Issue 3 - the Montana Secretary of State Website

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RESPONSE #5: The economic analysis has not changed from existing rule to the
proposed changes regarding supplies used for sampling. One pouch would be used
for PCR, three pouches for three cultures. Veterinary fees are individualized and are
not able to be estimated or averaged.
COMMENT #6: The local brand inspector is becoming overwhelmed by animal
health issues from Brucellosis to Trichomoniasis and some of these rules are
overkill.
RESPONSE #6: The local brand inspector is a critical component to a functioning
Department of Livestock in tracking animal movements and preventing the spread of
livestock diseases. The department is dedicated to increasing education and
providing support for these inspectors through the district brand investigators and by
providing more public information about livestock diseases.
COMMENT #7: ARM 32.3.502(d) says bulls sold, loaned, leased, or otherwise
acquired found to be without test must be treated as positive and sent to slaughter.
This is too aggressive to force the sale of these bulls since there is now a fine and a
misdemeanor ticket.
RESPONSE #7: The department agrees and has changed the language to be: (d)
Test eligible bulls sold, loaned, leased, or otherwise acquired without a negative test
are in violation of ARM 32.3.502 and must be quarantined away from females and
tested. The owner is liable for any fine, expenses, and/or misdemeanor ticket as
stated in new penalty rule.
COMMENT #8: How are these proposals to be enforced Numerous times the
state office has told me there is not enough manpower to enforce the equine
shipped semen regulations; therefore, how will the manpower be present to enforce
new Trich proposals
RESPONSE #8: Administrative staff handles import permits, including shipped
equine semen, while three regional animal health/brand investigators plus 16 district
brand inspectors perform local investigations, quarantine, and movement controls.
COMMENT #9: I was told brand inspectors would be in charge of manpower and
enforcement. How will grazing association testing be enforced if the cattle are not
crossing county lines
RESPONSE #9: Like any management program, the key critical component is
education and voluntary testing by participants for the benefit of the state's livestock
industry. Peer pressure helps, but unless the violations are passed on to brand
inspectors there will be minimal enforcement on animal movement within the county.
COMMENT #10: On page 1858 New Rule I(1)(c) how is this to be collected
Montana Administrative Register 3-2/11/10