MSGA’s Brucellosis and Bovine Tuberculosis Comments – Update of General provisions

MSGA’s Brucellosis and Bovine Tuberculosis Comments – Update of General provisions

May 16, 2016

Docket Clerk, USDA-APHIS

Docket No. APHIS-2011-0044

Regulatory Analysis and Development

PPD, APHIS, Station 3A-03.8

4700 River Road Unit 118

Riverdale, Maryland  20737-1238

RE: Docket No. APHIS-2011-0044, Brucellosis and Bovine Tuberculosis:  Update of General Provisions

The Montana Stockgrowers Association (MSGA) appreciates the opportunity to comment on the proposed rule to update the general provision of the Brucellosis and Bovine Tuberculosis programs.  Since 1884 MSGA has been the voice of Montana’s cattle ranching sector and today we represent nearly 2,000 members.   MSGA has been engaged in efforts to eliminate and mitigate the threat of Brucella abortus to the livestock industry in Montana for many years.

MSGA does generally support the continued effort to review current regulatory mechanisms and propose changes to these programs that allow for additional flexibility and adaptability that ultimately improve the effectiveness of these two programs.  In reviewing the rule, MSGA agrees with the comments submitted by the Montana Department of Livestock and the National Cattlemen’s Beef Association and shares many of the same recommendations for changes to the proposed rule.

As stated previously, MSGA is supportive of reviewing the current rules, but opposes USDA-APHIS finalizing the proposed rule until the identified problems, concerns, and program shortfalls can be adequately addressed.

Currently, Montana is under extensive regulatory surveillance orders that are costly and burdensome to both APHIS and the state of Montana. These orders are also extremely burdensome to the ranching sector due to increased testing costs and decreased market value of cattle. MSGA feels strongly that in order to move forward in making positive changes to these programs, sustained efforts toward the ultimate eradication of brucellosis and bovine tuberculosis from the United States is critical.   There has been significant progress to eradicate these diseases from the U.S., but there continues to be a reservoir of brucellosis in the Greater Yellowstone Area that impacts both wildlife populations and livestock populations in this area.  It now appears that eradication of these two diseases is no longer a primary focus of the proposed rule.  The change in the definition from free status (zero prevalence) to consistent status (no reference to prevalence) and asserting that the eradication programs based on achieving zero prevalence is no longer feasible due to wildlife reservoirs is utilized to support the USDA change in program focus from eradication to control.  MSGA’s recommendation is for to USDA to prioritize the long-term eradication goal for these two diseases.  Without this effort, we are concerned that particularly brucellosis could perpetuate in the wildlife in the GYA significantly affecting Montana.

MSGA does agree with the MT Department of Livestock and National Cattlemen’s Beef Association DOL agrees that regulation changes are necessary for both the TB and brucellosis programs, but combining these revisions under one rule is unnecessarily complex.    MSGA’s recommendation is maintain these programs separately, due to the differences in disease management and USDA’s regulatory approach.

As APHIS moves forward to finalize the rule, MSGA recommends the following actions or revisions to the proposed rule:

• Prioritize the goal of the proposed rule to include eradication of TB and brucellosis.
• Revise the structure of the program standards to separate out these two diseases in order to allow for increase clarity and to facilitate future implementation.
• Support collaborative efforts to facilitate research to close knowledge gaps for these two diseases.
• Better address the roles/responsibilities of State wildlife authorities in working with livestock health issues in recognized management areas.
• Reconsider the allowance of accredited free herds to exist in recognized management areas.
• Develop timely and achievable epidemiological reporting for disease traceability timelines.
• Consider breaking out State status by program species and disease.
• Engage in stakeholder discussions to determine the most appropriate way to meet the agency’s obligation for indemnity payments under the Animal Health Protection Act.
• Facilitate laboratory support to States/Tribes to meet the needs of enhanced surveillance initiatives in the AHPs.
• Establish an expert stakeholder advisory group to assist in program development, provide needed transparency, and facilitate successful future implementation of the proposed rule.
• Need to increase the direct involvement of the state animal health officials to direct epidemiological investigations in their state.
• The rule needs to recognize the epidemiology of brucellosis in the rule, which includes seasonality, and low transmission of disease from bulls.
• The rule needs to recognize and reflect the RB 51 vaccine doesn’t cross react with diagnostic testing.
• Proposed rule requires a buffer zone for livestock testing and an annual test. This would require a dramatic increase in costs in Montana, where we have demonstrated the ability to conduct the needed wildlife and cattle disease surveillance.

MSGA appreciates the opportunity to provide our comments on the proposed rule to update the general provision of the Brucellosis and Bovine Tuberculosis programs.  Due to the significant impacts these diseases have on animal health and our state, MSGA recommends APHIS to give careful consideration to these comments.

Sincerely,

Errol Rice

Executive Vice President

Montana Stockgrowers Association