When the CWD rules first came out one of the most important parts of the monitoring program was the requirement to test all
animals that die or are killed on a monitored farm. The key word here is “all”. We were told early on that if an animal died and was
not discovered until it was too decomposed to obtain a viable sample that we should have our veterinarians write a letter to that
effect to DATCP.
Unfortunately some farms were not testing any animals and claiming that they were all too decomposed to obtain a sample. This
prompted new action by DATCP and I will try to explain it in language everyone can understand.
First and foremost we still must test all animals that die or are killed on our farms. Now however, there can be very serious
consequences if tests are not done. These consequences can include the revocation of your CWD status which would prohibit
you from moving live animals off your farm.
What is the 8% rule? DATCP recognizes that there are going to be animals that are not found in time to take a viable sample.
The 8% rule states that the number of untested animals cannot exceed 8% of the number of testable animals over a 12 month
period. Example; It will require us to test 12 animals for every one animal that is not found in time to sample. Testable animals
include all animals that die or are killed on a monitored farm as well as all animals that escape and are not recovered. Another
example; A farm has no deaths in the 12 month period but has an escape. That would be a violation of the 8% rule because there
were not 12 good tests to offset it.
How will the sanctions be applied? After the first violation you will receive a warning letter. Several farms have already received
them. If you have a second violation within 5 years your CWD status will be revoked. These are very serious consequences for
violations that we often have no control over. We have informed DATCP that we feel these sanctions are excessive and
expressed a need to come up with a way to prevent a farm from losing its CWD status if tests are missed in violation of the 8 %
rule.
DATCP has been somewhat receptive to some of our suggestions. We are hopeful that we can come up with acceptable way to
avoid loss of status. The key is going to be in keeping the number of untested animals at less than 8% of the total number of
testable animals. That means getting credit for as many tests as we can so that if an animal is missed it won’t add up to 8 %.
Hunting ranches tests high numbers of animals that have come from other farms. If an animal tests positive for CWD, DATCP will
surely come back to the farm that produced that animal. We feel that the producer farm should also get credit for a negative test
in that situation. DATCP does not disagree with us.
Remember it takes 12 successful tests to offset one that is missed. We may be able to cull sufficient animals for testing to nullify
the sanctions of the 8% rule and thereby allow the farm to save its status. For now, check your pens frequently for sick or dying
animals. We cannot afford to miss a test. If you sell deer to hunting ranches ask them to forward a copy of the test result when
that animal is harvested. Match it up with a copy of the health certificate that you should retain when you ship any animal. Keep
these in your files. They could save your CWD status.
The sanctions imposed for violating the 8% rule can put us out of business. We are taking this very seriously and will continue
to meet with DATCP until we can come up with alternatives.
Bill Vyvyan