Comment from thomas holt. d.v.m.

Document ID: APHIS-2008-0112-0005
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: April 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: April 19 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: March 25 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: May 24 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c2f829
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In reviewing the proposed changes, Florida agrees with all the changes with the possible exception of requiring three sets of cultures from the stallion. We also agree with adding the distal urethra as an additional culture site but am not sure we know how much the two additional sets of cultures will increase our sensitivity in detecting the CEM organism prior to breeding of the test mares. From the experience and information we have we are doubtful that the organism will be detected even with the additional testing and think that most experts would agree that the breeding of the test mares is the gold standard for detection of the CEM organism. We believe the thought in requiring the additional sets of cultures is to hopefully increase the sensitivity of the CEM testing and to detect the organism on the stallion prior to exposing two test mares. The only real negative effect of the additional stallion culturing requirement is the additional time and expense required when the stallion enter CEM quarantine. In addition we would like the CF test, being required on imported mares, to be performed at the import centers, consistent with current import testing protocols. Overall, we are pleased with the changes.

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