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PUBLIC SUBMISSION

Comment from Chekroun, Yamina-Sarah
Posted by the Animal and Plant Health Inspection Service on Jan 26, 2026

Docket (/docket/APHIS-2025-0704) / Document (APHIS-2025-0704-0001) (/document/APHIS-2025-0704-0001)
/ Comment

Comment

I am submitting this comment as a licensed attorney admitted to practice and in good standing in the state
of New York to address the information collection associated with specimen submission for livestock
disease surveillance. While accurate diagnostic testing is a prerequisite for national biosecurity, I urge the
Agency to ensure that these collection protocols are utilized as a safeguard against the unnecessary
destruction of non-infected animals.

Mandatory Diagnostic Precedent: APHIS should prioritize the completion and verification of specimens (via
VS Form 10-4) prior to issuing depopulation orders. The "preemptive culling" of animals before lab results
are finalized is an extreme measure that should be restricted to cases of immediate and proven catastrophic
risk. The current information collection should be used to track and minimize the lag time between sampling
and results to spare healthy animals from unnecessary slaughter.
Chain of Custody for Sanctuary Off-Ramps: For animals intended for transfer to 501(c)(3) sanctuaries, the
specimen submission process should include a "priority track." Ensuring that these animals can be quickly
cleared of disease via rigorous testing allows the Agency to fulfill its health mandate while facilitating
humane rehoming instead of destruction.
Humane Sampling Requirements: The instructions for specimen collection should explicitly mandate the use
of the least invasive methods possible. Any professional nominated to collect specimens under this program
must be certified in humane handling to ensure that the process of "surveillance" does not itself result in
undue physiological stress or injury to the animal.
Verification of "Negative" Results: To ensure transparency, APHIS should include in this data collection a
requirement to report the number of animals that were culled before a negative test result was returned.
This data is essential for the public to evaluate whether the Agency's "take" of animal life is truly

Give Feedback

From an administrative law and animal welfare perspective, I advocate for the following:

proportionate to the biological threat.
Accurate data is the only legitimate basis for government-sanctioned loss of animal life. This information
collection must be a tool for precision, not a justification for broad-scale culling.

Comment ID
APHIS-2025-0704-0003

Tracking Number
mkr-qzjk-7alh

Comment Details

Submitter Info

Document Subtype
Public Comment
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