Comment from Rusty Ford

1) We believe USDA adopting and implementing program recommendations made by the 2007 CEM Review Committee will provide needed enhancement and strengthen the defense prohibiting introduction of a CEM causing organism. 2) We agree mares imported from CEM Affected Countries should be tested for CEM by Complement-Fixation. Our opinion is the testing should be completed at the time of importation and prior to release from the AIC, so long as the testing wouldn’t routinely extend the 42hr Post Arrival Quarantine. 3) We disagree with the change requiring imported stallions be routinely cultured 3 times (2 of the sets being pre-breeding). This change to the rule is not supported by the findings or conclusions of either the 2003 or 2007 program review. Members of the 2003 review committee gave consideration to recommending multiple stallion cultures but after failing to identify benefit abandoned the idea. The 2007 program reviewers ultimately concluded a single negative prebreeding culture (when properly collected, submitted and tested) was sufficient and that additional prebreeding swabbing would needlessly increase costs and lengthen the quarantine period. We recognize collecting a single set of swabs from the stallion post breeding could be advantageous in detecting infected stallions that were treated just prior to exportation, but do not believe there to be need or justification in delaying post breeding stallion treatments until after the final set of cultures is reported negative. 4) We believe recommendations made by the 2007 review panel to establish minimal standards of oversight of the program and quarantine facilities should be adopted by either rule or directive. 5) We believe stallions castrated just prior to importation, do present risk of introducing the disease causing organism and that consideration be given to including in the rule that 'recently' castrated horses be cultured and/or treated.