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From: TSS ()
Subject: A Risk-based Audit of the Captive/Privately-owned Cervid Industry in Michigan
Date: April 2, 2005 at 7:14 pm PST

-------- Original Message --------
Subject: A Risk-based Audit of the Captive/Privately-owned Cervid Industry in Michigan
Date: Fri, 1 Apr 2005 15:48:08 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy

##################### Bovine Spongiform Encephalopathy #####################

A Risk-based Audit of the Captive/Privatelyowned
Cervid Industry in Michigan
Michigan Department of Natural Resources Report Series
Issue Report No. 1
March 10, 2005
Data Analysis and Final Report Committee
Michigan Department of Natural Resources
D. OBrien, Wildlife Division (Chair)
P. Bernardi, Law Enforcement Division
S. Dubay, Wildlife Division
S. Mayhew, Wildlife Division
W. Moritz, Wildlife Division
D. Purol, Law Enforcement Division
Executive Summary
Deer and closely related species such as elk (Cervus elaphus nelsoni),
moose (Alces alces), and
caribou (Rangifer tarandus), scientifically classified as members of the
Family Cervidae are collectively
referred to as Cervids. While the general public commonly considers
cervids wildlife, cervids raised in
enclosures and cared for by humans (variously called captive,
privately-owned,1 or farmed) form a
group distinct from free-ranging (i.e., wild) cervids. Management of
these captive/privately-owned
cervids (C/P-OC) presents a number of unique challenges and
opportunities. Because C/P-OC
management involves aspects relevant to both agriculture and resource
conservation, both the Michigan
Departments of Agriculture (MDA) and Natural Resources (MDNR) have
responsibilities in C/P-OC
regulation. Both agencies recognize the potential of diseases,
specifically Chronic Wasting Disease and
Bovine Tuberculosis, to negatively impact both privately owned livestock
and wildlife in Michigan.
The term Captive/Privately Owned Cervid Industry refers to the
collective body of enclosures.
This industry is composed of 740 facilities located throughout the
State, ranging in size from less than 1
acre to over 5,000 acres. Facilities are classified into 4 categories
based on function: Hobby, Exhibition,
Ranch, and Full Registration. While Hobby and Exhibition are self
explanatory, Ranches provide
shooting opportunities, and Full Registration facilities provide
breeding stock, shooting stock, and sale of
live animals for hobby and exhibition operations.
As a result of recommendations from the Michigan CWD Task Force and an
Executive Order of
the Governor, a risk-based audit of the states C/P -OC industry was
carried out not to be punitive, but to
find any flaws or weaknesses in the current system that might lead to
the entrance of CWD into
Michigans captive and wild cervid herds. With the cooperation of the
MDAs Animal Industry
Division and C/P-OC producers around the state, the Law Enforcement and
Wildlife Divisions of the
MDNR audited 584 C/P-OC facilities throughout the state between June 15,
2004 and October 26, 2004,
of which 506 were active operations. Auditors collected data on a
variety of factors related to the risk of
introduction and spread of CWD in the state, including number and types
of cervids held, the places from
which they were obtained, how they were identified, the types, heights
and conditions of fences, and
information about CWD testing and escapes.
During the period of the audit, audited facilities housed a total of
32,493 C/P-OC based on facility
owner information. More than 30,000 (30,616 or 94.2%) of those animals
were of species known or
anticipated to be susceptible to CWD. The vast majority (25,976 or
84.8%) were white-tailed deer. Elk
were second most abundant at 4,029 animals (13.2%), and 611 animals
(2.0%) were red deer (Cervus
elaphus elaphus). Full Registration facilities housed 13,840 (42.6%) C/P
-OC while Ranches housed
18,394 (56.6%).
Overall, auditors determined that 37% of all C/P-OC facilities were not
in compliance with
current regulations at the time of the audit. The principal areas of
deficiency related to the identification
of animals, the rate of CWD testing, conditions of fences, and the rate
and reporting of escaped animals.
In spite of the unique characteristics of CWD as a disease, many of the
risks for its introduction
and propagation identified during the course of this audit are recurring
themes in the surveillance and
control of other contagious diseases in other species. While many issues
of note, both positive and
negative, were found in these inspections of Michigan C/P-OC facilities,
the following stand out as
deserving comments and recommendations:
∑ Efforts to minimize the risks of introduction and propagation of CWD
via C/P-OC in Michigan begin
and end with individual animal identification. The current animal
identification regulations are
inadequate because they do not require facility owners to identify all
C/P-OC or to identify them all in
1 The terms used to refer to these animals differ between stakeholder
groups. In Michigan, agricultural groups
prefer the term privately-owned cervids, whereas natural resource
groups more commonly recognize the term
captive cervids. To avoid confusion of either group, for the purposes
of this report they are referred to collectively
as captive/privately-owned cervids (abbreviated C/P-OC).
a unique and uniform way. A system must be implemented that is
mandatory, uniform across all
facilities and classes, and that provides unique and visible
identification to each individual by which
the animal can be traced throughout its lifetime. All animals must be
identified by 1 year of age , and
the appropriate state agency must issue and administer the
identification system. The identification
must also be easily visible so that each and every animal is clearly
identified as a C/P -OC in the event
of escape. In calling for this requirement, we understand that
identification of every animal may be
very difficult for Ranch facilities because of their size and their
inherently less intensive management
and handling of the animals. Nonetheless, individual animal
identification is so critical to minimizing
and managing disease risk that facilities such as Ranches that cannot
reliably and verifiably identify
each and every individual should be subject to more stringent and
vigorously enforced fencing and
biosecurity regulations to ensure that unmarked animals do not le ave
the facility alive under any
∑ Along with animal identification, CWD testing of Michigan C/P-OC, or
more accurately, the lack of
testing, was the greatest risk for introduction and propagation of the
disease identified during this
audit. In spite of a mandatory testing program for all C/P-OC over 16
months of age that die plus a
representative percentage of culls, nearly 90% of the reported C/P-OC
deaths were not tested for
CWD. While some facilities have tested in good faith, nearly half of the
audited Ranch and Full
Registration facilities reported that they had submitted no CWD tests at
all. Without adequate CWD
testing, the introduction of CWD into the States C/P -OC cannot be
detected. More ominously, this
same lack of testing means that we cannot rule out the possibility the
disease is already here and
currently propagating undetected. Steps have been taken jointly by MDA
and MDNR to notify
producers of testing requirements and provide information about sample
submission (letter dated Nov
15, 2004).
∑ The lack of a specified protocol for de-commissioning or
de-registering a C/P-OC facility is a risk for
introduction and propagation of CWD. Audit teams found a number of
facilities that wanted to leave
the C/P-OC business but had little guidance from regulations on how to
decommission. As a result,
understandably frustrated facility owners may deal with the situation in
a way they deem appropriate,
which, at worst, could mean releasing the ir C/P-OC into the
free-ranging cervid population.
Appropriate regulations should be developed speedily, and those
regulations should provide for an
outreach/education program to inform and assist C/P-OC producers who
wish to leave the business
and get rid of their animals.
∑ Procedures to deal with facility abandonment, are conspicuously absent
and critically needed. As an
example, when inspectors visited a facility during the audit, fences
were down, the C/P-OC were
gone, and the owner had moved out of state. In such cases, given the
currently inadequate regulatory
provisions for individual animal identification and recordkeeping, there
is no way to be sure what
happened to the animals or verify the CWD risk those animals, or the
land once used as a C/P-OC
facility, pose to the free-ranging cervid population. Penalties for
cases where an owner just walks
away from a facility should be sufficiently severe to provide a strong
deterrent for this unacceptable
∑ Another area of risk for CWD introduction and propagation for which
both C/P-OC facilities and
regulating state agencies bear some burden of responsibility is that of
inadequate recordkeeping. To
the credit of the C/P -OC industry, the vast majority of inspected
facilities not only keep records, but
the records they keep were judged to be in compliance with current
regulations. However, the current
regulations are not particularly stringent when viewed in the context of
what is required of a
recordkeeping system in order to minimize disease risks. For example,
most of the records kept are
on paper, and while they comply with current regulations, lack of
simultaneous accessibility of these
records by the multiple parties necessary to ensure adequate disease
surveillance presents an obvious
risk. In addition to the issues discussed relative to animal
identification, the State needs to reevaluate
and improve the way it gathers and stores regulatory information from
C/P-OC facilities so that the
information is rapidly, efficiently, and widely accessible to multiple
agencies and producers, and so
that important data linkages are maintained. The development of an
electronic data collection,
archiving, and reporting system to aid compliance, enforcement, and
disease risk assessment should
be a high priority. Such a system is currently lacking, and its design,
development, and
implementation should involve both information technology and disease
control specialists to ensure
an adequate system is developed.
∑ These audit findings also revealed the risk of C/P-OC escapes. In
spite of the fact that reporting of
releases is mandatory in current regulations, it is clear not only
that escapes occur but that they are
rarely reported. Of 464 escapes reported to audit inspectors, only 8
releases were apparently reported
to MDA. Twenty percent of Class IV and about 14% of Class III C/P-OC
facilities experienced
escapes, which is likely to be an underestimate. Adding to the risk is
the fact that only half of the
escaped C/P -OC from Ranches bore identification. Most escaped C/P-OC
were reported to have been
recovered, yet the time allowed for reporting and recovery under current
regulations is suffic ient to
add substantial risk of CWD introduction even for recovered animals. The
development of more
stringent escape and recovery protocols, along with enforcement and
stiffening of penalties for nonreporting,
is critical. Consideration should be given to measures which would allow
agencies to
dictate the rapidity and conduct of recovery operations based on risk
and automatically make
unreported escaped C/P -OC public property and subject to immediate
harvest. These protocols
should include measures to explicitly provide authority to agencies to
manage the harvest of nonnative
cervid species. The Natural Resources Commission approved regulations to
allow harvest of
escaped exotic Cervids in January 2005. The documentation by this audit
of another practice, the
intentional release of C/P-OC into the wild, is also both notable and
deeply troubling.
∑ Uniform regulatory requirements for the composition and maintenance of
perimeter fencing should be
developed and enforced. Current regulations specify that fences be
constructed only of woven wire,
yet in practice, C/P-OC facilities use a variety of other materials that
agencies consider to be in
compliance with the standards. Some of these materials very likely are
adequate. Updated
regulations should include specific guidance such as (but not limited
to) minimum gauge of wire,
mesh size, and distance between posts. In addition, the revised
regulations need to address the current
problematic conflict in fencing standards, which both specify minimum
fence heights by species, yet
also specify that fences need to prevent the ingress and egress of any
cervid species. We cannot
overstate the crucial role of fences in minimizing the risks of CWD
introduction and propagation. In
spite of their similar appearances, C/P-OC and free-ranging cervids are
separate populations from the
standpoint of disease control, and the separation between those
populations should be maintained at
all times. Good fences not only protect free-ranging cervids from
C/P-OC, but vice versa.
∑ Some summary mention of Ranch facilities is warranted because of their
unique characteristics and
the unique risks they hold for CWD introduction and propagation. This
audit found that of the 4
facility classes, Ranches enclosed the largest number of CWD-susceptible
C/P-OC (>18,000
statewide), imported the largest numbers of C/P-OC from out-of-state
sources (including from CWDpositive
states), had the largest percentage of animals lacking individual
identification, had the lowest
rate of CWD testing, and had the lowest rates of recovery and
identification of escapees. In addition,
Ranch facilities are located in areas with some of the highest
free-ranging WTD densities in the state.
If CWD were to infect C/P-OC that subsequently escape from one of these
facilities, propagation of
CWD in the surrounding free-ranging population would likely be rapid. We
do not intend these
remarks to stigmatize all Ranch facilities. Some of the best managed
C/P-OC facilities in the state are
Ranches. However, because of this combination of factors that increase
CWD risks, serious
consideration should be given to making registration and fencing
requirements for Ranches more
stringent than those for other classes of C/P-OC facilities. This may
help provide greater assurance
that registered facilities will be well managed and economically
self-sufficient, and capable of
providing needed disease surveillance and management safeguards.
∑ An emerging issue with respect to the risks of CWD introduction and
propagation is potential
environmental contamination via the manure or carcasses of infected
animals. This audit was able to
gather some of the first information on the ways that C/P -OC facilities
manage and dispose of these
materials. This is an area where development of workable regulations
should be an ongoing priority
for both agriculture and natural resource agencies. While the attention
paid to issues of carcass and
manure management and disposal is likely to increase in the future
because of recent research
findings, agencies and the industry must also keep the place of these
items in proper perspective
within the context of the overall risks of CWD transmission. The
available research and the current
scientific opinions of preeminent CWD scientists agree that the highest
risks for introduction and
propagation of the disease are the movements of, and contact between,
live animals. The role played
by carcasses and manure from infected animals, while by no means
negligible, is a distant second in
terms of risk importance, with contamination of machinery and equipment
an even more distant third.
It is critical that disease control experts and policy makers keep this
relative risk ranking in mind so
that attention, as well as limited time and resources, are not diverted
from the most important sources
of CWD risk.
∑ Measures of the overall non-compliance of C/P-OC facilities (37% of
C/P-OC facilities judged noncompliant
by audit inspectors) essentially speak for themselves. While the
validity and meaning of
these measures can be debated, clearly an appreciable amount of
non-compliance exists among C/POC
facilities, and there is substantial room for improvement.
In many respects, identifying the need for improvements in the C/P-OC
industry to minimize the risks
of introduction and propagation of CWD, and even suggesting remedies, is
the easy part of the process.
Much more difficult is the task of finding and applying sufficient
resources to make the remedies happen.
Agencies and policy makers should harbor no illusions about the amount
of funding, personnel, and time
needed to ensure the implementation and enforcement of the measures
suggested in this report. All will
be sizeable, but such support will be necessary if Michigan is serious
about minimizing disease risks. It is
only fair to point out that many of the problems identified with respect
to current C/P -OC regulations and
their implementation may have been largely due to a failure to provide
the money and expertise necessary
to do the job properly. In the end, measures taken to prevent the
introduction and spread of CWD to
Michigan will benefit both free-ranging cervids and C/P-OC, and the
methods devised to fund risk
mitigation measures should reflect that fact.
The authors want to acknowledge that even though our names appear on
this Final Report, others
completed the vast majority of the work of this audit. They deserve a
great deal of credit for their efforts,
efforts made over and above work schedules that for most were already
strained. Primary credit lies with
the teams of Conservation Officers and Wildlife Biologists who conducted
the audit inspections and with
D. Dominic and D. Purol who organized, scheduled, and managed the
logistical challenges of hundreds of
inspections. Credit is also due to T. Pullen who helped in the
organization of photographic data, to J.
Kennedy and T. Riebow who spent many hours entering questionnaire data
by hand, and to K. Gardiner,
Y. Li, T. Oliver and M. Strong who provided mapping expertise. The
members of the various audit
planning and training committees are too numerous to name here, but
their efforts to plan and organize
the audit from scratch in less than a months time were indispensable
and nothing short of amazing.
Thanks are also due to the Animal Industry Division of the Michigan
Department of Agriculture for
providing full cooperation and access to their data and records.
Finally, credit and thanks are extended to
the captive/privately-owned cervid facilities of Michigan and their
producer groups, whose cooperation
under difficult circumstances allowed this audit to be completed.
In writing this Report, we had three primary goals: 1) to provide the
best context we could for the
potential disease risks (or lack of them) associated with the audits
findings; 2) to comprehensively and
accurately document the findings of the audit inspections in the
interest of transparency; and 3) to
meticulously document the environment, planning, and conduct of the
audit, hopefully to provide some
guidance and assistance to other groups or agencies faced with a similar
task in the future.
The Report is long, but this was the unavoidable consequence of our
effort to be comprehensive.
All audit data that could be summarized and presented in a reasonably
concise way are included here,
either in the Results themselves or in Appendices. The Report was not
written with the intent that
everyone would read it cover to cover. Rather, it is organized into
sections which were intended to stand
on their own. As a result, some issues are covered repeatedly. Of
necessity, some topics overlap. The
Table of Contents is organized so that a reader with a specific interest
in a particular risk topic can locate
that topic easily and view a summary of the audit findings relevant to
it without having to read the entire

snip...Full Text 168 pages...TSS

" Captive/Privately Owned Cervid Facility Audit Report

PDF icon
An audit of captive/privately owned cervid facilities that house deer,
elk and other animals around the state showed that 37 percent of the
facilities are not in compliance with current regulations for the industry.
Executive Summary

Synopsis of the report


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