Board of Animal Health's Oversight of Deer and Elk Farms
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Board of Animal Health’s Oversight of Deer and Elk Farms 2018 EVALUATION REPORT Program Evaluation Division Office of the Legislative Auditor State of Minnesota Program Evaluation Division Evaluation Staff The Program Evaluation Division was created within James Nobles, Legislative Auditor the Office of the Legislative Auditor (OLA) in 1975. Judy Randall, Deputy Legislative Auditor The division’s mission, as set forth in law, is to determine the degree to which state agencies and Joel Alter programs are accomplishing their goals and Caitlin Badger objectives and utilizing resources efficiently. Ellen Dehmer Sarah Delacueva Topics for evaluations are approved by the Kristina Doan Legislative Audit Commission (LAC), which has Will Harrison equal representation from the House and Senate and Jody Hauer the two major political parties. However, evaluations David Kirchner by the office are independently researched by the Carrie Meyerhoff Legislative Auditor’s professional staff, and reports Ryan Moltz are issued without prior review by the commission or Jessica Obidike any other legislators. Findings, conclusions, and Jodi Munson Rodriguez recommendations do not necessarily reflect the views Laura Schwartz of the LAC or any of its members. Katherine Theisen Jo Vos OLA also has a Financial Audit Division that Madeline Welter annually audits the financial statements of the State of Minnesota and, on a rotating schedule, audits state To obtain reports in electronic ASCII text, Braille, agencies and various other entities. Financial audits large print, or audio, call 651-296-4708. People with of local units of government are the responsibility of hearing or speech disabilities may call through the State Auditor, an elected office established in the Minnesota Relay by dialing 7-1-1 or 1-800-627-3529. Minnesota Constitution. To offer comments about our work or suggest an OLA also conducts special reviews in response to audit, investigation, or evaluation, call 651-296-4708 allegations and other concerns brought to the or e-mail [email protected]. attention of the Legislative Auditor. The Legislative Auditor conducts a preliminary assessment in response to each request for a special review and Printed on Recycled Paper decides what additional action will be taken by OLA. For more information about OLA and to access its reports, go to: www.auditor.leg.state.mn.us. Photo provided by the Minnesota Department of Administration with recolorization done by OLA. (https://www.flickr.com/photos/139366343@N07/25811929076/in/album-72157663671520964/) Creative Commons License: https://creativecommons.org/licenses/by/2.0/legalcode OFFICE OF THE LEGISLATIVE AUDITOR O L A STATE OF MINNESOTA • James Nobles, Legislative Auditor April 2018 Members of the Legislative Audit Commission: The Board of Animal Health is responsible for protecting the health of Minnesota’s domestic animals, which includes enforcing state laws related to deer and elk farms. Our review focused on how well the board has enforced these laws, as well as its response to chronic wasting disease discovered among farmed deer or elk. We found that the Board of Animal Health has failed to enforce some laws relating to deer and elk farms. The board has not established clear expectations for deer and elk farm inventories, nor has it systematically analyzed compliance with state laws requiring chronic wasting disease testing. We make several recommendations for the board related to recordkeeping and enforcement. We also found that the board has a strained relationship with the Department of Natural Resources, which is responsible for managing Minnesota’s wild deer and elk. We recommend that the board and the department draft a memorandum of understanding to facilitate communication and data sharing between the two agencies. Our evaluation was conducted by Sarah Delacueva. The Board of Animal Health and the Department of Natural Resources cooperated fully with our evaluation, and we thank them for their assistance. Sincerely, James Nobles Judy Randall Legislative Auditor Deputy Legislative Auditor Room 140 Centennial Building, 658 Cedar Street, St. Paul, Minnesota 55155-1603 • Phone: 651-296-4708 • Fax: 651-296-4712 E-mail: [email protected] • Website: www.auditor.leg.state.mn.us • Minnesota Relay: 1-800-627-3529 or 7-1-1 ;mmmo V 4* ^ Qm •1 1« s «s s 55 m•' y mtm58 n m * Summary Key Facts and Findings: appropriately share the information they both require to respond to CWD The Board of Animal Health (BAH) outbreaks. (p. 47) is responsible for protecting the health of Minnesota’s domestic animals, While Minnesota’s CWD regulations including deer and elk. (p. 3) are among the most rigorous in the nation, there are some areas where The board has five members, but not other states’ policies better protect one who represents the general public. deer and elk against the disease. (pp. 11, 12-13) (pp. 49-50) As of April 2018, Minnesota had 398 Key Recommendations: registered herds, consisting of about 9,300 deer, elk, and other similar The Legislature should consider species. (p. 4) expanding the number of board members and adding at least one Minnesota law does not require that member of the general public. (p. 14) deer and elk identification tags be read and recorded when completing BAH should clarify expectations of an animal inventory. (pp. 21-22) whether and how often producers must verify their herd inventory on an Chronic wasting disease (CWD) is an animal-by-animal basis. (pp. 23-24) always fatal, neurodegenerative disease found in both farmed and wild BAH should (1) systematically deer and elk. (p. 6) analyze CWD-testing compliance, and (2) appropriately penalize those Since 2002, CWD has been identified producers who fail to submit CWD- on eight Minnesota deer and elk farms testing samples. (p. 27) and in wild deer in two Minnesota counties. (pp. 40-41) BAH should develop an approval program for deer and elk producers BAH staff do not systematically who wish to collect their own CWD analyze whether deer and elk test samples. (p. 30) producers submit tissue samples for CWD testing for all deceased animals. BAH should (1) ensure producers (p. 25) follow Minnesota deer and elk laws, (2) strengthen consequences for From 2014 to 2017, about one-third of producers, and (3) monitor field staff producers that reported dead deer or performance. (p. 33) elk failed to submit tissues from at least one of those animals for CWD BAH and DNR should draft a testing. (p. 26) memorandum of understanding outlining each agencies’ BAH has, in some instances, failed to responsibilities with respect to data enforce deer and elk regulations. sharing. (pp. 47-48) However, the board has improved its deer and elk program over the past The Legislature should convene an several months. (pp. 30-34) advisory task force to evaluate the state’s regulations related to deer BAH and the Department of Natural feeding and live-animal imports. Resources (DNR) have struggled to (p. 51) S-2 Board of Animal Health’s Oversight of Deer and Elk Farms Report Summary BAH is smaller than other state’s animal health boards, which range in size from Minnesota statutes charge the Board of 7 to 16 members. BAH is also smaller Animal Health (BAH) with protecting than other Minnesota boards that the health of Minnesota’s domestic license, permit, or register professions or animals, including members of the entities. While BAH’s composition 1 family cervidae. The cervidae family (three livestock producers and two includes deer, elk, and similar species, veterinarians) is similar to other states’ which may be collectively referred to as boards, BAH is unlike most Minnesota “cervids.” As of April 2018, Minnesota boards in that it lacks a public member. producers were raising more than 9,300 We recommend expanding the size of cervids in 398 registered herds. the board and adding a member of the general public, in order to diversify the Deer and elk health is threatened by perspectives represented. chronic wasting disease (CWD), an always fatal, neurodegenerative disease The law does not require that deer found among wild and farmed cervids. and elk identification tags be read CWD is difficult to manage because regularly, calling into question the there is no live-animal diagnostic test accuracy of cervid farm inventories. approved for routine herd monitoring. Further, infected animals may not show Annual inventories are an important tool clinical signs until the disease is quite for BAH. In the event that CWD is advanced. The only way to definitively detected on a deer or elk farm, BAH diagnose CWD is to analyze specific uses the inventories that producers tissues from a dead deer or elk. CWD submit to track animal locations and has been found on eight Minnesota deer movements and determine which other and elk farms since 2002. It has also farms to investigate for possible CWD been detected in wild deer in two exposure. Minnesota counties. By law, producers must submit annually BAH is smaller than other states’ to the board inventories that are verified animal health boards. by an accredited veterinarian.2 However, the law does not require that The board is made up of three livestock the producers or their veterinarians producers and two veterinarians physically read the tags on their deer practicing in Minnesota. Members are and elk in order to complete these appointed by the governor. BAH’s day- inventories. As such, the inventories to-day work is performed by 41 staff producers submit may not accurately members. reflect the animals on the farm, which could complicate the investigation that Minnesota’s structure for overseeing BAH must conduct if CWD is farmed deer and elk is unlike those in discovered among farmed cervids. most other states. Only six states give the responsibility to an entity like BAH.