Comment from Anthony Kettle

The proposed CEM Rule changes should serve to strengthen the confidence the USA has in the importation of horses from CEM affected regions as not being affected by the CEM organism however I would question the exemption of weanlings and yearlings that have not been bred. There is certainly annecdotal if not scientific evidence of non-venereal transmission if we review reports from the UK and submissions to the OIE, so to restrict testing only to horses that have been bred, may be a weakness. Similarly the USA experience of horses present in the US, that were imported for many years without showing any evidence of infection, may lead one to question the current policy of requiring horses to be present for 12 months in a non CEM affected country before being permited to be imported on a non CEM certificate. Similarly as commented elsewhere, recently gelded horses may still be a risk as I am not aware of any data on clearance rates of the organism following castration. There are practical matters to consider in the requirement for 3 sets of swabs to be taken from imported stallions prior to test breeding, and doubts exist as to whether there is any additional increase in the sensitivity of the testing. As it takes at least 7 days before a culture result can be obtained, effectively all 3 sets of swabs will have been taken prior to the test breeding so the taking of the 3rd set is immaterial to the pre-breeding. I would suggest the same argument applies to the second set and that a single sample should be all that is required prior to the test breeding.