|Take the 8% Rule Seriously!|
by Bill Vyvyan
Date Posted: 01-01-2010
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.