Can The Horse Industry Work Alongside The Environmental Protection Agency?

Why should the horse industry care about the Environmental Protection Agency (EPA)? EPA regulations impact not only where we can operate equine activities, but also how. This often feels like government overreach and leads to a collective industry recoil from increased agency oversight.

The horse industry relies on healthy pastures, fields, and waterways to feed and care for the animals as well as provide safe recreation space. The EPA is tasked with maintaining a healthy ecosystem for everyone and thus has oversight of many economic sectors, not just agriculture. It's a big assignment and often that means unintentional impacts on industries such as our own. To manage the full breadth of EPA responsibilities, the agency is split into multiple offices that focus on a specific topics and can be mapped through the EPA Organization Chart.

When the EPA or any other federal agency proposes a new regulation (or rule), it is posted to the Federal Register and available for public commentary. It's the onus of stakeholders to submit commentary during the open window, often within 30-60 days of the initial publication. Anyone can submit a comment, and comments are able to be read by the general public. The Office of the Federal Register published a guide to rulemaking to help any party interested in submitting a comment. If a proposed rule is very complex, it is possible to request an extension to the commentary period, though it is not guaranteed to be granted.

Currently, there are several topics at hand at the EPA that deserve due diligence to understand the downstream effects on the horse industry.

Rodenticides and Insecticides

The EPA is charged with reviewing rodenticides (rodent baits) as well as topically and environmentally applied insecticides that include many products commonly used in the horse industry. These regulations are reviewed every 10-15 years. With each product review there is the chance of loss of use. Most recently at risk was pyrethrins (used in many common fly and tick repellent products) and the majority of rodent baits sold in quantities of five pounds or more. The EPA has pushed the final decision for these products to 2024 to allow for appropriate review of the comments submitted in the rulemaking process.

In addition, there was a whitepaper published in February 2023 to the Federal Register proposing changes to an EPA understanding with the Federal Drug Agency (FDA) to shift regulation of topical insecticides from the EPA to the FDA. There would be many downstream affects, including loss of stakeholder input, if this were to happen.

CAFOs, WOTUS definitions, and the Clean Water Act

Concentrated Animal Feed Operations (CAFOs) are facilities that house livestock (inclusive of horses) 45 days or more per year in a confined area where forage doesn't grow. Many horse facilities, racetracks, and fair grounds qualify as CAFOs. CAFOs must be permitted, and the process may require expensive wastewater and manure management systems.

CAFO regulations originated from the Clean Water Act (CWA). Stemming from an update in 2015 for CWA designation, the Waters of the United States (WOTUS) is a ruling from the 2015 Clean Water Rule. Historically, horse facilities have been a very small percentage of CAFO permits. However, recently there has been an increase in private environmental groups pushing for a wide range of horse operations to be regulated as CAFOs.

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PFAS – The Forever Chemical

PFAS are man-made chemicals that have been used worldwide since the 1940s. The most commonly studied PFAS are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). These two chemicals first entered the environment through discharge from chemical manufacturing facilities, as well as firefighting foam and other common industrial and consumer products.

According to the Center for Disease Control and the EPA, PFAS are widely used and long-lasting chemicals that break down very slowly, if at all. Because of their persistence in the environment, many PFAS are found in the blood of people and animals all over the world and are present in a variety of food products and in the environment. Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals.

PFAS appeared on farms through the use of contaminated fertilizer from wastewater treatment facilities and irrigation from contaminated aquifers. There are many unknowns with PFAS. The EPA is working to research safe levels, proper site clean up protocols, and potentially regulate PFAS under CERCLA, also known as the “Superfund Law”. If PFAS are regulated under CERCLA, contaminated farms could be liable for clean-up costs despite unknowingly contaminating their property through fertilizing fields, which could total in the tens of millions of dollars.

Looking to the future

It's important to understand that EPA rulemaking and enforcement goals are often influenced by the changing policies of the Office of the President each election period. Further, regardless of what changes are made at the federal level, individual states have the right to further strengthen many EPA federal mandates. It's equally critical as an advocate to watch state specific rulemaking as closely as one watches Federal.

Simply opposing any and every new or updated EPA regulation doesn't help the horse industry (or the environment).  The horse industry must continue to strive to be model environmental stewards while working with the EPA and within the rulemaking process to find regulatory comprises that works for everyone.

To learn more about the issue the American Horse Council is following and regulations associated with EPA oversight, click here.

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CHRB: Fatal Injuries Down Sharply, Non-Exercise Related Deaths Up In 2022-’23 Fiscal Year

California horse racing again experienced a significant decline in the number of horses that died from injuries suffered during racing and training at California facilities during the 2022-'23 fiscal year that ended June 30. A total of 26 died last year as a result of musculoskeletal injuries that occurred while racing or training, compared with 39 the previous year. For context, approximately 30,000 race starts and far in excess of 100,000 workouts occur each year from 8,000 to 10,000 horses at California Horse Racing Board regulated facilities.

“That's still too many fatalities, but it shows that all of the new regulations, policies, and procedures that that we've introduced in cooperation with the industry have had a significant effect,” said CHRB Chairman Greg Ferraro. “Our efforts are focused primarily on preventable injuries, and that's what the numbers reflect. I don't know of any racing jurisdiction in the country that even comes close to matching this effort or result.”

In the interest of full transparency, the CHRB also tracks fatalities caused by any non-exercise-related catastrophic injury. The most common cause of death in this other group is gastro-intestinal diseases, such as colic, colitis, and enteritis, followed by respiratory disease. Unfortunately, the number of “other” deaths increased last year, and those 43 deaths, coupled with the 26 due to musculoskeletal injuries, brought the total to 69, or three more than the 66 the previous year.

“I've considered several times the idea of not counting other deaths, the type that occur among horse populations anywhere in the world, including the popular riding stables and in the wild, but I've always decided that full transparency is the best way to go,” said CHRB executive director Scott Chaney.

Those 43 other deaths occurred despite care and treatment by on-site veterinarians and specialized equipment located in stable areas.

“Six of those horses were transported to the veterinary hospital at the University of California, Davis, as well as other local referral hospitals, where experts did their best to save them,” said Dr. Jeff Blea, the CHRB equine medical director. “Illnesses such as severe colic, advanced neurologic cases, and obscure medical conditions, sometimes just are not treatable, as animal and horse owners throughout the world know from personal experience.”

For further context, equine fatalities at CHRB-regulated facilities have declined by 54 percent since 2019, including the “other” category.

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Vesicular Stomatitis Outbreak Update: 114 Premises Identified Between California, Texas

The vesicular stomatitis virus (VSV) outbreak that began in mid-May has been expanding. As of June 30, there have been 114 VSV-affected premises identified, with 39 confirmed VS cases and 75 suspected VS cases in two states: California and Texas. Of the 114 premises, 59 have been released from quarantine and the remaining 55 are still under official quarantine. 

There was only one VS-positive case in Texas. The affected horses in California reside in Los Angeles, Orange, Riverside, San Bernardino, San Diego and Ventura counties. 

A timeline of the disease outbreak is below.

On May 17, the National Veterinary Services Laboratories in Ames, Iowa, confirmed one case of vesicular stomatitis virus in San Diego County, California. It was the New Jersey serotype. The affected horse was an 11-year-old Quarter Horse mare. The premises were placed under official quarantine. Three other cases of VSNJ were confirmed in San Diego County. 

On May 22, 15 new premises in California were identified as VSV-affected, including two positive cases in Riverside County. 

On May 26, seven new premises were identified as VSV-affected. All cases were the New Jersey virus serotype. In total, there have been 26 VSV-affected premises, with nine positives and 17 suspected cases, all in California. 

On June 2, 18 additional VSV-affected premises were identified in Riverside, San Bernadino and San Diego counties. 

On June 6, 18 more counties were deemed VSV-affected in Orange, Riverside, San Bernadino and San Diego counties. 

On June 9, 14 more premises were deemed VSV-affected, including one in Los Angeles County. 

On June 15, VSV (New Jersey serotype) was confirmed in Maverick County Texas, in a 15-year-old Quarter Horse gelding. Additionally, 18 additional premises in California were identified as VSV affected.

On June 16, again 18 new VSV-affected premises were identified in California in already-affected counties. 

On June 22, eight new VSV-affected premises were identified in Ventura County, California. 

On June 30, 10 new VSV-affected premises were identified in California and the Maverick County, Texas quarantine was released. 

Vesicular stomatitis virus is a viral disease that can affect horses, donkeys, mules, cattle, swine and camelids in the Western hemisphere. The disease can cause blisters and ulceration of the lips, tongue, nose, ears, sheath, teats or coronary bands. The disease is transmitted by biting midges. There is no treatment and most animals recover from the disease. 

Read more at the Equine Disease Communication Center. 

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Arabian Skull Anatomy Increases Difficulty Level Of Sinus, Dental Surgery 

Arabians are known for their long, arched necks, high tail sets, and dished faces. In recent years, breeders have sought an even more dished face, believing it to be even more beautiful. 

Though it may be “pretty,” the smaller skull can lead to dental issues, sinus infections, and respiratory disease, reports The Horse. Treating these issues can also prove tricky as the smaller skull size leaves less room to work if surgical intervention is needed. 

Dr. Endrigo Pompermayer, an equine surgeon with the Equine Veterinary Medical Center, in Al Rayyan, Doha, Qatar, noted that Arabians in particular have proportionally more head-related issues as they are bred specifically for a more-dramatically dished face. 

Pompermayer and his surgical colleagues realized they were operating on more Arabians with dental disease and chronic sinusitis from overcrowded teeth than any other breed. They also determined that these surgeries were more complicated than when performed on non-Arabian horses; the structures were difficult to access, making the surgeries riskier. 

Pompermayer and the other surgeons carried out a study to determine whether Straight Egyptian Arabian Horse heads were truly smaller or just seemed that way. Straight Egyptian Arabians can trace their lineage back to the Bedouin tribes of Arabia and are considered the “purest” Arabians. However, this line of Arabians has also undergone the most intense genetic selection for horse showing and has relatively high levels of inbreeding, Pompermayer noted. 

The team of surgeons recorded head dimensions from 29 healthy horses that were 5 years old and older. This included 14 Thoroughbreds and 15 Straight Egyptian Arabians. 

The dimensions taken included basic eye-to-eye width, muzzle circumference, and jaw width, as well as eight advanced anatomical measurements using computed tomography. 

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The vets discovered that the Arabians' total head length was shorter than that of Thoroughbreds' head length – particularly in relation to body size. 

In particular, the researchers found shorter frontal sinuses in Arabians and that the maxillary septal bulla was set farther back. This explains why surgeons have difficulty performing the surgery needed to facilitate sinus drainage on Arabians. The team also found that the maxillary bone flaps on Arabians tended to be shorter, meaning surgeons had poorer access to the maxillary sinuses. 

Read more at The Horse.

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