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Response to South Carolina Deer Urine Ban….
 

Response to South Carolina Deer Urine Ban….

 

Response to South Carolina Deer Urine Ban….

August 2019…

The South Carolina Department of Natural Resources released a new hunting rule last week banning urine-based scents, taking away an important hunting tool used by many successful hunters every year.

Unfortunately, there is a lot of false and misleading information driving policy and regulations regarding urine-based scents being a risk for spreading CWD.  The impact of banning these products on hunters and businesses, both small and large across the state this year will be huge.

In the recent press release by the South Carolina DNR, it was stated “CWD research conducted in Colorado showed that mule deer were able to be infected with CWD after exposure to just the urine, feces and saliva of infected deer.” This statement is misleading and misrepresents the actual scientific finding of these studies.  Many studies have attempted to transmit CWD with urine and none have been successful in deer.  Later studies in Colorado used urine from CWD sick deer, concentrated it 10-fold, and injected it directly into brains of mice that were genetically altered to be 6 times more susceptible to the disease than deer.  One of the 9 mice became infected.  We are led to believe that urine is a risk for spreading the disease by putting a small amount, from facilities that are enrolled in a program to safeguard their deer from risk of contamination, on a scent wick or squirting it on the ground when only one mouse became infected by injecting infected and concentrated urine into its brain? Hunters are not injecting deer with urine and the urine is coming from healthy animals and not sick ones! 

Moreover, the urine collection process prevents or removes nearly all contamination from feces or saliva.  Based on the study referenced and other available research, it is estimated to take close to 2 fl oz of pure infected saliva from a single sick deer entirely ingested by one single deer to invoke an infection.  Even with the larger 4 oz bottles, we would have to believe that half of this bottle is pure saliva, and that the saliva was infected in the first place.  Then we would have to believe that a single deer would drink the whole bottle.  This is ridiculous to even be a consideration.

The urine from hunting scent companies like Wildlife Research Center® and Tink’s® is collected from healthy animals and not sick ones.  South Carolina wildlife officials say that the urine comes from captive herd facilities and that CWD has been found in 40 captive cervid facilities since 2012.  What they don’t tell you is the collection facilities that companies like Wildlife Research Center® and Tink’s® use are from a small number (less than a dozen) of highly specialized facilities and are vastly different than the other likely 10,000 deer farms across the country.  Of the 40 mentioned positives since 2012, only 16 were in a certified herd testing and certification program, and none of those were closed to importation of deer like the facilities where urine is sourced. The facilities the urine scent companies utilize are all 100% monitored, meaning every deer that dies is tested.  CWD has never been found in one of these urine collection facilities.

South Carolina wildlife officials also say the scent industry is not regulated by any agency or entity and there is no testing or marking requirements identifying the source of the urine products.  That is also false.  The collection facilities are regulated by state and federal department of agriculture and wildlife agency rules and regulations relating specifically to CWD and to the operation of those facilities.  All of the source herds are 100% monitored.  The department of agriculture requires that testing is conducted before issuing the testing certifications the facilities all have and maintain.

Furthermore, the scent industry with the help of the Archery Trade Association, worked with industry experts, wildlife disease experts, CWD scientists, and many others to develop the ATA Deer Protection Program to safeguard their facilities from any risk of CWD contamination.  The small number of elite operations in this program far exceed the USDA standards with a higher level of biosecurity than any other of the previously mentioned deer farms and their products proudly display the ATA checkmark on their packaging.  To name a few requirements of the program, the facilities have to be 100% monitored, closed to importation of deer, and are annually inspected by accredited veterinarians which also review their records to verify they are meeting all of the requirements of the program.  According to two of the top experts who authored the most commonly referenced studies on CWD relating to urine, “The risk of urine-based scents spreading CWD is virtually zero.  When you consider the process of how urine is collected and all the measures in place, these products are not a risk of spreading CWD.”

SCDNR also states that there is no commercially available CWD test for our products.  Wrong again.  Wildlife Research Center® and Tink’s® have collaboratively funded a research project and a test for urine has been developed.  It is now becoming commercially available to test and certify these products have no detectable levels of CWD in them.  Companies like Tink’s® and Wildlife® have already begun testing their products in 2019 and many others will be sure to follow.

Many other states have considered bans on urine-based scents. However, after learning about our industry processes and discussing these often referenced studies with the actual CWD scientist that authored one of the major studies, states have reversed course and either decided not to implement a urine ban or modified their rules to allow use of urine-based scent products that participate in the ATA Deer Protection Program.  SCDNR obviously did not reach out to the companies these bans would affect or adequately research the scent industry before implementing this new rule, otherwise this information could have been made readily available to them. Instead, they simply passed this rule that will not deter the spread of CWD and only takes away an important tradition and tool from hunters in that state.

There was no apparent notice or warning of this rule being passed.  Multiple dealers and hunters in South Carolina have reached out to us in total surprise.  Dealers have already purchased product to stock their shelves and natural urine products have been sold this year to hunters, only now to find out it is no longer allowed to be used in their state.  It was irresponsible and downright harmful for the agency to put hunting retailers, both big and small, who have already made significant investment in stocking product and hunters who rely on these products in this difficult position. 

Unfortunately, now it is up to the hunters in South Carolina who have needlessly lost their right to use these products, to hold the DNR and legislators responsible for these new rules accountable and demand change.  We encourage hunters to express your thoughts and comments on this new rule to the SCDNR.  To comment, visit their website at http://www.dnr.sc.gov/admin/contactus.html or simply email them at webmaster@dnr.sc.gov