Docket No. APHIS—2007—0127
Scrapie in Sheep and Goats
9 CFR Parts 54 and 79
The following comments are made on behalf of the American Association of Small Ruminant Practitioners (AASRP) which was founded in 1968 to further the programs and studies of those working with small ruminants-sheep, goats, camelids, elk, deer and other related species. Our membership stands at over 1,000 members in the United States and abroad. AASRP's primary goals are to work in cooperation with regulatory agencies, to further the professional development of members and to provide resources to elevate the standards of small ruminant issues.
AASRP has supported the eradication of scrapie from the U.S. and appreciates the hard work of APHIS, state animal health officials, markets, producers and veterinarians towards eradication. We appreciate the flexibility in traceability that the proposed amendments provide which allows veterinarians to work with numerous challenging situations.
We offer the following specific comments for consideration:
Sheep and Goat Identification
- 1. The success of the sheep scrapie program occurred because the tags were utilized by producers for a variety of management purposes. We believe that the producer should be able to choose tag placement (right or left ear), location on the ear, and type of tag (metal, plastic or RFID). We request APHIS continue to maintain funding to support scrapie tags for sheep and goat producers. APHIS can recommend a preferred ear and location but should not require a specific site for tag placement. It may be necessary to place a tag in a non-recommended ear because the recommended ear can no longer properly retain an ear tag (i.e. torn ear). APHIS must encourage an increase in acceptance and use of scrapie tags in goats.
2. Livestock auction markets should be allowed to continue to apply official ID on unidentified animals at the tagging site. It is important to maintain the current tagging regulations for the salebarns/markets. Non-flock official tag information should be maintained in an APHIS database for traceability.
3. Veterinarians should be able to order and use official scrapie tags for use in regulatory testing, Certificates of Veterinary Inspection (CVI), or any other reason requiring official identification. APHIS should maintain this traceability information in a user-friendly database.
4. County 4-H sheep and goat offices should be assigned official Scrapie tags. It is preferred that lambs and kids have farm of origin scrapie tags. For the lambs and kids which do not have farm of origin scrapie tags, 4-H can apply their assigned tags. This identification teaches the youth about the scrapie program and traceability.
5. Dealers with multiple sources should have their sheep and/or goats officially identified before unloading at a livestock market. However, livestock markets and other points of concentration should be allowed to identify sheep/goats as tagging sites if they choose. Dealers and other multiple source consignors must provide the traceability information needed at the tagging site.
6. We recommend that APHIS encourage and collaborate with the Agriculture Research Service (ARS) to research scrapie diagnostic tests in live goats and scrapie control methods specific to goats. ARS should continue to research genetic resistance and susceptibility in goats.
Consistent State Standards
7. APHIS should help states ensure Consistent State status by promoting RSSS collection (Regulatory Scrapie Slaughter Surveillance) for interstate testing, especially for those states not able to do adequate surveillance testing. APHIS VS or State employees should actively select and test older goats in poor condition for RSSS.
Part III under Ear Tag Placement
• We believe that the producer should be able to choose tag placement (right or left ear), location on the ear, and type of tag (metal, plastic or RFID).
8. APHIS should increase access to educational resources for goat producers and veterinarians. These resources should be goat specific and not the current sheep brochure. APHIS should encourage on-farm submissions for scrapie surveillance and adequate records by producers for possible traceback.
AASRP appreciates the opportunity to review and comment on the proposed rule to amend the regulations in 9 CFR Parts 54 and 79. AASRP will work with APHIS to educate small ruminant veterinarians on the changes to the National Scrapie Eradication Program and to finally eradicate scrapie from the U.S.
Patty Scharko, DVM, MPH, DACVPM