Episode 227 - USDA APHIS guidance document for federal order requiring H5N1 pre-movement testing for lactating dairy cattle crossing state lines - UMN Extension's The Moos Room
What is up, everybody? This is doctor Joe Armstrong. When last we talked, there had been a federal order. We did not have a guidance document yet. We have that guidance document.
Dr. Joe Armstrong:Today, it is 4/29/24 at approximately 1 PM. The guidance document came out on Friday. I'm waiting until today because I was waiting for further clarification on a few things. We have some of that clarification, but not all of it. So let's dive right into this guidance document.
Dr. Joe Armstrong:Remember, the Federal order made positive results for influenza a PCR or serology reportable. We will talk more about the implications of making serology reportable in a second. The other thing we need to address right away is this document applies to interstate movement. It is only when lactating dairy cattle are crossing state lines. There is no requirement in this document related to anything involving intrastate movement, movement within a state.
Dr. Joe Armstrong:Right out of the gate, we need to know what USDA is defining as a lactating dairy cow. In the guidance document, it states: The requirements outlined within this guidance apply to the movement of dairy cows currently in one of the lactation phases of their current production cycle, and their example of those lactation phases is early, mid, and late. The guidance document also defines non lactating as heifers, dry cows, and bull calves. The other big question that came out right away when we heard about this order was what about cull cows? What are we gonna do with them?
Dr. Joe Armstrong:Because we need to maintain their movement for animal welfare issues and just flow, and this is going to slow that down dramatically. So, in the guidance document, they added some clarity about cull cows and they stated in the document, non clinical, lactating dairy cattle moving interstate direct to slaughter are not required to have a pre movement test, but must move on a certificate of veterinary inspection or other documentation of movement approved by the sending and receiving state animal health officials and provided to the sending and receiving state animal health officials. So, basically, that means if they're going directly to slaughter, they have to move on the CVI, cowcows, but they do not need a test. Now the other question when it came to coal cows is what about if they're moving to an auction market? They provided more clarity on that on April 27th with an email saying what they wanted to do with that situation.
Dr. Joe Armstrong:So if lactating dairy cows are going to an auction market and they must cross state lines to do so, they need a test and a CVI. Once those animals are at an auction market, if they need to cross state lines to get to slaughter, they can move as one group on a CVI and they do not need a test. So, what do you need to know about sample collection? A big important note is that sample collection and testing must take place no more than 7 days prior to interstate movement. Those samples must go to an approved National Animal Health Laboratory Network Lab, NAHLN Lab, for testing.
Dr. Joe Armstrong:Because the test is required by USDA, they will be paying for the test, So the producer will not have to pay for any testing related to pre movement testing for lactating dairy cattle that are moving across state lines. Samples have to be collected at this time by an accredited veterinarian. There's some language in the guidance document that allows for state animal health officials in each state to kinda determine if they're going to allow anyone else to collect samples. But for right now, accredited veterinarians are to collect samples. What do samples look like?
Dr. Joe Armstrong:Well, the samples we need are milk or udder secretions from individual cows. We need to collect milk from each quarter and combine those in one composite sample from all 4 quarters. There is some data to show that, potentially, we're finding virus in only some of the quarters and not all of them. So you take a little bit from each quarter and make one sample for that cow. In total, we need 3 to 10 mils of milk per animal.
Dr. Joe Armstrong:There is some language in the document about pooling samples. Important, listen, do not pool samples. If pooling is going to be done, it will be done at the lab. They will pool the samples. Do not pool them.
Dr. Joe Armstrong:Send a sample for each individual animal. How many animals need to be tested? They've made that pretty clear. If it's under 30 animals total that are moving, all the animals need to be tested. If it is over 30 animals that are moving, only 30 need to be tested from that whole group.
Dr. Joe Armstrong:Now the big question, what happens if you have a positive? Well, here's exactly what it says in the guidance document. Lactating dairy cattle from herds which have tested positive for influenza a are not eligible for interstate movement for 30 days from the most recent collection of any sample that tests positive from any individual animal in that herd. After the 30 day period, animals must be tested again for movement. So basically, if an animal tests positive, that animal and all the animals it's with and the animals from that premise where the animal came from are not eligible for interstate movement for 30 days.
Dr. Joe Armstrong:And then before animals move interstate after that 30 days, they must be tested again. In the guidance document, they make it very clear that clinical lactating dairy cattle are ineligible for interstate movement or movement to slaughter. So if they fit the clinical picture, they are not eligible to cross state lines. Okay. That is the overview and the basics of what you need to know.
Dr. Joe Armstrong:Now let's get to some of my thoughts. The federal order made serological testing reportable. The guidance document does not mention anything about what will happen if you have a serological positive sample and everything in the guidance document just refers to a positive test. So, right now, I can't tell the difference based on what would happen between a PCR positive and a serological positive, which is a massive mistake. Serological positives are a great tool for epidemiology, risk assessment, and potentially for control as well.
Dr. Joe Armstrong:And at this point, because they are reportable and I have no guidance for what would happen if I get a positive, they are completely off the table. There is zero reason for anyone to run a serological test right now because I have no idea what would happen if you got a positive. Even though serological positive might even be protective, it's reportable, and I don't know what would happen if you got a positive. So serological testing at this point is off the table. This is a potentially valuable tool.
Dr. Joe Armstrong:And to have it not even a possibility at this point because of not having any guidance, but having the test and a positive result being reportable, I'm kind of at a loss here. Just taking a tool off the table by not providing enough detail for what does it mean and what would happen if I had a positive, I'm now stuck not being able to gather potentially important information for both control and for risk assessment because I have no direction to follow even though it's reportable. So that's my first thought on this guidance document. After that, you know, the the obvious place to go next is this covers interstate movement. So what's gonna happen with intrastate movement?
Dr. Joe Armstrong:If a farm tests positive, will there be a stoppage? I don't know the answer to that at this time. Where we look to some foreshadowing is when we look at the additional information that was included in this document. So below everything, after the requirements, there is a APHIS recommendations section. That usually becomes a section that is going to be foreshadowing of what is to come next.
Dr. Joe Armstrong:So in those recommendations, there's a set of bullet points that basically reads like this is what's going to happen next. I can't say that for sure, but that is how I look at it when I read it. One of those bullet points is if you have any animals with clinical signs on the premise, do not move animals off of the premise. It also says all animals that move on and off a premise should be isolated for 30 days to prevent the spread of disease. Additionally, it says, if cattle must be moved, we strongly encourage extreme diligence by producers, veterinarians, and states to ensure only healthy cattle are moving and to ensure the validity of interstate health certificates.
Dr. Joe Armstrong:There's a little bit to unpack there, but, basically, what you're hearing in those statements is if you have clinical animals, they should stay on the premise. If you move animals, regardless of whether or not they're clinical, they should be isolated for 30 days. They're putting some pressure on the states to say you need to restrict intrastate movement, and they are strongly suggesting that they do so. And finally, they are also hinting at the fact that any goofy business with health certificates for cattle moving interstate will be punished. And they're reminding you that you are submitting an official document to the federal government that must be accurate and valid.
Dr. Joe Armstrong:Now this brings up an interesting point for me because it's been fairly clear through a lot of the language from USDA that they do not have the staff to enforce this, but they are more than happy to make an example of someone who breaks the rules. So what does that mean? Well, selfishly, the first thing I think about is practicing veterinarians and how much pressure they are under to enforce this for USDA. They are the first line of defense. They are the people that are going to receive the most pressure in this situation to make sure things happen correctly.
Dr. Joe Armstrong:That pressure from USDA comes with all sorts of baggage. I am 100% expecting this to result in many arguments with clients, whether or not the practicing vet is the one that's handed down the rule, they are now enforcing it, And there are going to be clients lost over this situation. That amount of stress and pressure from two directions, USDA from the top, clients from the other side, puts practicing veterinarians in a very stressful day to day. There's already tons of stress in practice. This situation adds to that, and it creates the potential for a mental health crisis.
Dr. Joe Armstrong:So this is my offer to all veterinarians regardless of where you're listening from. If you are in a spot and you don't know what to do, you're feeling lost, you're feeling down, you are experiencing some kind of mental health issue, call me. 612-624-3610. I will get back to you as soon as I can. We can talk through this.
Dr. Joe Armstrong:I can provide resources to you to help you through that. Whatever you need, call me. Okay. A little bit of a tangent, but an important one. Let's get back to the document and these APHIS recommendations.
Dr. Joe Armstrong:Big bullet point. APHIS recommends pre movement testing of nonlactating cattle as well. This testing at NAHLN Laboratories will be completed at no cost to the producer. So preview what's to come. Potentially, they might be moving towards testing nonlactating animals for pre movement as well.
Dr. Joe Armstrong:I don't know. At this time, I don't think we have the tools to be able to do that and the correct tests, but it's a possibility, and it's in the recommendations. Two more bullet points. State specific guidance for moving cattle will also need to be followed. Straightforward, again, making sure states know they're up next and they get a chance to implement control programs, and they should be working on it.
Dr. Joe Armstrong:Last bullet point. APHIS scientists are working to establish testing protocols rapidly assessing currently available tests and test performance including sample types to better understand the characteristics. Based on this analysis, we may recommend testing for other classes of cattle beyond lactating dairy cows in the future. So that gets back to this nonlactating pre movement testing. Right now, I said they don't have the tools because they don't have a test that works extremely well for that population, but they're working on it.
Dr. Joe Armstrong:So it's possible that we might see that in the future, pre movement testing for nonlactating animals. Additionally, if you look at that bullet point, it's saying rapidly assessing currently available tests and test performance, including sample types. So there's 2 ways that I interpret that. It could refer to non lactating dairy cattle, but I think it could also refer to additional sample types found on the farm. FDA has already shown their willingness to find a composite sample and test it, that being grocery store milk, which, just as a reminder, is perfectly safe.
Dr. Joe Armstrong:No concern about the commercial milk supply safety. So when we take that logic and we apply it to a dairy farm, I guarantee you they are looking for a composite sample that can give them the most information possible with one test. I don't like testing the most obvious option, but I don't know if we're going to avoid that as this situation progresses. As we move forward with this situation, the way that we can control a little bit of the narrative is that we have to have a control plan in place that is industry run so that farmers have some say in how it works if we rely on the federal government to continue to hand down regulations about what must be done, rather than coming up with our own plan that will work with our business and our industry while also solving the issue. We are risking our industry without any control in the decisions that are made.
Dr. Joe Armstrong:Alright. Let's get to a couple of common questions I've gotten already about this. Alright. Show cattle. Lactating dairy cattle that are show cattle that are crossing state lines.
Dr. Joe Armstrong:How's that gonna work? Right now, they must adhere to the same guidelines. There is no exception for shows at this time. So, what is the safest way to handle that situation in my opinion? You test, you send in that test, you await results, you get your CVI, and you move to the show that is across state lines.
Dr. Joe Armstrong:The clock has now started. As soon as you sampled, you've got 7 days from the sampling date, So you have to cross state lines on a CVI with a test that is negative. That test is good from the sample date for 7 days. You need to return to the state of origin on a different CVI provided by the state that you were just at for the show, but you do not need another test if you come back within that 7 day window. That is how it's written right now.
Dr. Joe Armstrong:There may be changes as we move forward as the states talk and talk about these more specific scenarios, But right now, that is how it's going to work. We will update you if we hear differently or if there is something that changes with that. Okay. Big question is right now, let's say I test positive. I'm not eligible for interstate movement for 30 days.
Dr. Joe Armstrong:Then I retest at day 31, and it is positive again. What happens? Well, according to the rules, you are then not eligible for interstate movement again for another 30 days. That is where we are needing to do some more work to figure out how can we meet other criteria that would show that it's safe to move. It's also why we need way more guidance about serology because if we can't use that as a tool, which we rely heavily on in the poultry and the swine industry, I don't know how we can move forward to find other criteria that says, no, we are safe to go.
Dr. Joe Armstrong:And we can start chipping away at that 30 day mark and say, no. Actually, if I can meet this standard and this standard and this standard, I'm good to go at 21 days. But we're missing a big tool, which is serology. And if they're gonna make that reportable but not give us any guidance about what a positive test is going to do to that farm, we can't use it. Okay.
Dr. Joe Armstrong:I'm in danger of spiraling out of control into a topic that I've already ranted about. So we're gonna end it there. I think that's usually a good sign that it's time to end. If you have comments, questions, scathing rebuttals, themoosroom@umn.edu. If you wanna call me for any reason, 612 624-3610.
Dr. Joe Armstrong:Check us out on the web, extension.umn.edu. Thank you for listening everybody. Catch you next episode.
