October 19, 2004

 

Regulatory Analysis and Development

PPD, APHIS Station 3C71

4700 River Road, Unit 118

Riverdale, MD

20737-1238

 

Re: Docket No. 00-094-1

“Interstate Movement of Sheep and Goats; Approved Livestock Facilities, Identification and Recordkeeping Requirements”

 

We are commenting on behalf of the American Sheep Industry Association, Inc. (ASI).  ASI is the national trade association for America’s sheep producers representing 41 state organizations, as well as other allied members and affiliated groups.  We appreciate the opportunity to comment on this proposed rule.

 

ASI is on record supporting an aggressive and expeditious approach to eradicating scrapie. The livestock-marketing sector is a very important part of the U.S. sheep industry and, as has been the case with other animal disease eradication programs; this sector is playing a vital role in the scrapie eradication program.  Animal identification and recordkeeping throughout the marketing continuum for purposes of tracing animals is the key element in the program.  It is also very important that scrapie-infected, suspect, exposed and high-risk animals are handled separately and appropriately at assembly points and that the risk of exposure to healthy animals be minimized.  We believe that it is important to establish standards for marketing and handling facilities, including approval by APHIS for facilities that handle sheep in interstate commerce in order to accomplish scrapie eradication in a timely fashion. We, therefore, believe that it is appropriate to amend the regulations in 9 CFR, I, C part 71 to include sheep and goats along with cattle, swine, bison and horses as is being proposed.

 

With regards to the definitions of “scrapie exposed” and “scrapie high-risk”, we believe that a change is warranted.  This is particularly true in regard to the proposal in the docket to require certain breeding sheep to be quarantined. The definitions of exposed animal and high-risk animal in 9 CFR 79.1 as referenced in this proposal do not, based on current science, properly define the animals that pose a true risk for the spread of scrapie.  Sheep that have been tested and determined to be genetically resistant to scrapie pose a minimal risk of transmitting the disease.  These sheep should not be considered as high-risk and therefore should not be required to be segregated or quarantined at assembly points. Likewise the current definitions exclude some animals that could pose a risk, such as genetically susceptible animals that have resided on infected premises. We urge APHIS to redefine exposed animal and high-risk animal as follows and then to require the segregation or quarantine of only high-risk animals:

 

Scrapie exposed animal:

An animal that resided in a flock or in a pen (including outside the flock) with a scrapie-positive female animal.  Any animal that resided in a scrapie-infected or source flock after the infected animals were removed but before a scrapie flock management plan was completed (unless it is determined that an animal in question resided in the flock only before the flock became infected).  Scrapie-exposed animals could then be further defined as: genetically scrapie-resistant exposed animals and genetically scrapie-susceptible exposed animals.

 

Scrapie high-risk animal:

A genetically susceptible exposed female animal and the female offspring of a scrapie-infected female.  (It is understood that in unexpected or unusual circumstances and through concurrence of both the State Veterinarian and APHIS, additional scrapie-exposed female animals could be designated as high-risk.)


The preceding definitions are essentially those being used in the UM&R and the use of them here would reduce the potential number of animals that would need to be segregated or quarantined at assembly points.  The use of these definitions would also result in the segregation or quarantine of those animals with any significant risk of either transmitting scrapie to another animal or contaminating premises.

 

We appreciate the opportunity to comment on this proposed rule and we urge APHIS to move forward expeditiously to implement science-based enhancements and changes to the regulations regarding scrapie eradication and aggressively enforce them.

 

Sincerely,

 

Guy Flora

President