Issue 3 - the Montana Secretary of State Website

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COMMENT #25: What about open cows going to market All dry cows from a
positive herd should go to slaughter and not be allowed to "clear up" over time. We
need to require imported open cows to only be allowed to be sold to slaughter
unless coming from a Trich free herd or are virgin heifers. Open cows must go to
slaughter even if bulls are not tested. Open cows imported must be from Trich free
herds or not exposed to bulls.
RESPONSE #25: While recognizing the risk of importing open cows, the current
proposal does not include any requirements except for cows from positive herds.
The department is interested in receiving additional comments regarding the
movement restrictions on open cows. These rules would address the imported cows
as well as the open cows sold at livestock markets. South Dakota has an existing
rule that restricts import of open cows as well as open cows sold at a market.
SD12:68:27:04.
COMMENT #26: Why must all T. Foetus positive animals be kept for minimum of 30
days before being sold directly to slaughter
RESPONSE #26: Positive bulls may go immediately to slaughter through a market
or enter a Trichomoniasis approved feedlot. The 30 day requirement is specific to a
licensed Trich approved feedlot and allows the legitimate feeder to fatten the bull up
for slaughter before being sold directly to slaughter or going to market and then to
slaughter.
COMMENT #27: ARM 32.3.505(3)(e) does this mean heifer calves at cows' side
with no bulls on cows I have done numerous C-sections on 11 and 12 month old
heifers.
RESPONSE #27: This section provides that quarantine exemption to heifer calves
(virgin). Although it does occur, heifer calves getting bred during their first season of
life is not where the vast majority of this disease shows up. We have not seen any
data to restrict heifer calf movement from a positive herd, although it could be
incorporated into the rule if the data was presented.
COMMENT #28: How do we determine 120 day pregnancy The fetus is too old to
ultrasound at that time and there are inaccuracies with rectal palpation. No
veterinarian can determine a 120 day pregnancy.
RESPONSE #28: Numerous veterinarians have been queried over the course of the
last two years and this is the first time that this statement has occurred. Rectal
palpation is an artful science that combines specific anatomical facts with
practitioners' experience. The goal for this estimation of pregnancy is to ensure that
a minimum of 90 days and preferable 120 days has passed for exposure to a
positive bull for the majority of exposed cows to clear the infection. Market
veterinarians and dairy practitioners are quite excellent at rectal palpation, but the
vast majority of bovine practitioners questioned in Montana felt that they could
determine the difference between a 90 day and a 120 day pregnancy.
Montana Administrative Register 3-2/11/10