Comment from John R Irby, Florida Department of Agriculture & Consumer Services

I am the veterinarian manager for Florida?s Captive Cervidae Program. I have several concerns that I offer for your consideration. 1. ? 81.1(3) Many of our captive cervidae herds have an NAIS Premise ID. Will this be the premise identification number (PIN) listed in the CWD National Database? 2. ? 81.2 Assuming that the animal has an official USDA metal ear tag, issued to Florida by the APHIS Warehouse in Kansas City, how will the number be linked to the animal in the CWD National Database? 3. ? 81.2 Is there a more descriptive definition as to what is acceptable as the second form of animal identification and how will this number be linked in the CWD National Database? 4. In order to reduce this risk relative to testing for tuberculosis herd accreditation status, 9 CFR Part 77 was amended through Executive Order 12866 and Regulatory Flexibility Act to reduce the number of consecutive tests required to achieve herd status and increased the testing interval for re-accreditation from 2 years to 3 years. As explained in Federal Register/ Vol. 71, No. 81/ Thursday, April 27, 2006, this rule ?will reduce testing costs for herd owners, lessen the potential for animal injury or death during testing?. Clearly, to achieve CWD Herd Status, the owner will be placing his animals at risk of significant stress and injury due to restraint. I am concerned that there is significant inconsistency regarding consideration of risk to the animal between two rules in the CFR which deal with captive cervidae.