The Texas Animal Health Commission (TAHC) has proposed several regulations that will impact cattle and horse owners in Texas.
The proposed rule for equine electronic passports is relatively minor but is poorly worded and could cause problems as a result. In Texas, horses that enter the state, are being sold, or are in public places are required to have proof of a negative Coggins test, which detects the presence of Equine Infectious Anemia antibodies. The intent of the proposed rule change is to officially recognize the growing use of electronic methods (microchips and digital photos) to serve as official proof of the Coggins test, a practice that is becoming more widespread. But the proposed rule could easily be interpreted as a requirement for electronic documentation in addition to the still widely used paper certificate, which contains a physical description of the horse.
The proposed rule on cattle is broader and more complicated, with significant implications. TAHC proposes to establish a “control program” for Bovine Viral Diarrhea Virus (BVDV). Anyone whose cattle tests positive for BVDV would have to submit those results to the agency as a “reportable disease.” Cattle that test positive would have to be officially identified and they would not be allowed to relocate except with a permit under specific conditions. Feedlots or sale barns that accept BVDV cattle would have to have special biosecurity measures.
BVDV is endemic and widespread in cattle across this country. It is a serious health issue, particularly since calves can become infected in utero and be “persistently infected” – appearing normal, but spreading the disease and often having costly health complications. While it is appropriate to take steps to try to stem the spread of the disease, some provisions of the TAHC’s proposed rule could actually undermine attempts to control the disease, as well as imposing undue burdens on producers.
Problem #1: What can be used for “official identification.” The proposed rule leaves the question of whether non-electronic ID would be allowed entirely to the agency’s discretion. Metal tags have a better retention rate than electronic tags, are less costly, and are preferred by many producers – but the agency is not including them in the definition of official ID. The imposition of electronic ID for cattle that are moving solely within our state is unwarranted and would impose unnecessary costs on producers who will already be dealing with losses from having an infected animal.
Problem #2: Which tests can be used to confirm whether an animal is infected. FARFA has spoken to a veterinarian who has experienced false positives on the standard test for BVDV as a result of vaccination – the antibodies generated in response to the vaccine made the cows appear to be infected. The PCR test is the best way to distinguish between a true infection and a vaccine response, but the TAHC’s proposed rule doesn’t include the PCR test as an option. If controlling the disease is truly the goal, then the agency should be supporting vaccination – not creating situations in which those who vaccinate could be penalized because of false positive tests.
Problem #3: Who was involved in the process. The TAHC does not have a process for individuals or groups to apply to be part of stakeholder groups that provide early input into rulemaking. Instead, the agency staff and commissioners simply identify who they think should be part of the process. For this rule, the agency’s stakeholder group included all of the usual industry groups, such as Texas Southwest Cattle Raisers Association & Texas Farm Bureau, but – as is typical – the agency did not include any groups representing sustainable or organic producers, such as FARFA or Texas Organic Farmers & Gardeners Association.
The agency is accepting public comments by email or fax until Monday, July 8th, at 5 pm.
If you are a cattle or horse owner, please submit comments about the proposed rules. Your comments can be very short and simple, but it’s important that they be personalized.
For cattle owners, some things to include if they apply to you:
- Do you vaccinate for BVDV?
- Do you use metal ear tags?
- Have you tried using electronic tags and had problems with retention or reading?
- Do you have any other concerns about making BVDV a reportable disease?
- Do you think that groups such as Texas & Southwestern Cattle Raisers or Farm Bureau represent your interests during TAHC discussions? If not, then urge the agency to include groups that do.
For horse owners: it can be as simple as stating that you want to retain the option to identify your horse by physical-description-only on its Coggins forms.
Submit your comments:
Below is the key provision (the newly proposed language is underlined, with bolding added to emphasize the source of the potential confusion):
(c) Official Identification of Equine Tested for EIA. All official blood tests must be accompanied by a completed VS Form 10-11 (Equine Infectious Anemia Laboratory Test) listing the description of the equine to include the following: age, breed, color, sex, animal’s name, and all distinctive markings (i.e., color patterns, brands, tattoos, scars, or blemishes) and unique and permanent forms of identification, such as electronic identification that complies with ISO 11784/11785; or non-ISO electronic identification injected in the equine on or before March 11, 2014; or digital photographs sufficient to identify the individual equine. In the absence of any distinctive color markings or any form of visible permanent identification (brands, tattoos or scars), the animal must be identified by indicating the location of all hair whorls, vortices or cowlicks with an “X” on the illustration provided on the VS Form 10-11. It must list owner’s name, address, the animal’s home premise and county, the name and address of the authorized individual collecting the test sample, and laboratory and individual conducting the test. The EIA test document shall list one horse only.