State Effort Needed to Reach Scrapie Eradication Goal
March 31, 2005
Many States Still Have Not Met all Requirements to Maintain Consistent State Status
By Emily Tescher-Johnston
March/April 2005 -- All individual states across America have a vital role in the eradication of scrapie. The eradication of scrapie is dependent on the ability to trace positive animals from slaughter back to the farm were they were born, and to trace exposed animals from infected flocks to the flocks in which they currently reside. This can best be accomplished by requiring sheep and goats to be identified when they first leave the farm. The authority to do this resides with the States.
A federal regulation, published in August 2001, required each state in the Union to develop and maintain an effective, scrapie-control program, including identification on change of ownership in order to move sheep or goats with minimal restrictions to other states. States that met most of the federal standards for scrapie programs obtained Consistent State status at that time. The states were given additional time to develop the laws and/or regulations needed to fully implement effective scrapie programs, including the requirement for identification on change of ownership.
In the past three and a half years, most states have taken steps toward maintaining their Consistent State status, but only about a third of the states have enacted the required regulations.
As of March 3, 2005, 19 states (Arkansas, Alabama, Arizona, California, Florida, Georgia, Iowa, Idaho, Illinois, Michigan, Nebraska, New Jersey, Nevada, Ohio, Oregon, Texas, Virginia, Washington and Wisconsin) had the required regulations in place and 28 states had submitted work plans and specific timelines for getting the regulations in place. The other three states had not submitted complete work plans with specific timelines to the U.S. Department of Agriculture (USDA).
"Basically more than half of the states have not done everything they need to do, to reach Consistent State status," says Diane Sutton, the National Scrapie Program coordinator, for the USDA, Animal and Plant Health Inspection Service (APHIS), Veterinary Services.
Obtaining Consistent State status is an important link in the chain of steps taken toward scrapie eradication.
Sutton says, "The only way we can effectively eradicate scrapie is by having all the states reach this status, and have an active scrapie program which includes the identification of sheep and goats in intrastate commerce, so they can be traced back if necessary."
The guidelines for achieving Consistent State status are defined in Title 9 of the Code of Federal Regulations (CFR). Most notably, the CFR requires each state to promulgate a regulation requiring the official identification of most sexually intact sheep and goats upon change of ownership.
According to Sutton, the main stumbling block for the non-compliant states is implementing an identification and change of ownership rule. She explains there are different processes in each state for making regulatory change.
"Some states have very broad animal health authority, others have more limited authority, so it varies from state-to-state as to whether requiring identification on change of ownership needs to be a regulation or a law -- and some may need both."
Those responsible for leading the process to achieve Consistent State status in each state -- the state veterinarian and the USDA/APHIS area veterinarian in charge -- are familiar with their own state's regulatory process and will be able to guide their state in reaching Consistent State Status if the proper steps are taken. But the states are running out of time.
Back in August 2001, all states were given two years in which to complete Consistent State status. A grace period was added to the deadline.
"But now the grace period is coming to an end," says Sutton. "States have just one legislative cycle left to implement their program and achieve Consistent State status."
She adds, "If they by-pass the timeframe and fail to do this, that will be it."
Producers Burdened If State Fails
If a state does not meet Consistent State status requirements, then the burden falls to the producers. Individual producers who wish to move sheep over state lines in a non-compliant state will be required to enroll in the Scrapie Flock Certification Program. The producer's flock will have to be inspected annually by USDA or state personnel, the producer will be required to implement a record keeping system and keep more comprehensive animal identification records.
Sutton notes that producers in a non-compliant state may face time delays in moving sheep out of the state. USDA and state animal health departments will need to allocate staff, time and budget to inspect individual flocks.
"There are only so many flocks that will be able to be inspected per month," says Sutton.
There are further restrictions, as indicated in the CFR, if a state fails to reach Consistent State status. Those restrictions are: Low risk and low risk commercial breeding goats will need official identification and a Certificate of Veterinary Inspection (CVI). Sexually intact slaughter sheep under 18 months not moving directly to a terminal feedlot or slaughter will need official identification. Sexually intact slaughter sheep over 18 months will need a CVI in addition to official identification. And, animals moving for grazing must have official premises identification and CVI.
Jim Logan, DVM., health committee chairman for the American Sheep Industry Association (ASI), encourages producers to call their state veterinarian and USDA/APHIS area veterinarian to check where their particular state is in the Consistent State status process.
"Ask the state vet where they are in the process," says Logan. "He or she will know what has to be accomplished before the state reaches Consistent State status."
Logan explains that some states need statutory changes in order to finalize the Consistent State status process and that means legislative action.
"If the legislators don't see the need for achieving Consistent State status, then the state veterinarian will have a difficult time getting things done," Logan says.
Paul Rodgers, deputy director of policy for ASI agrees. "Sheep producers need to be in contact with state veterinarians, livestock boards and maybe even their legislature and let it be known that Consistent State status is something the industry needs to accomplish in a timely matter."
Rodgers emphasizes the importance of every state reaching Consistent State status.
"If the regulations didn't require the states to meet minimum standards, we would never achieve complete eradication. Each state should be allowed to achieve Consistent State status in a manner that is tailored to their own legal and industry circumstances so long as they meet the baseline requirements in the federal regulation," concludes Rogers.