Important! Please Read: USDA Interprets ?30 Day Rule?

June 6, 2007 — 

The USDA has reviewed regulations governing the timing of veterinary inspections prior to interstate shipments of pigs and provides an unfavorable interpretation. If you are issuing Certificates of Veterinary Inspection (CVI) to ship pigs interstate outside of a production system, you need to be aware of this interpretation.

The regulation described in 9CFR161.3(a)(2) reads as follows: "Following the third and subsequent inspections of a herd or flock in a regular health maintenance program, an accredited veterinarian shall not issue a certificate, form, record or report which reflects the results of any inspection, test, vaccination or treatment performed by him or her with respect to any animal in that program, unless he or she has personally inspected that animal within 30 days prior to issuance." USDA is interpreting this rule to require that an accredited veterinarian must inspect each individual animal within 30 days prior to issuing a CVI if the animals are moving interstate outside a production system. This means that pigs born after a veterinarian's last herd visit must be inspected before shipment.

For swine moving within a production system, this issue is adequately addressed in language found under 9CFR71.19(h)(3) which reads "[t]he swine must be found free from signs of any communicable disease during the most recent inspection of the premises by the swine production system accredited veterinarian(s) within 30 days prior to movement."

The AASV will actively pursue modification of this regulation to obtain wording that achieves the intent of the rule which is that an accredited veterinarian would have to have inspected the herd within 30 days of shipment, rather than individual animals, following the third and subsequent herd visits. It is, in our opinion, impractical and unnecessary for a veterinarian making regular monthly herd visits to have to inspect animals born between visits before issuing a CVI to ship pigs interstate. A regular health maintenance program certainly provides a broader and deeper understanding of the health of the herd and individual animals than does a one-time inspection before issuing a CVI.

The association will submit a resolution through the US Animal Health Association formally requesting a wording change that provides a workable and practical solution to this regulatory issue. However, in the interim, please be aware of the current USDA interpretation and insure that you are in compliance.