Comment from Thomas Holt

Comments: Docket No. APHIS 2009-0073 Bovine Tuberculosis Program Concept Paper Over the last 30 years, the United States has suffered severe setbacks in the bovine tuberculosis (TB) program nationally. The failure to control TB in Michigan whitetail deer and its continued spread into cattle herds, despite millions of dollars of federal and state of program costs, and the exposure of breeding cattle to Mexican imported feeder cattle that have spread Mexican strains of bovine tuberculosis to many states have contributed to significant setbacks in the tuberculosis eradication efforts. Down to one infected herd in the early 1980s, we now are finding multiple herds in numerous states and facing greater spread of the disease throughout the United States. The current trace-outs from a single large infected dairy herd in Texas now involve over 21 states. Just this week, Florida, free of bovine TB since 1989, was informed of the movement of 123 cattle from this herd that has resulted in the quarantine of over 5,000 animals. Determining the true status of this herd will take weeks, if not months, at considerable expense to the owner and the State of Florida. Should this herd be found to be infected, it will take months, if not years, to clean up without federal indemnity funds to depopulate infected and exposed animals. It is clear that changes to the state federal eradication program must be made. The huge size of dairy herds in particular in the United States has overwhelmed funding available at the state and federal levels to allow for depopulation. In addition, the punitive effects on marketing animals through channels that involve multiple states are so great on states that lose their free status that they seriously jeopardize the industries themselves. We support the suspension of an automatic loss of status for a state finding two or more infected herds within one year. A case-by-base assessment of each infected herd should be taken under consideration. Assessments should include the level of infection, steps taken to ensure quarantine compliance, movements out of that herd, and the probability of further spread within the state, and levels of surveillance throughout the state. With our support for the risk-based approach utilizing zones instead of whole state status to determine testing and movement requirements, we also believe that such measures need to be taken through clear and consistently applied standards. While the current UM&R restrictions are no longer workable on a whole state basis, a change to risk evaluation can only succeed through standardized measures and transparency to state and federal animal health officials and to the industries we serve. The following specific comments are made in response to the concept paper: ? It is critically important to allow for some flexibility in managing infected herds. While depopulation may not be possible because of a lack of funds, wise use of funding to depopulate high-risk animals or groups of animals will be especially important in eradicating disease in herds through a test and slaughter program. ? We must address the importation of Mexican feeder animals with strict controls to ensure that all of these animals and any contact animals are moved only to slaughter. If this cannot be enforced, the import of Mexican animals needs to be prohibited at least until the United States brings our disease spread under control. ? Development of, and validation of, a blood test for TB is critical to controlling this disease. With the increased movement of animals, larger herds, and establishment of tuberculosis in wildlife populations, we must obtain better surveillance and the skin test utilized over the last 100 years continues to be a poor and unreliable test to detect infection in individual animals. ? Identification and record-keeping of cattle in commerce is a basic component for any disease control and eradication effort. USDA must take the lead in setting out mandatory standards and systems to allow for identification and the integration of records to track diseases and exposed animals. Finally, we would comment on the first responsibility listed in the position paper under state animal health official’s responsibilities which is stated as “Revising state regulations where necessary to be consistent with federal regulations.” The first responsibility state animal health officials have with respect to bovine tuberculosis is to take measures to prevent the introduction of disease into our states, to work toward identifying any tuberculosis present in our state, and to take appropriate measures to control and eradicate this disease. If revising our rules to be consistent with federal regulations helps us in that regard, we certainly need to do this. Unfortunately, the status of bovine tuberculosis nationally and the current efforts to control the disease have forced many states to adopt rules that go beyond the federal regulations to protect their industries. As bovine tuberculosis continues to spread and represents more of a risk, we can expect tighter controls to be put in place by states, and in this respect, federal regulations and program changes will need to be implemented to provide greater assurance and confidence that animals moving interstate are free of bovine tuberculosis. Thomas J. Holt, D.V.M. State Veterinarian/Director Division of Animal Industry Florida Department of Agriculture and Consumer Services