouse, and the mouse 
will go down with TSE. Prion Infected Meat-and-Bone Meal Is Still Infectious 
after Biodiesel Production as well. the TSE prion agent also survives Simulated 
Wastewater Treatment Processes. IN fact, you should also know that the CWD TSE 
Prion agent will survive in the environment for years, if not decades. you can 
bury it and it will not go away. CWD TSE agent is capable of infected your water 
table i.e. Detection of protease-resistant cervid prion protein in water from a 
CWD-endemic area. it’s not your ordinary pathogen you can just cook it out and 
be done with. that’s what’s so worrisome about Iatrogenic mode of transmission, 
a simple autoclave will not kill this TSE prion agent. 
 
 
 
 
 
 
 
Tuesday, December 20, 2011 
 
 
CHRONIC WASTING DISEASE CWD WISCONSIN Almond Deer (Buckhorn Flats) Farm 
Update DECEMBER 2011 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
additional data submission ; 
 
 
 
 
Name: Terry S. Singeltary
 
Address: Bacliff, TX, 
 
Submitter's Representative: CJD TSE PRION VICTIMS
 
Organization: LAYPERSON 
 
 
 
-------------------------------------------------------------------------------- 
 
 
 
 
General Comment 
 
Agency Information Collection Activities; Proposals, Submissions, and 
Approvals: Chronic Wasting Disease Herd Certification Program (Document ID 
APHIS-2011-0032-0001) 
 
 
 
 
I believe that any voluntary program for CWD free herd certification from 
game farms will be futile, as was the partial and voluntary mad cow feed ban of 
August 4, 1997. That failed terribly, with some 10,000,000 of banned blood laced 
MBM being fed out in 2007, a decade post August 4, 1997 partial and voluntary 
ban. 
 
Game farms are a petri dish for CWD TSE Prion disease, with Wisconsin 
having documented 9 CWD infected game farms, with one having the highest CWD 
infection rate in the world, 80% CWD infection rate. 
 
I believe that all game farms should be SHUT DOWN PERMANENTLY. 
 
CWD TSE prion disease survives ashing to 600 degrees celsius, that’s around 
1112 degrees farenheit. 
 
you cannot cook the CWD TSE prion disease out of meat. 
 
you can take the ash and mix it with saline and inject that ash into a 
mouse, and the mouse will go down with TSE. 
 
Prion Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel 
Production as well. 
 
the TSE prion agent also survives Simulated Wastewater Treatment Processes. 
 
IN fact, you should also know that the CWD TSE Prion agent will survive in 
the environment for years, if not decades. 
 
you can bury it and it will not go away. 
 
CWD TSE agent is capable of infected your water table i.e. Detection of 
protease-resistant cervid prion protein in water from a CWD-endemic area. 
 
it’s not your ordinary pathogen you can just cook it out and be done with. 
 
that’s what’s so worrisome about Iatrogenic mode of transmission, a simple 
autoclave will not kill this TSE prion agent. 
 
 
 
Tuesday, December 20, 2011 
 
CHRONIC WASTING DISEASE CWD WISCONSIN Almond Deer (Buckhorn Flats) Farm 
Update DECEMBER 2011 
 
 
 
 
 
 
 
 
 
 
 
===================================== 
 
 
 
 
>>> o Complete physical inventory of the herd every three years 
 
 
 
 
By only doing a physical inventory of the herd every three years, any 
cervid escapee from any game farm will not be detected for 3 years. This will 
allow 3 years for any potential CWD infected cervid that might escape to infect 
the wild herds. 
 
 
 
 
*** I propose a physical inventory of the herd should be done every year, 
and this should be mandatory. ...TSS 
 
 
 
 
Deer, elk continue to escape from state farms 
 
 
 
 
Article by: DOUG SMITH , Star Tribune Updated: March 14, 2011 - 12:08 PM 
 
Curbing chronic wasting disease remains a concern; officials are increasing 
enforcement. 
 
Almost 500 captive deer and elk have escaped from Minnesota farms over the 
past five years, and 134 were never recaptured or killed. 
 
So far this year, 17 deer have escaped, and officials are still searching 
for many of those. 
 
 
 
 
see ; 
 
 
 
 
Friday, September 28, 2012 
 
Stray elk renews concerns about deer farm security Minnesota 
 
 
 
 
 
 
 
 
Monday, June 11, 2012 
 
OHIO Captive deer escapees and non-reporting 
 
 
 
 
 
 
 
 
================================== 
 
 
 
 
 
>>> o Fences must be 8 feet in height for herds enrolling after 
the rule is effective 
 
 
 
 
IT’s been documented that cervids can jump much higher than 8ft. This is a 
fact. This 8 foot rule on single fence heights does not completely protect the 
wild cervid herds from Chronic Wasting Disease CWD. 
 
 
 
 
*** I propose that it should be mandatory for double fencing, with the 
height of either fence not to be any lower than 12 feet, if these deer 
farms/ranches are going to be in existence. WE MUST PROTECT OUR WILD HERDS. 
...TSS 
 
 
 
 
Oh deer! Animals escape from Todmorden farm after fence cut 
 
 
Published on Saturday 7 April 2012 15:00 
 
A STAG and six hinds are on the loose after a wire fence was cut at a 
Todmorden deer farm.
 
The damage was carried out between Tuesday April 3 and 8am the following 
day at East Hey Farm, Stone Cross Road.
 
The high-value animals are reported to have run in the direction of 
Burnley.
 
Police and the owner are appealing for witnesses or anyone with information 
to contact Sergeant Damon Walker on 101 or Crimestoppers, in confidence, on 0800 
555 111. 
 
 
 
 
 
 
 
 
 
Last year, only one deer was removed from the airport. It was unclear how 
the deer got past the wildlife fence — there might have been a small opening in 
the fence, or the deer might have simply jumped the 10 feet. Scherschligt said 
wildlife studies indicate that deer can sometimes jump 12-foot-tall 
obstructions, and the U.S. Department of Agriculture rates some whitetail deer 
as capable of jumping 15 feet. 
 
 
 
 
 
 
 
 
 
 
Jumping to a vertical height of at least eight feet, deer can scale over 
barriers you may think are impossible. Watching a deer confronted with a 
vertical, eight-foot tall, hight-tensile wire fence then 
 
watching it leap over from a standing position makes a startling 
impression. A frightened deer mhurdle a fence as high as 12 feet if given a 
running start and enough adrenalin. Horizontally, a deer may leap 15 to 30 feet, 
the longer distance only when frightened. In general, a deer may jump high or 
long, but not both at the same time. Deer have also been known to crawl under 
fences and through openings as small as 7.5 inches. The will of a deer to 
penetrate a fence is dependent on the force of the motivation behind it. 
 
 
 
 
 
 
 
 
 
Sauer (1984) reported white-tailed deer could jump a 2.1-m fence from a 
standing start and could jump a 2.4-m fence from a running start. In 
contradiction, Fitzwater (1972) indicates that a 2.4-m fence is sufficient to 
prevent deer from jumping. Ludwig and Bremicker (1981) concluded that 2.4-m 
fencing was effective at keeping deer out of roadways as long as the length of 
the fence is extended well beyond the high-risk area for deer-vehicle 
collisions. 
 
 
 
 
 
 
 
 
 
 
=================================== 
 
 
 
 
>>> o Require 30 feet of separation between herds, with no shared 
working facilities 
 
 
 
 
IN my opinion, 30 feet is not enough separation between herds, considering 
AEROSOL SPREAD of the CWD TSE prion agent via dirt. Also, the spreading of the 
CWD TSE agent via rodents in the pens, from pen to pen, and any potential salvia 
from any feed that may be transferred from pen to pen via said rodents, could be 
a risk factor. 
 
 
 
 
 
*** I propose that all pens should be double fenced as I proposed above, 
and that the separation between herds, should be much, much, greater than the 30 
feet proposed, and that risk factors for any potential AEROSOL SPREAD, DIRT, 
RODENTS, WATER. ...TSS 
 
 
 
 
 
 
Saturday, September 01, 2012 
 
Resistance of Soil-Bound Prions to Rumen Digestion 
 
 
 
 
 
 
 
 
Monday, September 17, 2012 
 
Rapid Transepithelial Transport of Prions Following Inhalation 
 
 
 
 
 
 
 
 
 
 
Thursday, May 31, 2012 
 
CHRONIC WASTING DISEASE CWD PRION2012 Aerosol, Inhalation transmission, 
Scrapie, cats, species barrier, burial, and more 
 
 
 
 
 
 
 
 
 
 
Chronic Wasting Disease Susceptibility of Four North American Rodents 
 
 
 
Chad J. Johnson1*, Jay R. Schneider2, Christopher J. Johnson2, Natalie A. 
Mickelsen2, Julia A. Langenberg3, Philip N. Bochsler4, Delwyn P. Keane4, Daniel 
J. Barr4, and Dennis M. Heisey2 1University of Wisconsin School of Veterinary 
Medicine, Department of Comparative Biosciences, 1656 Linden Drive, Madison WI 
53706, USA 2US Geological Survey, National Wildlife Health Center, 6006 
Schroeder Road, Madison WI 53711, USA 3Wisconsin Department of Natural 
Resources, 101 South Webster Street, Madison WI 53703, USA 4Wisconsin Veterinary 
Diagnostic Lab, 445 Easterday Lane, Madison WI 53706, USA *Corresponding author 
email: 
cjohnson@svm.vetmed.wisc.edu 
 
 
 
 
We intracerebrally challenged four species of native North American rodents 
that inhabit locations undergoing cervid chronic wasting disease (CWD) 
epidemics. The species were: deer mice (Peromyscus maniculatus), white-footed 
mice (P. leucopus), meadow voles (Microtus pennsylvanicus), and red-backed voles 
(Myodes gapperi). The inocula were prepared from the brains of hunter-harvested 
white-tailed deer from Wisconsin that tested positive for CWD. Meadow voles 
proved to be most susceptible, with a median incubation period of 272 days. 
Immunoblotting and immunohistochemistry confirmed the presence of PrPd in the 
brains of all challenged meadow voles. Subsequent passages in meadow voles lead 
to a significant reduction in incubation period. The disease progression in 
red-backed voles, which are very closely related to the European bank vole (M. 
glareolus) which have been demonstrated to be sensitive to a number of TSEs, was 
slower than in meadow voles with a median incubation period of 351 days. We 
sequenced the meadow vole and red-backed vole Prnp genes and found three amino 
acid (AA) differences outside of the signal and GPI anchor sequences. Of these 
differences (T56-, G90S, S170N; read-backed vole:meadow vole), S170N is 
particularly intriguing due its postulated involvement in "rigid loop" structure 
and CWD susceptibility. Deer mice did not exhibit disease signs until nearly 1.5 
years post-inoculation, but appear to be exhibiting a high degree of disease 
penetrance. White-footed mice have an even longer incubation period but are also 
showing high penetrance. Second passage experiments show significant shortening 
of incubation periods. Meadow voles in particular appear to be interesting lab 
models for CWD. These rodents scavenge carrion, and are an important food source 
for many predator species. Furthermore, these rodents enter human and domestic 
livestock food chains by accidental inclusion in grain and forage. Further 
investigation of these species as potential hosts, bridge species, and 
reservoirs of CWD is required. 
 
 
 
 
 
 
 
 
 
please see ; 
 
 
 
 
 
 
 
 
 
 
 
Detection of Protease-Resistant Prion Protein in Water from a CWD-Endemic 
Area 
 
 
 
65 
 
 
 
Tracy A. Nichols*1,2, Bruce Pulford1, Christy Wyckoff1,2, Crystal 
Meyerett1, Brady Michel1, Kevin Gertig3, Jean E. Jewell4, Glenn C. Telling5 and 
M.D. Zabel1 1Department of Microbiology, Immunology and Pathology, College of 
Veterinary Medicine and Biomedical Sciences, Colorado State University, Fort 
Collins, CO 80523, USA 2National Wildlife Research Center, Wildlife Services, 
United States Department of Agriculture, Fort Collins, Colorado, 80521, USA 
3Fort Collins Water and Treatment Operations, Fort Collins, Colorado, 80521, USA 
4 Department of Veterinary Sciences, Wyoming State Veterinary Laboratory, 
University of Wyoming, Laramie, Wyoming, 82070, USA 5Department of Microbiology, 
Immunology, Molecular Genetics and Neurology, Sanders Brown Center on Aging, 
University of Kentucky, Lexington, Kentucky, 40536, USA * Corresponding author- 
tracy.a.nichols@aphis.usda.gov 
 
 
 
 
Chronic wasting disease (CWD) is the only known transmissible spongiform 
encephalopathy affecting free-ranging wildlife. Experimental and epidemiological 
data indicate that CWD can be transmitted horizontally and via blood and saliva, 
although the exact mode of natural transmission remains unknown. Substantial 
evidence suggests that prions can persist in the environment, implicating it as 
a potential prion reservoir and transmission vehicle. CWD- positive animals can 
contribute to environmental prion load via biological materials including 
saliva, blood, urine and feces, shedding several times their body weight in 
possibly infectious excreta in their lifetime, as well as through decomposing 
carcasses. Sensitivity limitations of conventional assays hamper evaluation of 
environmental prion loads in water. Here we show the ability of serial protein 
misfolding cyclic amplification (sPMCA) to amplify minute amounts of CWD prions 
in spiked water samples at a 1:1 x106 , and protease-resistant prions in 
environmental and municipal-processing water samples from a CWD endemic area. 
Detection of CWD prions correlated with increased total organic carbon in water 
runoff from melting winter snowpack. These data suggest prolonged persistence 
and accumulation of prions in the environment that may promote CWD transmission. 
 
 
 
snip... 
 
 
 
The data presented here demonstrate that sPMCA can detect low levels of 
PrPCWD in the environment, corroborate previous biological and experimental data 
suggesting long term persistence of prions in the environment2,3 and imply that 
PrPCWD accumulation over time may contribute to transmission of CWD in areas 
where it has been endemic for decades. This work demonstrates the utility of 
sPMCA to evaluate other environmental water sources for PrPCWD, including 
smaller bodies of water such as vernal pools and wallows, where large numbers of 
cervids congregate and into which prions from infected animals may be shed and 
concentrated to infectious levels. 
 
 
 
snip...end...full text at ; 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
====================================== 
 
 
 
 
>>> o Requires reporting of all CWD suspicious animals and testing 
of all death losses in animals 12 months of age or older (changed from 16 
months). 
 
 
 
 
Chronic Wasting Disease CWD, has been documented in many cervids (when 
tested), much younger than the 12 month rule now proposed. AS I so much 
appreciate the TAHC decreasing the age from 16 months to 12 months, I believe 
this rule to still leave a risk factor, due to the fact fawns as young as 4 or 5 
months old have been documented with CWD. 
 
 
 
 
*** I propose that ALL farmed cervids should be tested for CWD. going into 
a farm, leaving a farm, and or at death. ...TSS 
 
 
 
 
 
 
Wisconsin : Six White-Tailed Deer Fawns Test Positive for CWD 
 
Date: May 13, 2003 Source: Wisconsin Department of Natural Resources 
 
Contacts: Julie Langenberg Wildlife Veterinarian 608-266-3143 Tom Hauge 
Director, Bureau of Wildlife Management 608-266-2193 
 
MADISON -- Six fawns in the area of south central Wisconsin where chronic 
wasting disease has been found in white-tailed deer have tested positive for the 
disease, according to Department of Natural Resources wildlife health officials. 
These are the youngest wild white-tailed deer detected with chronic wasting 
disease (CWD) to date. 
 
Approximately 4,200 fawns, defined as deer under 1 year of age, were 
sampled from the eradication zone over the last year. The majority of fawns 
sampled were between the ages of 5 to 9 months, though some were as young as 1 
month. Two of the six fawns with CWD detected were 5 to 6 months old. All six of 
the positive fawns were taken from the core area of the CWD eradication zone 
where the highest numbers of positive deer have been identified. 
 
"This is the first intensive sampling for CWD in fawns anywhere," said Dr. 
Julie Langenberg, Department of Natural Resources wildlife veterinarian, "and we 
are trying to learn as much as we can from these data". 
 
"One noteworthy finding is simply the fact that we found positive fawns," 
Dr. Langenberg said. "These results do show us that CWD transmission can happen 
at a very young age in wild white-tailed deer populations. However, we found 
that the percentage of fawns infected with CWD is very low, in the area of 0.14 
percent. If there was a higher rate of infection in fawns, then fawns dispersing 
in the spring could be much more worrisome for disease spread." 
 
Dr. Langenberg noted that while the youngest CWD-positive fawns had 
evidence of disease-causing prions only in lymph node tissue, several of the 
older CWD-positive fawns had evidence of CWD prions in both lymph node and brain 
tissues -- suggesting further progression of the disease. 
 
"Finding CWD prions in both lymph and brain tissues of deer this young is 
slightly surprising," said Langenberg, "and provides information that CWD 
infection and illness may progress more rapidly in a white-tailed deer than 
previously suspected. Published literature suggests that CWD doesn't cause 
illness in a deer until approximately 16 months of age. Our fawn data shows that 
a few wild white-tailed deer may become sick from CWD or may transmit the 
disease before they reach that age of 16 months." 
 
One of the positive fawns was shot with a doe that was also CWD positive. 
Information about these fawn cases combined with will help researchers who are 
studying the age and routes of CWD transmission in wild deer populations. "More 
data analysis and ongoing deer movement studies should give us an even better 
understanding of how this disease moves across the landscape", said Langenberg. 
 
"Thanks to eradication zone hunters who submitted deer of all ages for 
sampling, we have a valuable set of fawn data that is contributing to our 
state's and the nation's understanding about CWD," Langenberg said. 
 
 
 
 
 
 
 
> > > Two of the six fawns with CWD detected were 5 to 6 months 
old. < < < 
 
 
 
 
Why doesn't the Wisconsin DNR want to routinely test fawns ? 
 
The DNR highly discourages the testing of any fawns regardless of where 
they were harvested. Of the more than 15,000 fawns from the CWD-MZ that have 
been tested, only 23 were test positive, and most of those were nearly one year 
old. It is exceedingly unlikely that a deer less than one year old would test 
positive for CWD, even in the higher CWD prevalence areas of southern Wisconsin. 
Few fawns will have been exposed to CWD, and because this disease spreads 
through the deer's body very slowly, it is very rare in a fawn that the disease 
has progressed to a level that is detectable. This means that testing a fawn 
provides almost no information valuable to understanding CWD in Wisconsin's deer 
herd and does not provide information of great value to the hunter in making a 
decision about venison consumption. 
 
 
 
 
 
 
 
 
 
 
> > > It is exceedingly unlikely that a deer less than one year 
old would test positive for CWD < < < ??? 
 
 
 
 
 
 
Chronic Wasting Disease in a Wisconsin White-Tailed Deer Farm 
 
 
and 15 of 22 fawns aged 6 to 9 months (68.2%) were positive. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
specific susceptibility? 
 
 
 
194. It is probable, based on age-class specific prevalence data from wild 
cervids and epidemiological evidence from captive cervids in affected research 
centres, that both adults and fawns may become infected with CWD (Miller, Wild 
& Williams, 1998; Miller et al., 2000). 
 
 
 
198. In Odocoileus virginianus – white tailed deer, out of 179 white-tailed 
deer which had become enclosed by an elk farm fence, in Sioux County, 
northwestern Nebraska, four fawns only eight months old were among the 50% of 
CWD-positive animals; these fawns were not showing any clinical signs of CWD 
(Davidson, 2002). 
 
 
 
 
 
 
 
 
see full text ; 
 
 
 
 
 
Saturday, February 04, 2012 
 
 
 
Wisconsin 16 MONTH age limit on testing dead deer Game Farm CWD Testing 
Protocol Needs To Be Revised 
 
 
 
 
 
 
 
 
 
 
================================= 
 
 
 
 
>>> • Delegates authority to the Executive Director to issue an 
order to declare a CWD high risk area or county based on sound epidemiological 
principles for disease detection, control and eradication. 
 
 
 
 
IN my opinion, there has been no ‘sound epidemiological principles for 
disease detection, control and eradication’ in Texas for CWD, or any other TSE. 
It’s been just the opposite. NOT even speaking about all the risk factors from 
the cervid game ranch farms in Texas over the years, and trading, and the lax 
rules and enforcement of said rules there from, the fact that CWD infected deer 
have been waltzing across Texas for the past decade, in the exact spot I tried 
warning TAHC back in 2001-2002, i.e. the Texas, New Mexico border at the WSMR 
area, the complete state of Texas is at risk for CWD, and has been at risk for 
CWD for years. 
 
 
 
 
 
 
*** I propose that Texas, and the Executive Director, should take that 
authority, and declare the complete state of Texas (not just a high risk area, 
where the State of New Mexico finally forced Texas to finally test, and finally 
embarrassed Texas enough to finally do CWD testing where it should have been 
done 10 years ago), but I believe the complete state of Texas should be declared 
a high risk area for CWD, until proper testing (in sufficient numbers, in all 
geographical regions), and tested 100% of all farmed cervids. ...TSS 
 
 
 
 
 
 
see full text ; 
 
 
 
 
 
Friday, October 12, 2012 
 
 
 
Texas Animal Health Commission (TAHC) is Now Accepting Comments on Rule 
Proposals for “Chronic Wasting Disease (CWD)” 
 
 
 
 
 
 
Texas Animal Health Commission (TAHC)
 
 
 
 
 
 
 
 
 
 
 
 
Chronic Wasting Disease Herd Certification Program and Interstate Movement 
of Farmed or Captive Deer, Elk, and Moose 
 
 
A Rule by the Animal and Plant Health Inspection Service on 07/20/2012 
 
 
This article has a comment period that ends in 20 days (08/13/2012) 
 
 
 
Action 
 
 
Interim Final Rule; Reopening Of Comment Period. 
 
 
Summary 
 
 
We are reopening the comment period for our interim final rule that will 
establish a herd certification program to control chronic wasting disease (CWD) 
in farmed or captive cervids in the United States. The interim final rule 
requested comment on our decision that our regulations will set minimum 
requirements for the interstate movement of farmed or captive cervids but not 
preempt State or local laws or regulations that are more restrictive than our 
regulations, except any such laws or regulations that prohibit or further 
restrict the transit through a State of deer, elk, and moose that are otherwise 
eligible for interstate movement. This action will allow interested persons 
additional time to prepare and submit comments on our preemption policy with 
respect to CWD. This document also indicates that we will consider comments on 
issues other than our preemption policy for future rulemaking.Show citation box 
 
 
Table of Contents DATES: ADDRESSES: FOR FURTHER INFORMATION CONTACT: 
SUPPLEMENTARY INFORMATION: 
 
 
DATES: Back to Top 
 
 
We will consider all comments that we receive on or before August 13, 
2012.Show citation box 
 
 
ADDRESSES: Back to Top 
 
 
You may submit comments by either of the following methods:Show citation 
box Federal eRulemaking Portal: Go to 
http://www.regulations.gov/#!documentDetail;D=APHIS-2006-0118-0199.Show 
citation box Postal Mail/Commercial Delivery: Send your comment to Docket No. 
00-108-8, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 
River Road Unit 118, Riverdale, MD 20737-1238.Show citation box Supporting 
documents and any comments we receive on this docket may be viewed at 
http://www.regulations.gov/#!docketDetail;D=APHIS-2006-0118 
or in our reading room, which is located in room 1141 of the USDA South 
Building, 14th Street and Independence Avenue SW., Washington, DC. Normal 
reading room hours are 8 a.m. to 4:30 p.m., Monday through Friday, except 
holidays. To be sure someone is there to help you, please call (202) 799-7039 
before coming.Show citation box 
 
 
 
FOR FURTHER INFORMATION CONTACT: Back to Top 
 
 
Dr. Patrice Klein, Senior Staff Veterinarian, National Center for Animal 
Health Programs, Veterinary Services, APHIS, 4700 River Road Unit 43, Riverdale, 
MD 20737-1231; (301) 851-3435.Show citation box 
 
 
SUPPLEMENTARY INFORMATION: Back to Top 
 
 
On June 13, 2012, we published in the Federal Register (77 FR 35542-35571, 
Docket No. 00-108-8) an interim final rule that will establish a herd 
certification program to control chronic wasting disease (CWD) in farmed or 
captive cervids in the United States. The interim final rule will be effective 
on August 13, 2012.Show citation box In the interim final rule, we requested 
comments specifically on our decision not to preempt State and local laws and 
regulations that are more restrictive than our regulations with respect to CWD, 
except any such laws or regulations that prohibit or further restrict the 
transit through a State of deer, elk, and moose that are otherwise eligible for 
interstate movement. That decision was discussed in section III of the 
Background section of the interim final rule, under the heading “APHIS' Decision 
Not to Preempt More Restrictive State Requirements on Farmed or Captive Cervids 
With Respect to CWD,” beginning on 77 FR 35545.Show citation box Comments on our 
decisions regarding preemption of State and local laws and regulations were 
required to be received on or before July 13, 2012. We are reopening the comment 
period on Docket No. 00-108-8 until August 13, 2012. This action will allow 
interested persons additional time to prepare and submit comments. We will also 
consider all comments received between July 14, 2012, and the date of this 
notice.Show citation box The interim final rule indicated that we will publish 
another document in the Federal Register after the comment period closes that 
will include a discussion of any comments we receive on our preemption policy 
and any amendments we are making to the rule. We still plan to do this. However, 
we have received comments on aspects of the interim final rule other than our 
preemption policy. While we will not address these comments in our document 
discussing our preemption policy, we will consider these comments to determine 
whether future rulemaking may be necessary, and we encourage commenters to 
address any aspect of the interim final rule that they wish to.Show citation box 
 
 
Authority: Back to Top 
 
7 U.S.C. 8301-8317; 7 CFR 2.22, 2.80, and 371.4.Show citation box 
 
Done in Washington, DC, this 16th day of July 2012. Kevin Shea, Acting 
Administrator, Animal and Plant Health Inspection Service. [FR Doc. 2012-17726 
Filed 7-19-12; 8:45 am] BILLING CODE 3410-34-P 
 
 
 
 
 
 
Comment from Terry Singeltary 
 
 
 
 
 
 
 
 
 
 
Document ID: APHIS-2011-0032-0002 Document Type: Public Submission This is 
comment on Notice: Agency Information Collection Activities; Proposals, 
Submissions, and Approvals: Chronic Wasting Disease Herd Certification Program 
Docket ID: APHIS-2011-0032 RIN: 
 
 
 
 
Topics: No Topics associated with this document View Document: More 
 
 
Document Subtype: Public Comment Status: Posted Received Date: January 24 
2012, at 12:00 AM Eastern Standard Time Date Posted: January 25 2012, at 12:00 
AM Eastern Standard Time Comment Start Date: January 24 2012, at 12:00 AM 
Eastern Standard Time Comment Due Date: March 26 2012, at 11:59 PM Eastern 
Daylight Time Tracking Number: 80fa2c68 First Name: Terry Middle Name: S. Last 
Name: Singeltary City: Bacliff Country: United States State or Province: TX 
Organization Name: LAYPERSON Submitter's Representative: CJD TSE PRION VICTIMS 
 
 
Comment: 
 
 
 
Agency Information Collection Activities; Proposals, Submissions, and 
Approvals: Chronic Wasting Disease Herd Certification Program (Document ID 
APHIS-2011-0032-0001) 
 
 
 
 
I believe that any voluntary program for CWD free herd certification from 
game farms will be futile, as was the partial and voluntary mad cow feed ban of 
August 4, 1997. That failed terribly, with some 10,000,000 of banned blood laced 
MBM being fed out in 2007, a decade post August 4, 1997 partial and voluntary 
ban. Game farms are a petri dish for CWD TSE Prion disease, with Wisconsin 
having documented 9 CWD infected game farms, with one having the highest CWD 
infection rate in the world, 80% CWD infection rate. I believe that all game 
farms should be SHUT DOWN PERMANENTLY. CWD TSE prion disease survives ashing to 
600 degrees celsius, that’s around 1112 degrees farenheit. you cannot cook the 
CWD TSE prion disease out of meat. you can take the ash and mix it with saline 
and inject that ash into a mouse, and the mouse will go down with TSE. Prion 
Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel Production as 
well. the TSE prion agent also survives Simulated Wastewater Treatment 
Processes. IN fact, you should also know that the CWD TSE Prion agent will 
survive in the environment for years, if not decades. you can bury it and it 
will not go away. CWD TSE agent is capable of infected your water table i.e. 
Detection of protease-resistant cervid prion protein in water from a CWD-endemic 
area. it’s not your ordinary pathogen you can just cook it out and be done with. 
that’s what’s so worrisome about Iatrogenic mode of transmission, a simple 
autoclave will not kill this TSE prion agent. 
 
 
 
 
Tuesday, December 20, 2011 
 
 
 
CHRONIC WASTING DISEASE CWD WISCONSIN Almond Deer (Buckhorn Flats) Farm 
Update DECEMBER 2011 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Saturday, June 09, 2012 
 
 
USDA Establishes a Herd Certification Program for Chronic Wasting Disease 
in the United States 
 
 
 
 
 
 
 
 
 
 
DOCKET-- 03D-0186 -- FDA Issues Draft Guidance on Use of Material From Deer 
and Elk in Animal Feed; Availability 
 
 
 
Date: Fri, 16 May 2003 11:47:37 –0500 
 
 
EMC 1 Terry S. Singeltary Sr. Vol #: 1 
 
 
 
 
 
 
 
 
 
 
 
SNIP...
 
 
 
 
Oral transmission and early lymphoid tropism of chronic wasting disease 
PrPres in mule deer fawns (Odocoileus hemionus ) 
 
 
 
Christina J. Sigurdson1, Elizabeth S. Williams2, Michael W. Miller3, Terry 
R. Spraker1,4, Katherine I. O'Rourke5 and Edward A. Hoover1
 
 
 
 
Department of Pathology, College of Veterinary Medicine and Biomedical 
Sciences, Colorado State University, Fort Collins, CO 80523- 1671, USA1 
Department of Veterinary Sciences, University of Wyoming, 1174 Snowy Range Road, 
University of Wyoming, Laramie, WY 82070, USA 2 Colorado Division of Wildlife, 
Wildlife Research Center, 317 West Prospect Road, Fort Collins, CO 80526-2097, 
USA3 Colorado State University Veterinary Diagnostic Laboratory, 300 West Drake 
Road, Fort Collins, CO 80523-1671, USA4 Animal Disease Research Unit, 
Agricultural Research Service, US Department of Agriculture, 337 Bustad Hall, 
Washington State University, Pullman, WA 99164-7030, USA5
 
 
 
 
 
 
 
 
Mule deer fawns (Odocoileus hemionus) were inoculated orally with a brain 
homogenate prepared from mule deer with naturally occurring chronic wasting 
disease (CWD), a prion-induced transmissible spongiform encephalopathy. Fawns 
were necropsied and examined for PrP res, the abnormal prion protein isoform, at 
10, 42, 53, 77, 78 and 80 days post-inoculation (p.i.) using an 
immunohistochemistry assay modified to enhance sensitivity. PrPres was detected 
in alimentary-tract-associated lymphoid tissues (one or more of the following: 
retropharyngeal lymph node, tonsil, Peyer's patch and ileocaecal lymph node) as 
early as 42 days p.i. and in all fawns examined thereafter (53 to 80 days p.i.). 
No PrPres staining was detected in lymphoid tissue of three control fawns 
receiving a control brain inoculum, nor was PrPres detectable in neural tissue 
of any fawn. PrPres-specific staining was markedly enhanced by sequential tissue 
treatment with formic acid, proteinase K and hydrated autoclaving prior to 
immunohistochemical staining with monoclonal antibody F89/160.1.5. These results 
indicate that CWD PrP res can be detected in lymphoid tissues draining the 
alimentary tract within a few weeks after oral exposure to infectious prions and 
may reflect the initial pathway of CWD infection in deer. The rapid infection of 
deer fawns following exposure by the most plausible natural route is consistent 
with the efficient horizontal transmission of CWD in nature and enables 
accelerated studies of transmission and pathogenesis in the native 
species.
 
 
 
 
snip...
 
 
 
 
These results indicate that mule deer fawns develop detectable PrP res 
after oral exposure to an inoculum containing CWD prions. In the earliest 
post-exposure period, CWD PrPres was traced to the lymphoid tissues draining the 
oral and intestinal mucosa (i.e. the retropharyngeal lymph nodes, tonsil, ileal 
Peyer's patches and ileocaecal lymph nodes), which probably received the highest 
initial exposure to the inoculum. Hadlow et al. (1982) demonstrated scrapie 
agent in the tonsil, retropharyngeal and mesenteric lymph nodes, ileum and 
spleen in a 10-month-old naturally infected lamb by mouse bioassay. Eight of 
nine sheep had infectivity in the retropharyngeal lymph node. He concluded that 
the tissue distribution suggested primary infection via the gastrointestinal 
tract. The tissue distribution of PrPres in the early stages of infection in the 
fawns is strikingly similar to that seen in naturally infected sheep with 
scrapie. These findings support oral exposure as a natural route of CWD 
infection in deer and support oral inoculation as a reasonable exposure route 
for experimental studies of CWD.
 
 
 
 
snip...
 
 
 
 
 
 
 
 
 
 
 
===================================
 
 
 
 
now, just what is in that deer feed? _ANIMAL PROTEIN_
 
 
 
 
Subject: MAD DEER/ELK DISEASE AND POTENTIAL SOURCES Date: Sat, 25 May 2002 
18:41:46 -0700 From: "Terry S. Singeltary Sr." Reply-To: BSE-L To: BSE-L
 
8420-20.5% Antler Developer For Deer and Game in the wild Guaranteed 
Analysis Ingredients / Products Feeding Directions
 
snip...
 
_animal protein_
 
 
 
 
 
BODE'S GAME FEED SUPPLEMENT #400 A RATION FOR DEER NET WEIGHT 50 POUNDS 
22.6 KG.
 
snip...
 
_animal protein_
 
 
 
 
 
Ingredients
 
Grain Products, Plant Protein Products, Processed Grain By-Products, Forage 
Products, Roughage Products 15%, Molasses Products, __Animal Protein Products__, 
Monocalcium Phosphate, Dicalcium Pyosphate, Salt, Calcium Carbonate, Vitamin A 
Acetate with D-activated Animal Sterol (source of Vitamin D3), Vitamin E 
Supplement, Vitamin B12 Supplement, Riboflavin Supplement, Niacin Supplement, 
Calcium Panothenate, Choline Chloride, Folic Acid, Menadione Soduim Bisulfite 
Complex, Pyridoxine Hydorchloride, Thiamine Mononitrate, d-Biotin, Manganous 
Oxide, Zinc Oxide, Ferrous Carbonate, Calcium Iodate, Cobalt Carbonate, Dried 
Sacchoromyces Berevisiae Fermentation Solubles, Cellulose gum, Artificial 
Flavors added.
 
 
 
 
 
===================================
 
 
 
 
MORE ANIMAL PROTEIN PRODUCTS FOR DEER
 
Bode's #1 Game Pellets A RATION FOR DEER F3153
 
GUARANTEED ANALYSIS Crude Protein (Min) 16% Crude Fat (Min) 2.0% Crude 
Fiber (Max) 19% Calcium (Ca) (Min) 1.25% Calcium (Ca) (Max) 1.75% Phosphorus (P) 
(Min) 1.0% Salt (Min) .30% Salt (Max) .70%
 
Ingredients
 
Grain Products, Plant Protein Products, Processed Grain By-Products, Forage 
Products, Roughage Products, 15% Molasses Products, __Animal Protein Products__, 
Monocalcium Phosphate, Dicalcium Phosphate, Salt, Calcium Carbonate, Vitamin A 
Acetate with D-activated Animal Sterol (source of Vitamin D3) Vitamin E 
Supplement, Vitamin B12 Supplement, Roboflavin Supplement, Niacin Supplement, 
Calcium Pantothenate, Choline Chloride, Folic Acid, Menadione Sodium Bisulfite 
Complex, Pyridoxine Hydrochloride, Thiamine Mononitrate, e - Biotin, Manganous 
Oxide, Zinc Oxide, Ferrous Carbonate, Calcium Iodate, Cobalt Carbonate, Dried 
Saccharyomyces Cerevisiae Fermentation Solubles, Cellulose gum, Artificial 
Flavors added.
 
FEEDING DIRECTIONS Feed as Creep Feed with Normal Diet
 
 
 
 
 
INGREDIENTS
 
Grain Products, Roughage Products (not more than 35%), Processed Grain 
By-Products, Plant Protein Products, Forage Products, __Animal Protein 
Products__, L-Lysine, Calcium Carbonate, Salt, Monocalcium/Dicalcium Phosphate, 
Yeast Culture, Magnesium Oxide, Cobalt Carbonate, Basic Copper Chloride, 
Manganese Sulfate, Manganous Oxide, Sodium Selenite, Zinc Sulfate, Zinc Oxide, 
Sodium Selenite, Potassium Iodide, Ethylenediamine Dihydriodide, Vitamin E 
Supplement, Vitamin A Supplement, Vitamin D3 Supplement, Mineral Oil, Mold 
Inhibitor, Calcium Lignin Sulfonate, Vitamin B12 Supplement, Menadione Sodium 
Bisulfite Complex, Calcium Pantothenate, Riboflavin, Niacin, Biotin, Folic Acid, 
Pyridoxine Hydrochloride, Mineral Oil, Chromium Tripicolinate
 
DIRECTIONS FOR USE
 
Deer Builder Pellets is designed to be fed to deer under range conditions 
or deer that require higher levels of protein. Feed to deer during gestation, 
fawning, lactation, antler growth and pre-rut, all phases which require a higher 
level of nutrition. Provide adequate amounts of good quality roughage and fresh 
water at all times.
 
 
 
 
 
===================================================
 
 
 
 
DEPARTMENT OF HEALTH & HUMAN SERVICES PUBLIC HEALTH SERVICE FOOD AND 
DRUG ADMINISTRATION
 
April 9, 2001 WARNING LETTER
 
01-PHI-12 CERTIFIED MAIL RETURN RECEIPT REQUESTED
 
Brian J. Raymond, Owner Sandy Lake Mills 26 Mill Street P.O. Box 117 Sandy 
Lake, PA 16145 PHILADELPHIA DISTRICT
 
Tel: 215-597-4390
 
Dear Mr. Raymond:
 
Food and Drug Administration Investigator Gregory E. Beichner conducted an 
inspection of your animal feed manufacturing operation, located in Sandy Lake, 
Pennsylvania, on March 23, 2001, and determined that your firm manufactures 
animal feeds including feeds containing prohibited materials. The inspection 
found significant deviations from the requirements set forth in Title 21, code 
of Federal Regulations, part 589.2000 - Animal Proteins Prohibited in Ruminant 
Feed. The regulation is intended to prevent the establishment and amplification 
of Bovine Spongiform Encephalopathy (BSE) . Such deviations cause products being 
manufactured at this facility to be misbranded within the meaning of Section 
403(f), of the Federal Food, Drug, and Cosmetic Act (the Act).
 
Our investigation found failure to label your swine feed with the required 
cautionary statement "Do Not Feed to cattle or other Ruminants" The FDA suggests 
that the statement be distinguished by different type-size or color or other 
means of highlighting the statement so that it is easily noticed by a 
purchaser.
 
In addition, we note that you are using approximately 140 pounds of cracked 
corn to flush your mixer used in the manufacture of animal feeds containing 
prohibited material. This flushed material is fed to wild game including deer, a 
ruminant animal. Feed material which may potentially contain prohibited material 
should not be fed to ruminant animals which may become part of the food 
chain.
 
The above is not intended to be an all-inclusive list of deviations from 
the regulations. As a manufacturer of materials intended for animal feed use, 
you are responsible for assuring that your overall operation and the products 
you manufacture and distribute are in compliance with the law. We have enclosed 
a copy of FDA's Small Entity Compliance Guide to assist you with complying with 
the regulation... blah, blah, blah...
 
 
 
 
SNIP...
 
 
 
 
 
PLEASE SEE FULL TEXT SUBMISSION ; 
 
 
 
 
 
 
 
 
 
 
 
 
Thursday, June 6, 2013 
 
 
 
 
BSE TSE PRION USDA FDA MAD COW FEED COMPLIANCE REPORT and NAI, OAI, and VAI 
ratings as at June 5, 2013 
 
 
 
 
 
Greetings, 
 
 
 
 
 
 
since our fine federal friends have decided not to give out any more 
reports on the USA breaches of the feed ban and surveillance etc. for the BSE 
TSE prion mad cow type disease in the USDA livestock, I thought I might attempt 
it. I swear, I just don’t understand the logic of the SSS policy, and that 
includes all of it. I assure you, it would be much easier, and probably better 
for the FDA and the USDA INC., if they would simply put some kind of report out 
for Pete’s sake, instead of me doing it after I get mad, because I am going to 
put it all out there. the truth. 
 
 
 
 
 
PLEASE BE ADVISED, any breach of any of the above classifications OAI, VAI, 
RTS, CAN lead to breaches into the feed BSE TSE prion protocols, and CAN lead to 
the eventual suspect tainted feed reaching livestock. please, if any USDA 
official out there disputes this, please explain then how they could not. 
paperwork errors can eventually lead to breaches of the BSE TSE prion mad cow 
feed ban reaching livestock, or contamination and exposure there from, as well. 
 
 
 
 
 
I would sure like to see the full reports of just these ; 
 
 
 
 
 
 
4018 CHI-DO 3007091297 Rancho Cantera 2866 N Sunnyside Rd Kent IL 
61044-9605 OPR FR, OF HP 11/26/2012 OAI Y 
 
 
 
 
9367 3008575486 Rocky Ford Pet Foods 21693 Highway 50 East Rocky Ford CO 
81067 OPR RE, TH HP 2/27/2013 OAI N 
 
 
 
 
9446 DEN-DO 1713202 Weld County Bi Products, Inc. 1138 N 11th Ave Greeley 
CO 80631-9501 OPR RE, TH HP 10/12/2012 OAI N 
 
 
 
 
9447 DEN-DO 3002857110 Weld County Bi-Products dba Fort Morgan Pet Foods 
13553 County Road 19 Fort Morgan CO 80701-7506 OPR RE HP 12/7/2011 OAI N 
 
 
 
 
 
 
see full list of the fda mad cow bse feed follies, toward the bottom, after 
a short brief update on the mad cow bse follies, and our good friend Lester 
Crawford that was at the FDA. 
 
 
 
 
 
ALSO, I would kindly like to comment on this FDA BSE/Ruminant Feed 
Inspections Firms Inventory (excel format)4 format, for reporting these breaches 
of BSE TSE prion protocols, from the extensive mad cow feed ban warning letters 
the fda use to put out for each violations. simply put, this excel format sucks, 
and the FDA et al intentionally made it this difficult to follow the usda fda 
mad cow follies. this is an intentional format to make it as difficult as 
possible to follow these breaches of the mad cow TSE prion safety feed 
protocols. to have absolutely no chronological or numerical order, and to format 
such violations in a way that they are almost impossible to find, says a lot 
about just how far the FDA and our fine federal friends will go through to hide 
these continued violations of the BSE TSE prion mad cow feed ban, and any 
breaches of protocols there from. once again, the wolf guarding the henhouse $$$ 
 
 
 
 
 
 
NAI = NO ACTION INDICATED
 
 
 
OAI = OFFICIAL ACTION INDICATED
 
 
 
VAI = VOLUNTARY ACTION INDICATED
 
 
 
RTS = REFERRED TO STATE 
 
 
 
 
 
 
Inspections conducted by State and FDA investigators are classified to 
reflect the compliance status at the time of the inspection, based upon whether 
objectionable conditions were documented. Based on the conditions found, 
inspection results are recorded in one of three classifications: 
 
 
 
 
OAI (Official Action Indicated) when inspectors find significant 
objectionable conditions or practices and believe that regulatory sanctions are 
warranted to address the establishment’s lack of compliance with the regulation. 
An example of an OAI classification would be findings of manufacturing 
procedures insufficient to ensure that ruminant feed is not contaminated with 
prohibited material. Inspectors will promptly re-inspect facilities classified 
OAI after regulatory sanctions have been applied to determine whether the 
corrective actions are adequate to address the objectionable conditions. 
 
 
 
 
VAI (Voluntary Action Indicated) when inspectors find objectionable 
conditions or practices that do not meet the threshold of regulatory 
significance, but warrant an advisory to inform the establishment that 
inspectors found conditions or practices that should be voluntarily corrected. 
VAI violations are typically technical violations of the 1997 BSE Feed Rule. 
These violations include minor recordkeeping lapses or conditions involving 
non-ruminant feeds. 
 
 
 
 
NAI (No Action Indicated) when inspectors find no objectionable conditions 
or practices or, if they find objectionable conditions, those conditions are of 
a minor nature and do not justify further actions. 
 
 
 
 
 
 
 
 
 
 
 
 
 
when sound science was bought off by junk science, in regards to the BSE 
TSE prion mad cow type disease, by the USDA, CFIA, WHO, OIE, et al. $$$ 
 
 
 
 
when the infamous, and fraudulently USDA, FSIS, APHIS, FDA, gold card was 
taken away that infamous day in December of 2003, all cards were off the table, 
it was time to change the science, and change they did. ...tss 
 
 
 
 
snip. ...please see full text ;
 
 
 
 
 
 
Thursday, June 6, 2013 
 
 
 
BSE TSE PRION USDA FDA MAD COW FEED COMPLIANCE REPORT and NAI, OAI, and VAI 
ratings as at June 5, 2013 
 
 
 
 
 
 
 
 
 
 
 
 
 
Tuesday, June 11, 2013 
 
 
Weld County Bi-Products dba Fort Morgan Pet Foods 6/1/12 significant 
deviations from requirements in FDA regulations that are intended to reduce the 
risk of bovine spongiform encephalopathy (BSE) within the United States 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TSS
 
 
 
 
 
 
 
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