In general I support the proposed rules. They recognize that this disease brucellosis in no longer the threat that it once was and have changed the regulations to be more cost effective and risk based. There are two specific comments I have. (1) APHIS is requesting information on the wildlife management plans in areas where diseased wildlife require that a management area or DSA be designated. It is important that APHIS request the state agencies managing this wildlife for this information. This will give the livestock industry leverage in getting this information from the fish and game departments from each state. This disease surveillance information is the basis for DSA and risk management actions. (2) It is not necessary to test females under 20 months of age in surveillance testing. If brucellosis is being eradicated from a herd, all females must be managed.
Thanks for the opportunity to comment and for updating rules that were outdated. It will allow us to manage this disease better from a economic and scientific prospective.
Comment from Jim Hagenbarth
This is comment on Rule
Revisions to Testing and Certification Requirements: Brucellosis Class Free States and Certified Brucellosis-Free Herds
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