Michigan DNR to present chronic wasting disease recommendations to Natural Resources Commission Singeltary submission
June 7, 2018
Contact: Ed Golder, 517-284-5815
DNR to present chronic wasting disease recommendations to Natural Resources Commission
After months of talking with interested citizens and hunting and wildlife stakeholders and reviewing the best available science regarding chronic wasting disease, the Michigan Department of Natural Resources is set to present CWD recommendations to the Natural Resources Commission at its next monthly meeting Thursday, June 14, in Lansing. Recommendations will be presented during Committee of the Whole.
The department’s recommendations are the result of a six-month-long public engagement effort, during which DNR staff and NRC members met with people around the state, hosted 11 public meetings, and offered online survey and comment opportunities. The recommendations are being presented for information to the commission, as part of the public input process.
The NRC will review, discuss and possibly modify recommendations before making a final decision at a future commission meeting. Comments may be submitted to the commission via email at NRC@michigan.gov.
“The DNR and the Natural Resources Commission appreciate the high level of engagement from our customers, partners and stakeholders, and the willingness to
co-create strategies to address CWD,” said DNR Director Keith Creagh. “We look forward to continued engagement and cooperation as we move into hunting season this fall.”
CWD is a fatal neurological (brain and nervous system) disease found in cervids – deer, elk and moose. The disease attacks the brains of infected animals and produces small lesions that result in death. There is no cure; once an animal is infected, it will die. Initially, CWD was first discovered in Michigan in a free-ranging deer in May 2015. Since that time, CWD has been confirmed in deer in five Michigan counties: Clinton, Ingham, Ionia, Kent and Montcalm.
The Natural Resources Commission meeting will take place June 14 at the Lansing Community College Downtown Campus, Health and Human Services Department, 515 North Washington Square, Conference Room HHS 005-0078.
The full meeting’s draft agenda includes the following.
8 a.m. – Committee on Finance and Administration
9 a.m. – Michigan State Parks Advisory Committee
12:30 p.m. – Committee on Wildlife and Fisheries
2 p.m. – Committee of the Whole
Immediately following the Committee of the Whole, the commission will receive public comments. To register for public comment, contact Cheryl Nelson, executive assistant to the commission, at 517-284-6237 or nelsonc@michigan.gov. Those registering by 5 p.m. Friday, June 8, will be allowed up to five minutes to address the commission. Those registering after June 8 or at the meeting will be allowed up to three minutes. Registration cards will be available at the meeting.
Following public comments, the commission is scheduled to vote on statewide trout, salmon, whitefish, lake herring and smelt regulations, as well as Wildlife Conservation Order amendments governing furbearer regulations, squirrel and falconry season dates, and open/closed deer management units. Director Creagh then is expected to approve the results of the May 2018 oil and gas lease auction, as well as several land transactions.
For more information about the Natural Resources Commission, including full agendas and meeting minutes, visit michigan.gov/nrc.
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The Michigan Department of Natural Resources is committed to the conservation, protection, management, use and enjoyment of the state’s natural and cultural resources for current and future generations. For more information, go to www.michigan.gov/dnr.
RICK SNYDER GOVERNOR
STATE OF MICHIGAN DEPARTMENT OF NATURAL RESOURCES LANSING
Image KEITH CREAGH DIRECTOR
SUBMITTED:
June 6, 2018
MEMORANDUM TO THE NATURAL RESOURCES COMMISSION
Subject:
Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 FOR INFORMATION ONLY
Authority:
The Natural Resources and Environmental Protection Act, 1994 P A 451, authorizes the Director and the Commission to issue orders to manage wild animals in this state.
Discussion and Background:
Since the finding of chronic wasting disease (CWD) in a free-ranging white-tailed deer in Michigan on May 20,2015, CWD-positive deer have been found in Clinton, Ingham, Ionia, Kent, and Montcalm counties. As of mid-January 2018, after testing approximately 30,600 free- ranging deer, 57 were positively confirmed with CWD, with 48 occurring during the 2017 deer hunting season. In addition, two Privately-Owned Cervid (pOC) facilities in Mecosta County were positively confirmed with CWD in 2017.
The Natural Resources Commission (NRC) and the Department are taking aggressive action based on the Michigan's Surveillance and Response Plan for Chronic Wasting Disease of Free- Ranging and Privately-Owned Cervids, herein referred to as "the Plan", and the recommendations from the Chronic Wasting Disease Working Group - a panel established by the NRC to develop recommendations on further steps and actions to substantially mitigate or eliminate CWD in Michigan - to address CWD in Michigan's deer population and to maintain healthy wildlife for current and future generations. In addition, the Department and the NRC hosted a series of public engagement meetings on CWD that provided an opportunity for the NRC and the Department to hear suggestions and observations from hunters and residents interested in the health of the state's deer herd. The Department and the NRC are focused on achieving specific CWD management goals that include slowing the spread of the disease, reducing or maintaining low prevalence rates, preventing the disease from reaching new areas, and preserving Michigan's rich hunting history for future generations to enjoy.
Based on the current available state of the science, recommendations from the Chronic Wasting Disease Working Group, suggestions from the public engagement meetings, and the specific CWD management goals, the Department recommends amending the protocols and control measures in the Wildlife Conservation Order to address CWD in Michigan's deer population.
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CONSTITUTION HALL· 525 WEST ALLEGAN STREET· P.O. BOX 30028· LANSING, MICHIGAN 48909-7528 www.michigan.gov/dnr (517) 284-MDNR(6367)
Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 Page 2 June 6, 2018
Statewide Regulations:
Restrictions on Tile Possession and Use of Natural Cervid Urine-Based Lures and Attractants
Chronic wasting disease is a fatal disease caused by the transmission of infectious, self-mutating proteins (prions) contained in the body and fluids of infected cervids that causes degeneration of the central nervous system of those same species. Although nervous system tissue and lymphatic tissues have the highest infectivity, these prions are also found in blood, feces and urine of infected cervids. Susceptible cervids can acquire CWD by direct exposure to these fluids or from environments contaminated with these fluids. Deer urine is used by hunters and sportspersons as an attractant and cover scent, with most commercially made products originating from POC facilities. This market is unregulated, and thus to take a pro-active approach to reduce the risk of spread or introduction of CWD to a new area, the Department recommends restricting the possession and use of non-synthetic cervid urine-based lures and attractants while hunting or trapping game species. Only synthetic cervid urine-based lures or attractants or natural cervid urine-based lures or attractants that are labeled with the official ATA (Archery Trade Association) Seal of Participation will be legal.
Issues Pros and Cons
The ATA is the organization for manufacturers, retailers, distributors, sales representatives, and others working in the archery and bowhunting industry. The ATA developed a Deer Protection Program, which seeks to ensure that AT A -member scent manufacturers, and their product suppliers do everything possible to prevent the spread of CWD in wild deer, elk, and moose herds in the United States. Manufacturers and their product suppliers voluntarily join the program and agree to take measures to meet or exceed state and federal CWD requirements and ensure that their products come from healthy deer herds. Manufacturers guarantee through their participation in the program, that the cervid urine utilized in their products comes only from facilities that are also participating in the ATA Deer Protection Program, and that strictly comply with the following measures:
Participate in a federally-approved CWD program
Have documented all cervid movement in/out of herd
Continually monitor their herd for CWD
Allow additional facility inspections
Physically inspect 100 percent of the herd every three years
Commit to advancement of sound science related to CWD
Remain aware of CWD instances within 30 miles, and maintain minimum fence requirements
Most urine used for lures and attractants is produced and collected from captive cervid facilities at both large commercial and small-scale operations. Although Michigan POC facilities participate in the state's CWD monitoring program, products used may come from large interstate operations. There are a variety of unregulated processes used to collect urine, and they often result in the accumulation of a mixture of secretions, therefore providing concurrent contamination risks. There are currently no standard regulations to ensure that urine collected for lures and attractants are disease-free.
Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 Page 3 June 6, 2018
Other States
Alaska, Arizona, Arkansas, Pennsylvania (within CWD areas), Vermont, and Virginia have banned the use of urine-based lures or attractants.
Biological
Urine-based lures and attractants are used in several different ways, many which involve direct contact between the scent and the environment. Use of urine-based lures and attractants has the potential to spread CWD to areas where it has previously not been detected. Infectious prions present in urine can contaminate the environment, where the prions can bind to the soil and be taken up by plants and are likely to remain infectious for many years. For example, research studies indicate that as little as 10 milliliters of contaminated urine can contain enough infectious prions to risk lethal infection in 50 percent of exposed deer. Though urine is considered less infectious than saliva or feces, collection methods for many of these facilities are unlikely to exclude these materials from the final product. Though facilities approved through the AT A are enrolled in the United States Department of Agriculture (USDA) Herd Certification Program (HCP), 28 breeder facilities nationally have tested positive for CWD since 2012, with 15 of these facilities em-oiled in the USDA-HCP.
Social
Regulating the use of urine-based lures and attractants may affect the business of the captive cervid industry, however, approximately 90 to 95 percent of manufacturers are certified through the AT A Deer Protection Program.
Economic
It's still legal to buy and sell products with cervid urine and other bodily fluids, however some businesses may see a decrease in sales.
Lower Peninsula Regulations:
Baiting and Feeding Ball- Effective January 31, 2019
Baiting is a popular practice among Michigan hunters, and its popularity has risen over the last few decades. However, research suggests that the relationships between baiting, feeding, and CWD transmission is in the risks associated with congregating animals. While natural food sources also congregate wildlife, human activities such as baiting or feeding do so at rates above natural sources, therefore the risk of transmitting CWD increases. The risks of congregating animals around bait and feed increases the probability of direct contact between infected and noninfected animals, and it also increases the risks of contaminating the food source or the surrounding environment. Therefore, the Department recommends instituting a baiting and feeding ban effective January 31, 2019, for the Lower Peninsula. A delayed implementation provides opportunity for those with economic interests to shift business models for next year.
Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 201 8 Page 4 June 6, 2018
Issues Pros and Cons
With the presence of CWD in the Southwest Lower Peninsula and Bovine Tuberculosis (TB) in the Northeast Lower Peninsula, the range of these two diseases now covers much of the Lower Peninsula. A proactive approach by banning baiting and feeding, with the uncertainty of the distribution of these diseases, is warranted to reduce the risk on the landscape. In addition, given that CWD is often present in areas long before it is discovered, elimination of baiting and feeding may be a strategy to lessen the spread of the disease should it be introduced in new areas.
There are both biological and social considerations to make regarding baiting and feeding. Baiting is a highly popular activity among Michigan hunters. Baiting and feeding also have economic value as a market for agricultural products. Studies suggest there may be public support for baiting regulations if they are perceived to effectively reduce transmission of a disease and if the public has been involved in the decision—making process, however studies also suggest that hunter activity may shift in response to those regulations.
Other States and Provinces
The Department sent out a survey to CWD—positive states and received responses from Alberta, Arkansas, Illinois, Iowa, Kansas, Maryland, Missouri, Mississippi, New York, North Dakota, Utah, Virginia, West Virginia, and Wisconsin. The results were the following:
Alberta: Baiting and feeding is illegal throughout the province.
Arkansas: It is illegal to feed deer within CWD affected areas, however there are certain baiting restrictions within CWD affected areas.
Illinois: Baiting and feeding is illegal statewide.
Iowa: Baiting is illegal, but feeding is allowed statewide.
Kansas: Baiting and feeding is legal statewide.
Maryland: Baiting and feeding is legal statewide.
Missouri: Baiting and feeding is illegal in the CWD affected areas.
Mississippi: Baiting and feeding is illegal in the CWD affected areas.
New York: Baiting and feeding is illegal statewide.
North Dakota: Baiting and feeding is illegal in the CWD affected areas.
Utah: Baiting and feeding is legal statewide.
Virginia: Baiting is legal, and feeding is allowed only in areas other than CWD affected areas.
West Virginia: Baiting and feeding is illegal in the CWD affected areas.
Wisconsin: Baiting and feeding is legal in counties 36 months since the last CWD confirmation or 24 months in an adjacent county; currently 48 of 72 “affected” counties remain under a baiting and feeding ban.
Biological
Chronic wasting disease can be transmitted directly (e.g., saliva, urine, and feces) and indirectly (contaminated environment) among deer. Evidence suggests that baiting and feeding increases both the congregation of deer and the risk of disease transmission through increasing the probability of contact, food source contamination, and environmental contamination. In a review
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Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 Page 5 June 6, 2018
of 29 studies investigating the relationship between supplemental feeding and disease transmitted through close or direct contact of animals, 95 percent reported that supplemental feeding increased the risk of disease transmission. In addition, the longer the food is on the landscape, the greater the likelihood of increasing disease transmission.
Social
In Michigan, while approval (71 percent) of baiting as a practice among hunters has steadily risen since the mid-19805, most hunters do support baiting restrictions when the health of the deer herd is in jeopardy. Studies have found that hunter support for management actions to address CWD, including baiting bans, is based on the perceived efficacy of those actions. Studies have also found that hunter acceptance of management activities increases as prevalence increases and as perception of risk increases. In addition, studies have also examined hunter behavior changes in response to baiting bans. In Michigan, after the implementation of baiting regulations in the northeast Lower Peninsula due to Bovine Tuberculosis (TB), 50 percent of bowhunters and 31 percent of firearm hunters in the area reported hunting less because of the baiting ban, and 22 percent stopped hunting in the area all together. However, declines in antlerless harvest and firearm season participation in the northeast Lower Peninsula following the ban were very similar to declines statewide.
Economic
Baiting and feeding have economic value as a market for agricultural products. Instituting a baiting and feeding ban effective for 2019 will allow time for those with economic interests to shift business models for next year.
Baiting Exception for Hunters with Disabilities
According to the Michigan Deer Hawest Survey Report, hunters with disabilities are, generally, some of the least satisfied hunters in Michigan. Although efforts have been made over the last decade to establish special hunt dates, equipment permits, and accessibility provisions, the success rate for hunters with disabilities continues to remain low compared to other hunters. The NRC and the Department received public input from hunters with disabilities regarding the use of bait. Hunters with disabilities rely on bait for the purposes of successfully harvesting a deer. The Department recommends granting a baiting exception for qualified hunters with disabilities outside of the 13-County CWD Management Zone and Bovine Tuberculosis (TB) Management Zone (Alcona, Alpena, Montmorency, and Oscoda counties) during the Liberty and Independence Hunts. Baiting would be limited to current regulations, allowing only two gallons of bait per site, distributed across a 10’x10’ area, and baiting may only occur from the first day of the season to the last day of the season. All bait must be removed from the area prior to any additional hunting during the rest of the season.
Issues Pros and Cons
The Liberty Hunt is a two—day season in mid—September that takes place on private or public lands. The Independence Hunt is a four-day season in mid—October that takes place on private lands. During these hunts, individuals with qualifying disabilities may participate and may hunt antlered (antler point restrictions do not apply) or antlerless deer with a firearm. These hunts
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Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 Page 6 June 6, 2018
provide hunters with disabilities the opportunity to deer hunt under less crowded conditions when weather conditions are more likely to be favorable.
Even though granting a baiting exception during these two hunts for individuals with qualifying disabilities will offer a service to some of our constituents, baiting causes unnatural concentrations of deer and this activity increases the risk of disease infection and spread, and repeated use of baiting areas poses a long-term risk of disease transmission. Allowing this exception may not help reduce risk of disease spread and transmission.
Other States
The Department is not aware of other CWD—positive states granting a baiting exception for hunters with disabilities.
Biological
Chronic wasting disease transmission occurs when disease prions are shed by infected animals through saliva, urine and feces, and through contact between deer and contaminated environments. Research suggests that the relationships between baiting, feeding, and CWD transmission is in the risks associated with congregating animals. While natural food sources also congregate wildlife, human activities such as baiting or feeding do so at rates above natural sources, therefore the risk of transmitting CWD increases.
Social
Granting a baiting exception for qualified hunters during these hunts may result in some social conflict. The Liberty Hunt is for both qualified hunters with disabilities and youths 16 years of age and younger. In addition, the Liberty Hunt coincides with the early antlerless firearm season, which may result in conflicts between hunters during the concurring seasons. The proposed regulations are to allow those individuals with disabilities who are eligible to hunt during the Liberty Hunt the opportunity to use bait, not youth hunters without qualifying disabilities who are hunting during the Liberty hunt or those hunting during the early antlerless season. The Independence Hunt has limited participation statewide; there were approximately 1,900 hunters in 2016 with a harvest of approximately 400 deer. The Liberty Hunt (both hunters with disabilities and youth hunters) has higher participation statewide, with approximately 22,000 hunters participating in 2016 with a harvest of approximately 6,400 deer.
Economic
There may be some local benefit to surrounding businesses that sell bait.
CWD Management Zone
Define 13-County CWD Management Zone
Chronic wasting disease has been found in a total of 57 free-ranging deer within Clinton, Ingharn, Ionia, Kent, and Montcalm counties. One of the control measures outlined in the Plan is to establish a CWD Management Zone that includes, at a minimum, any county with a boundary
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Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 2018 Page 7 June 6, 2018
that is intersected by a 10—mile radius around each of the documented cases where the infected animals were located. In addition, the Plan states that if results of a local population survey or credible scientific evidence suggests that cervids from within the radius are likely to move beyond these Management Zone boundaries, those boundaries should be expanded. Accordingly, the Department recommends establishing a 13-County CWD Management Zone that includes Clinton, Eaton, Gratiot, Ingharn, Ionia, Isabella, Kent, Mecosta, Montcalm, Muskegon, Newaygo, Ottawa, and Shiawassee counties.
In addition, the Department recommends eliminating the CWD Management Zone defined as Clinton, Eaton, Ingham, Ionia, and Shiawassee counties, also known as Deer Management Unit (DMU) 419. These counties will be included in the newly defined CWD Management Zone.
Issues Pros and Cons
The newly defined 13-County CWD Management Zone will allow the Department and the NRC to establish impactful regulations related to CWD and emphasizes those areas that will be impacted by CWD. In addition, it allows for continued management and surveillance as the development of the current state of the science related to CWD control continues. The Department and the NRC continue to support an aggressive approach and an adaptive management strategy. The Department will need continued support from the hunters and public related to CWD management. The Department will continue effective communications and customer service related to the regulatory changes.
Biological
The Department has tested approximately 31,000 free-ranging deer for CWD since May of 2015. Ten have tested positive for CWD in Clinton, Ingham, and Ionia counties and 47 have tested positive for CWD in Kent and Montcalm counties. Establishing the CWD Management Zone will allow the Department to continue aggressive surveillance and management outlined in the Plan.
Social
There has been expressed support for the CWD Plan and the Department’s implementation of the plan measures and protocols.
Economic
The Department does not expect an economic impact.
Baiting and Fceding Ban Effective Immediately
Of the 57 free-ranging deer that have been positively confirmed with CWD, 36 have been found in Montcalm County. Chronic wasting disease appears to be widespread in Montcalm county, and sampling in the surrounding areas (Kent, Mecosta, Gratiot, Isabella, and Newaygo) has been generally poor to identify the true scope of the disease. With CWD also identified in Clinton, Kent, Ionia, and Ingham counties, a response that bans baiting and feeding in the immediate area is a responsible endeavor to reduce the immediate risk of transmission in and near affected areas. Currently, there are baiting bans in Clinton, Eaton, Ingham, Tonia, and Shiawassee counties, and
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Chronic Wasting Disease Regulations Wildlife Conservation Order Amendment No. 12 of 201 8 Page 8 June 6, 2018
there was a baiting ban in Mecosta and Kent counties through an Interim Order of the Director that expired on March 29, 2018. The Department recommends instituting a baiting and feeding ban effective immediately for the 13-County CWD Management Zone defined as Clinton, Eaton, Gratiot, Ingham, Ionia, Isabella, Kent, Mecosta, Montcalm, Muskegon, Newaygo, Ottawa, and Shiawassee counties.
See above for the Issues Pros and Cons, Other States, Biological, Social, and Economic matters regarding baiting and feeding.
New Private Land License at a Reduced Cost; Expires First Sunday in November
snip...see full text 40 pages here;
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Subject: MICHIGAN FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEED VIOLATIONS OFFICIAL ACTION INDICATED OAI UPDATE BREACH APRIL 4, 2017
MICHIGAN FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEEDVIOLATIONS OFFICIAL ACTION INDICATED OAI UPDATE BREACH APRIL 4, 2017
FDA BSE/Ruminant Feed Inspections Firms Inventory
11998 DET-DO MI 48846-847 OPR 4/4/2017 OAI
http://www.accessdata.fda.gov/scripts/BSEInspect/bseinspections.csv
NAI = NO ACTION INDICATED
OAI = OFFICIAL ACTION INDICATED
VAI = VOLUNTARY ACTION INDICATED
RTS = REFERRED TO STATE
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...end...TSS
CWD National Perspective: Captive Herd Certification Program - Dr. Tracy Nichols
Michigan’s Chronic Wasting Disease Working Group Recommendations Report to the Natural Resources Commission Prepared December 2017 CWD Confirmed Cases holding for now at 57 cases
http://www.michigan.gov/emergingdiseases/0,4579,7-186-81018_25806-357110--,00.html
http://chronic-wasting-disease.blogspot.com/2018/01/michigans-chronic-wasting-disease.html
Deer Scents Banned Due To Cwd Transmission
From: Terry Singeltary <flounder9@verizon.net>
To: Tracy.A.Nichols <Tracy.A.Nichols@aphis.usda.gov>
Sent: Fri, Mar 30, 2018 12:51 pm
Subject: Docket No. APHIS-2018-0011 Chronic Wasting Disease Herd Certification Program Standards Singeltary Submission March 30, 2018
Docket No. APHIS-2018-0011 Chronic Wasting Disease Herd Certification Program Standards Singeltary Submission March 30, 2018
Greetings APHIS, USDA, Dr. Tracy Nichols, et al,
I wish to kindly submit my comments on the Docket No. APHIS-2018-0011 Chronic Wasting Disease Herd Certification Program Standards please. i have submitted online and sent a hard copy to Dr. Nichols via email. i know that my concern may not be the same concern as others, but ramifications from cwd tse prion can be long lasting, and science is still emerging. however, the science today warrants immediate and further actions be taken. my comments, with reference materials, are as follows, and will be formatted in such a way, i will address issues by numbers 1-10, and under each one of my comments by each number, i will reference my comments with science to back up what i am stating/asking...thank you kindly, terry
1. I believe that immediately, there should be a 'DECLARATION OF EXTRAORDINARY EMERGENCY FOR FOREIGN ANIMAL DISEASE OF THE United States of America USA' due to Chronic Wasting Disease CWD Transmissible Spongiform Encephalopathy TSE Prion disease. All Intercontinental, International, Interstate movements of cervid should be banned immediately from the USA, and documented CWD TSE Prion Countries. There was a 'DECLARATION OF EXTRAORDINARY EMERGENCY FOR FOREIGN ANIMAL DISEASE' declared in the USA way back On July 10, 2000, several sheep from the flock tested positive for a TSE, a class of degenerative neurological diseases that is characterized by a very long incubation period and a 100 percent mortality rate in infected sheep. Two of the better known varieties of TSE are scrapie in sheep and BSE in cattle. On July 14, 2000, USDA issued a declaration of extraordinary emergency to acquire the sheep. but those test were wrong, and a decade later after FOIA request after request, turns out those sheep from Belgium never had any TSE Prion disease. long story, but what is the difference here, especially since we are dealing with Chronic Wasting Disease CWD TSE Prion, and the fact now that not only has CWD been exported from North America to South Korea, and to Norway, but now Finland has confirmed it's first case of Chronic Wasting Disease CWD TSE Prion. So, where does the 'BUCK' stop? why has this 'DECLARATION OF EXTRAORDINARY EMERGENCY FOR FOREIGN ANIMAL DISEASE OF THE United States of America USA' due to Chronic Wasting Disease CWD Transmissible Spongiform Encephalopathy TSE Prion disease, not already been declared, and why has not a Intercontinental, International, Interstate movements of cervid BAN not already been put in place, especially since the recent findings of oral transmission studies with the Macaque, in relations with oral transmission of muscle meat with cwd, and oral transmission of cwd to the pig? do we just continue to truck, ship, or fly this CWD TSE Prion all around the globe, just to save the industry? see; August 15, 2000 OIG case # NY-3399-56 REDACTED, VT ''Enclosed is OIG's notification that they have scheduled an investigation of the following individual. REDACTED is alleged to have provided possibly inaccurate test results involving diseased sheep. However, because the results were determined to be inconclusive, no actual violation was actually committed.''
http://foiamadsheepmadrivervalley.blogspot.com/
2. Voluntary Chronic Wasting Disease Herd Certification Program should be made MANDATORY immediately, OR NO PERMIT TO FARM DEER OR ELK, PERIOD! you don't want to join, then fine, you don't farm cervid and or any product there from.
3. INDEMNITY, NO MORE Federal indemnity program, or what i call, ENTITLEMENT PROGRAM for game farm industry. NO MORE BAIL OUTS FROM TAX PAYERS. if the captive industry can't buy insurance to protect not only themselves, but also their customers, and especially the STATE, from Chronic Wasting Disease CWD TSE Prion or what some call mad deer disease and harm therefrom, IF they can't afford to buy that insurance that will cover all of it, then they DO NOT GET A PERMIT to have a game farm for anything. This CWD TSE Prion can/could/has caused property values to fall from some reports in some places. roll the dice, how much is a state willing to lose?
4. QUARANTINE OF ALL CAPTIVE, BREEDERS, URINE, ANTLER, VELVET, SPERM, OR ANY FACILITY that has been confirmed to have Chronic Wasting Disease CWD TSE Prion, the QUARANTINE should be for 21 years due to science showing what scrapie can do. 5 years is NOT enough. see; Infectious agent of sheep scrapie may persist in the environment for at least 16 years
Gudmundur Georgsson,1 Sigurdur Sigurdarson2 and Paul Brown3Correspondence Gudmundur Georgsson ggeorgs@hi.is1 Institute for Experimental Pathology, University of Iceland, Keldur v/vesturlandsveg, IS-112 Reykjavı´k, Iceland2 Laboratory of the Chief Veterinary Officer, Keldur, Iceland3 Bethesda, Maryland, USAReceived 7 March 2006Accepted 6 August 2006In 1978, a rigorous programme was implemented to stop the spread of, and subsequently eradicate, sheep scrapie in Iceland. Affected flocks were culled, premises were disinfected and, after 2–3 years, restocked with lambs from scrapie-free areas. Between 1978 and 2004, scrapie recurred on 33 farms. Nine of these recurrences occurred 14–21 years after culling, apparently as the result of environmental contamination, but outside entry could not always be absolutely excluded. Of special interest was one farm with a small, completely self-contained flock where scrapie recurred 18 years after culling, 2 years after some lambs had been housed in an old sheephouse that had never been disinfected. Epidemiological investigation established with near certitude that the disease had not been introduced from the outside and it is concluded that the agent may have persisted in the old sheep-house for at least 16 years.
http://www.microbiologyresearch.org/docserver/fulltext/jgv/87/12/3737.pdf?expires=1521907990&id=id&accname=guest&checksum=51DB085BD612A0603240F09E29D4AADD
Survival of Scrapie virus after 3 years interment
Paul Brown, D. Carleton Gajdusek
https://web.archive.org/web/20090505211734/http://www.bseinquiry.gov.uk/files/sc/Seac07/tab03.pdf
Back around 2000, 2001, or so, I was corresponding with officials abroad during the bse inquiry, passing info back and forth, and some officials from here inside USDA aphis FSIS et al. In fact helped me get into the USA 50 state emergency BSE conference call way back. That one was a doozy. But I always remember what “deep throat” I never knew who they were, but I never forgot;
Some unofficial information from a source on the inside looking out -
Confidential!!!!
As early as 1992-3 there had been long studies conducted on small pastures containing scrapie infected sheep at the sheep research station associated with the Neuropathogenesis Unit in Edinburgh, Scotland. Whether these are documented...I don't know. But personal recounts both heard and recorded in a daily journal indicate that leaving the pastures free and replacing the topsoil completely at least 2 feet of thickness each year for SEVEN years....and then when very clean (proven scrapie free) sheep were placed on these small pastures.... the new sheep also broke out with scrapie and passed it to offspring. I am not sure that TSE contaminated ground could ever be free of the agent!! A very frightening revelation!!!
---end personal email---end...tss
5. DESCRIBING APHIS' intent to amend the regulations to define susceptible species based on scientific evidence of natural infection or experimental infections through natural routes and adding the genera Rangifer and Muntiacus to the list of susceptible species...
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