Subject: URGENT!! Goin' Hog Wild!! - AGAINST New Rules Proposed by Texas Animal Health Commission - Comment Deadline July 6

To Mr. Snelson,                                        

General Counsel                                                          
Texas Animal Health Commission

Again, thank you sincerely, for your reply.

Per your request, I am forwarding you available information on hog fence:

The fencing industry, as confirmed with Tractor Supply, only offers 330 foot rolls of 4 foot tall “sheep and goat” wire with 4 inch x 4 inch holes, which is commonly used as hog wire and commonly called “Hog Wire”. This hog wire is a lot stronger than taller horse fence which may be available, however, horse fence is a much smaller gage and not strong enough to hold hogs. Actual Hog Panels are only 3 feet tall. 3 foot tall Hog Panels are commonly used for holding hogs, so the 4 foot tall “hog wire” fence is even better. Hog Wire is what is being used across the State. There is not a 5 foot hog wire fence, as specified in this rule, manufactured or available.

HOW MANY FENCED RANCHES IN TEXAS OFFER HOG HUNTS AND ARE LICENSED BY TPWD AS A HUNTING PRESERVE? HOW MANY ACRES? HOW MANY HOGS ARE HARVESTED ON THESE RANCHES?

Regarding our previous communication, referring me to:

Q&As About Proposed Feral Swine Regulations

There are still some unanswered questions, please:

RE: disease transmission

Q&As About Proposed Feral Swine Regulations

“The proposed regulations were designed for control of disease, not propagation of the species.  Except for hunting ranch operators, most farmers, ranchers and other landowners see feral swine as a destructive nuisance, not a species in need of propagation.  The feral swine regulations were developed by a committee represented by all aspects of the swine industry---wild swine hunting, domestic swine production, wildlife biologists, associations and regulatory agencies. Female swine are very prolific and are already present on most farms and ranches.  Promoting the propagation of wild hogs is neither warranted nor in the best interests of vast majority of farmers, ranchers or landowners in the state.  The regulations represent a compromise that allows hunters to continue their sport, while reducing the risk of disease transmission by wild hogs”
  
My Comments:
 The alleged “purpose of this rule is to prevent disease transmission.”

The Swine Brucellosis Brochure available on the TAHC website says Boars can also transmit the disease.

The Swine Brucellosis Facts document available on the TAHC website states, “How spread occurs Entry point: Breeding, ingestion of bacteria, eye (conjunctive), aerosol. Exit point: Semen, reproductive fluids, placenta, aborted fetuses, milk, urine.”

 
“The proposed regulations were designed for control of disease, not propagation of the species.” “The regulations represent a compromise that allows hunters to continue their sport, while reducing the risk of disease transmission by wild hogs.”

 
The provisions of this rule clearly benefit those hog ranchers who wish to start raising wild hogs as domestic animals and sell to the Slaughter Plant Operators. Certainly, they are required to test animals for disease and quarantine for 150 days. However, once they have a full house for breeding, they are of no more benefit to controlling the population. They will have their disease-free herd.

There are not any provisions for protecting the public against the Slaughter Plant Operators. NO DISEASE TESTING IS REQUIRED.

Dr. Ellis has stated, "From tests on feral swine over a four-year period, we know that around 20 percent of wild hogs in Texas carry pseudorabies, a regulatory flu-like swine disease not related to rabies.  About 10 percent of the feral pigs have swine Brucellosis, the swine form of "Bangs," or cattle Brucellosis."           

First, I challenge the word “KNOW”. That would be impossible without testing every hog in Texas.

Obviously, the largest numbers of trapped wild hogs will be going to the Slaughter Plant Operators as opposed to hunting ranches, by the design of this rule. Why? Because it is profitable at $20 to $30 and more per pound.

The following text comes from the Center for Disease Control which I found by searching The TAHC website. It addresses transmission of the disease from ANIMALS TO HUMANS and also HUMAN to HUMAN. 

What is brucellosis?

Brucellosis is an infectious disease caused by the bacteria of the genus Brucella. These bacteria are primarily passed among animals, and they cause disease in many different vertebrates. Various Brucella species affect sheep, goats, cattle, deer, elk, pigs, dogs, and several other animals. Humans become infected by coming in contact with animals or animal products that are contaminated with these bacteria. In humans brucellosis can cause a range of symptoms that are similar to the flu and may include fever, sweats, headaches, back pains, and physical weakness. Severe infections of the central nervous systems or lining of the heart may occur. Brucellosis can also cause long-lasting or chronic symptoms that include recurrent fevers, joint pain, and fatigue.

How is brucellosis transmitted to humans, and who is likely to become infected?

Humans are generally infected in one of three ways: eating or drinking something that is contaminated with Brucella, breathing in the organism (inhalation), or having the bacteria enter the body through skin wounds. The most common way to be infected is by eating or drinking contaminated milk products. When sheep, goats, cows, or camels are infected, their milk is contaminated with the bacteria. If the milk is not pasteurized, these bacteria can be transmitted to persons who drink the milk or eat cheeses made it. Inhalation of Brucella organisms is not a common route of infection, but it can be a significant hazard for people in certain occupations, such as those working in laboratories where the organism is cultured. Inhalation is often responsible for a significant percentage of cases in abattoir employees. Contamination of skin wounds may be a problem for persons working in slaughterhouses or meat packing plants or for veterinarians. Hunters may be infected through skin wounds or by accidentally ingesting the bacteria after cleaning deer, elk, moose, or wild pigs that they have killed.

                                                                (FOOTNOTE: I personally know 2 people who have contracted  brucellosis. One has never found a cure.)

Can brucellosis be spread from person to person?

Direct person-to-person spread of brucellosis is extremely rare. Mothers who are breast-feeding may transmit the infection to their infants. Sexual transmission has also been reported. For both sexual and breast-feeding transmission, if the infant or person at risk is treated for brucellosis, their risk of becoming infected will probably be eliminated within 3 days. Although uncommon, transmission may also occur via contaminated tissue transplantation.

THIS PROPOSED RULE WILL NOT PROTECT THE PUBLIC, THE CONSUMERS OF THE MEAT DISTRIBUTED BY THE SLAUGHTER PLANT OPERATORS, FROM THE DISEASED ANIMALS PROCESSED BY THE SLAUGHTER PLANT OPERATORS. (if they are diseased)

BY REQUIRING TESTING AT THESE FACILITIES YOU MIGHT GET ACCURATE DATA FOR THE PERCENTAGE OF HERDS ACTUALLY INFECTED, BY REGIONS OF THE STATE, AND YOU WILL PREVENT INFECTION TO UNKNOWING HUMANS. Otherwise, moms will be buying meat that is diseased and infect themselves and their families by handling the raw meat.

According to Dr. Ellis, “For nearly a year, a team of commercial swine and show pig producers, Slaughter Plant Operators, veterinarians, hunters, hog trappers and wildlife biologists have wrestled with rule ideas that would prevent captured wild hogs from creating more chaos, while still giving hunters an opportunity to bag a boar trophy worth bragging rites.” 

Dr. Dee Ellis, DVM, Texas' assistant state veterinarian and TAHC advisor to the feral swine working group, who has proposed these rules, actually told an operator of a current Hog Hunting Ranch, “YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!”

Obviously, the largest numbers of trapped wild hogs will be going to the Slaughter Plant Operators as opposed to hunting ranches, by the design of this rule. Why? Because it is profitable at $20 to $30 and more per pound.

The Slaughter Plant Operators have definitely benefited. As I understand, there was only one Hog Hunting Ranch Operator present or allowed input, who states,

Larry,

You probably won't like my response. I was one of the members of the Feral Swine Advisory Board for TAHC who helped come up with these regulations.  I along with a few ranch owners and a trapper represented the hunting aspect of the State.  Please believe me when I say that these regulations are 1,000 times better that what would have happened if we wouldn't have gotten a say.  This will not regulate hogs that you already have on your ranch or ones that you bring in with one-way trap doors, just ones that you may buy from hunters or trappers.  We worked hard to let ranches buy without blood tests being done and it was a struggle to get it to that point.  Bottom line is the animal health of Texas, and ranches will have to make sure their fences can hold hogs.  I've raised European hogs for over 10 years and I understand fencing and it's ability to hold hogs......You will just have to make sure your place is escape proof. 

Cody Weiser

RE: Canned Hunts, sows, and TPWD who already requires Hunting Preserve License

Q&As About Proposed Feral Swine Regulations
“HOWEVER, if you run a hunting operation and plan to bring in additional wild hogs to the property, then you must have a fence system capable of preventing escape of the hogs, and complete an application and inspection with the Texas Animal Health Commission.  Additions of new wild hogs would be limited to boars and barrows and these animals would be required to have an individual identification tag. “
 Q&As About Proposed Feral Swine Regulations

“Records would be required on the number of hogs brought in, their identification and description, and when they were removed through hunting. The Texas Parks and Wildlife Department also has requirements for hunting preserves and hunters, and operators should check with that agency to ensure all requirements are fulfilled.”

My Comments: “these animals would be required to have an individual identification tag.”   Respectable Hunters and Hunting Ranch Owners have always fought against “Canned Hunts”. Not one hunter I know wants to shoot any animal with an ear tag. No one wants to mount their trophy with an ear tag in his ear or a hole left behind because of the tag. This regulation is unsightly and will discourage hog hunting in Texas because of the perception of a Canned Hunt. I have hunted in numerous States and Countries around the world. I would never hunt ear tagged animals. Hell, the tags are going to get ripped out by the hogs fighting sometimes, leaving a ripped ear. Even if you mark them with wedges out of the ear it still ruins the trophy mount. What do you want to do? Paint names on them? All this rule is doing is giving the animal activists another shot at the hunting industry…Putting a target on our backs. Should we wear a fur coat too?

By forcing Hunting Ranches to get an application from your agency, you are regulating hunting in addition to TPWD who already requires Hunting Preserve License. What other industry is governed by 2 State Agencies?

I am concerned about hunting ranches who buy stock and will not be able to buy sows. More trophy sows are harvested with larger tusks for trophy mounts than boars or barrows. Most are harvested because of the meat. They are not around long enough to breed and propagate.  Any Hunting Ranch operator today already has a fence adequate to keep hogs from escaping. They have to protect their inventory. It is his best interest for obvious reasons. In addition, fences are usually patrolled daily. Where is the danger of disease transmission by wild hogs? The hogs inside the fence are not going to get out. And they are less likely to transmit any disease inside the fence than if they are still outside in the wild. Inside most fences, they are still in a wild environment….with a shorter lifespan.

Or are you saying if all hogs are trapped by/through an entrance one-way trap doors to the fenced area, this type of ranch is not governed by these rules?

Larry

Below is the email from Texas Animal Health Commission.
 
In a nutshell, TAHC is taking over hunting regulations from TPWD.
 
Dr. Dee Ellis, DVM, Texas' assistant state veterinarian and TAHC advisor to the feral swine working group, who has proposed these rules, actually told an operator of a current Hog Hunting Ranch, YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!
   
 

1. Given the arrogance of    Dr. Dee Ellis, DVM, TAHC advisor, to actually tell an operator of a current Hog Hunting Ranch, YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!, he is really saying he does not care about the hunting. He should stick to testing animals at livestock markets or slaughter plant operators where he might do some good. Swine Brucellosis is contagious by blood, to humans, so I am told. Why are they not testing at slaughter plant operators?
2. Allowing only Boars and Barrows to hunting ranches is discriminating.
3. No one even manufactures hog wire 5 feet tall. Who can afford to re-fence their entire ranch from 4 foot to 5 foot (that does not exist) with the price of steel today?
4. Most folks are meat hunting, not trophy hunting. More sows are mounted with long tusks than boars.
5. The record keeping is absurd and impossible and worse than exotic game.
6. When did TAHC start making hunting regulations and authorizing hunting preserves?
7. Who is it from the slaughter plant operators that is padding whos pockets?
8. Do you have any idea how many folks come to Texas to hunt on hog ranches? Are we going to give up on this income to the State. Who wants to shoot and ear tag?
9. Trappers are not able to sort sows and boars in a trailer and certainly cannot afford to drive to a slaughter plant operator and then to a hunting ranch with the price of fuel these days. If he does not sell to a slaughter plant operator, he certainly is not going to let the sows loose from his traps just to keep the boars. The sows are the cause of the extreme population. At a hunting ranch, they would be disposed into someones sausage machine. These rules are suggesting trappers can only sell conveniently to slaughter plant operators who are shipping the product over seas. Who are they paying off?         It is hard enough now to find enough trapped hogs.
10. Shortest evolution in history: wild (feral) hogsto feral swineto Commercial swine.
11. What advertising agency wrote this load?
12. HOGS ARE WILD GAME, NOT LIVESTOCK!!!!!!!!!!!!!
 
OK, I think I better stop here.
 
Larry

 
News Release
Texas Animal Health Commission
Box l2966 * Austin, Texas 78711 * (800) 550-8242 * FAX (512) 719-0719
Bob Hillman, DVM * Executive Director
For info, contact Carla Everett, information officer, at
1-800-550-8242, ext. 710, or ceverett@tahc.state.tx.us
For immediate release---
Proposed Wild Hog Rules Aim to Aid Producers, Trappers & Hunters
Described as being as prolific as cockroaches, destructive as rats,
and as surly as badgers, wild (feral) hogs are the bane of ranchers
and farmers, but they're a boon for hunters.  Nearly three million of
these dirt slingin' critters roam free in Texas, rooting up pastures,
wallowing in creek beds, and gorging themselves on crops and
gardens.  Trappers and hunters often are called in to help reduce hog
numbers when feral swine run amuck.
For nearly a year, a team of commercial swine and show pig producers,
slaughter plant operators, veterinarians, hunters, hog trappers and
wildlife biologists have wrestled with rule ideas that would prevent
captured wild hogs from creating more chaos, while still giving
hunters an opportunity to bag a boar trophy worth bragging rites.  In
mid-May, draft regulations were presented to commissioners for the
Texas Animal Health Commission (TAHC), the state's livestock and
poultry health regulatory agency.  Public comment on the proposed
rules, to be published in the Texas Register June 6, will be accepted
by the TAHC through July 6.   TAHC commissioners will consider the
rules for adoption at their next meeting on July 29 in Austin.
"The 80th legislature, in the TAHC's Sunset Bill, provided for the
TAHC to regulate feral swine, which are regarded as free-ranging
livestock.  The TAHC regulations are to be limited to disease control
purposes, including holding facilities, sale, exhibition, hunting or
movement," said Dr. Dee Ellis, Texas' assistant state veterinarian
and TAHC advisor to the feral swine working group.  "If these
proposed rules are adopted, they will supersede TAHC's current feral
swine regulations that aren't comprehensive.  We know we can't get
rid of feral swine, but we can find ways to deal with the animals so
that it benefits all sectors of the industry."
Dr. Ellis said the proposed regulations give trappers greater
latitude for holding and moving trapped swine.  Approved holding
facilities and authorized hunting preserves would be sanctioned and
inspected by the TAHC, and operators or owners would be required to
keep records on the animals for at least five years.  Applications
for operating the holding facilities or hunting preserves will be
available from the TAHC, if the regulations are adopted.
Because there is some limited interest in changing captured feral
swine to "domestic" swine by testing the animals, the proposed
regulations would allow for wild hogs to be reclassified as
"domesticated" pigs after a series of at least three negative blood
tests for swine Brucellosis and pseudorabies during a minimum 150-day
quarantine period.  (This practice is not recommended, however.)
Additionally, sows and other sexually intact female swine would be
required to undergo a fourth negative test for the diseases, at least
30 days after their initial farrowing in quarantine.
The disposition of feral swine that are not "domesticated" through
the quarantine and testing process is limited to slaughter only,
except for boars and barrows, which may be moved to TAHC-authorized
hunting preserves.
The proposed rules also would allow for the wild pigs to be held
after trapping in an escape-proof pen or enclosure on a trailer for
up to seven days before moving the animals directly to a federally or
state-inspected slaughter plant, to a TAHC-authorized hunting
preserve, or to an approved holding facility, awaiting final disposition.
The proposed rules would allow only boars and barrows to be moved to
TAHC-authorized hunting facilities, which would have to be equipped
with swine-proof fencing at least five feet high.  Boars and barrows
also would have to be individually identified prior to being placed
into the preserve.
Hunting preserve operators would need a "Hunting Lease License" and
hog hunters would need a hunting license, both from the Texas Parks
and Wildlife Department, but there is no season on these animals so
often regarded as a pest and a threat to livestock health.
"It is extremely important that proposed holding facilities and
hunting preserves be 'escape proof.'  Identification on the boars and
barrows in hunting preserves would help us identify pigs that 'get
loose,' " said Dr. Ellis.  Required record-keeping would include the
number of swine placed in or removed from the facilities, the
animals' weight, size, color, sex and any identification applied to
the animal, and the locations from which they were trapped and to
which they were moved.
"Strict requirements are necessary to prevent moving an animal that
has a potential livestock disease from one site to another," said Dr.
Ellis.  "From tests on feral swine over a four-year period, we know
that around 20 percent of wild hogs in Texas carry pseudorabies, a
regulatory flu-like swine disease not related to rabies.  About 10
percent of the feral pigs have swine Brucellosis, the swine form of
"Bangs," or cattle Brucellosis."
Since January 2006, the swine form of Brucellosis has been detected
in 26 cattle in 19 herds.  Although the swine infection in cattle
does not affect Texas' hard-won 'free' status for cattle Brucellosis,
it does cause positive test results when cattle are tested prior to
sale.  The bacteria must be "grown out" in the laboratory to
differentiate between swine Brucellosis and cattle Brucellosis
infection. In the meantime, cattle in the consignment or herd must be
held up, and additional tests may be needed to ensure there is no
cattle Brucellosis infection in the herd.
Feral swine also can have a health impact on noncommercial swine,
which may be housed in facilities that are more likely to have feral
swine contact than commercial swine facilities. Of the 41
noncommercial swine herds quarantined for swine Brucellosis infection
since January 2003, 29 either had definite or possible contact with
wild hogs.
" 'Contact with feral swine' can be as simple as a wild sow or boar
either being allowed in, breaking into swine pens, or making contact
through a fence," noted Dr. Ellis. "Related contacts" can include an
activity such as purchasing piglets from a producer who allows feral
swine into his or her pens.  In this case, a buyer could be
purchasing piglets that have been exposed to disease carried by feral swine.
Dr. Ellis advised domestic swine owners to keep feral swine out of
their pens. When purchasing replacement swine by private treaty, ask
if the pigs have been exposed to feral swine. If possible, keep the
animals isolated until tested for swine Brucellosis and pseudorabies.
At livestock markets selling sexually intact swine six months of age
or older, these tests are required, and blood samples are collected
from the animals by TAHC personnel.
"Commercial swine herds are operated with great attention to
biosecurity, and in Texas, these herds currently are swine
Brucellosis and pseudorabies-free," said Dr. Ellis.  But each time we
detect infection in a noncommercial herd, it puts a hardship on
producers, because we must trace animal movement, test herds in a
widespread area, and handle infected herds appropriately.  Swine
brucellosis also poses a significant public health threat to those
handling or inadvertently producing infected animals. By adopting
regulations that make it easier for trappers to remove feral swine
from an area, and place boars and barrows only in a hunting facility,
we encourage legal regulated movements of the animals and have less
chance of disease transmission from these wild hogs. These proposed
regulations can benefit swine producers, cattlemen, trappers and hunters, too."
On June 6, a link to the text of the proposed regulations will appear
on the TAHC website at
<http://www.tahc.state.tx.us/>http://www.tahc.state.tx.us. The
proposed regulations also are available by calling the TAHC at
800-550-8242, ext 710.  Comments on the proposed rules may be emailed
to: <mailto:comments@tahc.state.tx.us>comments@tahc.state.tx.us,
faxed to 512-719-0719, or mailed to  TAHC Comments, Box 12966,
Austin, TX 78711-2966.  Comments are due no later than July 6.

To Mr. Snelson,                                        

General Counsel                                                          
Texas Animal Health Commission

Again, thank you sincerely, for your reply.

Per your request, I am forwarding you available information on hog fence:

The fencing industry, as confirmed with Tractor Supply, only offers 330 foot rolls of 4 foot tall “sheep and goat” wire with 4 inch x 4 inch holes, which is commonly used as hog wire and commonly called “Hog Wire”. This hog wire is a lot stronger than taller horse fence which may be available, however, horse fence is a much smaller gage and not strong enough to hold hogs. Actual Hog Panels are only 3 feet tall. 3 foot tall Hog Panels are commonly used for holding hogs, so the 4 foot tall “hog wire” fence is even better. Hog Wire is what is being used across the State. There is not a 5 foot hog wire fence, as specified in this rule, manufactured or available.

HOW MANY FENCED RANCHES IN TEXAS OFFER HOG HUNTS AND ARE LICENSED BY TPWD AS A HUNTING PRESERVE? HOW MANY ACRES? HOW MANY HOGS ARE HARVESTED ON THESE RANCHES?

Regarding our previous communication, referring me to:

Q&As About Proposed Feral Swine Regulations

There are still some unanswered questions, please:

RE: disease transmission

Q&As About Proposed Feral Swine Regulations

“The proposed regulations were designed for control of disease, not propagation of the species.  Except for hunting ranch operators, most farmers, ranchers and other landowners see feral swine as a destructive nuisance, not a species in need of propagation.  The feral swine regulations were developed by a committee represented by all aspects of the swine industry---wild swine hunting, domestic swine production, wildlife biologists, associations and regulatory agencies. Female swine are very prolific and are already present on most farms and ranches.  Promoting the propagation of wild hogs is neither warranted nor in the best interests of vast majority of farmers, ranchers or landowners in the state.  The regulations represent a compromise that allows hunters to continue their sport, while reducing the risk of disease transmission by wild hogs”
  
My Comments:
 The alleged “purpose of this rule is to prevent disease transmission.”

The Swine Brucellosis Brochure available on the TAHC website says Boars can also transmit the disease.

The Swine Brucellosis Facts document available on the TAHC website states, “How spread occurs Entry point: Breeding, ingestion of bacteria, eye (conjunctive), aerosol. Exit point: Semen, reproductive fluids, placenta, aborted fetuses, milk, urine.”

 
“The proposed regulations were designed for control of disease, not propagation of the species.” “The regulations represent a compromise that allows hunters to continue their sport, while reducing the risk of disease transmission by wild hogs.”

 
The provisions of this rule clearly benefit those hog ranchers who wish to start raising wild hogs as domestic animals and sell to the Slaughter Plant Operators. Certainly, they are required to test animals for disease and quarantine for 150 days. However, once they have a full house for breeding, they are of no more benefit to controlling the population. They will have their disease-free herd.

There are not any provisions for protecting the public against the Slaughter Plant Operators. NO DISEASE TESTING IS REQUIRED.

Dr. Ellis has stated, "From tests on feral swine over a four-year period, we know that around 20 percent of wild hogs in Texas carry pseudorabies, a regulatory flu-like swine disease not related to rabies.  About 10 percent of the feral pigs have swine Brucellosis, the swine form of "Bangs," or cattle Brucellosis."           

First, I challenge the word “KNOW”. That would be impossible without testing every hog in Texas.

Obviously, the largest numbers of trapped wild hogs will be going to the Slaughter Plant Operators as opposed to hunting ranches, by the design of this rule. Why? Because it is profitable at $20 to $30 and more per pound.

The following text comes from the Center for Disease Control which I found by searching The TAHC website. It addresses transmission of the disease from ANIMALS TO HUMANS and also HUMAN to HUMAN. 

What is brucellosis?

Brucellosis is an infectious disease caused by the bacteria of the genus Brucella. These bacteria are primarily passed among animals, and they cause disease in many different vertebrates. Various Brucella species affect sheep, goats, cattle, deer, elk, pigs, dogs, and several other animals. Humans become infected by coming in contact with animals or animal products that are contaminated with these bacteria. In humans brucellosis can cause a range of symptoms that are similar to the flu and may include fever, sweats, headaches, back pains, and physical weakness. Severe infections of the central nervous systems or lining of the heart may occur. Brucellosis can also cause long-lasting or chronic symptoms that include recurrent fevers, joint pain, and fatigue.

How is brucellosis transmitted to humans, and who is likely to become infected?

Humans are generally infected in one of three ways: eating or drinking something that is contaminated with Brucella, breathing in the organism (inhalation), or having the bacteria enter the body through skin wounds. The most common way to be infected is by eating or drinking contaminated milk products. When sheep, goats, cows, or camels are infected, their milk is contaminated with the bacteria. If the milk is not pasteurized, these bacteria can be transmitted to persons who drink the milk or eat cheeses made it. Inhalation of Brucella organisms is not a common route of infection, but it can be a significant hazard for people in certain occupations, such as those working in laboratories where the organism is cultured. Inhalation is often responsible for a significant percentage of cases in abattoir employees. Contamination of skin wounds may be a problem for persons working in slaughterhouses or meat packing plants or for veterinarians. Hunters may be infected through skin wounds or by accidentally ingesting the bacteria after cleaning deer, elk, moose, or wild pigs that they have killed.

                                                                (FOOTNOTE: I personally know 2 people who have contracted  brucellosis. One has never found a cure.)

Can brucellosis be spread from person to person?

Direct person-to-person spread of brucellosis is extremely rare. Mothers who are breast-feeding may transmit the infection to their infants. Sexual transmission has also been reported. For both sexual and breast-feeding transmission, if the infant or person at risk is treated for brucellosis, their risk of becoming infected will probably be eliminated within 3 days. Although uncommon, transmission may also occur via contaminated tissue transplantation.

THIS PROPOSED RULE WILL NOT PROTECT THE PUBLIC, THE CONSUMERS OF THE MEAT DISTRIBUTED BY THE SLAUGHTER PLANT OPERATORS, FROM THE DISEASED ANIMALS PROCESSED BY THE SLAUGHTER PLANT OPERATORS. (if they are diseased)

BY REQUIRING TESTING AT THESE FACILITIES YOU MIGHT GET ACCURATE DATA FOR THE PERCENTAGE OF HERDS ACTUALLY INFECTED, BY REGIONS OF THE STATE, AND YOU WILL PREVENT INFECTION TO UNKNOWING HUMANS. Otherwise, moms will be buying meat that is diseased and infect themselves and their families by handling the raw meat.

According to Dr. Ellis, “For nearly a year, a team of commercial swine and show pig producers, Slaughter Plant Operators, veterinarians, hunters, hog trappers and wildlife biologists have wrestled with rule ideas that would prevent captured wild hogs from creating more chaos, while still giving hunters an opportunity to bag a boar trophy worth bragging rites.” 

Dr. Dee Ellis, DVM, Texas' assistant state veterinarian and TAHC advisor to the feral swine working group, who has proposed these rules, actually told an operator of a current Hog Hunting Ranch, “YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!”

Obviously, the largest numbers of trapped wild hogs will be going to the Slaughter Plant Operators as opposed to hunting ranches, by the design of this rule. Why? Because it is profitable at $20 to $30 and more per pound.

The Slaughter Plant Operators have definitely benefited. As I understand, there was only one Hog Hunting Ranch Operator present or allowed input, who states,

Larry,

You probably won't like my response. I was one of the members of the Feral Swine Advisory Board for TAHC who helped come up with these regulations.  I along with a few ranch owners and a trapper represented the hunting aspect of the State.  Please believe me when I say that these regulations are 1,000 times better that what would have happened if we wouldn't have gotten a say.  This will not regulate hogs that you already have on your ranch or ones that you bring in with one-way trap doors, just ones that you may buy from hunters or trappers.  We worked hard to let ranches buy without blood tests being done and it was a struggle to get it to that point.  Bottom line is the animal health of Texas, and ranches will have to make sure their fences can hold hogs.  I've raised European hogs for over 10 years and I understand fencing and it's ability to hold hogs......You will just have to make sure your place is escape proof. 

Cody Weiser

RE: Canned Hunts, sows, and TPWD who already requires Hunting Preserve License

Q&As About Proposed Feral Swine Regulations
“HOWEVER, if you run a hunting operation and plan to bring in additional wild hogs to the property, then you must have a fence system capable of preventing escape of the hogs, and complete an application and inspection with the Texas Animal Health Commission.  Additions of new wild hogs would be limited to boars and barrows and these animals would be required to have an individual identification tag. “
 Q&As About Proposed Feral Swine Regulations

“Records would be required on the number of hogs brought in, their identification and description, and when they were removed through hunting. The Texas Parks and Wildlife Department also has requirements for hunting preserves and hunters, and operators should check with that agency to ensure all requirements are fulfilled.”

My Comments: “these animals would be required to have an individual identification tag.”   Respectable Hunters and Hunting Ranch Owners have always fought against “Canned Hunts”. Not one hunter I know wants to shoot any animal with an ear tag. No one wants to mount their trophy with an ear tag in his ear or a hole left behind because of the tag. This regulation is unsightly and will discourage hog hunting in Texas because of the perception of a Canned Hunt. I have hunted in numerous States and Countries around the world. I would never hunt ear tagged animals. Hell, the tags are going to get ripped out by the hogs fighting sometimes, leaving a ripped ear. Even if you mark them with wedges out of the ear it still ruins the trophy mount. What do you want to do? Paint names on them? All this rule is doing is giving the animal activists another shot at the hunting industry…Putting a target on our backs. Should we wear a fur coat too?

By forcing Hunting Ranches to get an application from your agency, you are regulating hunting in addition to TPWD who already requires Hunting Preserve License. What other industry is governed by 2 State Agencies?

I am concerned about hunting ranches who buy stock and will not be able to buy sows. More trophy sows are harvested with larger tusks for trophy mounts than boars or barrows. Most are harvested because of the meat. They are not around long enough to breed and propagate.  Any Hunting Ranch operator today already has a fence adequate to keep hogs from escaping. They have to protect their inventory. It is his best interest for obvious reasons. In addition, fences are usually patrolled daily. Where is the danger of disease transmission by wild hogs? The hogs inside the fence are not going to get out. And they are less likely to transmit any disease inside the fence than if they are still outside in the wild. Inside most fences, they are still in a wild environment….with a shorter lifespan.

Or are you saying if all hogs are trapped by/through an entrance one-way trap doors to the fenced area, this type of ranch is not governed by these rules?

Larry

Below is the email from Texas Animal Health Commission.
 
In a nutshell, TAHC is taking over hunting regulations from TPWD.
 
Dr. Dee Ellis, DVM, Texas' assistant state veterinarian and TAHC advisor to the feral swine working group, who has proposed these rules, actually told an operator of a current Hog Hunting Ranch, YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!
   
 

1. Given the arrogance of    Dr. Dee Ellis, DVM, TAHC advisor, to actually tell an operator of a current Hog Hunting Ranch, YOU ARE LUCKY WE ARE LETTING YOU STAY IN BUSINESS!, he is really saying he does not care about the hunting. He should stick to testing animals at livestock markets or slaughter plant operators where he might do some good. Swine Brucellosis is contagious by blood, to humans, so I am told. Why are they not testing at slaughter plant operators?
2. Allowing only Boars and Barrows to hunting ranches is discriminating.
3. No one even manufactures hog wire 5 feet tall. Who can afford to re-fence their entire ranch from 4 foot to 5 foot (that does not exist) with the price of steel today?
4. Most folks are meat hunting, not trophy hunting. More sows are mounted with long tusks than boars.
5. The record keeping is absurd and impossible and worse than exotic game.
6. When did TAHC start making hunting regulations and authorizing hunting preserves?
7. Who is it from the slaughter plant operators that is padding whos pockets?
8. Do you have any idea how many folks come to Texas to hunt on hog ranches? Are we going to give up on this income to the State. Who wants to shoot and ear tag?
9. Trappers are not able to sort sows and boars in a trailer and certainly cannot afford to drive to a slaughter plant operator and then to a hunting ranch with the price of fuel these days. If he does not sell to a slaughter plant operator, he certainly is not going to let the sows loose from his traps just to keep the boars. The sows are the cause of the extreme population. At a hunting ranch, they would be disposed into someones sausage machine. These rules are suggesting trappers can only sell conveniently to slaughter plant operators who are shipping the product over seas. Who are they paying off?         It is hard enough now to find enough trapped hogs.
10. Shortest evolution in history: wild (feral) hogsto feral swineto Commercial swine.
11. What advertising agency wrote this load?
12. HOGS ARE WILD GAME, NOT LIVESTOCK!!!!!!!!!!!!!
 
OK, I think I better stop here.
 
Larry

 
News Release
Texas Animal Health Commission
Box l2966 * Austin, Texas 78711 * (800) 550-8242 * FAX (512) 719-0719
Bob Hillman, DVM * Executive Director
For info, contact Carla Everett, information officer, at
1-800-550-8242, ext. 710, or ceverett@tahc.state.tx.us
For immediate release---
Proposed Wild Hog Rules Aim to Aid Producers, Trappers & Hunters
Described as being as prolific as cockroaches, destructive as rats,
and as surly as badgers, wild (feral) hogs are the bane of ranchers
and farmers, but they're a boon for hunters.  Nearly three million of
these dirt slingin' critters roam free in Texas, rooting up pastures,
wallowing in creek beds, and gorging themselves on crops and
gardens.  Trappers and hunters often are called in to help reduce hog
numbers when feral swine run amuck.
For nearly a year, a team of commercial swine and show pig producers,
slaughter plant operators, veterinarians, hunters, hog trappers and
wildlife biologists have wrestled with rule ideas that would prevent
captured wild hogs from creating more chaos, while still giving
hunters an opportunity to bag a boar trophy worth bragging rites.  In
mid-May, draft regulations were presented to commissioners for the
Texas Animal Health Commission (TAHC), the state's livestock and
poultry health regulatory agency.  Public comment on the proposed
rules, to be published in the Texas Register June 6, will be accepted
by the TAHC through July 6.   TAHC commissioners will consider the
rules for adoption at their next meeting on July 29 in Austin.
"The 80th legislature, in the TAHC's Sunset Bill, provided for the
TAHC to regulate feral swine, which are regarded as free-ranging
livestock.  The TAHC regulations are to be limited to disease control
purposes, including holding facilities, sale, exhibition, hunting or
movement," said Dr. Dee Ellis, Texas' assistant state veterinarian
and TAHC advisor to the feral swine working group.  "If these
proposed rules are adopted, they will supersede TAHC's current feral
swine regulations that aren't comprehensive.  We know we can't get
rid of feral swine, but we can find ways to deal with the animals so
that it benefits all sectors of the industry."
Dr. Ellis said the proposed regulations give trappers greater
latitude for holding and moving trapped swine.  Approved holding
facilities and authorized hunting preserves would be sanctioned and
inspected by the TAHC, and operators or owners would be required to
keep records on the animals for at least five years.  Applications
for operating the holding facilities or hunting preserves will be
available from the TAHC, if the regulations are adopted.
Because there is some limited interest in changing captured feral
swine to "domestic" swine by testing the animals, the proposed
regulations would allow for wild hogs to be reclassified as
"domesticated" pigs after a series of at least three negative blood
tests for swine Brucellosis and pseudorabies during a minimum 150-day
quarantine period.  (This practice is not recommended, however.)
Additionally, sows and other sexually intact female swine would be
required to undergo a fourth negative test for the diseases, at least
30 days after their initial farrowing in quarantine.
The disposition of feral swine that are not "domesticated" through
the quarantine and testing process is limited to slaughter only,
except for boars and barrows, which may be moved to TAHC-authorized
hunting preserves.
The proposed rules also would allow for the wild pigs to be held
after trapping in an escape-proof pen or enclosure on a trailer for
up to seven days before moving the animals directly to a federally or
state-inspected slaughter plant, to a TAHC-authorized hunting
preserve, or to an approved holding facility, awaiting final disposition.
The proposed rules would allow only boars and barrows to be moved to
TAHC-authorized hunting facilities, which would have to be equipped
with swine-proof fencing at least five feet high.  Boars and barrows
also would have to be individually identified prior to being placed
into the preserve.
Hunting preserve operators would need a "Hunting Lease License" and
hog hunters would need a hunting license, both from the Texas Parks
and Wildlife Department, but there is no season on these animals so
often regarded as a pest and a threat to livestock health.
"It is extremely important that proposed holding facilities and
hunting preserves be 'escape proof.'  Identification on the boars and
barrows in hunting preserves would help us identify pigs that 'get
loose,' " said Dr. Ellis.  Required record-keeping would include the
number of swine placed in or removed from the facilities, the
animals' weight, size, color, sex and any identification applied to
the animal, and the locations from which they were trapped and to
which they were moved.
"Strict requirements are necessary to prevent moving an animal that
has a potential livestock disease from one site to another," said Dr.
Ellis.  "From tests on feral swine over a four-year period, we know
that around 20 percent of wild hogs in Texas carry pseudorabies, a
regulatory flu-like swine disease not related to rabies.  About 10
percent of the feral pigs have swine Brucellosis, the swine form of
"Bangs," or cattle Brucellosis."
Since January 2006, the swine form of Brucellosis has been detected
in 26 cattle in 19 herds.  Although the swine infection in cattle
does not affect Texas' hard-won 'free' status for cattle Brucellosis,
it does cause positive test results when cattle are tested prior to
sale.  The bacteria must be "grown out" in the laboratory to
differentiate between swine Brucellosis and cattle Brucellosis
infection. In the meantime, cattle in the consignment or herd must be
held up, and additional tests may be needed to ensure there is no
cattle Brucellosis infection in the herd.
Feral swine also can have a health impact on noncommercial swine,
which may be housed in facilities that are more likely to have feral
swine contact than commercial swine facilities. Of the 41
noncommercial swine herds quarantined for swine Brucellosis infection
since January 2003, 29 either had definite or possible contact with
wild hogs.
" 'Contact with feral swine' can be as simple as a wild sow or boar
either being allowed in, breaking into swine pens, or making contact
through a fence," noted Dr. Ellis. "Related contacts" can include an
activity such as purchasing piglets from a producer who allows feral
swine into his or her pens.  In this case, a buyer could be
purchasing piglets that have been exposed to disease carried by feral swine.
Dr. Ellis advised domestic swine owners to keep feral swine out of
their pens. When purchasing replacement swine by private treaty, ask
if the pigs have been exposed to feral swine. If possible, keep the
animals isolated until tested for swine Brucellosis and pseudorabies.
At livestock markets selling sexually intact swine six months of age
or older, these tests are required, and blood samples are collected
from the animals by TAHC personnel.
"Commercial swine herds are operated with great attention to
biosecurity, and in Texas, these herds currently are swine
Brucellosis and pseudorabies-free," said Dr. Ellis.  But each time we
detect infection in a noncommercial herd, it puts a hardship on
producers, because we must trace animal movement, test herds in a
widespread area, and handle infected herds appropriately.  Swine
brucellosis also poses a significant public health threat to those
handling or inadvertently producing infected animals. By adopting
regulations that make it easier for trappers to remove feral swine
from an area, and place boars and barrows only in a hunting facility,
we encourage legal regulated movements of the animals and have less
chance of disease transmission from these wild hogs. These proposed
regulations can benefit swine producers, cattlemen, trappers and hunters, too."
On June 6, a link to the text of the proposed regulations will appear
on the TAHC website at
<http://www.tahc.state.tx.us/>http://www.tahc.state.tx.us. The
proposed regulations also are available by calling the TAHC at
800-550-8242, ext 710.  Comments on the proposed rules may be emailed
to: <mailto:comments@tahc.state.tx.us>comments@tahc.state.tx.us,
faxed to 512-719-0719, or mailed to  TAHC Comments, Box 12966,
Austin, TX 78711-2966.  Comments are due no later than July 6.