Comment from Mark Achenbach

Document ID: APHIS-2012-0087-0002
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: February 05 2013, at 02:56 PM Eastern Standard Time
Date Posted: February 13 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: January 9 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: March 11 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-83ij-mkq7
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The CervidTB STAT-PAK assay detects IGG and IGM antibodies in blood. This testing uses Mycobacterium antigens to produce a antigen/ antibody reaction that is specific for Mycobacterium Bovis and Tuberculosis. The testing can only be done at the National Veterinary Services Laboratory currently only with permission from your area Veterinarian in charge (AVIC) in your state prior to samples shipment. This antigen antibody methodology has been in use in clinical laboratories for decades now, it is highly specific with low rates of cross reactivity. Unless there is documented clinical research that proves that there is a species dependant Mycobacterium antibody variation in cervids this test should be usable in any cervid species. Additionally any positive reactors will require confirmation with a secondary test the DPP serological test using serum from the same sample. So technically any cervid tested positive using the CervidTB STAT-PAK assay will have confirmatory testing done by a method of greater specificity. A positive result from both tests will result in a epidemiological investigation being done and the disposition of the animal will be determined by and regional TB epidemiologists. The rational that this test should only be performed on cervid species that have been currently evaluated negates an opportunity for USDA and APHIS to obtain specimens and data from some of the minor species that they did not evaluate. The study only evaluated a small sampling of cervid less than 2,000 from Elk, Whitetail Reindeer the APHIS STAT-PAK ppt. presentation does not list Fallow deer as being tested yet they are listed. So Sika deer (a elk sub species) and other minor species should not in my opinion be excluded from this test. Respectfully Mark Achenbach MLT, ASCP, HEW Sika Deer Producer.

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Total: 11
Comment from Roberta Cahill
Public Submission    Posted: 02/13/2013     ID: APHIS-2012-0087-0003

Mar 11,2013 11:59 PM ET
Comment from Mark Achenbach
Public Submission    Posted: 02/13/2013     ID: APHIS-2012-0087-0002

Mar 11,2013 11:59 PM ET
Comment from Elizabeth Curry-Galvin
Public Submission    Posted: 03/04/2013     ID: APHIS-2012-0087-0004

Mar 11,2013 11:59 PM ET
Comment from Ray Hanson
Public Submission    Posted: 03/11/2013     ID: APHIS-2012-0087-0010

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Comment from John Cain
Public Submission    Posted: 03/12/2013     ID: APHIS-2012-0087-0011

Mar 11,2013 11:59 PM ET