The Texas Animal Health Commission is reviewing the agency’s rules governing equines, 4 Tex. Admin Code Chapter 49. You can see the text of the rules online at http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=4&pt=2&ch=49&rl=Y

We recommend that everyone with horses read the regulations and send in comments on any issue of concern to them. The comment period ends on September 25.

Of particular concern is the provision that, if a horse at a sales barn does not have the proper Coggins papers, it can only be sold for slaughter: “Any equine sold, through a market, which has not had a negative EIA test in thtwelve months preceding the date of sale must be permitted for movement … to slaughter.” This provision applies even if testing would show that the horse is negative for Equine Infectious Anemia (EIA)! While Coggins testing may be a good means for reducing the occurrence of EIA in horses, the requirement that untested horses be slaughtered does not improve animal health.

The TAHC’s notice of the rule review indicates that the TAHC is starting with the assumption that the rules should remain as they are. So making any change will be difficult. But if we want to reduce unnecessary government regulations, we have to start speaking up with the consistent message: government regulations that impose burdens on individuals and do not improve animal or human health should be abolished. Even if the agency does not act on the comments at this time, the fact that people are paying attention and demanding that the agency make better decisions will make a difference in the long run.
A sample letter is provided below. Please personalize your comments and provide your own arguments and facts in support.

As many horse owners know, HR 503 just passed in the House of Representatives, forbidding horse slaughter for human consumption. If it passes the U.S. Senate, it will obviously impact this issue. But since we do not know if or when the Senate will adopt HR 503, this issue should still be addressed by the TAHC.

Comments can be sent to Delores Holubec, P.O. Box 12966, Austin, Texas 78711-2966. They may also be sent by facsimile to (512) 719-0721 or by e-mail to comments@tahc.state.tx.us. Comments must be submitted by 5 pm on Monday, September 25.

Working together, we can make our voices heard.

Judith McGeary
Executive Director
Farm and Ranch Freedom Alliance
8308 Sassman Rd
Austin, Texas 78747
(512) 243-9404
(866) 687-6452 ol Free
www.farmandranchfreedom.org

Sample letter – Use this letter to help you with ideas for your own, personalized comments.

Delores Holubec
PO Box 12966
Austin,TX 78711-2966
Fax: 512-719-0721

Dear Commissioners:

I am writing to ask that you repeal §49.1(m) of Title 4 of the Texas Administrative Code.

This regulation provides that horses sold at a market without current Coggins papers can only be sold for slaughter. This provision applies even if the horse is healthy and, if tested, would test negative. While Coggins testing is a useful tool for addressing Equine Infectious Anemia in horses, the requirement that untested horses be slaughtered does not have a valid health reason. Moreover, by limiting who can purchase the horse, the regulation reduces the options for both sellers and buyers.

In FY2004, the USDAreprted that only 333 horses tested positive for EIA nationwide. The rate of positive tests was .017% (http://www.aphis.usda.gov/vs/nahps/equine/eia/images/percent_positive.jpg), meaning that fewer than 2 out of every 10,000 horses tested positive. Healthy animals should not be killed simply because of a bureaucratic requirement. There is no reason to think that the slaughter of untested animals contributes in any way to the reduction of EIA in horses.

The regulation allows the untested horses to be held for up to 10 days before slaughter. That same 10-day window could be used to test the horse and determine whether or not it has EIA, instead of mandating its sale to a kill buyer. The rare horse that has EIA will quickly be detected through the testing, and can be handled under the regulatory provisions for reactors. The vast majority of horses, who would test negative for EIA, ouldbe sold to regular buyers and continue to have productive, useful lives.

The state pays for Coggins tests at the slaughterhouses. What is the animal health reason for this use of our tax dollars? This is not about being for or against horse slaughter. Rather, it is an issue of whether animals should be condemned to slaughter simply because they have not been tested, only to then be tested at taxpayer expense at the slaughterhouse.

This regulation does not reduce the spread of EIA, interferes with the free market, and uses taxpayer dollars to benefit the slaughter buyers. I therefore ask that you propose a repeal of §49.1(m).

Sincerely,

Name
City, Texas