USDA Proposed New CEM Testing Procedures

The U.S. Department of Agriculture (USDA) proposed new requirements for importing horses from countries that are affected by contagious equine metritis (CEM).

On March 25, 2011, USDA published an interim rule, which was to go into effect that day, changing the requirements for horses imported from CEM countries.  On April 1, 2011, USDA delayed the rule changes for 120 days after the AHC and several state representatives expressed concern over the cost and burden to the industry that would result by implementing the interim rule without prior notification.  The proposed rule was scheduled to go into effect on July 25, 2011.

At the 2011 USAHA meeting, USDA announced that the proposed CEM-Interim Rule changes will remain on delay while the Agency reviews comments received on the changes and undertakes possible revisions.  At this time, USDA has not provided an anticipated date to publish the revised CEM rule changes.

Background

There have been several CEM disease outbreaks in the U.S. in recent years involving more than a thousand exposed horses.  During these outbreaks, the estimated cost of veterinary services for testing and treatment ranged from $1,500 to $5,000 depending on whether the animal was a mare or a stallion. The full economic impact of these past CEM incidents is difficult, if not impossible, to quantify.

Federal and state animal health officials along with industry stakeholders spent an enormous amount of time, efforts, and resources in emergency response, epidemiological investigations, testing, and treatment to retain our CEM-free status.  Future CEM outbreaks in the U.S. could have extensive and considerable economic consequences for the entire U.S. equine industry.

Rule Proposal

The proposed changes affect the anatomical sites to be cultured, the number of culture sets required, and the time period over which culture sets may be taken.  The proposed rule also establishes additional requirements for complement fixation testing of mares and for health certificate statements for horses under 731 days of age.

Further, the proposed rule will adjust the time frame of the sets of swabs used for CEM testing.  Currently, USDA requires CEM swabs be taken on days 1, 4, and 7 of a 1-week period.  Under the proposed rule, the sets of swabs will be taken over a 12-day period with at least 72 hours between sets.

AHC Comments

The AHC strongly supported the intent behind USDA’s proposed rule changes and USDA’s efforts to address weaknesses within the current requirements.  The AHC also asked USDA to consider the impact the proposed changes might have on business continuity and for private CEM quarantine facilities.

In 2007, a CEM Program Review Team was formed to review CEM import activities in the U.S. and submitted recommendations to USDA that identified concerns about the lack of consistent CEM testing and treatment protocols on both a state and federal level.  The AHC supported including the 2007 CEM Program Review Team’s recommendations in the proposed rule.

The AHC also noted that including the 2007 CEM Review Team’s recommendations would address the lack of reliable and consistent CEM procedures across all state approved private CEM quarantine facilities while balancing the essential element of business continuity within the private CEM quarantine facilities.

The AHC supported USDA’s actions to establish and train CEM coordinators and laboratory staff in each State approved to receive horses imported from CEM countries. The AHC also supported oversight and training to maintain a satisfactory level of proficiency for state-approved laboratories. The AHC supported USDA’s efforts to develop a database that state veterinarians and USDA field offices could use to monitor the testing information on imported horses from CEM countries.

The AHC felt these quality control measures, along with implementing the 2007 CEM Program Review Team’s recommendations, would address current shortfalls and provide additional safeguards when importing horses from CEM countries without adding significant economic hardship to the U.S. equine industry.

Status

The initial comment period closed on May 24, 2011, and the interim rule was scheduled to go into effect on July 25, 2011.  USDA reopened the comment period until September 7, 2011.  USDA is delaying any further action while the Agency reviews all the comments received and considers possible revisions.

Review the complete AHC comments here

AHC Position

The AHC supports combining many of the proposed rule changes with the 2007 CEM Program Review Team’s recommendations.